What are the labelling requirements for declaring traces of allergens?

Dear all

I would like to have your opinion about the following.

Imagine that an ingredient of your end product states on its technical sheet that it may contain traces of ...(alergens).

Would you indicate " traces of ...alergens" on the label of your end product.

What an IFS/BRC auditor would say? Any experience?

Thank you all in advance

Best regards
Esther

Dear Esther,

<< Would you indicate " traces of ...alergens" on the label of your end product.>>

IMO, such a statement would be simply meaningless. It is similar (in reverse) to some specifications (both official and private) for raw food that I hv met which state that the product must be free of pathogens.

Hv you actually encountered this format ??

Rgds / Charles.C

I'd go back to the supplier if I could and clarify what they mean by "traces of..." do they mean they process said allergen on site? Are they just covering their ****? It might mean you can be more specific on the packaging, e.g. "recipe; allergen x free, processing sites; allergen x processed on site". Not sure if that would be acceptable?

I'd go back to the supplier if I could and clarify what they mean by "traces of..." do they mean they process said allergen on site? Are they just covering their ****? It might mean you can be more specific on the packaging, e.g. "recipe; allergen x free, processing sites; allergen x processed on site". Not sure if that would be acceptable?

Dear GMO & Charles

First of all, thanks for your comments.

GMO, That is what I was thinking about because by saying " it contains traces of ...allergens" it may mean

a) you have those allegens in your plant for other products and, in order to cover your ****, you decide to mention those allegens on the label of the products running in the same line

or

b)you do not have those allegens in your plant but, because the technical data sheet of your ingredient say " it may contain allergen" then you write the same on your products' label. Till when? Ad infinitum?
How would you deal with it in this case?

Any other experience to share?

Charles, sorry but I do not undertand your comment. Maybe it was my fault. When I said " << Would you indicate " traces of ...alergens" on the label of your end product.>> it was not an affirmation but a question.

BEst regard
Esther

Dear Esther,

Sorry, my eyes skipped yr 3rd line.

This issue has created endless discussion with ,as far as I know, no consensus.
I suppose in general it is preferable to invoke the standard precautionary principle just like in the case of the recent volcano. The English (maybe everybody) hv a saying, "prevention (or protection) is better than cure".

Actually i believe from earlier forum threads that "guidelines" do exist but I cannot remember what they were. My guess is that every country is different.

Rgds / Charles.C

Dear Esther,

Sorry, my eyes skipped yr 3rd line.

This issue has created endless discussion with ,as far as I know, no consensus.
I suppose in general it is preferable to invoke the standard precautionary principle just like in the case of the recent volcano. The English (maybe everybody) hv a saying, "prevention (or protection) is better than cure".

Actually i believe from earlier forum threads that "guidelines" do exist but I cannot remember what they were. My guess is that every country is different.

Rgds / Charles.C

Dear Charles

Thank you for your reply.

I will search the forum looking for the mail mentioning those guidelines. I am really interested in that.

Best regards
Esther

Dear all

I would like to have your opinion about the following.

Imagine that an ingredient of your end product states on its technical sheet that it may contain traces of ...(alergens).

Would you indicate " traces of ...alergens" on the label of your end product.

What an IFS/BRC auditor would say? Any experience?

Thank you all in advance

Best regards
Esther

Dear All,
Esther, A link that I think will help you to analyze the risk and give guidance on allergen labeling is
www.allergenbureau.net.
On this site there is "Vital" (Voluntary Incidental Trace Allergen Labeling) explanation and spreadsheet calculator (download). The risk is calculated by inputting product ingredient data and the calculated results indicate the required label declaration.
This analysis is required (mandatory) for WQA private label standard, and provides a strong due diligence.
I find this tool removes the grey area and gives confidence when designing label claims.

Dear Esther,

I apologise for not replying promptly to your question, but I am new to this network. You raise an issue that has been troubling food suppliers and allergic consumers since around 1993. Having worked with the UK food industry and people with allergies since around that time, I feel sympathy for both sides. Consumers have become angry and frustrated with the spread of "may contain" statements, but industry has to put consumer safety first. My current work focuses on helping food businesses to assess and manage allergen risks. Individual companies require individual solutions, depending on a wide range of matters including what kind of foods they are producing. There are no simple answers that can be provided in a few words, but if anyone would like to discuss this further I can be contacted at EMAIL REMOVED.

Best wishes, David Reading

The issue is country specific - especially since some countries recognize certain ingredients as allergens that must be declared and other countries do not. In the U.S., all allergens are supposed to be declared no matter how much might be - or not be - there. If there is the possibility that the product contains an allergen - it should be stated. At one time, a survey showed that in the U.S. there were at least 28 different phrases being used on labels to indicate allergens. The variety exists because the issue is not simple. To declare something as absent as a risk- you have to have very good test methods with detection limits that will address the most sensitive of persons. The problem is that those levels are not not established.

Dear Cathy,

Maybe I misunderstood yr comment but this link (2004, pg last updated 2009) seems to state that the labelling requirements for allergens in the USA are actually quite limited in scope -

http://www.fda.gov/F...cm106890.htm#q1

Rgds / Charles.C

I'm not sure what you mean. The scope is limited to the 'Big 8' but the confusion comes along in that FDA allows advisory statements and those vary quite a bit.

Dear Cathy,

Must admit I hv no idea what an advisory statement is. Sounds quite dangerous. Perhaps you could give an example.

I had thought the intention of FALCPA was particularly to define the range of (basic) labelling possibilities.

Rgds / Charles.C

Advisory statements are comments like "May Contain" or "Processed in a facility that also processes nuts" or "Processed on shared equipment that also processes egg and dairy products". The list goes on....

These statements are not mandatory but they are also not prohibited. The law requires clear identification of allergens in prodducts. This must be done either in the ingredient statement or in a "contains" statement. Advisory or disclaimer statements are optional and the format is clearly not dictated.

They are common on FDA regulated items, partially because (in my opinion) FDA labels are not pre-approvd before use. Products regulated by FSIS (meat and poultry) are less likely to have these statements because FSIS will ask a company to show that they are not using such statements as a replacement for good practices. FSIS is not likely to approve use of these staments.

Dear Cathy,

OK,thks, now I get it, the "back covering" syndrome.

The FSIS approach seems admirable but looks like a potential heavy load option. Indeed the potential legal aspects vis-a-vis the range of possible allergic reactions / sensitivities almost guarantees this problem will not go away.

Rgds / Charles.C