Fedima Position Paper on Labelling of Allergens

Similar documents
GLUTEN LABELLING BEST PRACTICE:

Customer Focused, Science Driven, Results Led

NOVEMBER 2016 I V1 SNE I GUIDANCE ON GLUTEN FREE LABELLING

Thought Starter. European Conference on MRL-Setting for Biocides

Relevant Biocidal Product Types in Food Contact Applications

Who is this booklet for?

Gluten regulations frequently asked questions

Food Allergies and Intolerance

Index. IV.1. Foods without a list of ingredients V. UPDATING OF ANNEX II CAUSE ALLERGIES OR INTOLERANCES... 12

Food Information Regulations what have we learnt so far?

REFIT Platform Opinion

This document is meant purely as a documentation tool and the institutions do not assume any liability for its contents

5. Supporting documents to be provided by the applicant IMPORTANT DISCLAIMER

Allergen Policy. Ingredients/Labelling. The 14 allergen groups listed are as follows;

Flavourings Legislation and Safety Assessment

Developments in the legislation on food hygiene related with VTEC Kris De Smet European Commission GD SANCO, Unit G4 Food, alert system and training

ILSI Workshop on Food Allergy: From Thresholds to Action Levels. The Regulators perspective

SANCO/1069/2008 Rev. 1 (POOL/E4/2008/1069/1069R1-EN.doc)

How can we report a product that is misusing the GFCO logo? By going to or by calling

BPR Requirements for Treated Articles. A.I.S.E. Biocides WG First revision - December 2017

The New EU Rules on Articles Treated with Biocidal Products. Cándido García Molyneux European Food Law Conference 2014 ERA, Trier May 5, 2014

Use of a CEP. CEP: What does it mean? Pascale Poukens-Renwart. Certification of Substances Department, EDQM

Precautionary Allergen Labelling. Lynne Regent Anaphylaxis Campaign

(Text with EEA relevance)

The New Food Information Regulations. Is your business ready?

COMMISSION IMPLEMENTING REGULATION (EU) No /.. of XXX. on the traceability requirements for sprouts and seeds intended for the production of sprouts

COMMISSION DELEGATED REGULATION (EU) /... of XXX

Bilateral screening: Chapter 27 PRESENTATION OF THE REPUBLIC OF SERBIA Biocidal Products Regulation (BPR)

Technical Data Sheet

INNOVATIVE SOLUTIONS POWERING YOUR SAFETY SUCCESS

Towards EU MRLs for biocides current status. Karin Mahieu

Flavour Legislation Past Present and Future or From the Stone Age to the Internet Age and Beyond. Joy Hardinge

Treated Articles and their regulation under the European Biocidal Products Regulation

COMMISSION RECOMMENDATION

PRODUCT REGISTRATION: AN E-GUIDE

19/09/2016 Esther Chartres Compliance in practice: how to meet your obligations to control food allergens

MINISTRY OF AGRICULTURE, LIVESTOCK AND FOOD SUPPLY OFFICE OF THE MINISTER. NORMATIVE INSTRUCTION N. 054, OF 18 th NOVEMBER 2009.

10086/17 dbb*/sg/mm 1 DGB 1 A

Official Journal of the European Union L 75/7

Specification. PSC16-D073 Premium Swiss Chocolate - Dark Chocolate (46% cocoa) Recipe number: Recipe name: Page 1/5. Distributor

Guide to managing food allergies

THE NEW LAW FOOD INFORMATION FOR CONSUMERS THE FOOD STANDARDS AGENCY VIEW. Sharon Gilmore FSA NI

PRODUCT SPECIFICATION - HARD BOILED EGGS (CO9003BK, CO9006BK AND CO9007BK)

Official Journal of the European Union

CEPE guidance Labelling of Treated Articles

COMMISSION OF THE EUROPEAN COMMUNITIES. Proposal for a COUNCIL REGULATION

Defra Consultation on Food Information Regulations 2013

Council of the European Union Brussels, 30 July 2014 (OR. en)

Union Authorisation. Gosia Oledzka. A.I.S.E. Bratislava May Scientific and Technical Affairs Manager

(Food) Allergen Management

CONSEQUENCES OF THE BPR

Fédération européenne de la Restauration Collective Concédée. European Federation of Contract Catering Organisations

