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Precautionary statement for Tree Nut Allergen

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Nutritious_ff

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Posted 27 January 2021 - 07:52 PM

I'm wondering if someone can advise on this precautionary allergen labelling issue. We have a product which contains almonds, cashews, hazelnuts and walnuts as ingredients. We are putting a precautionary statement on the label because our ingredient suppliers cannot guarantee that these tree nuts are free from cross contamination with other tree nuts they process. On the label we would like to put a precautionary statement which says "May Contain Other Tree Nuts" however our customer insists we use "May Contain Tree Nuts" which seems confusing because the product contains some but not others. is there a correct way of declaring tree nuts on precautionary statements?



Scampi

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Posted 27 January 2021 - 08:01 PM

Yes--here is the info and the link 

 

Cross contamination statements

A cross contamination (or precautionary) statement is a declaration on the label of a prepackaged product that alerts consumers of the possible presence of an allergen in the food. For more details, refer to Food allergen cross contamination (or precautionary) statements.

 

https://www.inspecti...52326591?chap=4

 

 

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Nutritious_ff

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Posted 27 January 2021 - 08:26 PM

Thank you Scampi, my apologies I should've mentioned that this product will be sold in the US



Scampi

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Posted 27 January 2021 - 08:38 PM

Exclusively?

 

GMPs
Subpart B of Part 117 establishes Current GMPs. Each of the following sections within that subpart imposes GMP requirements with respect to the prevention of allergen cross-contact:

•    § 117.10 – Personnel

•    § 117.20 – Plant and grounds

•    § 117.35 – Sanitary operations

•    § 117.40 – Equipment and utensils

•    § 117.80 – Processes and controls

•    § 117.93 – Warehousing and distribution

FDA’s 1996 “Notice to Manufacturers” explains that label statements such as “may contain peanuts” are not an acceptable substitute for GMPs:

The agency is aware that some manufacturers are voluntarily labeling their products with statements such as “may contain (insert name of allergenic ingredient).” FDA advises that, because adhering to good manufacturing practice (GMP) is essential for effective reduction of adverse reactions, such precautionary labeling should not be used in lieu of adherence to GMP.

 

a)(2)Food allergen controls. Food allergen controls include procedures, practices, and processes to control food allergens. Food allergen controls must include those procedures, practices, and processes employed for:

(i)    Ensuring protection of food from allergen cross-contact, including during storage, handling, and use; and

(ii)    Labeling the finished food, including ensuring that the finished food is not misbranded under section 403(w)[§343(w), which requires disclosure of allergens by specific name] of the Federal Food, Drug, and Cosmetic Act.

 

In a nut shell NO you cannot use a precautionary statement (sorry about the pun-it was totally intended!)


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SQFconsultant

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Posted 27 January 2021 - 09:15 PM

processed in a facility that processes various types of tree nuts.  This is a warning placed by one of our clients.


All the Best,

 

All Rights Reserved,

Without Prejudice,

Glenn Oster.

Glenn Oster Consulting, LLC -

SQF System Development | Internal Auditor Training | eConsultant

Martha's Vineyard Island, MA - Restored Republic

http://www.GCEMVI.XYZ

http://www.GlennOster.com

 




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