Food > Labelling > Allergens 

National Sector Assessment 2000 - Import Sector

Labelling and Allergen Controls in the Import Sector

FINAL REPORT and RECOMMENDATIONS

WHY AND HOW THE ASSESSMENT WAS DONE:

The presence of undeclared allergens in imported foods may result in minor to life-threatening allergic reactions in persons with food allergies. The most commonly known allergen is peanuts. However there are several other allergens and their derivatives which are known to cause most adverse food reactions, they include the following:

The presence of undeclared allergens in food products can lead to costly recalls. During the past year almost 54% of all allergy related recalls coordinated by the Canadian Food Inspection Agency (CFIA) resulted from imported foods.

To promote allergen awareness and evaluate the controls needed to reduce the risk of allergic reactions from imported foods, the CFIA conducted a nationwide assessment of labelling and allergen controls in the import sector. The assessment started with the distribution of an information package which was sent to approximately 3,700 importers. Then from June 1999 to February 2000 on-site assessments were conducted of 116 randomly selected importers. During the assessment product labels were examined to verify label accuracy against the available product information. An importer survey was also completed to assist in understanding the importing environment and general labelling practices.

Only the importers who are primarily regulated under the Food and Drugs Act and Regulations were included in the on-site assessments. Four criteria for labelling and allergen controls were used in on-site assessments (the four criteria are not new requirements, and are already being used to reduce the likelihood of allergic reactions to imported foods).
They are:

For each importer, applicable criteria were assessed and rated as Complete, Partial or Absent and a report was provided to each importer.

WHAT WAS FOUND DURING THE ASSESSMENT - HIGHLIGHTS

The assessment found that there was a lack of available product information at importers, such as identification of specific ingredients, components and additives including allergens as well as processing and handling information. When information was available it was often up to date and complete. For the majority of importers, procedures for ensuring label accuracy were considered inadequate. Importers predominantly handled pre-packaged and pre-labeled products, though some importers also re-packaged or re-labeled imported products. Eighty-six percent of importers were aware of the allergy concerns. This awareness, however mainly focused on peanuts. Only a few had a complete formal policy or allergy-related employee training.

In the Survey, importers reported on their current allergy related activities. Twenty-three percent had previously received an allergy related complaint or had dealt with the presence of undeclared allergens in their products. Forty-six percent had been asked by their customers to provide allergy related information. Forty-one percent had asked their suppliers to provide allergy related information, and 29% supplied products with precautionary statements, i.e., may contain nuts. Additionally, 18% had taken some action to improve controls after receiving the information package from CFIA.

The assessment ratings indicate the need for importers to improve labelling and allergen controls in order to ensure that accurate product information is obtained from suppliers and conveyed to customers. Some importers realizing the need to improve their controls took the following types of corrective actions:

WHAT IMPORTERS CAN DO TO IMPROVE CONTROLS - RECOMMENDATIONS

Based on the CFIA findings the following recommendations are made:

This may be achieved by:

• maintaining written information sheets for all products;
• regularly updating and controlling (eg. initial, date, verify, etc.) information sheets;
• identifying (eg. supplier, brand, etc.) and listing amounts of specific ingredients, including food additives;
• identifying all nine food allergens when present;
• including processing or product handling information (eg. frying oil, egg washes, pan coatings, etc.) to determine the need for precautionary statements (eg. may contain...) on product labels.

• Ask for product information preferably before purchase or at least at the time of purchase, using a supplier checklist or an equivalent document. [see attached]
• Keep and update a product information binder and ensure accessibility to all staff. Plasticizing sheets may prevent unauthorized changes and ensure durability.
• Include special product handling instructions on information sheet (eg. "pack as the last batch for the shift").
• Include brand names, names of suppliers and issue date on product information sheets.

This may be achieved by:

• verifying that the ingredient list (including precautionary statements) of each product is accurate by checking it against available product information;
• ensuring that any formula substitutions are reflected on the label;
• ensuring that precautionary statements on product labels are current, accurately reflect product information provided by suppliers, follow the list of ingredients and are not used in lieu of good manufacturing practices;
• disseminating clear, timely and accurate information about ingredients to appropriate personnel;
• matching all new labels or precautionary labels developed by the importer against product formulations and associated manufacturing or handling information.

• Make a person responsible for maintaining and updating all labels.
• Use written procedures to verify the accuracy of new and existing labels (eg. ingredient checklist).
• Identify the source of ingredients (eg. hydrolyzed soy protein, wheat starch, modified wheat starch, soy lecithin, etc.)
• Declare peanuts, milk, soy, eggs, sesame seeds, sulphites, wheat, treenuts, fish, crustaceans and shellfish and their derivatives even when exempted under the Food and Drug Regulations.
• Check that all labels, especially those generated by in-house label printers or when purchased from a new printing company, accurately and legibly contain required label information.
• Check all labels to ensure all labelling requirements are met, including mandatory information and accurate nutritional information.

This may be achieved by controlling:

• shipping, receiving and storage;
• use of equipment involved with opened products;
• repackaging/labelling;
• on-site retailing operations.

• If re-packing, ensure that every opened product is transported, stored and packaged in a manner that avoids contamination with undeclared allergens, i.e. dedicated packing lines for high risk allergens or a full clean-up between product change-overs.
• Promptly close or cover all opened containers and clean all spills.
• If labelling match the product against the label. Also, proper storage and removal of unnecessary products and labels from the immediate area helps avoids mis-labelling.
• When using brokers, third party warehousing or direct shipping ensure by means of spot checks, written contracts, letters of guarantee or certificates that the product is always being handled properly to prevent possible contamination with undeclared allergens.

This may be achieved by:

• documenting and implementing an allergy policy;
• training employees in appropriate labelling and allergen controls.

• Company policy on allergens should address all allergens most frequently associated with allergic reactions (see list on page 1).
• Include all employees in allergy training.
• Make a person or a team responsible to plan, implement and monitor allergen and labelling controls.
• Inform your suppliers and customers about the policy.
• Check to ensure that policy is being followed.

WHY IMPORTERS SHOULD IMPROVE CONTROLS

Importers are the primary link between imported foods and consumers and play a very important role in ensuring the safety of imported foods for consumers. The CFIA expects that importers will apply the required labelling and allergen controls to:

• Meet their legal responsibility to ensure the safety of their products;
• Provide accurate information to their customers;
• Improve the safety of imported products for people with food allergies;
• Avoid allergy related complaints, costly recalls and product withdrawals.

In the future, the CFIA may use the results of this assessment as a baseline to measure changes in the labelling and allergen controls within the import sector.

WHERE TO GET MORE INFORMATION

To obtain further information concerning the assessment and for assistance regarding the labelling of foods, food safety or related information, please visit the CFIA Web site or contact CFIA office nearest you via Government of Canada information line at 1-800-O-Canada.

For further information on food safety and food labelling, including proposed enhanced labelling initiatives to make label declaration of priority allergens mandatory, please visit the Health Canada Web site at www.hc-sc.gc.ca.