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In April 2005, Afssa received a request from the association “Consommation, Logement et Cadre de Vie” (Consumers, Housing and Living Environment) on the labelling of products from the food processing sector regarding food allergies and, more particularly, on indications warning consumers of the “risk of allergens being accidentally present” in prepackaged foodstuffs. The wide range of indications used, termed collectively as advisory labelling, has been set up following the initiative of food processing businesses, but has no regulatory framework.

In France, 3.2% of the population suffer from food allergies. According to the allergy monitoring network, which has been helping to record serious allergic reactions to food since 2001, the presence of masked allergens in an industrial food product is responsible for 8.6% of all severe allergic reactions to food. These reactions are usually caused either by no labelling on products when they are sold or by a change in packaging and/or recipe with a subsequent labelling error. The allergy sufferer may also read the label incorrectly after a change in recipe. Moreover, it is estimated that less than 1% of these serious reactions concern contamination occurring during manufacture of the food product.

Since November 2005, a European Directive has made the labelling of 12, and then 14, allergenic ingredients compulsory on industrial products. However, the precautions taken regarding the risk of allergens being accidentally present in food are currently not harmonised, neither in terms of standardised tools for screening for allergens in food matrices nor in terms of recommendations on labelling. Accordingly, indications such as “
Product may contain a given allergen”, “Product made in a factory using the given allergen” and “Risk of allergen being accidentally present” can unnecessarily worry food allergy sufferers. Such people are then presented with a decisive choice: either buy products that are guaranteed to be free from allergens (expensive), or consume products without really knowing the risks.

In response, Afssa has issued several recommendations in its report entitled “
Food allergies and advisory labelling”.
Concerning allergens that are accidentally present in products, Afssa recommends using a limited number of expressions tailored to the actual contamination that may have occurred during manufacture. Afssa suggests that food processing professionals, risk managers and allergy sufferers' associations meet to discuss this matter together. In addition, it recommends that all companies set up an allergen Hazard Analysis-Critical Control Point (HACCP) method. This would imply that precautions in terms of sector organisation have been taken and can be justified. Allergen detection tests may be used as tools to assist with setting up the allergen HACCP method, but on the basis of current scientific knowledge, these tests cannot be used as the only allergic risk prevention tool. Afssa believes that the rational organisation of production and distribution sectors currently offers the best guarantee of controlling the allergen risk, since the sole use of detection tests cannot suffice to guarantee the effectiveness of an HACCP method.
If no HACCP method has been put in place, Afssa recommends that an indication be provided, stipulating that no precautions have been taken by the manufacturer as regards the allergen risk. In view of the information provided, the informed consumer can then consume the product knowing full well about the risks.
Concerning
labels that guarantee the absence of allergens in foods, such as "allergen free", it seems essential that the meaning of the claim "guaranteed free from" be clarified. It would, in all cases, be preferable that the ingredients used in products bearing this claim can be guaranteed “free from accidental presence” and not just “free from allergens”. It is also of the utmost importance that the use of “guaranteed free from…” claims is validated by HACCP methods and quality controls confirming the absence of allergens, which is not always the case at present.
When the allergen is intentionally incorporated, Afssa recommends that the information provided be precise (the term 'peanut' should not replace 'peanut oil' for example). Moreover, manufacturers may choose not to list ingredients on the labelling of dairy products sold as “cheese”, “butter” or “yoghurt” insofar as it is considered that reference to the allergen "milk" is clear. However, because the list of notifiable allergens does not specify the type of milk that must be notified and due to the occurrence of certain serious reactions observed in France to ewe's and/or goat's milk sometimes used as a substitute for cow's milk, Afssa considers it important to mention the origin of the milk used: cow's milk, ewe's milk or goat's milk.


To know more :

>Report "Food allergies and advisory labelling"

>La fiche pratique "Allergène alimentaire" sur le site de la Direction générale de la concurrence, de la consommation et de la répression des fraudes
Food allergens and advisory labelling
12 march 2009
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