Is a 'may contain peanut traces' statement on the label enough

Dear All,

We are the manufacturers of Pickles, Chutney , cooking sauces and spice mix i India.

Everyday peanut contamination in Cumin Poeder are declared recll in US & UK. On label issue our expert team suggest that we have to check peanu contamination from raw materials to finished products.

But I think it is only label declaration issue. If we declare on label IT MAY CONTAIN PEANUT on label an in case if found any peanut trace in any product not necessay to check peanut or any other allergens at every stage as we are not adding peanut deliberatly.

Please guide us regarding this matter an thank you in advance to everybody.

Food Forum

From the FDA's website:

Does Food Allergen Labeling and Consumer Protection Act  (FALCPA) require food manufacturers to label their products with advisory statements, such as "may contain [allergen]" or "processed in a facility that also processes [allergen]?"

No. FALCPA does not address the use of advisory labeling, including statements describing the potential presence of unintentional ingredients in food products resulting from the food manufacturing process. FALCPA does require FDA to submit a report to Congress, a part of which assesses the use of, and consumer preferences about, advisory labeling. In earlier guidance, FDA advised that advisory labeling such as "may contain [allergen]" should not be used as a substitute for adherence to current Good Manufacturing Practices (cGMPs). In addition, any advisory statement such as "may contain [allergen]" must be truthful and not misleading.

Note the part in RED.  "May Contain" statements do not absolve you of anything.  Unless you are declaring "CONTAINS: PEANUTS", your product should nominally not contain any peanut, including cross contamination/product residue/etc. 

JPO is correct.  This labeling is not sufficient. 

The issue is that in many countries peanut is an allergen that has serious effects on people and some manufacturers were adding it to bulk up their cumin spices.  This should be more than an allergen alert, IMO, it should be a tampering or falsified sales issue, also

Edited to add:  This article implies it wasn't accidental, but fraud

.http://www.foodquali....html?tzcheck=1

They are selling the 'solution', too :smile:

Agreed here, you need to know what you are getting from your suppliers.  If just putting the advisory label would be enough, then every food item would have the advisory statement and no one would be required to be careful.

You could also lose sales if you put the advisory statement for everything, because people who are allergic to peanuts would not buy your product.

Bottom line, make sure that your suppliers are honest and provide a quality product.

Martha

 

From the FDA's website:

 

Does Food Allergen Labeling and Consumer Protection Act  (FALCPA) require food manufacturers to label their products with advisory statements, such as "may contain [allergen]" or "processed in a facility that also processes [allergen]?"

No. FALCPA does not address the use of advisory labeling, including statements describing the potential presence of unintentional ingredients in food products resulting from the food manufacturing process. FALCPA does require FDA to submit a report to Congress, a part of which assesses the use of, and consumer preferences about, advisory labeling. In earlier guidance, FDA advised that advisory labeling such as "may contain [allergen]" should not be used as a substitute for adherence to current Good Manufacturing Practices (cGMPs). In addition, any advisory statement such as "may contain [allergen]" must be truthful and not misleading.

 

Note the part in RED.  "May Contain" statements do not absolve you of anything.  Unless you are declaring "CONTAINS: PEANUTS", your product should nominally not contain any peanut, including cross contamination/product residue/etc. 

 

tHANKS FOR YOUR COMMENTS

If found trace <10ppm is it called adulteration? There is an issue how to communicate with allergenic people.

My problem is if we give warning for allergen as we know we are not going to sell  this products to allergenic people is there any law to prohibite voluntary statement like IT MAY CONTAIN OR PROCESSED IN A FACILITY THAT ALSO PROCESS (ALLERGENS).

Food manufacturer always habe a GMP in place and have dicipline to have food safety, quality and legal requirement. Also trained people for allergen handling, cleaning and hygiene of the plant.

Being a manufactue of food products we use nuts, peanuts etc. in our plant. We do risk assessment for unintensional presence of allergens we think it may ccross contamination during production as we are using same line for production only way to communicate risk by way of warning on label i.e. IT MAY CONTAIN OR PROCESSED IN A FACILITY THAT ALSO PROCESS (ALLERGENS)

Just wanted to add this recent post by CFIA regarding the cumin recall that was international....

Ottawa, April 30, 2015 - The food recall warnings issued on March 20 and 22, 2015 are being rescinded. The Canadian Food Inspection Agency is advising the public that there is no longer evidence to indicate that the cumin and cumin-containing products described below contain almond. Consequently, based on the information presently available, there is no evidence that these products could pose a risk to individuals allergic to almond.

The products were recalled as a result of laboratory testing indicating that they contained undeclared almond. However, additional testing has confirmed that the original laboratory results were false positives.

The false positives were confirmed based on new evidence regarding the cross-reactivity of mahaleb, a spice obtained from a specific species (Prunus mahaleb) of cherry seeds, with the almond allergen test kit. It is highly likely that the positive sample results for the ground cumin and cumin-containing products were due to mahaleb contamination and not almond.

We are being FORCED to put a "may contain egg" statement on our raw poultry........the whole allergen business is getting a bit out of hand IMHO. I understand the need for people with allergies (FYI i am one of them) to have accurate and meaningful information on packaging, but when an immature egg is broken during the normal dressing procedure of a whole bird, having to declare an egg allergen is a bit over the top

Agreed, Scampi. Next thing they'll be putting "may contain traces of fish" on bottled water!

Or let's just cut to the chase "May contain ingredients that might sicken and/or kill you."

Seems to me to be the perfect way for the food industry to get ahead of the curve.

Marshall

The last thing we want is a declaration label on a package of food that is as detailed as the TV or magazine adverts here in the USA for pharmaceuticals (aka "drugs") as in the Food and Drug Administration.

After listening to all the side effects that "may" happen, one wonders why anyone would take any of these drugs that are supposed to benefit you?

Marshall