Yes, you need to revise your labeling. For one, the ingredient declaration is a bit confusing and if you have a separate "may contains" statement along with it even more confusing. It took me a good 5 minutes to understand what is exactly going on in your ingredient declaration which is way too long. At any rate, I do have some suggestions and see the link below regarding Canadian allergen labeling requirements. Be careful on the oats because they may contain gluten. I don't know what the flavor base or derivation is, but I would have that ingredient tested for gluten to see if it is in the flavor.
- Separate out the sugars and list individually
- Be consistent in usage of parenthesis. I get why you don't do it for "Peanut Butter" because it is obvious, right? Well...if one does not read carefully they overlook it because they focus on parenthesis items and see "Milk" and think, ok only milk allergen.
- If you can eliminate the "May Contains". I know bakeries have difficulty because of ingredients and equipment / cleaning.
- Here's my suggestion on ingredient declaration for your product with a contains statement and may contains statement (if you want to keep it).
Ingredients: Sugar, Brown Sugar, Peanut Butter, Enriched Wheat Flour, Butter, Peanuts, Water, Natural Flavour, Soy Lecithin, Baking Powder, Salt, Baking Soda.
Contains: Peanuts, Wheat, Milk, Soy (**Gluten if you find the flavor with oats tests for gluten)
May Contain: Tree Nuts, Egg, Sulphites
I have a question...
We currently produce a cookie with the following ingredient declaration in Canada:
Sugars (sugar, brown sugar), Peanut butter, Enriched wheat flour, Butter (milk), Peanuts, Water, Natural flavour, Soy lecithin, Baking powder, Salt, Baking Soda.
May contain: Tree nuts, Egg, Sulphites.
We are planning to add another flavour which will contain oats.
Will we need to add "oats" to the may contain list when "wheat" is already declared in the ingredient declaration.
Any help you could provide would be greatly appreciated.
Thank you all.