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01 April 2021
Food Allergy
- Food Safety

As part of our role as Observers to the FAO/WHO Codex Alimentarius Commission work on food labelling, EFA responded to the call for comments on allergen labelling within the revision of the General Standard for the Labelling of Prepackaged Foods (GSLPF).

In particular, the background document of the consultation identifies four main topic categories under review, and subsequently proposes changes to the Standard. The topic categories are the following:

Scope and structure of the GSLPF relevant to allergen labelling

EFA supports the extension of the scope of the GSLPF in the case of foods and ingredients that cause food hypersensitivities to all options for food provision in the food chain. This comprises information on prepacked and non-prepacked food not only for consumers and catering purposes, but also between businesses as well as in e-commerce.

Definitions e.g. of terms such as ‘hypersensitivity’ and ‘food allergy’

EFA cautions against the use of the term ‘hypersensitivity’ as it is too broad to summarise very different diseases. Instead, there should be a distinction between the different diseases based on severity of symptoms/public health significance.

Furthermore, ‘food allergy’ means an adverse immune reaction to certain food proteins, which may be immunoglobulin E (IgE) mediated, non-IgE mediated, or a combination of both and can cause anaphylaxis and result in a life-threatening allergic reaction.

Therefore, there should be an indication regarding the difference between ‘food intolerance’ and ‘food allergy’ not only to the underlying mechanism, but also to the medical consequences. While it is of course necessary to inform patients with food intolerance on the presence of their trigger in food, there should be an indication in the GSLPF to inform food manufacturers, who are not familiar with the medical aspects, about the different scope of the disease, as it has been suggested in the text for Coeliac Disease.

Mandatory labelling of pre-packaged foods e.g. of compound ingredients, ingredient and class names, exemptions etc

Food allergens can elicit allergic reaction in even small amounts. EFA highlights that when a compound ingredient constitutes less than 5% of the food and contains a food allergen, it must be clearly indicated to consumers with food allergies.

Presentation of mandatory information

EFA agrees to the proposal to add a specific section that deals with the presentation of mandatory declaration of foods and ingredients known to cause hypersensitivity.

Another important aspect that EFA stressed, is that all ingredient and additional allergen information (‘contains…’ or ‘may contain…’ statement) must be grouped together in the same place on the label and not hidden amongst other labelling information so consumers can easily find and read this information when making food choices.

More information on the General Standard for the Labelling of Prepackaged Foods

You can find EFA’s full response via this link.