eu food regulations food allergen labelling

EU FOOD INFORMATION FOR CONSUMERS REGULATIONS

WHAT YOU NEED TO KNOW ABOUT FOOD ALLERGEN LABELLING

The symptoms can include: • rashes (usually very itchy)• tingling sensation in the mouth• swelling of the lips, tongue, face and throat• difficulty breathing• diarrhoea• vomiting• abdominal cramps • and on rare occasions anaphylaxis

The impact of food allergy

Key facts

1.92m people have food allergy in the UK (based on population of 63.1m). This figure excludes food intolerance.

Estimated: 4,500 hospitalisations between 2011-12 and 10 deaths, due to food allergies and eating out.

No cure for allergy!

You must avoid what makes you ill üRead ingredient labels

üLook out for hidden allergens

Food labelling is changing• Moving from General Labelling (2000/13/EC) to Food Information for Consumers Regulation (1169/2011/EC)

• Regulation 1169/2011 entered into force on 13 December 2011

• From 13 December 2014 new rules on allergen labelling shall apply

• Existing requirements for pre-packed foods are retained – but new requirement to emphasiseallergenic foods in the ingredients list

• Introduction of new requirement to provide allergy information for unpackaged foods

• Criminal sanctions for breaches in food allergen provisions – food safety

Scope of the Regulation

• Covers business operators at all stages of food chain concerning provision of information to consumers:Ø Food intended for the final consumerØ Foods delivered by mass caterersØ Foods intended for supply to mass caterers

• Also applies to catering services provided by transport leaving from the EU Member StatesØ airline cateringØ Trains, ships…

Article 9 Mandatory particulars

• Article 9(1)c - Any ingredient or processing aid listed in Annex II, or derived from a substance or product listed in Annex II causing allergies or intolerances, used in the manufacture or preparation of a food and still present in the finished product, even if in an altered form

• Article 9(2) - The specified allergenic foods to be indicated with words and numbers - they may additionally be expressed by means of pictograms or symbols

Annex II: ‘The Big 14’

Cereals containing gluten

Crustaceans

Eggs

Fish

Lupin

Milk

Molluscs

Mustard

Nuts

Peanuts

Sesame seeds

Soya

Sulphur dioxide

Celery

Article 12 - 13 Clarity and Legibility • For prepacked foods, mandatory information to appear directly on the package or on a label attached to it

• Mandatory food information to be available and easily accessible for all foods

• Mandatory information to be marked in a conspicuous place, be easily visible, clearly legible and, where appropriate, indelible. It should not be hidden, obscured, detracted from or interrupted by other written or pictorial matter

• To ensure clear legibility, use characters with a font size where the x-height is at least 1.2mm

• In the case of packaging or containers, the largest surface of which has an area of less than 80 cm2, the x-height of the font size to be at least 0.9mm

Article 21 of the FIC• Allergens declared in the list of ingredients with a clear reference to the name of the substance or product as listed in Annex II

• In the absence of a list of ingredients, allergens to be declared using a ‘contains’ statement followed by the Annex II.food

• If the product contains the allergen in more than one form then all forms of the allergen should be indicated

• If the name of the food clearly refers to the substance or product concerned and there is no ingredients list there is no need for a contains statement

How a label can change

What’s on a label? – prepacked food

Distance selling

For food offered for sale online, by telephone or catalogue etc, mandatory food allergen information to be made:

• available before the purchase is concluded (i.e. appearing on material supporting the distance selling or other appropriate means clearly identified by the food business operator)

• available upon delivery in writing (eg. stickers on takeaway food containers)

Article 36 Voluntary information

• The Commission has option to introduce new rules on the following voluntary information:

Ø ‘information on the possible and unintentional presence in food of substances or products causing allergies or intolerances’

• Precautionary allergen warnings (“may contain”) can still be used

• Permits the introduction of agreed phrases or allergen reference doses for the accidental presence of allergens in prepacked foods

Article 44 non-prepacked food• A new requirement for allergen ingredients information to be provided for non-prepacked foods and food provided prepacked for direct sale

• Foods are offered to sale to the final consumer or to mass caterers without prepackaging, or where foods are packed on the sales premises at the consumer’s request or prepacked for direct sale, the provision of the information about allergenic ingredients is mandatory

• The UK has introduced a national measure to enable to provide this information orally

Article 44 –non-prepacked foods

• Oral information must be indicate clearly that such information can be obtained upon request.

