May Contain Tree Nuts - Plain English Allergen Labelling
Hi everyone.
We are currently developing a product which does not contain any tree nuts.
One of the raw ingredients has may contain tree nuts: almond, pistachio, brazil, macadamia, walnut, hazelnut, pine and pecan.
In our facility, our equipment are also used to make products containing these tree nuts: almond, pistachio, macadamia and walnut.
With the new Plain English Allergen Labelling, it requires us to breakdown what the tree nuts are in the labelling. So I wonder if I should declare in the may contain section: "almond, pistachio, brazil, macadamia, walnut, hazelnut, pine and pecan" or just "almond, pistachio, macadamia and walnut"?
Thanks heaps everyone!
Hi prwib,
Unless you are confident there is no chance of contamination of brazil/hazelnut/pine/pecan via the raw material I would include these on your statement. You could perhaps ask the supplier for their rationale on the 'may contain', but if they have assessed it to be necessary then I would be cautious on removing it.
I would also suggest labelling unless you are sure. I would ask your supplier as well as yourself if you have taken adequate measures to remove the nuts from the products. The form of the nuts is also very important, since the powder could travel in the air (if you have it being used on a close by line. Slices or pieces of nuts may get stuck in the conveyer belts and other machinery, so you need to think if this. Testing to get levels in products in general does not work if you have the potential for slices or pieces to get stuck in the line, since these are sporadic.
Only if you are 100% sure there is no chance of contamination can you take the traces away.
As for labelling, I think you need to label each nut separately, rather than just tree nuts. If it is all of them, I would think about putting "traces of all tree nuts" as an option, but I am not sure this is legal.
Some of this depends on your country or regional labeling laws. In the U.S., "May contain" and other disclaimer statements are not regulated. They are voluntary. The regulations only address the actual ingredient and "contains" statement. IN the end our goal is the same - communicate as best as possible to protect your consumer.
My understanding of PEAL is that it only covers the Contains statement, and that the May Contains statement is still optional. I would give as much information to consumers as possible so they can make an informed choice.