29 September 2021
Food Allergy
PREVENT, - Food Safety

The Food Labelling committee (CCFL) of the Food and Agriculture Organization’s (FAO) Codex Alimentarius Commission organised a request for comments on two key issues: A proposed revision of the General Standard for the Labelling of Prepacked Food (GSLPF) relevant to allergen labelling; and the proposed guidelines for the use Precautionary Allergen Labelling (PAL). As an observer organisation, EFA attends the meetings to provide the perspective and needs of the European food allergy patient community.

On the revision of the GSLPF, EFA’s recommendations focused on the following aspects:

  • The need to establish a clear distinction between food allergies (IgE-mediated and non-IgE-mediated) and food intolerances as non-IgE-mediated food hypersensitivities. From our patient perspective this distinction is key, as it can lead to more targeted labelling and therefore better protection of all patients.
  • Define a labelling requirement for compound ingredients regardless of their percentage in the food. This implies removing the existing provision, which establishes a labelling requirement only if the quantity of the compound ingredient represents more than 5% of the food. This indication would enable consumers with food allergies to better protect themselves from allergens, even in small amounts.
  • Maintain soy in the list of priority allergens, as it can provoke anaphylactic reactions and is prevalent ingredient worldwide. If removed from the list, soy will not be labelled as potentially harmful, while it is widely used as a substitute for children with cow´s milk allergy.

On the proposed guidance on PAL, EFA made the following recommendations:

  • PAL should be referred to as ‘Precautionary Allergen Labelling’ (and not as ‘advisory labelling’), given that Precautionary Allergen Labelling is a more specific description, and is an already established term within the patients and consumers communities.
  • PAL should only be used when the food product poses a health risk to allergic consumers, which should be defined as when the unintended allergen present due to cross-contact is above an agreed threshold (action) level. PAL’s definition should reflect this principle.
  • Codex should be clearer that not ‘any risk of cross contact’ should lead to the application of PAL, but rather only a risk that is likely to have an adverse health impact to consumers with food allergies.

EFA suggested the two documents should be worked on separately, as the PAL guidance is likely to take more time to be finalised, and is therefore likely to cause unnecessary delays to the revision of the GSLPF.

Beyond its membership, EFA’s response has received support from other patient organisations, including: SOS Alergia (Argentina), Allergy and Anaphylaxis Australia, Alergia Alimentar (Brazil), Food Allergy Canada, Yahel (Israel), Atopicco (Japan), Allergy New Zealand, Nederlands Anafylaxis Netwerk – NAN, and the Food Allergy Research & Education – FARE (United States).

You can find here EFA's full response to the General Standard for the Labelling of Prepacked Food and the Guidelines for the use of Precautionary Allergen Labelling.