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06 October 2022
Food Allergy
PREVENT, - Food Safety

In July, EFA addressed to the European Commission DG SANTE a letter highlighting reports on accidental contamination of soy lecithin with peanut protein that emerged in Germany, Spain and Italy. The cases became public via notifications of the EU Rapid Alert System for Food and Feed (RASFF), the main EU tool that facilitates information-sharing among Member States in case of existing or imminent risks.

Beyond the reporting countries, the three cases involved up to 63 countries in five continents. Moreover, the cases prompted action by national authorities, not only in the three initial countries but also in others such as France and Romania. Their responses were accompanied by risk assessment at the national level and ranged from public alerts to product recalls.

Now, the scientific community, the food allergy patient groups and some national authorities have validated a quantitative approach to assess the true risk of allergens present in food.

EFA calls for the right balance between risk minimisation and protection of consumer choice

In our letter, EFA stressed that it is not justifiable to take drastic actions such as recall (often linked to food waste), or impose the re-labelling of food just because it may contain a minuscule amount of allergens, sometimes in levels even lower than level of detection of the analytical methods and, in any case, harmless.

Importantly, despite the RASFF notifications, no allergic or otherwise adverse reaction was reported among the population. However, as we have seen in the past, unjustified alerts often lead to abuses of PAL labelling and the unnecessary limitation on food choices for allergic consumers.

EFA calls for harmonised risk assessment and PAL rules

In our letter, we highlighted our concerns about the lack of a harmonised approach on risk assessment and classification, and of subsequent corrective measures. Moreover, we reiterated our call for detailed rules regarding the use of voluntary information such as Precautionary Allergen Labelling (PAL), in line with its commitment in the 1169/2011 Regulation on Food Information to Consumers. Since zero risk is impossible, we urged the Commission to do everything to ensure risk minimisation, while safeguarding consumer choice.

Response of the European Commission

In its response, DG SANTE acknowledged EFA’s concerns. Regarding the inconsistencies in risk classifications among Member States, the Commission stressed that it is for the country to determine the appropriate risk management measures to be implemented in such cases. For EFA perspective though, the European Commission also has a competency and a role to ensure public health.

The Commission gave reassurance that its actions consider first and foremost the interest of consumers with food allergies and in particular of the almost 10% of food allergic people who may have acute anaphylactic reactions that could be fatal to their lives.

In relation to PAL, DG SANTE underlined that it is awaiting progress on this work at the Codex Alimentarius Commission, which is ongoing.

Read the EFA letter to the Commission on soy lecithin, and the Commission response.