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Allergen Labelling 1169/2011 - a practical approach

alergen may contain practcial aproach

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#1 lucky86

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Posted 16 May 2016 - 09:29 PM

Hello,

 

I read almost all leaflet brochure which I founf but still I didn't get answer about my question about "may contain information. X" x - name of allergen. I've got a sample.

 

Line no.1: diferent type of soups (tomatoe, vegetable, beetroot soups etc)

 

PRODUCT for instance SOUP tomato soup

INGREDIENTS: concentrated tomato juice, coconut oil, spice  extracts, natural flavors

Ingredients doesn't consist directly any allergen (from 14 list f allergens)  but all spice extracts  have in specifications (SDS)

information that may contain: Cereals containing gluten, milk, nuts, soya

(Informing about the unintended pr

esence of the allergen)

 

Two other soup which are made on same LINE NO 1 have:

1) vegetable soup (celery as an ingredient)

2) beetroot soup ( no allergen as a igredients)

 

 

In this situation what is correct:

 

1) Tomatoe soup

A) Product may contain: Cereals containing gluten, milk, nuts, soya (because them can be unintended in spice extract ???) and may contain celery because it is on the same line.

B)  May contain; celery   because I know that is using on the same line

 

 

2) Vegetable soup IGREDIENTS:... celery   ... .

A) Product may contain Cereals containing gluten, milk, nuts, soya (because them can be unintended in spice extract ???)

B) ONLY BOLDED INFORMATION ABOUT CELERY because is a igredient without information may contain.....?

 

3) BEETROOT SOUP

A) PRODUCT MAY CONTAIN CELERY (becaus we us it on the line as ingredient)

B) NO information about may contain

C) PRODUCT may contain ereals containing gluten, milk, nuts, soya (because them can be unintended in spice extract ???) and may contain celery because it is on the same line.

 

 

PLEASE share with me with ypur experience. I hope that I explained everything clearly . If you have any questions please do not hesitate to ask.   I think that in legislative is too small amount of examples which help us understand them correctly.

 

Best regards,

Lucas



#2 Tony-C

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Posted 17 May 2016 - 03:13 AM

Hi Lucas,

 

The use of may contain for celery seems reasonable.

 

The use of voluntary precautionary allergen labelling such as ‘may contain’, to indicate the risk of unintentional presence of allergens in a food, is still permitted and has not been affected by this regulation.
 

Although probably still legal there is concern that 'may contain' labelling is used too much, sometimes when it isn't really necessary. I would be looking at your spice extract to see if there are alternatives or discussing the possible levels of contamination with the manufacturer in order to achieve a 'cleaner' label for your products.

 

Kind regards,

 

Tony



#3 probard

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Posted 17 May 2016 - 03:04 PM

Hi Lucas,

 

As Tony said, there hasn't been any regulation specifically for traces of allergen yet.

 

However, I would advise you to do the following :

 

1- Label the possible traces based on a risk Analysis, both for raw ingredients cross contamination (for example, some companies only Label traces of allergen from ingredient contamination if this ingredient is present in more than ??% in the finished product) as for plant cross-contamination (for example test the surface of the Equipment after the usual cleaning - allergen tests can be found in kits, but sending them to a specialized lab usually allows to have a lower Limit of detection).

2 - Prefer phrasing such as "Product may contain traces of " so that it is clearer to the consumer that the recipe does not "Change" to sometimes include the allergen and sometimes not.

 

As the labelling of traces is not regulated by the 1169/2011, you don't have to write the traces in bold (only the Allergens in the ingredients list must be bold or otherwise highlighted).

 

Best regards,

 

Pauline



#4 lucky86

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Posted 18 May 2016 - 09:38 PM

Hello,

I'd like to thank you both for your answer. I have questions to Pauline.

 

Do I understand you corectly regarding to this proper examples of soups.

" 1- Label the possible traces based on a risk Analysis, both for raw ingredients cross contamination (for example, some companies only Label traces of allergen from ingredient contamination if this ingredient is present in more than ??% in the finished product) as for plant cross-contamination (for example test the surface of the Equipment after the usual cleaning - allergen tests can be found in kits, but sending them to a specialized lab usually allows to have a lower Limit of detection)."

 

 

For instance  if in my  final product   from first post spices extract are  below 1% I can consider this content as an unimportant and limit only to inform about possible cross contamination on the line?

 

Second one:

|"2 - Prefer phrasing such as "Product may contain traces of " so that it is clearer to the consumer that the recipe does not "Change" to sometimes include the allergen and sometimes not."

 
Because in Community law there is no definition that would show how much of the substance allergenic can be regarded as "trace amount" and the term is sometimes arouses in other Member States of controversy (see the situation in the Czech Republic) is permitted to label the information "may contain ..." \ "the possible presence of ..." etc.
 
 
I encourage to discussion.  :)
 
Best regards,
Lucas
 
 
 
 


#5 probard

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Posted 19 May 2016 - 04:42 AM

Hello Lucas,
1- yes, that's the idea. (some companies even consider much larger amounts).
2- I wasn't aware of this controversy. There are in fact in European law no defined sentence. Another frequently used is "produced in a factory which also uses...". Looking at packagings from similar products may help you finding your favorite sentence!
Regards,
Pauline



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