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Introduction of foreign food allergen label management (Part 1)

 Last Update: 2021-10-09
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Due to the different countries of diet different structures, so the allergic food types are also differences, the foreign population of some food allergies occur much less frequently in our country
.
For example, the EU population is more sensitive to celery and its products, and sesame , while the Canadian population is more sensitive to mustard seeds and sesame
.
The Food Partner Network will be divided into two articles to help you understand foreign food allergen labeling regulations, in order to help food export companies
.
This issue mainly introduces the requirements of CAC, the European Union and the United States
.

1.
CAC

(1) Mandatory labeling requirements for food allergens

The Codex Alimentarius Commission (CAC) stipulated in the "General Standards for the Labeling of Prepackaged Foods" (CXS 1-1985) that there are 8 types of mandatory allergens:

(A) Cereals containing gluten, namely wheat, rye, barley, oats, spelt wheat or their hybrid varieties and their products;

(B) Crustaceans and their products;

　　(D) Fish and fish products;

　　(E) Peanuts, soybeans and their products;

　　(F) Milk and dairy products (including lactose);

　　(G) Tree nuts and nut products;

　　(H) Sulfite with a concentration of 10 mg/kg or more
.

　　(2) Labeling requirements for allergens that "may contain" caused by cross-contact

　　CAC did not make clear regulations on the labeling of "may contain" allergens due to cross-contact, but on November 25, 2020, CAC issued the "Code of Practice for the Management of Food Allergens for Food Operators" (CXC 80-2020), which covers Allergen management throughout the supply chain, including primary production, production process, retail and food service terminals, provides guidance for companies to reduce cross-contact of allergens in the production process
.

　　2.
European Union

　　(1) Mandatory labeling requirements for food allergens

　　(EU) No 1169/2011 Appendix 2 (ANNEX II) stipulates 14 types of mandatory labeling allergens (except for exemptions):

　　(A) Cereals containing gluten, namely wheat (spelt wheat and oriental wheat), rye, barley, oats or their hybrids and their products;

　　(B) Crustaceans and their products;

　　(D) Fish and its products;

　　(E) Peanuts and their products;

　　(F) Soybeans and their products;

　　(G) Dairy and its products;

　　(H) Nuts, namely almonds (Amygdalus communis L.
), hazelnuts (Corylus avellana), walnuts (Juglans regia), cashews (Anacardium occidentale), pecans (Carya illinoinensis (Wangenh.
) K.
Koch), Brazil nuts (Bertholletia) excelsa), pistachio (Pistacia vera), Macadamia ternifolia (Macadamia ternifolia) and their products, except for nuts used to make alcoholic distilled oil (including alcohol derived from agriculture);

　　(I) Celery and its products;

　　(J) Mustard and its products;

　　(K) Sesame and its products;

　　(L) Lupin and its products;

　　(M) Mollusks and their products;

　　(N) Sulfur dioxide and sulfite with a concentration greater than 10mg/kg or 10mg/L (as recommended for direct consumption or the total sulfur dioxide in the product prepared according to the manufacturer's instructions)
.

　　(2) "Cross contact" leads to "may contain" allergen labeling requirements

　　EU legislation does not provide for information on substances or products that may or occasionally be present in any food that can cause allergies or intolerances.
Such information can be provided voluntarily by food operators
.
Article 36 of the European Union (EU) No 1169/2011 stipulates that the food information provided on a voluntary basis shall meet the following requirements:

　　(A) Do not mislead consumers;

　　(B) It must not cause ambiguity or confusion among consumers;

　　3.
The United States

　　(1) Mandatory labeling requirements for food allergens

　　The US Food Allergen Labeling and Consumer Protection Act (2004) (FALCPA) stipulates 8 mandatory labeling allergens (except for exemptions): milk, eggs, fish (such as sea bass, flounder or cod), crustaceans Species (such as crab, lobster, or shrimp), tree nuts (such as almonds, pecans, or walnuts), wheat, peanuts, and soybeans
.

