Working with extracts and flavorings with allergen ingredients or derived from allergenic material both industrial and retail packaging.
This topic/discussion was a result of an internal review of HAACP, manufacturer control and traceability. The final control point is a verification of allergen labeling. The problem is industrial/ bulk product have no label indicating allergen. Beside label with product name, company name date of manufacture and lot code.
Our documentation provided to our customers states the product is contains allergic material. Labeling in regards to industrial products will need to be an organizational decision.
Under current CFR and regulations
Raw agricultural commodities are exempt from labeling and allergen labeling.
Bulk ingredients intended for further processing and manufacturing do not require nutritional labeling
FALCP only addresses retail packages.
In summary, there are EU and US regulations regarding allergen labeling, but they are weak and with numerous loops and grey areas. I would like more global consensus and directive on the issue and not addressed by any GSFI schemes.