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Allergen - Not bold. Meaning?


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#1 salakidum87

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Posted 18 December 2019 - 02:26 PM

Declaration in the EU

I am trying to understand an ingredient was mentioned but not highlighted in bold. 

Can someone tell if this is acceptable or not? 

e.g: Wheat and salt. (wheat is not highlighted in bold)



#2 Slab

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Posted 18 December 2019 - 02:41 PM

Hi, salakidum87;

 

It would have to meet the requirements written in sub-part (b)
 

According to Article 21(1), point (b) of the Regulation:

‘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:

(…)

(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.’

 

 

 

https://eur-lex.euro...52017XC1213(01)


Edited by Slab, 18 December 2019 - 02:43 PM.

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#3 pHruit

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Posted 18 December 2019 - 02:43 PM

The regulation - specifically Article 21(1)(b) of Regulation (EU) 1169/2011 - does provide other options beyond bold. Whilst that seems to have become the de facto norm, there is provision for potentially using a different typeface or colour to achieve the same end; namely that the allergen must be emphasised in some way.

If that isn't the case and this is a final retail pack then yes, this sound like it doesn't meet that requirement and someone may need to look at their recall procedure...

 

Edit: Slab is a faster typist than me (or possibly just less verbose ;) ) but we've both come to the same conclusion.


Edited by pHruit, 18 December 2019 - 02:44 PM.


#4 Andy_Yellows

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Posted 18 December 2019 - 02:44 PM

Hi Salakidum87,

 

Allergens don't HAVE to be indicated in bold on pre-packed foods but they do have to be displayed in the ingredients list in a way that makes them more noticeable than non-allergenic ingredients. Personally I think bold and capital letters is the best way but putting them in a different colour or underlining them would be satisfactory. Has wheat been displayed differently to the other ingredients despite not being bold?

 

More info available here: https://eur-lex.euro...018:0063:EN:PDF

 

Or here https://www.food.gov...d-manufacturers for a more straightforward explanation.

 

Hope that helps,

 

Andy


Edited by Andy_Yellows, 18 December 2019 - 02:45 PM.

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#5 salakidum87

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Posted 18 December 2019 - 02:50 PM

Hi, I checked the FSA and it says a different format to be expressed to show allergens differently than ingredient. 

 

 

Hi Salakidum87,

 

Allergens don't HAVE to be indicated in bold on pre-packed foods but they do have to be displayed in the ingredients list in a way that makes them more noticeable than non-allergenic ingredients. Personally I think bold and capital letters is the best way but putting them in a different colour or underlining them would be satisfactory. Has wheat been displayed differently to the other ingredients despite not being bold?

 

More info available here: https://eur-lex.euro...018:0063:EN:PDF

 

Or here https://www.food.gov...d-manufacturers for a more straightforward explanation.

 

Hope that helps,

 

Andy

Yes, the label is displayed as - Wheat, salt. Thats all. 



#6 salakidum87

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Posted 18 December 2019 - 03:47 PM

How does it work on single ingredient products? 

 

E.g - Cod (Fish)? Do you still have to declare??



#7 pHruit

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Posted 18 December 2019 - 04:11 PM

How does it work on single ingredient products? 

 

E.g - Cod (Fish)? Do you still have to declare??

 

It depends on the nature of the product - if it is self-evident that the food has only one ingredient and this is an allergen then there is not specific extra requirement. See article 19 of 1169/2011 and part 61 of the attached technical guidance.

It may still be required in some cases, where it wouldn't necessarily be obvious to the consumer that the single ingredient is itself an allergen.

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