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This issue mainly introduces the requirements of Australia, New Zealand and Canada , in order to provide assistance to food export companies
.
1.
Australia and New Zealand
Australia and New Zealand
(1) Mandatory labeling requirements for food allergens
The Australia and New Zealand Food Standards Code Standard 1.
2.
3 and Schedule 9 stipulate 13 mandatory allergens (except for exemptions):
2.
3 and Schedule 9 stipulate 13 mandatory allergens (except for exemptions):
(A) Cereals containing gluten (rye, barley, oats and their hybrids);
(B) Wheat and its hybrid varieties (whether or not they contain gluten);
(C) Tree nuts (almonds, Brazil nuts, cashews, hazelnuts, macadamia nuts, walnuts, pine nuts, pistachios, walnuts);
(D) Crustaceans;
(E) Shellfish;
(F) Eggs;
(G) Fish;
(H) Peanuts;
(I) Soybeans;
(J) Black sesame;
(K) Milk;
(L) Lupin;
(M) Sulfite with a concentration greater than or equal to 10 mg/kg
.
.
On February 24, 2021, Australia and New Zealand revised the labeling requirements for food allergens, stipulating that in addition to labeling allergens in accordance with mandatory designated terms in the ingredient list, a summary allergen declaration must be displayed in the vicinity of the ingredient list
.
The regulation has a three-year transition period.
During this transition period, food companies can comply with the existing allergen labeling requirements in the Food Standards Code, or they can comply with the new requirements
.
After the transition period is over, there will be a two-year inventory period
.
Any food that has been packaged and labeled before the end of the transition period can be sold within two years after the end of the transition period
.
For the detailed background and content of the amendments, please refer to the previous original article-"Australia and New Zealand Amendments to the Mandatory Labeling Requirements for Food Allergens"
.
.
The regulation has a three-year transition period.
During this transition period, food companies can comply with the existing allergen labeling requirements in the Food Standards Code, or they can comply with the new requirements
.
After the transition period is over, there will be a two-year inventory period
.
Any food that has been packaged and labeled before the end of the transition period can be sold within two years after the end of the transition period
.
For the detailed background and content of the amendments, please refer to the previous original article-"Australia and New Zealand Amendments to the Mandatory Labeling Requirements for Food Allergens"
.
(2) Labeling requirements for allergens caused by "cross-contact"
In Australia and New Zealand, because allergens generated by cross-contact are not subject to mandatory labeling requirements in the Australia and New Zealand Food Standards Code, manufacturers cannot be exempted from the responsibility of communicating the existence of possible allergens to their consumers.
Manufacturers can use preventive The allergen label (PAL) voluntarily declares these allergens
.
The Australian Food and Grocery Council (AFGC) and the Allergens Board issued the "Guidelines for the Management and Labeling of Allergens in the Food Industry (2021 Edition)" and "Voluntary Attached Trace Allergen Labels" (VITAL), requiring manufacturers to undergo strong PAL can only be applied based on the VITAL risk assessment process and described in a clear, accurate and consistent manner
.
The recommended best label format is:
Manufacturers can use preventive The allergen label (PAL) voluntarily declares these allergens
.
The Australian Food and Grocery Council (AFGC) and the Allergens Board issued the "Guidelines for the Management and Labeling of Allergens in the Food Industry (2021 Edition)" and "Voluntary Attached Trace Allergen Labels" (VITAL), requiring manufacturers to undergo strong PAL can only be applied based on the VITAL risk assessment process and described in a clear, accurate and consistent manner
.
The recommended best label format is:
(A) Mandatory allergen ingredient declaration;
(B) Mandatory collective allergen declaration;
(C) Voluntary preventive allergen labeling statement (after VITAL risk assessment, PAL recommends using the format "may exist: allergen x, allergen y")
.
.
Example: Best label format
2.
Canada
Canada
(1) Mandatory labeling requirements for food allergens
The "Canada Food and Drug Regulations" B.
01.
010.
1 stipulates 13 mandatory allergens (except for exemptions):
01.
010.
1 stipulates 13 mandatory allergens (except for exemptions):
(A) Almonds, Brazil nuts, cashews, hazelnuts, macadamia nuts, pecans, pine nuts, pistachios or walnuts;
(B) Peanuts;
(C) Sesame;
(D) Wheat or triticale;
(E) Eggs;
(F) Milk;
(G) Soybeans;
(H) Crustaceans;
(I) Mollusks;
(J) Fish;
(K) Mustard seeds;
(L) Cereals containing gluten: barley, oats, rye, triticale, wheat;
(M) Sulfite with a concentration greater than or equal to 10 ppm
.
