4 replies to this topic

[shookimogh]

Hi Folks,

We have purchased an ingredient that contains lactose. The ingredient is on the way. Should we consider it milk allergen and use all regulations regarding milk (labeling, production, etc.)? If yes, we would like to return the ingredient as we don’t handle milk and its derivatives in our facility.

I couldn’t find anything under allergen section of CFIA website and i know lactose is not an allergen itself.

to wrap up, what considerations should we take, when using this ingredient?

[kconf]

If you don't handle milk or its derivatives, then send it back. Lactose is found in milk and milk products, you won't be able to use it. 

[AltonBrownFanClub]

I just noticed you are in Canada after typing all this. Posting in case it helps you or someone in the future.

 

According to the FDA, lactose is only an allergen if protein is included. Would depend on the process used to create the lactose.

It is still a milk derivative regardless of the allergen status.

 

Here is a link to an FDA Q&A that asks this exact question. (Page 18, D.8)

https://www.fda.gov/...163454/download

 

D.8 Lactose is a milk sugar and ghee is a milk-derived fat. As a manufacturer, do I have to declare milk on the label if I use these ingredients?

• The FD&C Act requires labeling of a food or ingredient that is or contains protein from a major food allergen (section 403(w) and 201(qq)). Ingredients derived from a major food allergen that do not contain proteins are not subject to FDA’s allergen labeling requirements and would not be subject to the labeling requirements described in section 403(w)(1) of the FD&C Act. If your major food allergen-derived ingredient is processed using technology that reliably produces a protein-free ingredient and you can ensure that the ingredient does not contain protein, then you would not have to declare the major food allergen on the label. While lactose is a milk sugar and ghee is a milk-derived fat, we understand that there is commonly residual protein from milk in these ingredients. When that is the case, lactose and ghee must be labeled in accordance with section 403(w)(1) of the FD&C Act. However, the manufacturer may consider the Food Allergen Labeling Exemptions Petition and Notification process if the firm believes that their ingredient qualifies for an exemption from section 403(w) of the FD&C Act

[Tony-C]

Hi shookimogh,

 

As AltonBrownFanClub has posted, it is highly likely that your lactose will contain milk protein which is not what you want.

 

You could ask your supplier to provide information regarding the purity but you will always be giving yourself a worry and a lot of work checking that there is no protein there.

 

Kind regards,

 

Tony

[Scampi]

As per CFIA lactose is a sweetening agent HOWEVER you should verify whether or not their process removes the protein that is the allergen causing source

 

 

Ingredient that is a monosaccharide or disaccharide or a combination of these

Monosaccharides are basic units of sugar and there are only 3 monosaccharides: glucose, fructose and galactose. Disaccharides are sugars made up of 2 monosaccharide units. Common examples of disaccharides include sucrose, lactose and maltose. Therefore, a sugars-based ingredient that is a monosaccharide, disaccharide or a combination of these refers to sugars that have their common name ending in "-ose" or contains the word "sugar". This includes glucose-fructose, cane sugar, sucrose, beet sugar, and lactose. Refer to Annex 1A: examples of sugars-based ingredients that are monosaccharide, disaccharide or a combination of these for a list of additional examples.

 

https://inspection.c...s-and-allergens

 

I want to add also that FDA definitions do not always transfer so ensure you're using CFIA as your regulator