• Oral information must be accurate, consistent and verifiable upon challenge– Is there a process in place to enable consistent information to be provided? Refer queries to the nominated person(s)

– Verifiable ingredients information on a chart, recipe book, ingredients information sheets, scrap books with labels

Article 44 –non-prepacked foods

• Could declare allergen ingredients information through a contains statement, charts, tables etc.

– i.e. chicken tikka masala – Contains: milk, almonds (nuts)

• Consider Article 12 and 13 on accessibility of mandatory information - Marked in a conspicuous place, easily visible, clearly legible

• Signposting is required when information is not provided written and upfront. It should be where consumer would expect to find allergen information e.g in a folder, on menu board, at till or on the menu card

Signposting to allergen info (example)

Providing allergen information

Article 44 – non-prepacked food

• How are dietary requests communicated from front to back of house? e.g. use of chef cards, order tickets, receipts

• Preparing foods for allergic consumers- what process is in place

• Do you use Safer Food, Better business (SFBB) “Safe Method: Allergy”?

• Are you making specific claims i.e. gluten free– How this claim is verified or validated– Would no gluten containing ingredients (NGCI) statement be better? – more factual rather than attributed to a set level

Regular reviews, keep it current

Food businesses need to have processes in place to ensure the information they provide is accurate

• Regularly review the ingredients information

• Where ingredients change, review the accuracy of the recipe

• Do your garnishes or dressings change the allergenic profile? Check!

Communication is key

Accuracy is dependent on correct labelling, updating allergen information, updating staff and consumers• The person buying the food • The person handling the food• The person taking the order• The person ordering the food

Communication is key• Engage with serving staff• Extra precautions can be made• Recipes change• Ingredients change

Communicating the changes• Joint messaging, conferences, workshops and training

• Engagement with our interested parties • Speaking at conferences, seminars and exhibitions, articles for trade publications etc

• Food allergen information and updates (consumers and for food businesses) on the regulation can be obtained from:http://www.food.gov.uk/policy-advice/allergyintol/label/

CommunicationsJoint messaging

Consumer leaflet and Chef Cards

Allergy Awareness Week (28 April – 4 May 2014)

E- learning

Access free training on: http://allergytraining.food.gov.uk/

http://multimedia.food.gov.uk/multimedia/pdfs/publication/foodallergies-sfbb-0513.pdf

SFBB – allergy safe method

http://multimedia.food.gov.uk/multimedia/pdfs/publication/thinkallergy.pdf

Supporting businesses – non-prepacked

Developed in collaboration with food industry and consumer support organisations

http://multimedia.food.gov.uk/multimedia/pdfs/publication/loosefoodsleaflet.pdf

Supporting businesses –prepacked food

http://multimedia.food.gov.uk/multimedia/pdfs/publication/allergy-labelling-prepacked.pdf

Further information

• FSA allergy pages (guidance, advice, leaflets on allergen labelling: www.food.gov.uk/business-industry/allergy-guide

• Allergy E-learning http://allergytraining.food.gov.uk/• Allergy resources, templates, posters, leaflets: www.food.gov.uk/allergen-resources

• Safer Food Better Business for Caterers – Food allergies www.food.gov.uk/multimedia/pdfs/publication/foodallergies-sfbb-0513.pdf

• General FIR information to be found on GOV.uk• Consumer advice http://food.gov.uk/multimedia/pdfs/publication/allergy-leaflet.pdf

• BRC-FDF guidance for prepacked foods www.brc.org.uk/downloads/Guidance%20on%20Allergen%20Labelling.pdf

Guidance on new allergen rulesFSA technical guidance –www.food.gov.uk/news-updates/news/2014/6140/sme-allergen-guidanceEuropean Commission guidance –http://ec.europa.eu/food/food/labellingnutrition/foodlabelling/proposed_legislation_en.htm

Further assistanceFSA Websitehttp://www.food.gov.uk/science/allergy-intolerance/labelAllergens enquiries [email protected]

Please join the conversation on Twitterfood.gov.uk/twitter #14Allergens

and finally…ü Speak to colleagues

ü Share knowledge

ü Develop good working practices