GUIDE TO MANAGING FOOD ALLERGIES

Guidelines on Flavourings

6. Checklist for people working in: Stores and Retail

MacKillop Catholic College Allergy Awareness and Management Policy

Labelling for Food Allergen and Gluten Sources and Added Sulphites. Food Allergen Labelling / Domestic Canada Brand Sessions February 16-17, 2012

Allergen Control for Dietary Supplements

Dr. Bert Popping

Official Journal of the European Union

2nd working meeting of the Regional Expert Advisory Working Group on Wine in South Estern Europe 14/12/ /12/2015, Skopje, Macedonia

APPENDIX to TBT Notification G/TBT/N/EU/432/Rev.1

Carole Bingley Customer Focused, Science Driven, Results Led

Bringing Faith and Learning to Life

COMMISSION IMPLEMENTING REGULATION (EU) No 543/2011 of 7 June 2011 EXCERPT: ANNEX I, PART B, PART 9 MARKETING STANDARD FOR TABLE GRAPES

safefood Knowledge Network training workshops: Food Allergens

Environmental Services. Allergy and Intolerance (Advice for Caterers)

ImuPro shows you the way to the right food for you. And your path for better health.

Control of treated articles in the Biocidal Products Regulation ECHA Biocides Stakeholders Day 25 June 2013

# 2328 PREMIUM CHEDDAR PURE GOLD

Specify the requirements to be met by agricultural Europe Soya soya bean collectors and Europe Soya primary collectors.

Guidelines on the registration of national guides to good practice. In accordance with Article 8 of Regulation (EC) No 852/2004

INDUSTRY FACT SHEET. Vintage Wine and Application of Enhanced Allergen Regulations July 2012

GLUTEN FREE FLOUR FOR BAKERY PRODUCT I'M FEEL GOOD! FOR YOUR PIZZA FOR YOUR BREAD! TECHNICAL DATA SHEET FOR HANDMADE DOUGH AND FOR BREAD MACHINE

FOOD ALLERGY AND MEDICAL CONDITION ACTION PLAN

Official Journal of the European Union L 165/25

Note for agreement with Competent Authorities for Biocidal Products

HELLENIC MULTI ANNUAL CONTROL PROGRAMME FOR PESTICIDE RESIDUES

INSTRUCTIONS TO COMPLETE THE SELF EVALUATION CHECKLIST

REGULATORS PERSPECTIVE ON ALLERGEN MANAGEMENT IN THE FOOD INDUSTRY

The Biocidal Products Regulation in the Automotive Supply Chain

European Union comments for the. CODEX COMMITTEE ON CONTAMINANTS IN FOOD (CCCF) 4th Session. Izmir, Turkey, April 2010.

Specify the requirements to be met by Donau Soja soya bean primary processors.

COMMISSION DIRECTIVE 2003/118/EC

EU Legal framework Wine Council Regulation (EC) 1234/207 integrating Regulation (EC) 479/2008 Commission Regulation (EC) 606/2006 Amendments of this r

Allergy Awareness and Management Policy

S. I No. 117 of 2010: EUROPEAN COMMUNITIES (OFFICIAL CONTROL OF FOODSTUFFS) REGULATIONS 2010 CLOSURE ORDER

Food Information Regulation (FIR) Advice for Caterers

GUIDANCE NOTE ON UK IMPLEMENTATION OF A EUROPEAN DIRECTIVE DEREGULATING SPECIFIED QUANTITIES (FIXED PACK SIZES)

Spirit Drinks. EU Legislative Framework. AGRI.C.2 - Wine, Spirits, Horticultural Products, Specialised Crops

This document is meant purely as a documentation tool and the institutions do not assume any liability for its contents

What is a Food Allergen?

Official Journal of the European Union L 243/41 DIRECTIVES

US EAS 141 UGANDA STANDARD. First Edition Whisky Specification. Reference number US EAS 141: 2014

BPR in Brief. Guidance Document for A.I.S.E. members

# 2142 CARAMEL ONE STEP CORN TREAT MIX

Streamlining Food Safety: Preventive Controls Brings Industry Closer to SQF Certification. One world. One standard.

