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Is it mandatory to implement allergen control programs if we declare the allergen on the label?

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Posted 22 April 2021 - 09:18 AM

Is it still mandatory to implement allergen control programs if we declaring the allergen on the label?


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Posted 22 April 2021 - 09:24 AM

If you are handling allergen, you need to have allergen management program in place

Ehab Nassar

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Posted 22 April 2021 - 11:09 AM

Yes for sure, declaration has a different purpose than control program , declaration is a way of communication with the consumer before consuming the product , it is a legal issue in most countries e.g. GCC it is mandatory.


Allergen control program is a is your company's written document regarding the storage, handling, processing, packaging, and identification of allergenic foods and ingredients to mitigate the risk of cross contamination due to mishandling. if you are certified with food safety certificate it is mandatory


So they are not alternative , 


below is food code Dubai

3.6 Control of Allergens

Operational standards of the food establishment shall consider protection of consumers with food

allergies, intolerances and autoimmune diseases. Food establishments shall integrate allergen

management as a part of the food safety management system and should consider the risk from food

allergens together with other food safety risks.

3.6.1 General Requirements for Allergen Management

a. All food establishments shall implement an allergen management system.


The food industry faces the threat that the food it serves may endanger workers or customers. Microbes

are everywhere. Pathogenic microorganisms pose the greatest danger causing foodborne illnesses. Good

policies and procedures for preventing microbial contamination serve as barriers to these disease-causing



Food Code – Version 4

b. Food establishments must declare the 12 most common ingredients known to cause allergenic

reactions when they are present in the food that is prepared or sold in the establishment.

c. The following ingredients are contained in food–whether as an ingredient, compound

ingredient, food additive or processing aid–they must be declared on the label or the menu,

no matter how small the amount:

• crustaceans and their products (e.g. prawns)

• peanuts and their products

• soybeans and their products

• tree nuts and their products (almonds, hazelnut, walnut, macademia, pecan, pistachio etc)

• sesame seeds and their products

• fish and fish products

• egg and egg products

• milk and milk products

• gluten and cereals containing gluten (wheat, rye, oats, barley and spelt)

• celery and their products

• mustard and their products

• sulphur dioxide and sulphites

d. For the product labels on packaged food produced or imported to Dubai where federal or GCC

standards are applicable, declaration of allergens can be limited to the ingredients provided in

the relevant food standards.

Note: Over 250 foods have been identified as possible allergens. While it is not possible to identify

all those foods as potential hazards, food service businesses should carryout an internal risk

assessment process as a part of their food safety management systems and identify any specific

allergens that might be applicable to a certain clientele. For instance, identification of lupin and

molluscs as allergens in a restaurant that serves to consumers from European Union where these

ingredients are labelled as allergens.

3.6.2 Management of Allergens

a. Food establishments shall conduct an assessment of raw materials to establish the presence

and likelihood of contamination by allergens listed under Section 3.6.1. This assessment

should include but not be limited to the review of raw material specifications and, where

necessary, acquire additional information from suppliers through questionnaire or supplier


Food Code – Version 4

audit to verify the allergen status of the raw material, its ingredients and the production


b. The establishment shall identify and list allergen-containing materials handled on site. This

list shall include all the allergen containing raw materials, intermediate, finished and newly

developed products.

c. Food establishment where a certified food safety management system is mandatory, the

establishment shall carry out a risk assessment to identify routes of allergens and establish

documented policies and procedures for handling raw materials, intermediate and finished

products to ensure cross-contact is avoided. This should include:

i. identification of the scope of the program.

ii. consideration of the physical state of the allergenic material (i.e. powder, liquid,


iii. systematic identification of probable areas or steps of cross-contact throughout the

process flow.

iv. assessment of identified risk at each process step.

v. identification and implementation of suitable controls to reduce or eliminate the risk of


vi. establish and implement systematic monitoring of those controls.

vii. establish appropriate corrective action when monitoring indicates that control is


viii. regularly review the program to ensure that the measures outlined above are working


d. Procedures or controls implemented by the establishment to ensure the effective

management of allergenic material to prevent cross-contact into non allergen products shall

include but not be limited to:

i. physical or any other appropriate control during storage, processing and packing.

ii. the use of separate or additional protective clothing when handling allergenic materials.

iii. the use of good hygiene practices like hand washing, cleaning of food contact surfaces

etc. when handling allergenic materials.

iv. use of identified, dedicated equipment and utensils for processing

v. identify specific and labelled areas to store equipment and utensils used for processing

allergen free foods

vi. scheduling of production to reduce changes between products containing an allergen

and products not containing the allergen.

vii. systems to restrict the movement of airborne dust containing allergenic material.

viii. waste handling and spillage controls.


