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26 April 2022
EU, Europe
Food Allergy
- Food Safety

Apart from terrible costs in human lives and suffering, the Russian war against Ukraine has considerable implications for food availability across Europe and globally. One outstanding example is sunflower oil, of which 80% of global exports are produced by these two countries. Its scarcity will  have an impact on food allergy patients all over Europe.

Widely used in cooking, sunflower oil is a common ingredient in European diets and food markets. The disruptions in the supply chain of sunflower oil has led to shortages in many European countries, forcing food manufacturers to replace it with other ingredients. Some of its substitutes, such as oils from peanut and wheat germ, are made of ingredients that are typified as allergens in the European Union. Others, such rapeseed, coconut and corn oils, are also linked to less common food allergies.

Allergen-based oils: labelling derogations vs health risks

The replacement process has raised concerns over the labelling of the substitute ingredients. Several European countries have granted derogations from the obligation to indicate the ingredients through conventional labelling, as required by the EU Regulation 1169/2011 on the Food Information to Consumers (FIC Regulation).

On April 8, EFA expressed these concerns in a letter addressed to the European Commission Directorate General for Health and Food Safety (DG SANTE). In this letter EFA reminds that food industry and operators need to inform consumers about their new recipes and the allergens present in their products. Allergen labelling is a safety issue for the food allergy patient community. Any label that does not report, information on allergens, or provides it incorrectly or partially, represents a considerable risk to the health of allergic consumers, as an anaphylactic reaction can lead to death.

EFA pinpointed the risks involved in these emergency measures:

  • If general temporary derogations to the FIC Regulation are granted, substitute products containing allergens will enter the EU without requirement for labelling changes.
  • Adhesive labels and inkjet printing, adopted by many national authorities as temporary solutions, might prevent consumers from readily detecting allergen ingredients, as well as other useful food information.
  • Communicating changes only in the physical or online stores may undermine access to information: physical labelling in the store can be easily overlooked; while online information requires a certain level of digital literacy, a device and the availability of internet access.

Given that food allergen labelling constitutes a public health and food safety issue, EFA calls for a response to the situation according to the principles of the EU FIC Regulation 1169/2011:

  • Publish a notice addressed to national food safety authorities requiring that any ingredient change implying allergens should be compliant with the EU law, encouraging them to increase their vigilance in case of unclear information and non-declaration of allergenic oils and fats, and alert consumers about these changes.
  • Urgently adopt a harmonised EU-wide approach for the use of adhesive stickers (a specific symbol or logo) on the front of the pack, indicating a recipe change relevant to allergens. 
  • Monitor the scope and volume of food products that will change composition if replacing sunflower oil to help understand the impact from the consumer and industrial perspectives.

You can find the full EFA letter here.