# 2029 BUTTERY TOPPING

# 2090 CONCENTRATED CHOCOLATE CORN TREAT MIX

This document is meant purely as a documentation tool and the institutions do not assume any liability for its contents

Transcription:

Fedima Position Paper on Labelling of Allergens Adopted on 5 March 2018 Introduction EU Regulation 1169/2011 on the provision of food information to consumers (FIC) 1 replaced Directive 2001/13/EC. Article 9.1(c) of this Regulation requires all allergens listed in Annex II of this Regulation to be labelled, including the allergens in processing aids. In the absence of a list of ingredients, Article 21 foresees the mention contains followed by the name of the substance or product as listed in Annex II. The information on the presence of allergens allows consumers to make an informed choice which is safe for them (recital 24). The FIC Regulation applies only to ingredients and substances voluntarily used in a foodstuff (recital 48). The question of adventitious presence of allergenic substances in a food (cross contamination) is not addressed by the new rules. However, the European Commission needs to harmonise the approach for precautionary allergen labelling (PAL). On 13 July 2017, the European Commission published a Commission Notice relating to the provision of information on substances or products causing allergies or intolerances 2, which gives guidance on the labelling of allergens in the context of the FIC regulation. Fedima approach Fedima is following the recommendations of the European Commission Notice. Allergen labelling must be clear, accurate and meaningful. Therefore, Fedima welcomes the regular review of the scientific basis for allergen labelling possibly leading to exemptions from allergen labelling requirements of derivatives not able to trigger adverse reactions. As manufacturers and suppliers of food ingredients, Fedima members will inform their customers by giving the required allergen labelling information on the product label and/or on the product information sheet. Although there s no harmonized European approach on risk assessment with regards to allergen cross contamination, Fedima members commit to provide information on the potential presence of allergens due to cross contamination. This information shall be based upon a risk evaluation (e.g. HACCP, Vital 2.0) in cases where various formulations are produced on the same production line or in the same production room taking into account the cleaning procedures in place. Fedima s recommendation is to avoid free from claims, except for products especially produced and marketed for specific groups of allergic people. The claim gluten free is an exception, because it is officially regulated under Regulation (EU) 1169/2011. Products complying the specific legal requirements (a.o. <20ppm gluten) can be marketed as gluten free. 1 Regulation (EU) No 1169/2011 of the European Parliament and of the Council of 25 October 2011 on the provision of food information to consumers, amending Regulations (EC) No 1924/2006 and (EC) No 1925/2006 of the European Parliament and of the Council, and repealing Commission Directive 87/250/EEC, Council Directive 90/496/EEC, Commission Directive 1999/10/EC, Directive 2000/13/EC of the European Parliament and of the Council, Commission Directives 2002/67/EC and 2008/5/EC and Commission Regulation (EC) No 608/2004 2 COMMISSION NOTICE of 13.7.2017 relating to the provision of information on substances or products causing allergies or intolerances as listed in Annex II of Regulation (EU) No 1169/2011 on the provision of food information to consumers 1

Summary Fedima members commit to: - Provide labelling information on allergenic ingredients and substances according to EU Regulation 1169/2011 - Provide information on cross contamination risks in the production process 3 - (as a matter of policy) avoid free from claims except for products produced under a specific regime 3 Information will be given to direct customers only. Information will be printed on the product label and/or on the product information sheet. 2

Annex I: Cross contamination Fedima members are advised to adopt and implement a policy on allergens which should include measures in place to avoid cross contamination, a risk assessment of possible cross contamination and guidelines used to inform customers on cross contamination risks. The information in this Annex could be used by Fedima members in formulating an allergen policy. Cross contamination The Fedima allergen policy requires the transmission of information on cross contamination risks. Cross contamination risks must be analysed in each production location and includes risks in the production of raw materials at the supplier s production site. Production sites should be carefully screened for the risk of cross contamination with allergens of Annex II of Regulation (EU) 1169/2011. Cross contamination in raw materials Ingredient suppliers are required to complete raw material specification sheets including allergen information. For each allergen listed the presence or absence via ingredients or via cross contamination must be indicated 4. The raw material specification sheet should also include information on the existence of a company s allergen policy. During supplier audits the effectiveness of the system should be assessed. Information on cross contamination from suppliers will undergo a (HACCP) risk evaluation. Based on this risk evaluation it will be decided whether or not the information is transferred to the next link in the chain. Factors to be considered are: probability of cross contamination, maximum concentration of a given allergen through cross contamination in the raw material and in the finished product and the magnitude of adverse health effect. A system like Vital 2.0 is based upon these factors. In case a Fedima member company has a specific allergen policy to exclude certain allergens in their products or production facility, cross contamination of those allergens in raw materials is unacceptable. Additional guarantees will need to be negotiated with suppliers. If cross contamination in raw materials is indicated by the supplier and a health risk cannot be excluded this information should be transmitted to the next link in the chain. Cross contamination in production If the result of a risk assessment is that cross contamination in production cannot be avoided and a health risk cannot be excluded, this information should be transmitted to the next link in the chain. When the product is fully labelled, a Precautionary Allergen Labelling (PAL) will be applied. The advice is not to use a variety of different wordings, but us the words May contain [allergen]. This advice follows the Technical Report from DG SANTE and Joint Research Center workshop (June 2016) (Fedima/17/143). The information will also be transmitted via the product information sheet. 4 To collect and provide detailed information on cross contamination, it can be recommended to use the Allergen Questionnaire as developed by Allergenenconsultancy 3

