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On the label

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High importance

Very small amounts of some allergens, such as nuts, can cause adverse reactions in people with food allergies, including potentially fatal anaphylactic shock. It is therefore important that food products are clearly labelled and adhere to industry guidelines to ensure that consumers can make informed decisions when purchasing foods that might contain allergenic ingredients.

Labelling rules in European Directives 2003/89/EC and 2006/142/EC ensure that all consumers are given comprehensive ingredient listing information and make it easier for people with food allergies to identify ingredients they need to avoid. However, following implementation of the Food Information for Consumers Regulation (EU) No. 1169/2011, allergen labelling rules changed in December 2014.

The new regulation, which was published in October 2011, builds on allergen labelling provisions for prepacked foods and introduces a new requirement for allergen information to be provided for foods sold non-packed or prepacked for direct sale. The three year transition period allows businesses to make the necessary changes to their processes and labelling designs in order to meet the provisions laid out in the legislation.

The Agency continues to work with all its stakeholders to develop industry-led guidance to support businesses with regard to their responsibilities on provision of allergen information for foods sold prepacked and non-prepacked.

The British Retail Consortium and the Food and Drink Federation have already produced guidance on the new allergen labelling requirements for prepacked foods. The Agency welcomes this guidance and industry’s efforts for greater consistency in their approach to allergen labelling and interpretation of the provisions within the new Regulation. This more consistent approach will make it easier for the allergic consumer to find and understand the allergen information provided on prepacked foods.

Ingredient lists

The new EU FIC requirements mean allergenic ingredients need to be clearly emphasised within the ingredient list. Ingredients are listed in descending order of their weight, with the largest ingredient first. If an ingredient is mentioned in the name (such as chicken in chicken pie), is depicted on the label, or is usually associated with the food (as lamb is with shepherd's pie), the amount contained in the food will be given as a percentage.

Where an ingredient is made up of other ingredients (compound ingredients), with a few exceptions, these must also be declared in the ingredients list.

Allergy advice box

The use of "allergy advice boxes" to repeat mandatory information on allergenic ingredients is not permitted under the EU FIC. All allergenic ingredients contained in a prepacked product should be listed clearly within the ingredients list.

There will be a period of time where you may see the old and new style allergy advice statements.

May contain

Some food manufacturers also use voluntary labelling to indicate the possible accidental presence of an allergen in a food – using phrases such as 'may contain nuts'. The Food Standards Agency has produced guidance for the industry on allergen control. This includes advice on how to decide if such advisory labelling is needed and the wording to be used.

There is concern that 'may contain' labelling is used too much, sometimes when it isn't really necessary. This could undermine valid warnings on products and restrict people's choice unnecessarily.

We recognise that advisory labelling is essential for people with food allergies, and that manufacturers are striving to provide helpful information. As a result, we have been working to reduce the unnecessary use of 'may contain' labelling and to provide clear advice to the public on why these labelling terms are used and what they mean.

This has included working with regulators in other countries, with the food industry and with consumer support organisations to agree how management thresholds can be derived for the common food allergens. The outcomes from this work should be published shortly. The results will enable businesses and regulators to make decisions on whether or not advisory warnings are needed in a more consistent way.

It's not a legal requirement to say on the label that a food might accidently contain small amounts of an allergen, but many manufacturers label their products in this way to warn their customers of this risk.

'Gluten free' or 'very low gluten' claims

About 1% of people in the UK are intolerant to gluten – this condition is also known as coeliac disease. People with coeliac disease need to avoid foods that contain gluten to prevent potentially serious health effects. This means labelling claims about gluten in foods are very important. Foods that contain gluten include wheat, rye and barley.

The European Commission compositional and labelling standards (Commission Regulation (EC) No. 41/2009) establish levels of gluten for foods that makes a claim to be either 'gluten-free' or 'very low gluten'. These levels are:

  • 'gluten-free' – 20 parts or less of gluten per million
  • 'very low gluten' – 100 parts or less of gluten per million. However, only foods with cereal ingredients that have been specially processed to remove the gluten may make a 'very low gluten' claim

Manufacturers can only use the phrase 'gluten-free' if they can demonstrate that, when tested, their product is 20 parts or less of gluten per million. They will also be required to demonstrate that any products claiming to be 'very low gluten' comply to the legislation.

Manufacturers producing foods with no deliberate gluten containing ingredients, but due to the high risk of gluten cross-contamination, will be unable to label foods as 'gluten-free' or 'very low gluten'. However, if steps have been taken to control gluten cross-contamination, these manufacturers may be able to indicate which foods do not contain gluten-containing ingredients. This allows people with coeliac disease to make informed choices about the food they eat based on their individual levels of sensitivity.

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