5 replies to this topic

[Cherrypie68]

Hi

Any thoughts regarding allergen control and supplier specs that detail "may contain"

How does anyone else manage this without the reliance of precautionary labelling?

Thanks

[MDaleDDF]

I guess it kind of depends what it is, and what the may contain allergen is, but for me and my process in my building?   No go.   I wouldn't let that in my building.

[Sanjay INDANI]

Hi

 

May contain is precautionary labeling for consumers.

If supplier mentions that the material may contain traces of allergens, its simply not acceptable.

You need to push your supplier to establish allergen management program, supported by verification & validation, to ensure that, this may contain possibility is eliminated.

 

Regards

[Scampi]

Agree with PP

 

That's a no go  (unless said ingredient is in your finished good--obvs)

[Charles.C]

Hi

Any thoughts regarding allergen control and supplier specs that detail "may contain"

How does anyone else manage this without the reliance of precautionary labelling?

Thanks

Hi CP,

 

IIRC the UK/FSA (maybe et al)  have issued some (Risk-based) Guidelines on this, occasionally vexed, topic.

 

There are a variety of threads on this Forum relating to pro/anti use of such labelling, often referring to FARRP contexts.

 

Some people regard it as a purely "escapist" manoeuvre, others as a genuine Safety -Protection option..

[pHruit]

(TL;DR - I'd start by talking to your supplier)

 

The latest UK allergen labelling technical guidance from the FSA directs users towards FoodDrinkEurope's Precautionary Allergen Labelling document.

In general I agree with Scampi and MDaleDDF that "may contain" from a raw material supplier is a potential red flag, but as a first step I'd be talking to them to understand why they are taking this approach. If it's a simple case of absent / poor / unvalidated control in their process (whether that be manufacturing or the raw material sourcing stage) then I'd be looking for an alternative supplier.

 

But there is also a possibility that they'll present a very reasoned justification, for example where there is genuinely unavoidable risk carried over from potential co-mingling of allergens at the agricultural stage of things. It is genuinely very difficult to maintain absolute separation of some types of crops at the growing level - as a basic example I'm pretty sure there is a small amount of barley growing with amongst some of the soft fruits in my garden, and I definitely didn't plant it there. It just so happens that a farmer a few fields away grows barley sometimes, so it spreads as a semi-wild plant throughout the area. If I was to mechanically harvest some of those fruits in my garden (rather than delicately hand-picking each one, which isn't practical with some crops on a commercial scale) there is a definite possibility there will be a declarable allergen mixed in with them.
If this type of scenario is the basis for your supplier's position then they will hopefully be able to give you some actual numerical data on potential cross-contamination levels, which you can then plug in to a quantitative risk assessment of the type discussed in the FoodDrinkEurope link.

 

I'd expect this type of scenario to come under increasing scrutiny in the EU/UK (IIRC the FSA ran a consultation on precautionary allergen labelling in 2021/22), but in the meantime it's not an easy area to navigate - the regulators may point towards documents like the FDE one in their guidance, but it doesn't carry any direct legal weight, and certainly doesn't override the general obligations under e.g. Article 14 of Regulation (EC) 178/2002.