　　The label of allergens can be indicated in the ingredient list, such as flour (wheat); or “Contains” can be indicated after the ingredient list, such as Contains: wheat, milk, and soybeans
.

　　On April 23, 2021, the US Congress passed the Food Allergy Safety, Treatment, Education and Research Act of 2021, also known as the FASTER Act of 2021
.
The bill stipulates that foods containing sesame that enter interstate trade on or after January 1, 2023 must label "sesame" in their allergen declaration
.
Prior to this, there is no need to label sesame as an allergen
.

　　(2) "Cross contact" leads to "may contain" allergen labeling requirements

　　"Cross-contact" is different from microbial "cross-contamination" and specifically refers to the unintentional incorporation of food allergens into food
.
The US FDA Food Industry Guide "Questions and Answers on Food Allergens (4th Edition)" states that if there is cross-contact with allergens in the United States, manufacturers can voluntarily mark preventive allergen labeling statements on foods to inform consumers Possible food allergens
.
For example, you can indicate "may contain [allergen]", "produced in a facility that also uses [allergen]" and other warnings
.
However, this preventive allergen statement should not be used to replace compliance with current Good Manufacturing Practices (cGMPs), and must be truthful and not misleading consumers
.

　　The above are the relevant requirements of CAC, the European Union and the United States for allergen labeling.
The next issue of the Food Partner Network will bring you the relevant content of Australia, New Zealand and Canada's food allergen labeling regulations, so stay tuned!

　　This article is an original article by the Food Safety Compliance Division of FoodPartner.
com, please contact us for reprinting
.
The Food Safety Compliance Division provides domestic and foreign food standards and regulations management and consulting, food safety information monitoring and analysis and early warning, product registration and filing services, label review and compliance consulting, conference training services, etc.
, for detailed inquiries: 0535-2129301, email : Vip@foodmate.
net
.

Dietary allergies EU celery sesame Canadian mustard greens food partners network food allergen label logo exported to the United States

　　1.
CAC

　　(1) Mandatory labeling requirements for food allergens

　　The Codex Alimentarius Commission (CAC) stipulated in the "General Standards for the Labeling of Prepackaged Foods" (CXS 1-1985) that there are 8 types of mandatory allergens:

　　(A) Cereals containing gluten, namely wheat, rye, barley, oats, spelt wheat or their hybrid varieties and their products;

　　(B) Crustaceans and their products;

　　(D) Fish and fish products;

　　(E) Peanuts, soybeans and their products;

　　(F) Milk and dairy products (including lactose);

　　(G) Tree nuts and nut products;

　　(H) Sulfite with a concentration of 10 mg/kg or more
.

　　(2) Labeling requirements for allergens that "may contain" caused by cross-contact

　　2.
European Union

　　(1) Mandatory labeling requirements for food allergens

　　(EU) No 1169/2011 Appendix 2 (ANNEX II) stipulates 14 types of mandatory labeling allergens (except for exemptions):

　　(A) Cereals containing gluten, namely wheat (spelt wheat and oriental wheat), rye, barley, oats or their hybrids and their products;

　　(B) Crustaceans and their products;

　　(D) Fish and its products;

　　(E) Peanuts and their products;

　　(F) Soybeans and their products;

　　(G) Dairy and its products;

　　(I) Celery and its products;

　　(J) Mustard and its products;

　　(K) Sesame and its products;

　　(L) Lupin and its products;

　　(M) Mollusks and their products;

　　(2) "Cross contact" leads to "may contain" allergen labeling requirements

　　(A) Do not mislead consumers;

　　(B) It must not cause ambiguity or confusion among consumers;

　　3.
The United States

　　(1) Mandatory labeling requirements for food allergens

　　The label of allergens can be indicated in the ingredient list, such as flour (wheat); or “Contains” can be indicated after the ingredient list, such as Contains: wheat, milk, and soybeans
.

　　(2) "Cross contact" leads to "may contain" allergen labeling requirements

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