Labelling Guidelines

The new allergen labelling directive 2003/89/EC became mandatory on 25th November 2005. The new directive makes it much easier for people with coeliac disease and food allergies to identify allergens in foods at a glance, and therefore select food safely.

The key points of the new regulations

In the past, if an ingredient made up less than 25% of the product it did not have to be included in the ingredients list. This rule has been deleted from the new regulations so all deliberate ingredients will now have to be listed unless they are on the exemptions list (1).

All deliberate ingredients, no matter how small the quantity used, must be listed in the ingredients list. All allergens and ingredients derived from allergens have to be specified, including additives, flavourings, processing aids and solvents (1) .

Manufacturers can highlight allergens in the food by means of an 'Allergy Box'. For example, stating "CONTAINS WHEAT" or "CONTAINS GLUTEN" in a separate box on the label. If a separate allergy information/alert box is used, best practice dictates that all specified allergens present in the food should be included (3).

Exemptions from labelling

Although there are currently no threshold levels in the Allergen Labelling Directive, the European Food Safety Agency (EFSA) has developed a list of ingredients that are exempt from allergen labelling. These are ingredients that are not allergenic in practice, as processing has removed the allergenic factor (2) .

The list of exemptions for gluten, according to the Guidance Notes on the Food Labelling (Amendment) (No. 2) Regulations 2004 are as follows (2);

• Wheat based glucose syrups including dextrose.
• Wheat based maltodextrins.
• Glucose syrups based on barley.
• Cereals used in distillates for spirits.

Products that do not comply with the new allergen legislation are prohibited from sale.

What you need to know:

• All deliberate ingredients have to be listed on food packaging in the ingredients list.
• If an ingredient containing gluten is used in the food, it must be clearly listed in the ingredients (e.g. malt extract from barley, or malt extract (contains gluten)).
• Highlighting allergens in a CONTAINS box is recommended but not mandatory.
• If gluten is not present, the product will not necessarily be labelled as gluten-free, although some manufacturers are choosing to label in this way.
• Some manufacturers also use the Crossed Grain symbol to highlight the fact that their products are gluten-free and therefore suitable for a gluten-free diet. The symbol is well recognised by those on a gluten-free diet and can be used, under licence, on suitable gluten-free foods and drinks. Click here to find out more.

'May Contain' Labelling

Manufacturers should assess the risk of cross-contamination of a food with gluten-containing cereals, and label productsaccordingly. Guidance on the use of 'May Contain' labelling is available from the Food Standards Agency (4).

Further information

You will find specific guidance on the Food Standards Agency  website to enable you to comply with the allergen labelling guidelines.

References

1 The Food Labelling (Amendment) (England) (No.2) Regulations 2004.

2 The Food Labelling (Amendment) (England) (No.2) Regulations 2004. Annex: List of food ingredients or substances provisionally excluded from Annex IIIa of Directive 2000/13/EC of the European Parliment and of the Council (as published in Commission Directive 2005/26/EC and corrected by Commission Directive 2005/63/EC)

3 Guidance notes on the Food Labelling (Amendment) (No.2) Regulations 2004.

4 Guidance on Allergen Management and Consumer Information - Best Practice Guidance on Managing Food Allergens with Particular Reference to Avoiding Cross-Contamination and Using Appropriate Advisory Labelling (e.g. 'May Contain' Labelling)