The Package Label: Food Allergens
By Marjana Peterman, B.Sc.
“Is there a shellfish in this sauce, and do you use sodium glutamate in your dishes?” is my usual question in restaurants. “I must check with our chef” is the usual answer; after checking in the kitchen, the waiter comes back with a question: “What is sodium glutamate?” This is my routine experience in restaurants that most often irritates my table companions, since ordering often extends to a 10-minute discussion on dishes I am allowed to eat. My allergies, intolerances and sensitivities extend not only to shellfish and glutamate, but also to sulfates, gluten and aspartame as well as penicillin. Multiple hypersensitivities are more and more common, and industry as well as catering businesses must become more socially responsible in providing proper and real-time information to consumers. Legislation is not enough.
Allergies and Intolerances
The scope of the problem, particularly for young people, is a significant public health issue. It is generally accepted that nearly 10 percent of children and 4 percent of adults have allergies and intolerances to food. Translating these numbers into number of families, one can estimate that every tenth family in the developing world has a family member who has this disease or physiological state. Most often, allergies and intolerances are not life threatening, but avoidance of certain foods is the only way to prevent adverse response. In the U.S., it is estimated that anaphylactic reaction to food results in 30,000 emergency room visits, 2,000 hospitalizations and 150 deaths.
It is not clear why a person develops allergies or hypersensitivities, but we do know that family medical history (genetics) does contribute a great deal to it, as do the environment, foods and medicines, which may trigger a sensitive state. Most food allergies start in childhood; some adults develop an allergy to a food they could once eat with no problem. Sometimes, a child outgrows a food allergy only to have it reappear in adulthood.
The only way for a consumer to avoid risks of allergic and intolerance reactions inherent in food is to have clear and understandable information on all ingredients present in food, prepackaged or served, for the consumer to make a choice.
I like the policy by Health Canada for enhancing the protection of food-allergic consumers in Canada, which is based on two guiding principles: prevent the inadvertent consumption of undeclared allergens by sensitive consumers and enable a variety of safe and nutritious food choices for the allergic consumer.
Regulations on Labeling and Presenting Food
The Codex Alimentarius General Standard for prepackaged food on labeling ingredients known to cause hypersensitivity (followed by a nonexhaustive list of food groups) requires that the following shall always be declared:
• Cereals containing gluten; that is, wheat, rye, barley, oats, spelt or their hybridized strains and products of these
• Crustaceans and products of these
• Eggs and egg products
• Fish and fish products
• Peanuts, soybeans and products of these
• Milk and milk products (lactose included)
• Tree nuts and nut products
• Sulfite in concentrations of 10 mg/kg or more
In the U.S., legislation requires labeling of the eight most common foods (and any ingredient that contains protein derived from one or more of them) with allergenic properties, including milk, eggs, peanuts, tree nuts (e.g., almonds, cashews, walnuts), fish (such as bass, cod, flounder), shellfish (such as crab, lobster, shrimp), soy and wheat. U.S. legislation also states that ingredients derived from allergenic food must be additionally labeled with the name of a food source or food group from the list of the eight common foods.
The most recent European act on food information to consumers, EU Regulation No. 1169/2011, requires that there should be a broad definition of food information law covering the rules of a general and specific nature as well as a broad definition of food information covering information provided also by means other than the label:
• They (ingredients causing allergies and intolerances) shall be indicated in the list of ingredients with clear reference to the name of the substance or product as listed and shall be emphasized through typography that clearly distinguishes it from the rest of the ingredients list, for example, by means of the font, style or background color.
• To ensure the provision of food information, it is necessary to consider all ways of supplying food to consumers, including selling food by means of distance communication.
European legislation lists the following foods to be considered for labeling and other means of information on food provided by the producer, processor, seller, advertiser or catering establishment:
• The same list (Codex) as mentioned above, plus
• Nuts, specifically almonds (Amygdalus communis L.), hazelnuts (Corylus avellana), walnuts (Juglans regia), cashews (Anacardium occidentale), pecans [Carya illinoinensis (Wangenh.) K. Koch], Brazil nuts (Bertholletia excelsa), pistachios (Pistacia vera), macadamia or Queensland nuts (Macadamia ternifolia) and products thereof, except for nuts used for making alcoholic distillates, including ethyl alcohol of agricultural origin
• Celery and products thereof
• Mustard and products thereof
• Sesame seeds and products thereof
• Sulfur dioxide and sulfites at concentrations of more than 10 mg/kg or 10 mg/L in terms of the total SO2, which are to be calculated for products proposed as ready for consumption or as reconstituted according to the instructions of the manufacturers
• Lupin and products thereof
• Mollusks and products thereof
Regulatory lists should not be considered exhaustive, and consideration must be taken for specific national legislation and public health situation.
