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List allergen "may contain" of an ingredient on finished product label?

labeling allergen

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#1 soriondee

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Posted 07 December 2020 - 01:48 PM

Hello! We manufacture a product that contains almonds and chocolate chips.

 

The chocolate chips specification states that they contain soy and may contain trace amounts of tree nuts and dairy. The chocolate chips are Pareve.

 

Our product does not contain dairy and we do not have dairy present in our facility, so we do not currently list dairy in our may contain statement.

 

We have "contains almonds and soy" and "may contain peanuts, tree nuts, and wheat" (other allergens present in our facility). My question is, does our may contain statement need to include dairy since the chocolate chips list dairy in their may contain statement? Thanks for the help!



#2 olenazh

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Posted 07 December 2020 - 02:22 PM

You use certain percentage of choc chips in your product, right? So, it's "traces of traces" of dairy. I would not bother to include dairy in "May contain"...



#3 Charles.C

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Posted 08 December 2020 - 12:09 AM

Hello! We manufacture a product that contains almonds and chocolate chips.

 

The chocolate chips specification states that they contain soy and may contain trace amounts of tree nuts and dairy. The chocolate chips are Pareve.

 

Our product does not contain dairy and we do not have dairy present in our facility, so we do not currently list dairy in our may contain statement.

 

We have "contains almonds and soy" and "may contain peanuts, tree nuts, and wheat" (other allergens present in our facility). My question is, does our may contain statement need to include dairy since the chocolate chips list dairy in their may contain statement? Thanks for the help!

 

Definitely not my area of knowledge/expertise but some degree of caution might be worthwhile, eg -

 

https://vosizneias.c...bbi-speaks-out/

 

https://kosherquest....hocolate-chips/

 

PS - offhand,  the above line 2 seems a little self-contradictory based on above articles, ie, as I understand, "Pareve" demands no dairy ? eg -

 

https://www.ok.org/c...t-dairy-pareve/

 

PPS - how do you operationally validate above line 3 ?


Kind Regards,

 

Charles.C


#4 Marloes

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Posted 08 December 2020 - 08:35 AM

How does your supplier explain the fact that the chocolate chips that are pareve (no dairy) and may contain trace amounts of dairy.
I would ask your supplier what that means. One of their statements has to be a mistake because they cancel eachother out.

Perhaps their explanation will help you.



#5 Ryan M.

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Posted 08 December 2020 - 03:04 PM

I can tell you a "may contains" statement provides your company NO PROTECTION from potential allergen lawsuits.  You have to either declare all potential allergens, which in your case would include dairy even though it is traces.  There are no "limits" in terms of allergen labeling in the US.  So you really need to remove the "may contains" and add all the items to your ingredients declaration which in reality is just stating "contains".

 

Yeah, yeah...you may lose customers because of the change, but would you rather have less customers, or persons who get ill or die from your product?



#6 Ryan M.

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Posted 08 December 2020 - 03:06 PM

How does your supplier explain the fact that the chocolate chips that are pareve (no dairy) and may contain trace amounts of dairy.
I would ask your supplier what that means. One of their statements has to be a mistake because they cancel eachother out.

Perhaps their explanation will help you.

 

Because they pay the rabbi off.  Most chocolate producers do not segregate equipment when they run their chocolate items, with or without milk.  They typically will purge with the product and run.







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