Food allergens are ingredients or additives in food products that are known to occasionally produce allergic reactions in the population. Understanding how these food allergens function, and labeling your foods correctly, is key to maintaining legal operations (not to mention keeping your customers safe from accidental ingestion of allergens).
So what are the most important things to know about allergen labeling?
The Food Allergen Labeling and Consumer Protection Act
The Food Allergen Labeling and Consumer Protection Act (FALCPA) is a United States law that came into effect January 1, 2006, and mandates that all food labels in the country list allergens explicitly. The goal here was to eliminate the possibility of misleading or confusing methods to mark ingredients, such as using uncommon names for certain ingredients or technical terms that aren’t readily understood. If a company is found to be using an allergen ingredient without marking it clearly on the label, it can be penalized, with the suspected food product recalled.
For example, the ingredient casein is derived from milk and can trigger an allergic response in people allergic to milk. However, not everyone can immediately recognize that casein is a milk product—the FALCPA is designed to address this dilemma.
The eight major allergens
There are eight major allergens described by the FALCPA. If your food product contains any of these eight ingredients, or any ingredient that contains proteins derived from the root ingredient, it must be listed on the label. This includes even trace amounts, such as in food coloring or spices.
- Milk. Milk allergies are actually distinct from “lactose intolerance,” as milk-based allergic reactions are usually caused by casein, a specific protein found in milk.
- Fish. When labeling the fish allergen, the specific type of fish must be named (such as “swordfish”).
- Crustacean shellfish. Like with fish, when labeling crustacean shellfish, the specific type of animal must be named (such as “lobster”).
- Tree nuts. Again, tree nuts must be labeled with specificity (such as “walnuts”).
- Peanuts. Be aware that not all people who are allergic to tree nuts are allergic to peanuts, or vice versa.
Two methods of listing
There are two distinct methods for listing these ingredients. Either may be applied, or both:
- Parenthetical citations. Parenthetical citations are used in the standard list of ingredients to help designate ingredient derivatives in clear, specific language. For example, lecithin is an ingredient derived from soy, and therefore qualifies as a major allergen. In the ingredients list, a manufacturer could list lecithin (soy), and remain in compliance with the law.
- “Contains” reference. Alternatively, a manufacturer could use a “contains” reference at the bottom of the ingredients list. Here, the manufacturer would use the word “contains:” next to a list of any and all major allergens contained in the product.
If a product is merely made in the same environment as another product that contains allergen ingredients, the possibility for cross-contact (or cross-contamination) is present. Manufacturers must also indicate this, using referential language such as “manufactured in a facility that processes tree nuts.”
There are a few cases where exemptions may be filed. For example, sometimes an ingredient is modified so heavily that they no longer contain a protein that triggers an allergic response. If a food manufacturer processes milk to the point where it doesn’t cause an allergic reaction, it doesn’t have to be listed as an allergen. Additionally, the amount of an ingredient featured in a product may be so small that it also doesn’t trigger an allergic response—this situation also doesn’t demand the listing of the ingredient.
In either case, a food manufacturer must formally apply to be exempt from the labeling requirements. The company must provide peer-reviewed scientific evidence and/or clinical studies that demonstrate their ingredients do not produce an allergic reaction, and petition for an exemption from there.
There are many small rules when it comes to labeling food allergens, but it’s all for the safety of consumers. The eight major food allergens and the two main ways to label them on your ingredients list are the most important pieces of information to have, as it’s unlikely you’ll qualify for an exemption.
Play it safe here and you won’t have to worry about facing a recall or penalty—and your customers will stay safer, too.
Allergen labeling and segregation play a large part in global food safety initiatives
In the past, we’ve covered a number of different global food safety certifications that food manufacturers are working towards in order to meet their customers’ growing demands. One of the certifications we see a lot of companies working towards is the Safe Quality Food (SQF) certification. A large part of SQF compliance comes from how you manage allergens in your facility and label your products.