Test production Test productions with new ingredients containing allergens that have not been present on the given production line can only take place when the line is thoroughly cleaned after the test run and validated for release. Production lines When moving products between production lines it must be avoided that the cross contamination risk is increased. Before a decision is made to produce a given product on a non-assigned production line a risk analysis on allergen cross contamination must be carried out. Rework It is best practice that rework only contains the same or less allergens then the product where it is used in. If a rework product contains more allergens, this should be part of the risk assessment and consequently the ingredient list must be amended following the labelling Regulation. A thorough cleaning and validation have to be carried out after this rework operation. Products with free from claim For products carrying a free from claim a special production regime must be in place and ingredients used may not be cross contaminated with the allergen for which the claim is made. The production regime includes dedicated production lines and/or thorough cleaning before the free from production begins. These procedures should be well documented and the effectiveness of the cleaning must be verified. 4

Annex II: Labelling of enzyme preparations An enzyme complex is a compound ingredient (ex: WHEAT flour, enzyme 1, enzyme 2). The identical components are added together to form the list of ingredients. All ingredients are mentioned in descending order. In the case of enzymes used in bakery intermediate foodstuffs (bread improvers, cake mixes etc.) the carrier often contains wheat. The enzyme is not derived from an allergen but the allergen is one of the ingredients in the enzyme complex. In order to label the final product (e.g. bread/cookie) correctly, the relevant components of the enzyme complex need to be indicated in the list of ingredients. The enzyme itself, being a processing aid in the end product, it is exempted from labelling in the end product ingredient list. Its carrier (e.g. WHEAT flour) is not exempted. Examples of labelling a bakery raw material and a consumer product can be: Wheat bread Recipe wheat flour (100 gr.), water (56 gr.), yeast (2 gr.), salt (1,5 gr.) and bread improver (3 gr.) Ingredients bread improver: WHEAT gluten, WHEAT flour i, palm oil, malt flour (BARLEY), sourdough devitalised (RYE flour), emulsifiers: E471 (SOY), E482, MILK protein, dextrose, enzymes ii. Labelling of the bread: WHEAT flour iii, water, yeast, WHEAT gluten, salt, palm oil, malt flour (BARLEY), sourdough devitalised(rye), emulsifiers: E 471 (SOY), E482, MILK protein, dextrose. Oat cookie Recipe 1.000 gr. Oat Cookie mix, 500 gr. raisins, 200 gr. barn eggs, 150 gr. water. Ingredients cookie mix OATmeal, sugar, glucose syrup, vegetable oil (palm), raising agent E450, E500, thickener E412, salt, MILK protein, flavouring, WHEAT flour iv, enzymes v. Labelling of the cookie OATmeal, raisins, sugar, barn EGG, water, glucose syrup, vegetable oil (palm), raising agent E450, E500, thickener E412, salt, MILK protein, flavouring, WHEAT flour vi. i This term gathers the ingredient in the bread improver + carrier of the enzyme complex ii Labelling according to Regulation (EC) No 1332/2008 unless specified differently in national legislation iii This term gathers main ingredient + ingredient in the bread improver + carrier of the enzyme complex iv The wheat flour is the carrier of the enzyme complex v Labelling according to Regulation (EC) No 1332/2008 unless specified differently in national legislation vi The wheat flour is the carrier of the enzyme complex. The enzyme is not labelled because it is a processing aid in the cookie 5