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In the UK do allergen May Contain statements have to be accented in Bold?


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StevieP

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Posted 06 July 2020 - 09:17 AM

Morning Everyone,

Could anyone confirm that for the back of pack allergen "May Contain" statement, the allergens now have to be also accented in 'Bold'.

 

just wanted clariification.

 

Kind Regards, Steve 



Setanta

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Posted 06 July 2020 - 01:28 PM

In the US, the verbiage May Contain has mixed success. Some feel it is overused as a generalization and could demonstrate a potential lack in allergen program. I BELIEVE that again in the US, we embolden the word ALLERGEN: followed by allergens in regular font.


-Setanta         

 

 

 


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kettlecorn

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Posted 06 July 2020 - 05:51 PM

In the US, the verbiage May Contain has mixed success. Some feel it is overused as a generalization and could demonstrate a potential lack in allergen program. I BELIEVE that again in the US, we embolden the word ALLERGEN: followed by allergens in regular font.

Yes in the U.S. "May Contain" is frowned upon. Either it does or does not contain. 



pHruit

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Posted 06 July 2020 - 06:51 PM

The requirement for the emphasis (bold or similar) of allergens relates specifically to the ingredient list, in accordance with Article 21 of Regulation (EU) 1169/2011.

This article does contain provision for alternative indication in the form of "contains..." for products that don't require an ingredient list, and there is no requirement included here for the use of emphasis in the text - I suppose the theory is that, rather than having to make it stand out amongst a list of numerous ingredients, the fact that it says e.g. "contains peanuts" is taken to be sufficient communication.
There is no real provision for "may contain" in this regulation , but I'd personally infer from Article 21 that there would be no requirement to do so.

 

(N.B. as indicated by Setanta and Kettlecorn for the US, the FSA isn't overly keen on "may contain" unless substantiated by a risk assessment)



Charles.C

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Posted 06 July 2020 - 07:53 PM

At one time there was a  debate over whether to use "may contain" or "likely to contain"..

 

An interesting risk assessment for both supplier and consumer.

 

The common issue is where multiple products with varying allergens are in proximity of course.

 

One might argue that the conservative approach is safest from a consumer's POV, as long as they don't starve first.


Kind Regards,

 

Charles.C





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