Module 4 – Introduction
Very small amounts of allergens 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.
Module 4 – Ingredient lists
The 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.
Module 4 – 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.
Module 4 – 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.
Module 4 – 'Gluten free' or 'very low gluten' claims
About 1% of people in the UK have Coeliac disease which is a life-long autoimmune disease where the body attacks its own tissues, such as the lining of the stomach, when gluten is consumed. 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 Commission Implementing Regulation (EU) No. 828/2014, Enforced in Scotland by The Food Information (Scotland) (Amendment) Regulations 2016 established levels of gluten for foods that makes a claim to be either 'gluten-free' or 'very low gluten'. These levels are:
- 'gluten-free' – 20 mg/kg of gluten.
- 'very low gluten' – 100 mg/kg of gluten. 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.
Find out more
- Guidance on Allergen Management and Consumer Information – Best Practice Guidance on Managing Food Allergens with Particular Reference to Avoiding Cross-contamination and using Appropriate Advisory Labelling (ie May Contain)
- Allergy – What to Consider when Labelling Food: A Guide for Small Businesses that make or sell pre-packed food
- British Retail Consortium (BRC ) guidance on allergen labelling
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