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24 March 2022
Food Allergy
PREVENT, - Food Safety

In December 2020, the European Commission launched the revision of the Food Information to Consumers (FIC) regulation 1169/2011, the main EU legislation covering provisions and requirements around food information. Since it entered into force in 2014, the FIC regulation has brought positive change and protection for patients living with food allergies in Europe.

The initiative to review the FIC regulation is part of the EU Farm-to-Fork strategy: the overarching framework of policies aiming to ensure healthy food consumption and a sustainable food production system in Europe. The revision also responds to the EU’s Beating Cancer Plan, whose ambition is to work on the great potential of healthy diets, and particularly nutrition, in the prevention of cancer. Evidence shows that consumer access to information on food and diets has an impact on the occurrence of other chronic diseases too, such as allergy and airways diseases.

As important as these considerations are for human health, unfortunately they have not been adequately reflected in this initial European Commission consultation on FIC. Even more importantly, the current consultation narrows its focus to only review information on nutrition, origin and date, thus leaving allergen labelling considerations out of scope.

At EFA we felt compelled to highlight these gaps by publishing an official statement on allergen labelling, especially regarding Precautionary Allergen Labelling (PAL).

Protecting food allergy patients: the need detail legislation on Precautionary Allergen Labelling

PAL is a voluntary labelling mechanism used by food manufacturers to indicate potential unintended allergen presence in food. In most cases this is due to cross-contact in the production cycle e.g. manufacturing, processing, storage, or transportation. In their actual form, PAL statements are given in various forms such as ‘may contain…’, ‘may contain traces of…, ‘manufactured in a facility that also processes…’.

While the FIC Regulation describes general requirements on voluntary information such as PAL, it stops short of defining the specific aspects of its implementation. Until this happens, food allergy patients are left with a daily uncertainty over the safety of the food bearing a PAL statement.

For EFA and the food allergy patient community we represent, allergen labelling (including PAL) is very much a safety issue. Any label that does not report, or provides incorrect or incomplete, information on allergens represents a severe risk to the health of allergic consumers, as an anaphylactic reaction can lead to death.

As EFA highlighted in its 2019 report ‘FoodDetectives – Quality of Life for People with Food Allergies in Europe: A Menu for Improvement’, the lack of legal provisions and requirements for the use of PAL, and the resulting absence of a harmonised approach across Europe, has led to an inconsistent, but also excessive, use of PAL. In its current use, PAL protects food operators rather than consumers and patients.

Under such circumstances, consumers with food allergies are often forced to interpret themselves the PAL statements that they see, with the obvious health risks that this entails. As EFA has reported, consumers tend to lose trust in the current food labelling system and see their fear and anxiety increase when deciding which foods to consume. 

The revision of FIC should improve current PAL rules

This is why EFA considers the ongoing revision of the FIC Regulation as a missed opportunity to address legislative issues around food information holistically and decisively. We call the European Commission to amend this gap as soon as possible by:

  • Harmonising EU-wide rules on Precautionary Allergen Labelling, based on common wording and conditions for use, in line with Article 36 of the FIC Regulation.
  • Encouraging and financing scientific research to establish reference doses for the 14 recognised allergens listed in the Annex II of the FIC Regulation, on the basis of a common approach to quantitative risk assessment.

EFA stands ready to convey allergy patients’ needs to the EU institutions and agencies and work closely together to provide the highest food quality information and standards.

You can find here the full EFA response to the consultation on the Food Information to Consumers regulation, and EFA’s Policy Position on Precautionary Allergen Labelling

For more details on PAL and the perspective of food allergy patients, see our 2019 report ‘Quality of Life for People with Food Allergies in Europe: A Menu for Improvement’.