Declaration Example: Poor Labeling
Figure 1 is an example of poor labeling, considering a clear and readable list of ingredients. It was brought to my attention through a consumer question on the ingredients present in this soup. The consumer was asking why milk, soya and eggs were present in a clear chicken soup concentrate, since his own chicken soup is never made with such ingredients. The same consumer was also complaining that the point size for the ingredients was small, the paragraph on ingredients was hidden among other nonessential text and allergens were very hard to distinguish from other ingredients.
The ingredient list (labeled “SI: Sestavine” on the figure) uses the smallest type of all the text paragraphs on the picture, it uses poor contrast (black on green) and is placed among nonessential information telling the consumer about the goodness and freshness of the ingredients as well as directions for preparing the soup. It is quite a trap for the allergy sufferer, since several allergens are present, including milk, eggs, celery, soy and wheat (allergens should be emphasized through a typography that clearly distinguishes them from the rest of this text), as there is sufficient room to add a comprehensive and visible ingredient list to the package.
Another example comes from a consumer suffering from peanut allergy who had made several trips to the hospital (due to anaphylactic shock) after eating a food product containing “vegetable oil.” Vegetable oil, although declared but not specified, was used and the consumer assumed that the food bought did not contain peanut oil within the declared vegetable oil. It is a costly experience to learn which prepared foods contain peanut oil when declaring “vegetable oil” and which do not.
The above examples are merely the tip of the iceberg with respect to poor labeling and declaration of allergens on foods. Hazard Analysis for allergen risk clearly is necessary for the producer to sell a safe product.
Labeling allergens should be:
• Clear, readable and understandable by any consumer
• Emphasized on the label; alerts may be also used
• Ingredients like lecithin, vegetable oil, starch, flour, whey, casein, etc. should also be labeled as a food source, to be understood by the consumer
• Formula/recipe changes to the food product should be clearly indicated on the package
• Restaurants should label allergens on the menu
• Industry and businesses should consider that consumers/families that have hypersensitivities would avoid buying new products that are poorly labeled
It is still not proven whether food colors (whether azo dyes, synthetic colors or natural colors) have an effect on attention deficit-hyperactivity disorder; however, it has also not been proven that there is no impact, but effects on certain sensitive groups of children cannot be excluded. In many studies, azo dyes had no effect; however, strong effects were observed in children receiving azo dyes and benzoic acid combinations. Due to scientific uncertainty, in Europe, the precautionary principle is exercised by risk managers (i.e., legislators), such that the following legislative requirement is now part of a regulation (EC 1333/2008 of the European Parliament and of the Council of 16 December 2008) on food additives requiring, in Annex V, that the labeling of foods include additional information stating: “may have an adverse effect on activity and attention in children” on foods containing one or more of the following food colors:
• Sunset yellow (E 110)*
• Quinoline yellow (E 104)*
• Carmoisine (E 122)*
• Allura red (E 129)*
• Tartrazine (E 102)*
• Ponceau 4R (E 124)*
*With the exception of foods where the color(s) has been used for the purposes of health or other marking on meat products or for stamping or decorative coloring on eggshells.
Labeling that indicates “may contain an allergen” is not a precaution and should not be a substitute for Good Manufacturing Practices or risk of legal action, but must be applied and used only if it is truthful and cannot be reasonably avoided. The statement “produced in a facility that also uses…allergen” is hardly understood by the consumer and should be avoided.
Let me conclude with a quote from President John F. Kennedy in March 1962: “Consumers by definition include us all. They are the largest economic group, affecting and affected by almost every public and private economic decision. Yet they are the only important group…whose views are often not heard.”
Marjana Peterman, B.Sc., is a food officer at the Slovene Consumer Association and a project manager with the International Consumer Research Institute. She has spent more than 30 years in the food industry, holding management and research positions, mainly in Canada. Marjana holds a B.Sc. degree in food science and technology from University of Ljubljana, Slovenia.
Categories: Food Types: Ingredients; Process Control: Packaging; Regulatory: Guidelines, International Standards/Harmonization