Declaration of Food Allergens - Pre-Packaged Foods
| TO: |
FOOD MANUFACTURERS, IMPORTERS, DISTRIBUTORS AND
RETAILERS |
| RE: |
DECLARATION OF FOOD ALLERGENS |
The Canadian Food Inspection Agency (CFIA) has published two advisories
regarding labelling of allergens in foods.1, 2 The CFIA is again reminding food
manufacturers, importers, distributors and retailers of their responsibility to
ensure that the foods they sell are safe for all consumers, including those
with food allergies.
Food Allergens
Most allergic reactions are caused by the following foods and their
derivatives:
- Peanuts
- Tree nuts (almonds, Brazil nuts, cashews, hazelnuts [filberts], macadamia
nuts, pecans, pine nuts, pistachios, walnuts)
- Sesame seeds
- Milk
- Eggs
- Seafood (fish, crustaceans, shellfish)
- Soy
- Wheat
- Sulphite
Label Requirements Applicable to Pre-Packaged Foods in Respect to
Allergens
The Food and Drug Regulations (FDR) requires a complete and accurate list of
ingredients and their components on the label of most pre-packaged foods. There
are some exemptions to this requirement. For example, certain components of the
ingredients used in making sandwiches may be exempt from declaration under the
Regulations. However, a pre-packaged food product labelled with a list of
ingredients is unsafe for people with food allergies if some of those
ingredients or components are priority allergens and are not declared on the
label. Failure to declare allergenic components may be contrary to Subsection
5(1) of the Food and Drugs Act and Subsection 7(1) of the Consumer Packaging
and Labelling Act. These products may therefore be subject to regulatory
measures taken by the CFIA, including a product
recall.
In addition, the CFIA encourages identification of
the plant source of ingredients (e.g.
hydrolysed soy protein, wheat starch, modified wheat starch, soy lecithin) on
the label.
Allergen Prevention Plans
The CFIA
recommends that the food industry develop strategies, such as an allergen
prevention plan3, to manage the risks associated with priority
allergens. The strategy should include a thorough evaluation of manufacturing
and ingredient control procedures. In the case of imported pre-packaged food
products, it is the importers’ responsibility to ensure those products
are fully and correctly labelled.
Precautionary Labelling
Despite all possible precautions, the presence of allergenic ingredients in
foods cannot always be avoided. In order to assist consumers affected by food
allergies, the Canadian government, in consultation with industry and allergy
groups, developed a policy on precautionary labelling (“may
contain” statements). 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 legal requirements. When an
allergen is likely to be present in a product, the use of precautionary
labelling is not acceptable and the presence of the allergenic ingredient
should be accurately declared on the label. Further information on basic
labelling requirements can be found in chapter 2 of the 2003 Guide to Food
Labelling and Advertising4.
For More Information
Atlantic - Ronald Arsenault 506-851-4880
Quebec – Claude Desaulniers 514-283-3815 x4335
Ontario – Mary Rutherford 519-826-2948
West – Terry Peters 604-666-1080
1 Labelling of Foods Causing
Allergies and Sensitivities -
http://www.inspection.gc.ca/english/fssa/labeti/inform/19980331be.shtml
2 Undeclared
Allergens in Food -
http://www.inspection.gc.ca/english/fssa/invenq/inform/20041018e.shtml
3 A Tool for
Managing Allergen Risk in Food Products -
http://www.inspection.gc.ca/english/fssa/invenq/inform/toualle.shtml
4 Guide to Food
Labelling and Advertising -
http://www.inspection.gc.ca/english/fssa/labeti/guide/toce.shtml
March 23, 2007
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