6 replies to this topic

[Yoloooo]

Hi All,
I need you help .
We are using olive oil spray with soy lecithin as ingredient.
We are using this as a release agent - on the trays .

So my question is: would that be a consider as allergen if its not 100% soy lecithin? It’s olive oil spray that has one of the ingredients?

[SHQuality]

The amount doesn't matter. Soy lecithin contain allergenic soy proteins, so they should be listed as an allergen on these particular products.

I would recommend to switch to a olive oil spray that uses sunflower lecithin instead.

 

Similar functionality, no allergens.

[Yoloooo]

Thanks . So another question- does this work for the supplements as well ? So if you open this attachment that is chocolate company that on their website is saying that they are not declaring the soy lecithin on their labels etc

[SHQuality]

I think you forgot the attachment...

[Yoloooo]

Sorry please see above

[SHQuality]

The law in both the USA and the EU requires you to list all potential sources of allergenic proteins in ingredients, additives and processing aids (when those allergens could potentially be left in the product in ANY amount). The law does not exempt certain levels of allergens. For soy, they should be listed on the label regardless of the expected amount present.

 

Only sulphites and gluten have specific limits in EU law.

 

The chocolate company says the levels present are insufficient to cause a reaction in the majority of soy allergic consumers, but they should be labelling it to protect ALL soy allergic consumers, INCLUDING the ones that would react to the small amounts present. While they deem the risk of occurrence minor, the potential harm (aka death) is so high that the overall risk is very much significant.

 

References:

Food Allergies | FDA

EUR-Lex - 32011R1169 - NL - EUR-Lex (europa.eu) (Article 21 and Annex II)

[Scotty_SQF]

You have to declare it even if it is a release agent and even if for the release agent it is a minor ingredient.  I was part of company that had to do a voluntary recall because we did not declare soy for soy lecithin used in a release agent.  We even had proof and a letter from the company of the release agent stating the soy lecithin was refined and thus did not pose any risk to people with soy allergies.  It did not matter as we still had to declare it.