.
(2) Labeling requirements for allergens caused by "cross-contact"
In Canada, because allergens generated by cross-contamination do not fall under the mandatory labeling requirements of the Canadian Food and Drug Regulations, food manufacturers and importers can voluntarily use the prevention/cross-contamination declaration, but the cross-contamination declaration is not a substitute for complying with good production Norms
.
When allergens or allergen-containing ingredients are deliberately added to food, no cross-contamination statement should be used
.
In this case, mandatory food allergen and gluten declarations are required
.
However, the cross-contamination statement, like all label statements, is subject to Section 5(1) of the Canadian Food and Drug Act, and must be true and not misleading
.
.
When allergens or allergen-containing ingredients are deliberately added to food, no cross-contamination statement should be used
.
In this case, mandatory food allergen and gluten declarations are required
.
However, the cross-contamination statement, like all label statements, is subject to Section 5(1) of the Canadian Food and Drug Act, and must be true and not misleading
.
The Canadian Food and Drug Regulations B.
01.
010.
4 (1) stipulates that prepackaged foods may contain food allergens or gluten due to the risk of cross-contamination.
The cross-contamination declaration format is as follows:
01.
010.
4 (1) stipulates that prepackaged foods may contain food allergens or gluten due to the risk of cross-contamination.
The cross-contamination declaration format is as follows:
(A) The cross-contamination statement must immediately follow the mandatory "food allergen source, gluten source and added sulfite" statement, or, if not, immediately after the ingredient list, and must appear in the "Food allergen source, gluten source and added sulfite" statement or ingredient list on the same background color and/or continuous surface within the solid boundary
.
.
(B) There shall be no printed, handwritten or graphic elements in the cross-contamination statement and the ingredient list or mandatory statement
.
If the statement is not on the same line as the list of ingredients and the end of the mandatory statement, a solid line (dividing line) is allowed
.
.
If the statement is not on the same line as the list of ingredients and the end of the mandatory statement, a solid line (dividing line) is allowed
.
(C) If the cross-contamination statement begins on the same line as the list of ingredients or the immediately preceding mandatory statement, and there is no leading word, the statement must be displayed in bold
.
.
(D) If the cross-contamination statement begins on the same line as the list of ingredients or the immediately preceding mandatory statement, and there is a leading word, the leading word must be displayed in bold
.
.
Health Canada and the Canadian Food Inspection Agency recommend that food manufacturers and importers use only the following description to introduce a prevention/cross-contamination statement on food labels: "May contain: [X]" or "May contain: [X]"
Note: When the "may contain" sentence starts on a single line, the "may contain" can be displayed in bold or regular form (see option 1 below)
.
.
The following example illustrates two acceptable forms of showing a cross-contamination/prevention statement after the list of ingredients and the mandatory declaration of “food allergens, gluten sources and added sulfites”
.
.
Option 1:
Ingredients: white beans, water, sugar, pork, salt, modified corn starch, onion powder, mustard, spices
.
.
Contains: Mustard
May contain (or may contain): sesame, soybean
When the "may contain" statement starts on a single line, it can be displayed in bold or regular form
.
.
Option 2:
Ingredients: white beans, water, sugar, pork, salt, modified corn starch, onion powder, mustard, spices
.
.
Contains: Mustard
.
May contain: sesame, soybean
.
.
May contain: sesame, soybean
.
In this example, when the "may contain" statement does not begin with a single line, it must be displayed in bold
.
.
The above-mentioned mainstream countries/regions and organizations have stipulated a list of mandatory allergen labels; for the management of preventive allergen labels (PAL), different countries/regions and organizations have not reached an agreement, but most countries/regions and organizations allow Manufacturers voluntarily use PAL to warn of potential allergen cross-contamination
.
Although China is recommended for allergen labeling requirements, but the "national food safety standard pre-packaged food labels General (draft)" intends to identify the allergen recommended changes to mandatory labeling
.
FoodPartner.
com reminds all food export companies to pay close attention to the regulatory requirements of allergen labeling in exporting countries to prevent food recalls due to unlabeled allergens
.
.
Although China is recommended for allergen labeling requirements, but the "national food safety standard pre-packaged food labels General (draft)" intends to identify the allergen recommended changes to mandatory labeling
.
FoodPartner.
com reminds all food export companies to pay close attention to the regulatory requirements of allergen labeling in exporting countries to prevent food recalls due to unlabeled allergens
.
Related report: Introduction to the management of foreign food allergen labels (part 1)
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
.
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
.