Food Code – Version 4

ix. restrictions on food brought onto site by staff, visitors, contractors and for catering


e. Procedures shall be in place to avoid contamination during rework.

f. The establishment shall fully validate and routinely verify the production process, in case the

claim is made regarding an allergen in food.

g. Equipment or area cleaning procedures shall be designed to remove or reduce to acceptable

levels any potential cross-contamination by allergens. The cleaning methods shall be validated

to ensure they are effective, and the effectiveness of the procedure routinely verified. Cleaning

equipment used to clean allergenic materials shall either be identifiable and specific for

allergen use, single use, or effectively cleaned after use.

h. The establishment shall have appropriate internal and external communication related to

allergen management. This includes but is not limited to information related to primary and

secondary ingredients, change in procurement, recipes, packaging, preparation or production

procedures, equipment, layout and staff.

i. Establish documents and records that are appropriate for the nature and size of the food

establishment to demonstrate the effective application of the above-mentioned requirements.

3.6.3 Labelling of food with allergens

Food containing any ingredient or derived from a substance or product listed in clause 3.6.1 shall meet

the following requirements:

a. If foods containing allergen are packaged or re-packaged, the food establishment must list the

presence of these allergen with its type in the ingredient list in bold font. This shall be easily

visible, clearly legible and not obscured in any way or "Contains" followed by the name of the

food source from which the major food allergen is derived, immediately after or adjacent to

the list of ingredients, in type size that is no smaller than the type size used for the list of


b. Modification of any recipe with an any known allergen ingredient, the food establishment shall

clearly declare on the pack with suitable warning like New recipe or Now contains, in addition

to the amended ingredients list.

3.6.4 Providing allergen information to non-packaged food

The following allergen labelling regulations apply to food sold in retail and food service


a. When food is sold to the customers directly, for example in a restaurant or cafe, the

establishment must provide allergen information in writing. This could be either:


Food Code – Version 4

i. full allergen information on a menu, digital devices or boards

ii. a written notice placed in a clearly visible position explaining how customers can obtain

this information - for example by speaking to a member of staff

iii. Use allergy and intolerance icons to tell your customers how they can find out allergy


b. If food is offered on a buffet, allergen information for each food item should be provided

separately. Measures should be in place to facilitate consumers with severe allergy to consume

food prior to other customers thus reducing the risk of contamination.

c. If food is sold through online platforms or provided up on phone order for a takeaway, allergen

information must be provided before the purchase of the food is completed - this could be in

writing (for example on a website, catalogue or menu) or orally (for example by phone)

d. All service staff should be formally trained on procedures and policies regarding management

of allergens prior to start of work. Service staff should:

 be trained and required to ask the customer about potential allergies before

taking an order in person, or on phone

 be trained on handling allergy information requests and when relevant, be able to

guarantee that allergen-free meals are served to the right customers.

e. Food handlers should know the risks of allergen cross-contact when handling and preparing

foods and how to prevent cross-contact.

f. Where the nature of the production and preparation process is such that cross-contact from

an allergen cannot be prevented, a warning shall be included on the label and/or food menu.

3.6.5 Precautionary allergen labelling

If there is a risk of a food product being affected by allergen cross-contact, the label should include

one of the following statements:

• may contain X


• not suitable for someone with X *


* Name of ingredient

Precautionary allergen labelling should only be used after a thorough risk assessment. It should only

be used if the risk of allergen cross-contact is real and cannot be removed.

3.6.6 Free-from Allergen Claims

Strict controls are required for ingredients, handling and preparation when foods are sold with ‘free

from’ claims. If the label or declaration in any format indicate or suggest that the product is free from

a particular allergen, this declaration has to be based on specific and rigorous controls needed to

ensure that the produce is completely free from the particular allergen. This should include verification

of ingredients and packaging materials and prevention of cross-contact.


Food Code – Version 4

Note: Free-from claim is a guarantee that the food is suitable for all with an allergy, intolerance or an

autoimmune disease. Exceptions for the lower limit of a particular allergen is applicable to foods when

lower limits are specified by food standards applicable in UAE





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Posted 22 April 2021 - 03:08 PM

Absolutely, because you need to be able to prove that other allergens besides the named allergen aren't making their way into your product.

chris ciarcia

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Posted 22 April 2021 - 03:43 PM

Absolutely it is as your allergen management program will also include your storage practices 


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Posted 23 April 2021 - 12:29 PM

Yes, Yes, Yes!!!!


the industry standard says you must prove that you took steps to minimise the allergen contamination on site and BRC Interpretation Quote: The use of a warning label should be justifiable and should not be a substitute for good manufacturing practices. Therefore if there is a genuine reason for stating all allergens on your label, then you should prove, why it is a case.


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Posted 29 April 2021 - 01:20 PM

Control the allergens that are not supposed to be there. 


Are there supply chain risks?

Are there employee lunches?

Are your methods of segregation sufficient and followed?



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