Allergen Labelling - Legislation
& Best Practice Guidance
FreeFrom
‘Allergy & Intolerance’ Seminar
10 December 2008
Dr Chun-Han Chan
Food Allergy Branch
Food Standards Agency
Types of Labelling
Statutory requirements
• deliberate ingredients in pre-packed foods –
implements EU legislation (Directive 2003/89/EC
and subsequent Directives)
Voluntary Best Practice Guidance
• labelling of possible allergen cross contamination
• allergen information provision for non pre-packed
foods, including in catering establishments
List of Allergenic Ingredients
Cereals containing gluten Crustaceans
Eggs Fish
Lupin Milk
Molluscs Peanuts
Sesame seeds Soybeans
Tree nuts Celery
Mustard Sulphite (above
10mg/kg or l)
EU Food Information Proposal
• proposal issued on 30 January 2008 aims to
consolidate food labelling requirements into single
piece of legislation
• incorporates existing provisions for allergen
labelling for pre-packed foods
• proposes extending allergen labelling requirements
to non-prepacked foods, including in catering
businesses
• currently being negotiated with Commission
and other Member States
Best Practice Guidance
- providing allergen information for foods that
are not pre-packed
Non Pre-Packed Foods -
provision of information on allergens that are
deliberate ingredients in foods
• Foods sold loose or pre-packed on the premises for
direct sale, including in catering establishments
–exempt from provisions of EU Directive 2003/89/EC
• Agency published best practice guidance in January
2008
• Recent draft food information regulation proposes
extending requirements for allergen labelling from
pre-packed foods to foods sold non pre-packed
Non Pre-Packed Foods -
Agency best practice guidance
How to balance the needs for information of those
that are allergic or intolerant to certain foods against
the practical problems faced by businesses in
supplying such information
• Which allergens?
• Following statutory or voluntary labelling?
• Dialogue between consumer and seller
Format of the Guidance
• Voluntary Best Practice Guidance booklet
– background information
– key messages
– examples of issues to consider in range of
different types of businesses
• Leaflet for small/micro businesses
• Poster
Main Guidance Document
• Aimed at medium and larger businesses and
enforcement officers
• Full information on providing accurate
information on the allergen content of the foods
sold non pre-packed
• Practical advice on how to tackle allergy issues
Leaflet
Key Messages
• Aimed at small and micro businesses
• Highlights the key principles that businesses
need to think about in a simple, easy to access
format
• Introduces the 14 food allergens required to be
labelled in pre-packed foods and where they can
be found
Poster
• Highlights allergy issues in the non-prepacked
foods sector
• Intended as a training aid to introduce the main
allergens of concern
• Highlights how to deal with enquiries from food
allergic customers
• May be of particular use in training staff who do not
have English as their first language
Allergen information for non pre-
packed foods - key messages
• Effective communication
– between staff and customers
– between food preparation staff and those
dealing with customers
• Staff training
• Ingredient information
Effective Communication
If a customer asks about the ingredients in a food:
never guess
– if you don’t know, try to find out
– if you are unable to provide the information, say so
– if information is unavailable, can you provide an
alternative food?
Always ensure staff are advised of any ingredient
changes
Staff Training
• All staff should receive training on handling allergy
information requests from their first day in the job
• There should be an agreed practice for dealing with
allergy information requests and all staff should
know about this
• Online training for enforcement officers which is
also of use to anyone wanting to learn more about
food allergy http://allergytraining.food.gov.uk/
Ingredients Information
• Know the ingredients in the food you sell
• Make sure ingredients information is accessible to
all staff and is up to date
• If you use part-prepared ingredients, make sure
you know what is in them
• Consider risks of allergen cross-contamination
Gluten Intolerance:
Guidance
An overview
Codex standard for gluten-free foods
• This is a revision of the previous standard for
gluten-free foods agreed in 1983
• The previous standard permitted products to be
called ‘gluten free’ if there were less than 200 parts
per million of gluten in the finished product
• After many years of discussions at Codex, a new
standard was agreed in July 2008
• As this is only guidance, a new EC regulation has
drafted based on the Codex standard
New Codex standard
- levels permitted & labelling
• Two different categories with foods being labelled
according to the level of gluten they contain
– <20ppm - labelled as ‘gluten-free’ or ‘naturally
gluten-free’
– 21-100ppm – decisions on the marketing and
labelling of these products will be decided on a
national level
Gluten Free – the EU Regulation
• EU Regulation has been made under PARNUTS
framework – to be implemented by end of 2008
• ‘gluten free’ = for all foods with <20ppm gluten
• ‘very low gluten’ = 21 - 100ppm gluten
• Food businesses will have a 3-year transition
period before products have to comply
• Need for education for health professionals
and consumers
Oats
• Oats can generally be tolerated by most but not all
people intolerant to gluten
• Only oats which have been specially grown to
ensure that they are <20ppm can be used in foods
labelled ‘gluten free’
Timelines for implementation
• It is likely that a Commission final Directive will be
published by the end of this year
• Businesses can start to use new labelling terms
as soon as Regulation is implemented (20 days
after publication in the Official Journal)
• food products that do not comply with the new
requirements will become illegal on 1 January
2012
Agency – next steps
• gluten guidance for industry
• focus group work for gluten labelling
• work with consumer organisations (Coeliac UK)
and health professionals to develop research
areas to inform policy and advice
Contact Details
Dr Chun-Han Chan
Food Allergy Branch,
Room 6C, Aviation House
125 Kingsway, London,
WC2B 6NH
Tel: +44 20 7276 8602
Email: chun-han.chan@foodstandards.gsi.gov.uk