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Allergen Labelling

The new Food Information to Consumers (FIC) legislation Regulation (EU) No. 1169/2011  includes new requirements for the way in which allergen information must be displayed. This legislation applies from the 13th December 2014. You can read more about the new legislation in the legislation section.
  

 

Allergen labelling requirements for prepacked foods

Is this a new requirement?
No. Declaring the presence of any of the 14 listed allergenic ingredients has been a requirement since 2003. However, under the new FIC legislation the way in which these allergens are declared has changed.

How must allergenic ingredients be displayed on prepacked foods?
Allergenic substances or products used as ingredients must be listed in the list of ingredients with a clear reference to the name of the allergenic substance or product as they are listed in Annex II of the Regulation. They must be emphasised through a typeset that clearly distinguishes them from the rest of the list of ingredients, for example by means of font, style or background colour.

Example:
In this example, allergenic ingredients are in bold and italic
Ingredients: Flour (wheat), sugar, Eggs, Milk, cocoa powder

How should gluten-free oats be labelled in the list of ingredients?
Oats are considered an allergen and must be highlighted in the list of ingredients by way of bolding, different font etc. to differentiate them from non-allergenic ingredients. For oats to be called ‘gluten-free’ they must have been specially produced, prepared and/or processed in a way to avoid contamination by wheat, rye, barley, or their crossbred varieties and the gluten content of such oats must not exceed 20 mg/kg.

Where gluten-free oats are used as an ingredient in a food they can be listed as ‘oats’, which must be highlighted as they are an allergen, with an asterisk to direct consumers to a note indicating that the oats used are gluten-free. Alternatively, the oats could be listed as ‘gluten-free oats’ again highlighting ‘oats’. As best practice it would be advisable to also direct the consumer to a note indicating why they are gluten-free.

Example:

Ingredients: Rice flour, potato flour, oats*, sugar, salt, spices
*Oats used in this product are gluten free and have been specially produced, prepared and processed in a way to avoid contamination by cereals containing gluten    

Or

Ingredients: Rice flour, potato flour, gluten-free oats*, sugar, salt, spices
*Oats used in this product are gluten free and have been specially produced, prepared and processed in a way to avoid contamination by cereals containing gluten

For cereals containing gluten, is it 'gluten' or the cereal name that must be highlighted in the list of ingredients?
The cereal itself is considered the allergen and so must be highlighted e.g. wheat, oats, rye etc. Gluten may be placed in brackets after the name of the cereal.

When declaring nuts in the list of ingredients, should the word 'nut' or the name of the nut be highlighted?
The actual nut is considered the allergen so this should be highlighted and not just the word 'nut' e.g. hazelnut, almond etc.

Can a 'contains' box or statement still be used for declaring allergenic ingredients?
No, the use of a box or statement declaring, for example 'contains nuts', is no longer allowed. Allergenic ingredients must now be declared and highlighted in the list of ingredients only.

When and how should sulphites be declared on a food label?
Sulphur dioxide and sulphites must appear on the label under their chemical names e.g. sodium metabisulphite, where present at levels exceeding 10mg/kg or 10mg/l, expressed as SO2. So, the list of ingredients will show the additive category followed by the additive name e.g. preservative: sodium metabisulphite. Labelling the category and the additive number is not sufficient. Therefore, it is not enough to label as preservative: E220.

Does wine have to declare allergen information?
Yes, all wines contain sulphites, either naturally occurring or added for preservative effects. Where the level of sulphites exceeds 10mg/L then sulphites must be declared on the label. However, previous legislation granted certain derogations in relation to allergen information and must be taken into account when reading the information provided on wine bottles.This is covered in more detail in our legislation section.
     
What about pre-packaged foods which do not intentionally contain allergens but are made on a site which handles allergens?
The legislation does not apply to unintentional cross-contamination of foods with allergenic ingredients which are used on a manufacturing site for foods which are known to contain allergens. Manufacturers should have in place good manufacturing practices (GMP) to prevent cross-contamination. If it is not possible to prevent cross-contamination, manufacturers may choose to advise consumers of this by way of a 'may contain..' statement. However, the use of a ‘may contain’ statement should not be used as a substitute for GMP.

Are there any additional allergens that would be required to be labelled on children’s products?
No. The allergenic ingredients listed in FIC apply to all foods whether for adults or children and so would need to be labelled accordingly.

Are pine nuts and coconuts considered as allergens?
No. Pine nuts and coconuts are are not considered as being part of the category ‘nuts and products thereof’ and so will not have to be listed as an allergen. However, when used in a food product, they must still be labelled in the list of ingredients.

Allergen labelling requirements for non-prepacked foods

What is the new legal requirement to declare the use of allergenic ingredients in non-prepacked foods?  

New legislation on the provision of food information to consumers came into effect on 13th of December 2014. This requires food businesses providing non-prepacked food e.g. restaurants, delis, canteens, takeaways, cafes, retail outlets etc., to indicate to consumers the use of any of the 14 listed allergenic ingredients in the production or preparation of food.

In Ireland the information will need to be provided in a written format and the precise requirements are detailed in national legislation which has been published by the Department of Health.

The FSAI has published two guidance documents to assist both food businesses and enforcement officers:

What can I do to prepare for the new food allergen labelling requirement?  

  • make all staff aware of the 14 allergenic ingredients  
  • put a system in place to identify and record the allergenic ingredients being received and handled by the food business to enable you to meet the food allergen declaration requirements

You should bear in mind that:

  • Food businesses should be aware of any allergenic ingredients used to make foods, whether produced on the premises or purchased from an outside source
  • Food businesses should be able to identify the allergenic ingredients present in a food brought into the food business by checking the list of ingredients on the food label or on the accompanying commercial documents
  • Declaration of allergenic ingredients is required only when they are used in the preparation of a food
  • Declaration of allergenic ingredients which may be present in a food a very low levels due to potential cross-contamination is not required
  • Food businesses should incorporate good practices and staff training to minimise or eliminate cross-contamination with the specified allergenic ingredients
  • Only the use of the 14 specified allergenic ingredients need to be declared in foods. Other ingredients to which some people may have an allergy or intolerance do not need to be declared, although this information can be provided voluntarily. 

Are there any useful resources for caterers in managing food allergens?  

FSAI leaflet on Food Hypersensitivity - Food Allergy and Intolerance
Safefood's resource on food allergy for caterers 
   

 

Last reviewed: 12/6/2015

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