Food Standards Agency Scotland
Food Allergen Labelling
New Statutory Requirements and Other Initiatives
Susan Pryde/Christine Green
Food Labelling/Standards, Diet and Nutrition
Food Standards Agency Scotland
What is food allergy and food
intolerance?
Food Allergy
• A reproducible adverse reaction to a food or food
ingredient that involves the immune system - e.g. peanuts,
tree nuts fish and shellfish, eggs and milk
Food Intolerance
• A reproducible adverse reaction to a food or food
ingredient that does not involve the immune system - e.g.
lactose intolerance
Gluten Intolerance
Possible Symptoms
Symptoms can appear within minutes, or up to several
hours after the person has eaten the food they are
allergic to. They can include:
•
rashes (usually very itchy)
•
tingling sensation in the mouth
•
swelling of the lips, tongue, face and throat
•
difficulty breathing
•
diarrhoea
•
vomiting
•
abdominal cramps
•
and, on rare occasions, anaphylaxis
How common is food allergy?
• Prevalence of different food allergies not well established
• 20 - 30% of UK population think they have an adverse
reaction to food
• Tests show 1-2% of adults and 5-8% of children have food
allergies
• Recent FSA consumer research shows that 12% of
consumers look at food labels for allergen information
(Consumer Attitudes Survey 2004)
Types of Allergen Labelling
Statutory Requirements
• Deliberate ingredients in pre-packed foods
Voluntary Initiatives/Best Practice Guidance
• Accidental contaminants in pre-packed foods - “May
Contain” labels
• Non pre-packed foods and foods pre-packed for
direct sale
New EU Legislation Directive
2003/89/EC
Amends 2000/13/EC (OJ publication November 2003)
• Established a list of specified ingredients for which
ingredients listing exemption should not apply
because of link with allergy/intolerance
• Requires that products derived from these allergens
be labelled with reference to that allergen
• Makes provision for the list to be revised
Directive 2003/89/EC
Specified allergens list
• Cereals containing gluten*
• Soybeans*
• Crustaceans*
• Nuts*
• Eggs*
• Sesame seeds*
• Milk*
• Celery*
• Fish*
• Mustard*
• Peanuts*
• Sulphite (=/>10mg/kg or 1)
*And products derived from them
Directive 2003/89/EC
Indication of allergenic ingredients on
pre-packed Foods
Scope: Total
• Covers all deliberately added allergenic
ingredients and their derivatives
• Includes carry-over additives, additives used
as processing aids and solvents and media
for additives/flavourings
• Applies to alcoholic drinks
• Removes 25% rule
Directive 2003/89/EC
Timing of Implementation
• Came into force 26 November 2004
• Compliance by 25 November 2005
• Products marked and labelled before this time can
continue to be sold
Implementing Domestic Legislation
• Food Labelling Amendment (Scotland) (No. 2)
Regulations 2004
Drawing up a Provisional List of
Exempt Derived Ingredients
•
Recognition that not all ingredients derived from allergenic
foods may be allergenic
•
Submissions from industry to the Commission
•
EFSA consideration of the dossiers and published
opinions
•
Commission Directive 2005/26/EC - list of provisional
exemptions
•
EFSA responsible for reviewing this list
http://www.efsa.eu.int/science/nda/nda_
opinions/catindex_en.html
What about other derived
products not on the provisional
list?
• Industry can make submissions for an exemption from
labelling for other derived ingredients at any time
• Submissions should be supported by scientific information
• Dossiers will be examined by EFSA
• Final list of exemptions to be published by November 2007
Implementation of Directive
2005/26/EC
1. Provisions of the Directive apply from 25
November 2005
2. Draft Food Labelling Amendment (No. 2)
(Scotland) Regulations 2005 issued for
consultation
3. SSI laid before Parliament
4. SSI to come into force
Correcting Directive 2005/63/EC
• Amended Directive 2005/26/EC
• 3 December deadline for adoption
• Implemented in Scotland by The Food Labelling
(No. 3) (Scotland) Regulations 2005
Types of Allergen Labelling
Statutory Requirements
• Deliberate ingredients in pre-packed foods
Voluntary Initiatives/Best Practice Guidance
• Accidental contaminants in pre-packed foods “May Contain” labels
• Non pre-packed foods and foods pre-packed for
direct sale
‘May Contain’ Labelling
History
•
Anaphylaxis Campaign Report
•
Focus Group Research
•
Stakeholder Meetings
Consumer Concerns
•
Finding the warning label
•
Do different wordings reflect different levels
•
Restriction in choice
‘May Contain’ Labelling
Development of best practice guidance for industry
on when to use such labels
•
Amalgamation of existing industry guidance
•
Drafting group - involves all stakeholders
•
Consultation period ended 6 December 2005
•
To be published in summer 2006
Approach being taken in the
guidance on ‘May Contain’
advisory labelling
Hazard control approach, identifying:
•
particular hazards and where they occur
•
how, at these points, the hazards identified can be
controlled (reduced or eliminated)
Leading to:
•
an assessment of the risk posed
•
a determination of the appropriate level of
advisory labelling
Possible wording for
advisory labelling
Possible options include:
•
may contain (traces of) X - to be used, for
example, where the product may be
contaminated in the factory
•
ingredient Y may contain (traces of) X - to be
used, for example, where an ingredient may be
contaminated further back along the supply
chain
Non Pre-packed Foods and Foods
Pre-packed for Direct Sale
• Provision of information on allergens
• Food Labelling Regulations 1996 - Definitions
• Initial Views
• Stakeholder Meetings
• The way forward
Current advice to caterers
• Food allergy and intolerance are important safety
issues
• Caterers need to be able to answer consumers
who ask for information on which ingredients are
present in the foods being served
• But if caterers are not sure if an ingredient is
present, they should say so and NEVER guess
www.food.gov.uk/safereating/
allergyintol/caterers
Caterers - next steps
• Increasing awareness and use of this advice
• Training for caterers to include food allergy and
intolerance issues
• Enforcement officers to include control of foods
causing allergy and intolerance in discussions
with food businesses
• Discussions with Hospitality Organisations
Contact Details
Susan Pryde
Address: Food Standards Agency Scotland
6th Floor
St Magnus House
25 Guild Street
Aberdeen
AB11 6NJ
Telephone: 01224 285152
Email: susan.pryde@foodstandards.gsi.gov.uk