The balancing act of allergen labelling

The food industry has a responsibility to label allergenic ingredients as big and bold as they can – but also not to over-egg the slimmest of slim possibilities that a trace amount of an allergen may have slipped into a product.

Many of us are used to scouring food labels for as much information as we can glean. After all, too much saturated fat, salt and sugar could contribute to an early demise.

But imagine if just one bite could, in the worst case, kill you in minutes. That is the reality faced by millions of food allergy sufferers around the globe, for whom information on food labels is not ‘nice to know’. It can be a matter of life and death.

It is crucial, then, that food labels flag up allergens on labels. Indeed, labelling allergenic ingredients has been a requirement in Europe since EU directive 2003/89/EC came into effect in November 2005.

The same is not the case all over the world: Incredibly Canada has only just unveiled plans to make allergenic ingredient labelling mandatory. Brewers have secured an exemption, presumably on the grounds that those with gluten-containing grain allergies know what not to glug.

Allergens in disguise

Especially important, however, is the need to draw attention to allergens in product formats where a consumer wouldn’t expect to encounter them. If you are allergic to fish and seafood, you know you will be better off ordering a steak.

But dairy proteins in a fruit drink? Soy in a doughnut? Go figure.

Such added extras are even more likely to crop up when food manufacturers are looking to bolster protein to give foods a functional edge. And there is essentially nothing wrong with that, as long as the allergens are marked as BIG and as bold as can be.

Last year New Zealand company Fonterra withdrew from market a clear beverage product containing bovine whey protein due to poor sales – but not before two children with dairy allergies suffered reactions. Because the product was clear it did not occur to the parents or carers to check the label, where the dairy ingredient was noted.

Labelling de-sensitisation

But there is another issue at play: the risk of de-sensitising allergen sufferers to warning use through excessive and inappropriate use of ‘may contain’ wording. This refers not to allergenic ingredients, but to the chance of a tiny amount of allergen slipping into a product because there are sometimes nuts, soy or eggs used in the factory.

There is no clear instruction for precautionary labelling in case of cross-contamination in EU directive, but in these litigious times food manufacturers prefer to cover their backs and use ‘may contain’ to shift the responsibility to the consumer.

If they use these two words on every product, however – even those for which controls are so tight that no allergen is going to slip through even if it is wearing a wig and a false moustache – the effect will be to narrow further the pool of products sufferers can eat unnecessarily.

More than that, it may give the impression that ‘may contain’ exists to protect the manufacturer rather than the consumer – whereas in fact, the probability of allergens slipping will be far higher in some cases than in others.

Ignoring the ‘may contain’ label on one product may be fine. On another it could be catastrophic.

Where next?

The UK’s Food Standards Agency is set to conduct a survey of sample chocolate and biscuit-type products this year to determine the extent of use and the nature/wording of ‘may contains’ labelling as well as providing quantitative measurements of milk, peanut and hazelnut allergens.

These data will be used to determine how closely the advisory labelling correlated with actual levels of allergens present in the foods.

This will certainly help. Also helpful will be the establishment of action or threshold levels for peanuts, milk and eggs, expected in 2012 in the UK following extensive research.

The Food and Drink Federation has published some sensible guidelines, too, in which it proposes shifting from the hazard-based approach to a more consistent risk-based approach whereby manufacturers carefully assess the risk of cross-contamination with allergens and only use 'may contains' terms where this risk cannot be controlled.

Once in place these initiatives will help. They will help make the grocery store a less daunting place for allergy sufferers and their parents or carers – and the dinner table a less dangerous place.

In the meantime, correct and safe food allergen labelling sits on a knife edge. There’s no space for complacency, either by manufacturers or by consumers.

Jess Halliday is senior editor of Over the past twelve years she has worked in print, broadcast and online media in both Europe and the United States, and has specialised in the food industry since 2005. She holds a MSc in Food Policy from City University London. Jess lives in a small village famous for figs near Montpellier, France.

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Comments (1)

Kim Leighton - 08 Mar 2011 | 11:21

VITAL to accurately assess trace allergen risk

Why is it that the EU stubbornly refuses to adopt the Allergen Bureau risk assessment tool designed to accurately assess the real risk of trace levels of allergens in food? The allergen tool known as Voluntary Incidental Trace Allergen Labelling (VITAL) is freely available at and has successfully been used by Australia food manufacturers since 2007. If you are serious about moving to a risk-based allergen management system, then you need to seriously look at VITAL.

08-Mar-2011 at 23:21 GMT

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