4 replies to this topic

[moskito]

Hi,

my company is a biscuit manufacturer with several plants in europe. We are using many raw materials important for the products (e.g. nuts),but which are unfortunately allergens. We have installed an effective allergen management reducing the risk of cross contamination.
The declaration is going to be harmonized by the new EU-FIC. With respect to allergens there are some changes, but not in the number. The list of allergens has not been changed. Our risk assessment is mainly based on our major markets in europe. But of cource we are doing export too. In that cases we to do individual checks for the products.

We want to expand our risk assessment to export already in the NPD, i.e. we have to expand the allergen related part of the supplier questionairs for the major regions worldwide. There are differences in the number of "legally required" allergens and differences in details (e.g. What is meant with nuts in each region?). And in each region exits a inofficial list of allergens (in EU ALBA or LeDa) many consumers ask for.

Does anybody know whether there is a document available listing the allergen declaration requirements for all the (major) markets worldwide ?

[Charles.C]

Hi,

my company is a biscuit manufacturer with several plants in europe. We are using many raw materials important for the products (e.g. nuts),but which are unfortunately allergens. We have installed an effective allergen management reducing the risk of cross contamination.
The declaration is going to be harmonized by the new EU-FIC. With respect to allergens there are some changes, but not in the number. The list of allergens has not been changed. Our risk assessment is mainly based on our major markets in europe. But of cource we are doing export too. In that cases we to do individual checks for the products.

We want to expand our risk assessment to export already in the NPD, i.e. we have to expand the allergen related part of the supplier questionairs for the major regions worldwide. There are differences in the number of "legally required" allergens and differences in details (e.g. What is meant with nuts in each region?). And in each region exits a inofficial list of allergens (in EU ALBA or LeDa) many consumers ask for.

Does anybody know whether there is a document available listing the allergen declaration requirements for all the (major) markets worldwide ?

Dear moskito,

I suppose it rather depends on where the major markets for "X" are (X = population?) ?

This 2006 document appears to claim data for something like the scope of yr request. It also illustrates the probable difficulties in achieving a uniform requirement-

 global allergen legislation 2006.pdf   626.11KB   151 downloads

This link points to a (2012) USFDA (harmonising project) document covering approx 10% (my estimate) of the world's countries and i daresay they were selected for being of some allergenic significance although i didn't see any criteria mentioned . -

http://www.allergenb...ing-regulations

I deduce you have an ambitious expansion plan coming up ?

Rgds / Charles.C

[moskito]

Dear Charles C.

thank you for your informations.

Your assumption is correct. We are planning to enhance export sales.
I am planning a uniform supplier questionaire that supports already from the beginning of a new product development process the risk assessment. Today we do it on single request. That is time consuming and delaying (in some cases skipping) the sales plans. The need is to have a more standardized process.
The optimum would be an overview or database which is updated on regular basis and which helps to keep the companies questionaire updated. Due to the health and legal impact the source has to be reliable. Companies have to review their HACCP on regular basis and would be able to cross-check.
10% of the major markets covering several "legally comparable areas" (US/Canada; EC; Australia/NZ; South America; Japan; South East Asia; GCC; Russia) would be already a big success. Most of the surronding countries relies on legislation of "focus countries" near by - that is my experience. In pharmaceutical there exist MRAs and ICH hormonization processes (US, EC, Japan), which is hard enough.

Unfortunately I failed til now to find such information. And your links tell that this requirement is picked up and something is on the way, but not available.

Rgds/moskito

Dear moskito,

I suppose it rather depends on where the major markets for "X" are (X = population?) ?

This 2006 document appears to claim data for something like the scope of yr request. It also illustrates the probable difficulties in achieving a uniform requirement-

 global allergen legislation 2006.pdf   626.11KB   151 downloads

This link points to a (2012) USFDA (harmonising project) document covering approx 10% (my estimate) of the world's countries and i daresay they were selected for being of some allergenic significance although i didn't see any criteria mentioned . -

http://www.allergenb...ing-regulations

I deduce you have an ambitious expansion plan coming up ?

Rgds / Charles.C

[Charles.C]

Dear Charles C.

thank you for your informations.

Your assumption is correct. We are planning to enhance export sales.
I am planning a uniform supplier questionaire that supports already from the beginning of a new product development process the risk assessment. Today we do it on single request. That is time consuming and delaying (in some cases skipping) the sales plans. The need is to have a more standardized process.
The optimum would be an overview or database which is updated on regular basis and which helps to keep the companies questionaire updated. Due to the health and legal impact the source has to be reliable. Companies have to review their HACCP on regular basis and would be able to cross-check.
10% of the major markets covering several "legally comparable areas" (US/Canada; EC; Australia/NZ; South America; Japan; South East Asia; GCC; Russia) would be already a big success. Most of the surronding countries relies on legislation of "focus countries" near by - that is my experience. In pharmaceutical there exist MRAs and ICH hormonization processes (US, EC, Japan), which is hard enough.

Unfortunately I failed til now to find such information. And your links tell that this requirement is picked up and something is on the way, but not available.

Rgds/moskito

Dear moskito,

Thks yr interesting reply. It’s an admirable project.

I daresay you are aware of the references below already. They all looked quite useful to me, especially the first two in terms of your own possible onward investigation. The attachment is extracted from first link in case of later disappearance of link.

http://farrp.unl.edu/IRChart

http://www.ifst.org/...gen_management/

http://www.foodaller...Guidelines.html

http://www.hindawi.c...ja/2012/746125/

 International Allergens (FARRP).pdf   28.69KB   111 downloads

Rgds / Charles.C

[moskito]

Dear Charles C.

thank you for sending these links - some I was aware, but one I have not known even I am using the farrp-homepage. This link is very helpful.

Rgds

moskito

Dear moskito,

Thks yr interesting reply. It’s an admirable project.

I daresay you are aware of the references below already. They all looked quite useful to me, especially the first two in terms of your own possible onward investigation. The attachment is extracted from first link in case of later disappearance of link.

http://farrp.unl.edu/IRChart

http://www.ifst.org/...gen_management/

http://www.foodaller...Guidelines.html

http://www.hindawi.c...ja/2012/746125/

 International Allergens (FARRP).pdf   28.69KB   111 downloads

Rgds / Charles.C