"May Contains" allergen labelling

Morning All

I'm after some guidance on an allergen labelling query.  I have a product which contains no allergens therefore would not require a positive allergen labelling declaration.  However, through risk assessment I have identified a cross-contamination risk with egg.  I have adopted the new labelling requirements of the EU Food Information to Consumers Regulation 1169/2001 which requires allergens to be "highlighted" in the ingredients list.  Most retailers are opting for the declaration "For Allergens See ingredients In Bold" and our business have followed suit.  However, how and where would I add a "may contains" statement if  I am not declaring any allergens in the first place?  I hope that makes sense?  It feels uncomfortable to just plonk it on the end of the ingredients list, feels more appropriate to give it some sort of header?  Not sure where this fits in the regulations though and can't seem to find any guidance notes on the FSA website.  Any thoughts would be most welcome as always!

Dear elaine,

 "2001" = 2011 ?.

Yr post has obvious similarities to this other recent starter -

http://www.ifsqn.com...ids/#entry66652

There appears to be some (i presume recent) confusion in UK over this matter. (the precise "matter" is a little blurry to me).

Have to admit that I didn't fully understand yr post, probably due not directly involved. Similar, although less,  problems to other thread. :smile:

Hopefully there are other UK posters here who will be more clued-in.

Rgds / Charles.C

Thanks Charles, I think the linked post is slightly different in that the other member is trying to understand how to declare known allergens in a processing aid when there are other allergens already present. I'm trying to determine best practise for declaring an allergen present through cross contamination when no other allergens within the formulation or declared on pack. i.e. I can't use the statement "For allergens see ingredients in bold, may also contain egg" as there would be no allergens highlighted in bold.  Just stating "may contain egg" does not (in my eyes) comply with the labelling regulations which, you are correct, should be 2011 in my original post!!

Hi Elaine

You can still use the "May Contain" statement (see page 7 of attached FSA allergy leaflet)

Caz x

I thought that most people thought the 'may contain' was going?  Interesting to read the leaflet Caz.

We use "produced in a facility that uses ...(allergen)" to connote that there is a possibility of cross contamination, we put the statement below the contains: (allergen) statement. This statement does generate some phone calls, generally parents wanting to assess how big the cross contamination risk may be, while speaking with people who call with those concerns I take the opportunity to ask their preference for labeling statements. Most (very very small sample) would like a statement that would communicate if the product was produced on the same equipment as product that contains allergens.(shared equipment)

Somewhat OT :off_topic:

Dear jamesdlm,

generally parents wanting to assess how big the cross contamination risk may be

It sounds like you possess some remarkably savvy parental customers. :spoton:

Might I enquire what yr typical response to such questions is ?

(I am curious how many customers realise that such statements are often a "means to a "legal" end")

Rgds / Charles.C

Hi Elaine

 

You can still use the "May Contain" statement (see page 7 of attached FSA allergy leaflet)

 

Caz x

Thank you for that Caz :thumbup:

Hopefully a common approach will be taken by all retailers and brand owners to avoid customer confusion.

There has been quite a range of views in the past from no mention on the label, 'produced in a factory that handles X allergen', 'may contain X allergen' to 'contains x allergen' (when the product didn't but there was a slight risk of cross-contamination).

Regards,

Tony

Dear All,

Do the FSA / EC  "Decision(s)" as elaborated in this thread indicate an absence of interest in topics such as allergen threshold levels ?

Or simply an acceptance of the difficulty of any implementation of such, even if scientifically agreed to be meaningful ? ie a preference to obfuscate with labelling compromises.

Or ??

Rgds / Charles.C

I attended a FSA Allergen workshop last week, and the FSA are currently working on thresholds and they are aware that there are still some grey areas. They are printing a guidance document in the new year.

They are going to post their presentation on line, when they do, i'll post the link.

Caz x

Hello Elaine1980,

You did not mention the cause of cross contamination in your post.

Here in the Philippines we uses the precautionary "May contains...." but before we uses the "Made on equipment the also process (allergen)" i don't know if your country and or your standard will allow you use that.

I saw this link in our procedure hope it will help you or can be use as reference. http://www.efsa.euro...78620761196.htm

Thanks,

Factory Hygienist

Dear Factory Hygienicist,

Thks for the link.

The EFSA file is dated 2004 (source page stated to be updated to 2007). The site/content is valuable and  many opinions are probably still valid today however it does show how much information / new ideas, eg VITAL, have been generated in last 10 years.

BTW(1), just to illustrate the complexity of keeping up with the EC’s, here is the history (presumably) up to 2011 for the 1169 Regulation  (my re-formatting)(after 2011 no idea, hopefully nil) –

REGULATION  (EU)  No  1169/2011  OF  THE  EUROPEAN  PARLIAMENT  AND  OF  THE  COUNCIL  of  25  October  2011 on  the  provision  of  food  information  to  consumers,

 amending –

Regulations  (EC)  No  1924/2006  and (EC)  No  1925/2006  of  the  European  Parliament  and  of  the  Council,

and  repealing -

Commission Directive     87/250/EEC,

Council     Directive     90/496/EEC,

Commission     Directive     1999/10/EC,

Directive   2000/13/EC   of   the   European   Parliament   and   of   the   Council,

Commission   Directives 2002/67/EC  and  2008/5/EC  and

Commission  Regulation  (EC)  No  608/2004

alg1 - EC reg. 1169-2011.pdf   1.12MB   84 downloads

BTW(2) -  Here is a  seminar on the current EC allergen-labeling situation stated to be as of April 2013 –

alg2 - Seminar on EU Regulations on Food labelling (Allergenic Substances), 2013.pdf   881.49KB   85 downloads

BTW(3) - There is a considerable amount of  very readable EC allergen law material (including FAQs,  historical back-linkages / dwl files) available on the official Irish FS site ( :thumbup: )  –

http://www.fsai.ie/faq/allergens.html

Rgds / Charles.C

Dear All,

I recently noticed that BRC have also issued a Guidance document regarding EC 1169/2011 (posted here already ? :dunno: ) -

BRC Guidance on Allergen Labelling and the Requirements in Regulation 1169-2011.pdf   2.81MB   103 downloads

Rgds / Charles.C