In the amidst of COVID-19, I got a general query on good old allergen labeling .
We as a manufacturer do not handle or store peanut on site but we handle all different tree nuts sourced from all around the world from different supplier. As Nut supplier most of our nut supplier do not handle peanut either on site as they are dedicated one or few kind of tree nuts only but few European supplier handle Peanut and take an advisory statement as packed in same site which handles Peanut and some take allergen alibi too as they are packed in the same line.
all these time as we dont handle peanut on site we never took may contain claim on any of our finished product ( We make chocolate and various cocoa confectioneries). One of our retail client by default take Allergen Alibi for peanut as their own corporate policy considering that most nut supplier handles peanuts but rest of our client dont take that advisory claim for peanut as we dont handle them or store peanut on site.
Under my site allergen risk assessment too which is a very comprehensive one it doesn't ask me to take the peanut as alibi either. We do got an annual validation process too.
So now the query is " we are developing a new product which is a chocolate coated biscuit ,a type of very specialized biscuit limiting to couple of suppliers in Europe only and they take Peanut as may contains statement. After having a discussion and reviewing their allergen risk assessment they ruled out the sesame and egg allergen we found they were quite over declared ! and the same process and steps and equipment used same as peanut but they said though we understand sesame and egg risk is low we will never avoid peanut alibi as an allergen . I really didn't get it as i can see the risk factor is over estimated. Now we want to use the biscuit and will take Peanut as allergen may contain on final pack label but as its a biscuit which is already made in solid form I am interested to know the thought of the forum to advise how much does it affect exiting line allergen advisory and may contain statement.
I can always make a positive release by checking the raw material for peanut allergen and i will do that in this case to protect due diligence defense if necessary for future but should it be affecting my any existing product if this biscuit is introduced to my site which is taking an overkill as may contain peanut statement :)