Allergy: what to consider when labelling food A guide for small and medium businesses that make or sell prepacked food June 2014 Contents Introduction . 1 Food allergies . 2 How to label allergens . 4 Cross-contamination . 6 How can allergen cross-contamination be avoided? . 7 Free- from labelled foods . 10 More information . 11 Introduction Who is this booklet for? Food labelling, allergies and the law This booklet is for small businesses producing prepacked foods . It will Food allergens used as help you decide what you should ingredients or processing aids put on the label if foods you must be declared . See the EU Food produce contain ingredients that Information for Consumers (EU FIC) some people are allergic to . Regulation No .1169/2011 . Food must not be placed on the What does ‘prepacked’ mean? market if it is considered to be harmful to health (see Article ‘Prepacked’ refers to any food put 14 of EU General Food Law into packaging before being placed Regulation 178/2002) . Food on sale, when all the following labelling information is important things apply: in deciding if a food is safe to eat ●● the food is either fully or partly and to prevent consumers from enclosed by the packaging accidentally eating a food which will make them ill . ●● the food cannot be altered without opening or changing the packaging ●● the product is ready for sale to the public or to a catering establishment Allergy: what to consider when labelling food 1 Food allergies Some people are allergic to certain What foods should foods . Eating these foods could I consider? make them ill and may even be life Although people can be allergic threatening . There is currently no to a wide variety of foods and cure for food allergies and the only ingredients, there are certain ones way to manage this is to avoid the which are particularly important food that makes you ill . when labelling products . Allergens The allergen rules within the EU Food Information for Consumers Allergens are proteins found in Regulation (EU FIC) will change food and there is usually more how allergens are labelled on than one in a food which can make you ill . An allergic reaction can be produced by a tiny amount of the ingredient that a person is sensitive to; for example a fragment of peanut or just one or two sesame seeds . Symptoms of an allergic reaction include stomach upsets, rashes, itching of the skin or mouth, swelling of the throat and difficulties breathing . Around ten people a year in the UK die from allergic reactions to food . 2 Allergy: what to consider when labelling food prepacked foods sold in the IMPORTANT UK . The new rules will apply on 13 December 2014 and will be Some ingredients do not need enforced in the four UK nations to be declared as they have (England, Scotland, Wales and been highly processed and the Northern Ireland) by the Food allergen has been removed Information Regulations 2014 . and considered to be safe (for The EU FIC lists fourteen major example refined soya oil or allergens (see list below) which glucose syrups) . will need to be emphasised within the ingredients list . These allergens are: ●● cereals containing gluten (such as wheat, (including spelt and khorasan), rye, barley and oats and their hybridised strains) ●● crustaceans (for example prawns, crab and lobster) ●● eggs ●● fish ●● peanuts ●● soybeans ●● milk ●● nuts (namely almonds, hazelnuts, walnuts, pecan nuts, Brazil nuts, pistachio nuts, cashew, macadamia nuts or Queensland nuts) ●● celery (including celeriac) ●● mustard ●● sesame ●● sulphur dioxide/sulphites (preservatives used in some foods and drinks) at levels above 10mg per kg or per litre ●● lupin ●● molluscs (for example clams, mussels, whelks, oysters, snails and squid) Allergy: what to consider when labelling food 3 How to label allergens You should declare the presence of allergens which are used as ingredients within the ingredients list for the prepacked food . You can choose the method you want to use to emphasise the allergen in the ingredients list . This can be done by listing them in bold or contrasting colours or underlining . For example: You may also decide to use an allergy advice statement on the Old product label to explain how INGREDIENTS: Water, Carrots, allergens are emphasised within Onions, Red Lentils (4 .5%) Potatoes, the ingredients list, for example: Cauliflower, Leeks, Peas, Cornflour, ‘Allergy Advice: for allergens, see Wheatflour, Salt, Cream, Yeast Extract, Concentrated Tomato Paste, Garlic, ingredients in bold’ or ‘Allergy Sugar, Celery Seed, Vegetable Oil, Advice: for allergens including Herbs and Spice, White Pepper, Parsley . cereals contain gluten see ingredients in red’ . New Where foods containing allergens INGREDIENTS: Water, Carrots, do not have an ingredients list, Onions, Red Lentils (4 .5%) Potatoes, for example a bottle of wine, Cauliflower, Leeks, Peas, Cornflour, statements such as ‘Contains: Wheatflour, Salt, Cream, Yeast Extract, Concentrated Tomato Paste, sulphites’, can be used where Garlic, Sugar, Celery Seed, Sunflower sulphites have been added to Oil, Herbs and Spice, White Pepper, the product . Parsley . 