6 replies to this topic

[Wian]

Good day

 

I did some searching and can't find any reference material  (apart from egg, milk, peanut, sulfites & gluten) which states what the 14 common EU allergen limits are before it needs to be declared on product packaging.

 

I found a lot of recommendations but no specific legislation.  Are there currently set limits as for egg, milk, peanut, sulfites & gluten, and where can i find reference source?

 

Thanks

 

[Charles.C]

Good day

 

I did some searching and can't find any reference material  (apart from egg, milk, peanut, sulfites & gluten) which states what the 14 common EU allergen limits are before it needs to be declared on product packaging.

 

I found a lot of recommendations but no specific legislation.  Are there currently set limits as for egg, milk, peanut, sulfites & gluten, and where can i find reference source?

 

Thanks

 

Hi Wian,

 

There are various threads here on this, eg -

 

http://www.ifsqn.com...ces/#entry89943

[Charles.C]

addendum

 

the reason for very few EC limits is usually due the limit = 0, (with a few exceptions, eg glutens, SO₂₎

 

_{(There are a few locations which do use thresholds, eg Australia)}

[Wian]

addendum

 

the reason for very few EC limits is usually due the limit = 0, (with a few exceptions, eg glutens, SO₂₎

 

_{(There are a few locations which do use thresholds, eg Australia)}

 

Thanks Charles, but as mentioned I cant find supporting documentation stating that the EC limits is = 0, or anything otherwise.  A lot of sources and legislations state the allergens but does not mention when it should be declared.  Maybe I missed it, will go through them again.

[GMO]

Thanks Charles, but as mentioned I cant find supporting documentation stating that the EC limits is = 0, or anything otherwise.  A lot of sources and legislations state the allergens but does not mention when it should be declared.  Maybe I missed it, will go through them again.

 

That's because there are no limits well, almost, (I will explain that statement further in a mo.)  The reason being that different allergenic consumers have different sensitivity and currently there is insufficient research to prove a limit can be "ok".  It could also be argued that if you detect some allergens, albeit at a low level, you cannot be certain of the homogeneity of the batch so if they are detectable at a low level, it's possible they could be detectable at a higher level elsewhere.

 

Next, it also assumes complete recovery from your food matrix when the product is tested.  I've had experience with sulphites where this is very poor and I know someone else has had very big problems with egg when cooked with wheat so your lab result of, say, "10ppm" may actually be out by a vast margin.  (I kid you not, I had a sample I knew to be c. 1000ppm SO₂ reported as <10 and I know someone else who did a controlled trial on egg at similar levels and had results out by factors of 100s.)

 

How EU manufacturers approach this is by declaring all ingredients which go in which contain allergens (with a few minor exceptions e.g. glucose derived from wheat) even if that allergen is in all likelihood destroyed by the process.  So you will always see "barley" declared on vinegar but you'll never find gluten if you test it.

 

Then you validate clean downs between products.  How we do it is possibly OTT vs. what others do but we test positive controls (which checks the lab can actually recover the allergen, which, as I explained is not a given) and "dirty" swabs then test clean swabs and the first three products off the line to ensure the clean is effective.  We then use visual cleanliness as our ongoing verification (but we use minimal allergens at my site).  Other sites using a lot of allergens may use regular rapid swab tests for verification.

 

As for limits, there are two, kinda.  SO₂ or sulphites if <10ppm does not have to be declared.  Cereals containing gluten doesn't officially have a limit but you can declare something is "gluten free" if there is <20ppm.

 

So in summary, if you can detect it for EU sale in most cases, that's a problem.  As a result, and this does seem disingenuous, be very careful about what you test.  I recommend only testing product or processes where you can hold the product until you know the results or you are very confident of your processes, otherwise you could be having a public recall.

[Madam A. D-tor]

dear Wian,

 

All answers to your post are correct.

Limits are 0. (except for sulphite)

This is documented in EU 1169/2011

Article 9

List of mandatory particulars

1.   In accordance with Articles 10 to 35 and subject to the exceptions contained in this Chapter, indication of the following particulars shall be mandatory:

...

©

any ingredient or processing aid listed in Annex II or derived from a substance or product listed in Annex II causing allergies or intolerances used in the manufacture or preparation of a food and still present in the finished product, even if in an altered form;

This means that all ingredients containing allergens need to be declared.

 

Article 21

Labelling of certain substances or products causing allergies or intolerances

1.   Without prejudice to the rules adopted under Article 44(2), the particulars referred to in point © of Article 9(1) shall meet the following requirements:

 

(a)

they shall be indicated in the list of ingredients in accordance with the rules laid down in Article 18(1), with a clear reference to the name of the substance or product as listed in Annex II; and

 

(b)

the name of the substance or product as listed in Annex II shall be emphasised through a typeset that clearly distinguishes it from the rest of the list of ingredients, for example by means of the font, style or background colour.

 

In the absence of a list of ingredients, the indication of the particulars referred to in point © of Article 9(1) shall comprise the word ‘contains’ followed by the name of the substance or product as listed in Annex II.

 This is saying the way all allergens need to be declared: Behind the ingredient in the ingredient declaration and in a distinctive typo.

 

In annex II of this regulation is the list with the allergens. Stating that sulphite only needs to be declared > 10 ppm.

[Madam A. D-tor]

conclusion: (art 9) if there is allergenic material in your product, you should declare it. No matter what the amounts are and no matter if it has changed it forms.