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Guidance on Labelling Allergen Content of Processing Aids

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Posted 25 November 2013 - 12:41 PM



Can anyone advise on Allergen Labelling and the Requirements in Regulation 1169/2011 in the following circumstances:


Bakery manufacturing Cakes

Release agent to assist with depanning contains soya.

Soya currently listed in Allergy Advice panel "contains .... (list of allergens) because the cakes will almost certainly contain soya from the release agent.


Regulation 1169/2011 requires:

Allergy Advice

For allergens including cereals containing gluten, see ingredients in bold.


The soya in the processing aid is not considered to be an ingredient and would appear to have to be accounted for in the following manner:

Also, may contain soya


The manufacturer of the processing aid is unable to assist.


Any thoughts on this matter or details of solutions applied in other circumstances would be much appreciate.


Thanking you in anticipation.




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Posted 26 November 2013 - 07:15 AM

Dear redmajor,


i had a look at the EC regulation you refer, all 46 pages of it.


Maybe only me but I found yr post rather difficult to understand as stated. You may hv to make yr queries more specific, eg state which paras in the reg. are involved and expand yr current difficulty.


Rgds / Charles.C

Kind Regards,



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Madam A. D-tor

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Posted 04 December 2013 - 09:15 AM

Even though the releasing agent is actually only a processing aid, I would declare this as an 'ingredient' in a very low percentage. 0,2?

Motivation for this is that this releasing agent has contact with the product and it is not clear if maybe a small amount of this processing aid is absorbed by the products.

When declaring this processing aid as an ingredient, you can also declare this allergen as present in the product. Which fitts better than declaring as 'may contain', while you are quite certain that (at least the outside of the product) will contain a small amount of this processing aid.

Kind Regards,

Madam A. D-tor

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Posted 08 December 2013 - 03:32 PM



I think there is no change to the past - per definition a processing aid which contains an allergen is an ingredient and has to be declared.




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