4 Allergy: what to consider when labelling food Clear reference to the Distance selling allergen The EU FIC rules on distance Allergens should be declared with selling concern businesses which clear reference to name of the sell foods online and/ or by allergenic ingredient as listed in telephone/ catalogue order . If you the EU FIC Annex II; for example sell prepacked foods in these ways ‘tofu (soya)’ or ‘tahini paste you will need to provide the same (sesame)’ . If there are several level of information on allergens, ingredients or processing aids in on your website or catalogue for a food which come from a single instance, as when food is bought allergen, then the labelling should from a retail environment . This is clearly emphasise each ingredient so allergen information is made or processing aid concerned – for available to the consumer before example ‘skimmed milk powder, they decide whether or not to whey (milk)…’ buy the product . The allergen information needs to be made The use of ‘contains’ type available at the point of purchase statements and upon delivery . The voluntary use of allergen The distance selling rules do statements such as ‘Contains: not apply to prepacked foods milk and nuts’ to repeat allergen sold through vending machines . ingredient information already Nevertheless, prepacked food given in the ingredients list will no manufacturers should ensure longer be allowed . All information that correct allergen information about allergenic ingredients must appears on the food labels be in a single place and that is regardless of the method by within the ingredients list . which it is sold . Allergy: what to consider when labelling food 5 Cross-contamination Sometimes traces of allergens can get into products unintentionally during the manufacturing process or during transport or storage . This is called ‘cross-contamination’ . Ideally, you should prevent this from happening (see the section ‘How can allergen cross- contamination be avoided?’); but in some circumstances this may not be possible . Some manufacturers choose to say on the label that a certain food could have got into say so on the label using one of the product unintentionally and these phrases: this is called precautionary allergen ●● ‘may contain X’, labelling, for example ‘may contain’ ●● ‘not suitable for someone type statements . This type of with X allergy’ labelling is voluntary and is not covered by the provisions set out in the EU FIC . IMPORTANT Precautionary allergen labelling Precautionary allergen labelling should only be used following a thorough risk assessment when If you think there is a real risk of you think there is a real risk of a food product being affected allergen cross-contamination by cross-contamination with that cannot be eliminated . an allergen you may choose to 6 Allergy: what to consider when labelling food How can allergen cross-contamination be avoided? There are several ways cross- Design contamination can occur, but with The ideal approach to avoiding careful management many of these cross-contamination with risks can be avoided or reduced . allergenic foods is to have separate Some of the areas to think about production facilities for specific are described below: products . Alternatively, you may be able to make the food containing Staff awareness the allergenic food on a separate All staff involved in handling day, or at the end of the day, ingredients, equipment, utensils, and then thoroughly clean the packaging and final food production area . However, food products should be aware of manufacturing premises and the situations in which foods product ranges vary greatly and can be cross-contaminated by these approaches are not always an allergenic food . an option . Storage Where possible, allergenic raw materials should be stored away from other ingredients . One way of doing this would be to keep them in sealed plastic bins that are clearly marked or colour-coded . Allergy: what to consider when labelling food 7 Sourcing your ingredients There may be times when equipment may need to be You should find out about the dismantled and cleaned by hand allergens present in the ingredients to make sure that ‘hard-to-clean’ you use and of those used by areas are free from allergen your suppliers . Any change in residues . Even dust contamination supplier should be accompanied by some allergens can cause an by the appropriate checks . It may adverse reaction . be possible to manage the risk of cross-contamination by changing a By developing and following a particular ingredient that contains suitable cleaning regime, you it, or by changing the supplier . can help minimise allergen cross- contamination and reduce the Cleaning likelihood of product recalls . Very small amounts of some Packaging allergens, such as nuts, can cause severe allergic reactions in Incorrect packaging and/or sensitive people .