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Labelling of Foods Causing Allergies and Sensitivities

March 31, 1998

To: Food Manufacturers, Importers, Distributors and their Associations

Numerous incidents of allergic and sensitivity reactions to both domestic and imported foods are being reported to the Canadian Food Inspection Agency (CFIA). The purpose of this letter is to inform you of the potentially serious consequences of such adverse reactions and to highlight the importance of developing strategies to prevent their occurrence.

A variety of foods contain ingredients that can cause adverse reactions in hypersensitive individuals. Most adverse food reactions are caused by the following foods and their derivatives:

• peanuts
• tree nuts (almonds, Brazil nuts, cashews, hazelnuts [filberts], macadamia nuts, pecans, pinenuts, pistachios, walnuts)
• sesame seeds
• milk
• eggs
• fish, crustaceans (e.g. crab, crayfish, lobster, shrimp) and shellfish (e.g. clams, mussels, oysters, scallops)
• soy
• wheat
• sulphites

If these foods, or their derivatives, are not labelled or are incorrectly labelled, or if inadvertent carry-over occurs during manufacture, the results can be serious and sometimes fatal. Although this list represents the foods causing the most common and serious reactions, a wide variety of other foods have been reported to cause adverse reactions in certain individuals.

The Canadian Food and Drug Regulations require almost all prepackaged foods to have a complete list of ingredients and components (ingredients of ingredients). It is your responsibility to ensure that the foods you manufacture, import, sell or distribute are safe and meet the labelling requirements of this legislation. Therefore, the CFIA urges you to ensure that the above foods are included in the ingredient list on your labels when present as ingredients or components. To further assist consumers in making safe food choices, the CFIA encourages you to identify the plant source of ingredients, such as hydrolysed plant proteins, starches, modified starches and lecithin (e.g. hydrolysed soy protein, wheat starch, modified wheat starch, soy lecithin).

The CFIA recognizes the efforts by many members of the food industry to improve the accuracy of ingredient declarations and to implement controls to reduce carry-over of ingredients. As food safety is paramount to consumers, the food industry, and government, the CFIA also urges you to develop strategies, such as an allergen prevention plan, to manage the risks associated with those foods known to cause severe adverse reactions. Part of your strategy should include a thorough evaluation of your manufacturing and ingredient control procedures. It is also your responsibility to ensure that all prepackaged foods you import are fully and correctly labelled, and preferably are sourced from suppliers having an allergy prevention plan in place.

Undeclared ingredients may occur in foods as a result of:

• carry-over of product through incomplete cleaning of food contact surfaces and utensils, sometimes because of poor equipment design;
• inappropriate use of rework containing allergenic ingredients;
• ingredient changes, substitutions or additions not reflected on the label;
• incorrect labels put onto products;
• incorrect or incomplete list of ingredients;
• unknown ingredients in raw materials;
• misrepresentation of common names to describe products/ingredients (e.g. mandelonas for reformed, reflavoured peanut);
• labelling exemptions under the Food and Drug Regulations.

The CFIA recognizes that despite all possible precautions, the presence of allergenic ingredients cannot always be avoided. In order to assist consumers with food sensitivities, the Canadian government, in consultation with industry and allergy groups, developed a policy on precautionary labelling, e.g. "may contain peanuts". This policy allows the food industry to voluntarily label products which may inadvertently contain substances capable of causing severe adverse reactions. Precautionary labelling, however, must be truthful and must not be used in lieu of adherence to good manufacturing practices.

Accurate and complete labelling of foods will reduce the need for costly food recalls. It will also assist Canadians with severe food sensitivities to make safe choices from a wider variety of foods in the marketplace.

For further information, please contact the Canadian Food Inspection Agency office nearest you.

Anne A. MacKenzie
Director General
Food Inspection Directorate

Proposed Labelling of Foods Causing Severe Adverse Reactions in Canadians, A Report by a joint Canadian Food Inspection Agency and Health Canada Committee