Put simply, if one of the main allergens is found in the product, it must be declared on the label. This sounds simple, and it is, but its simplicity is the problem. There are very few qualifying rules here; this means that, generally speaking, the presence of any allergen, in any form, in any amount must be declared on the labelling. One would still think this a relatively simple task, but consider the number of suppliers any one food and beverage manufacturer may have. The allergen information of each supplied product must be noted and recorded; whenever that same product is moved around the facility, handled, set down, stored or used in manufacturing, there is the potential for some cross-contamination. It is easy to see the pressure that allergen control puts upon manufacturers.
And thus far we have simply talked about the control of allergen presence under normal circumstances. Suppliers may accidentally mislabel their products, allowing an allergen to pass through the quality control system unchecked. An employee may unintentionally transfer allergens from one production line to another. The labelling supplier may use an old version of the packaging. The Research and Development department may change an ingredient list without telling quality control. The list goes on.
Then there is the sheer number of ingredients currently identified as allergens. There are more ‘main’ allergens than you might think – 14 to be exact, in the UK. They range from the more obvious, such as crustaceans, fish, peanuts, soybeans, milk, nuts, sulphur dioxide / sulphates and molluscs, to less conspicuous ones, such as cereals containing gluten, sesame, lupin, mustard, celery and egg. Quite an array of things which carry such a low regulatory tolerance.
Whilst harmful pathogens and foreign matter tend to grab the headlines when it comes to food safety news, allergens have accounted for over half of the Food Standards Agency recalls in the last three years. Just looking back to November 2017, there were no recall notices issued due to any other food safety issues in the UK… but there were thirteen for allergen mislabelling.
CFC’s recall cover offers protection for food manufacturers from the costly implications of an error in their allergen controls. With the increasingly prevalence of allergies, the risk to manufacturers of allergen mislabelling is becoming a severe one.
