EU Food Information for Consumers Regulations: What you need to know about food allergen labelling

1. EU FOOD INFORMATION FOR
CONSUMERS REGULATIONS
WHAT YOU NEED TO KNOW ABOUT
FOOD ALLERGEN LABELLING

2. The symptoms can include:
• rashes (usually very itchy)
• tingling sensation in the
mouth
• swelling of the lips,
tongue, face and throat
• difficulty breathing
• diarrhoea
• vomiting
• abdominal cramps
• and on rare occasions
anaphylaxis
The impact of food allergy

3. Key facts
1.92m people have food allergy in the UK (based on
population of 63.1m). This figure excludes food
intolerance.
Estimated: 4,500 hospitalisations between 2011-­12
and 10 deaths, due to food allergies and eating out.

4. No cure for allergy!
You must avoid what makes you ill
üRead ingredient labels
üLook out for hidden allergens

5. Food labelling is changing
• Moving from General Labelling (2000/13/EC) to Food
Information for Consumers Regulation (1169/2011/EC)
• Regulation 1169/2011 entered into force on 13
December 2011
• From 13 December 2014 new rules on allergen
labelling shall apply
• Existing requirements for pre-­packed foods are
retained – but new requirement to emphasise
allergenic foods in the ingredients list
• Introduction of new requirement to provide allergy
information for unpackaged foods
• Criminal sanctions for breaches in food allergen
provisions – food safety

6. Scope of the Regulation
• Covers business operators at all stages of food chain
concerning provision of information to consumers:
Ø Food intended for the final consumer
Ø Foods delivered by mass caterers
Ø Foods intended for supply to mass caterers
• Also applies to catering services provided by
transport leaving from the EU Member States
Ø airline catering
Ø Trains, ships…

7. Article 9 Mandatory particulars
• Article 9(1)c -­ Any ingredient or processing aid listed in
Annex II, or derived from a substance or product listed
in Annex II causing allergies or intolerances, used in
the manufacture or preparation of a food and still
present in the finished product, even if in an altered
form
• Article 9(2) -­ The specified allergenic foods to be
indicated with words and numbers -­ they may
additionally be expressed by means of pictograms or
symbols

8. Annex II: ‘The Big 14’
Cereals containing gluten
Crustaceans
Eggs
Fish
Lupin
Milk
Molluscs
Mustard
Nuts
Peanuts
Sesame seeds
Soya
Sulphur dioxide
Celery

9. Article 12 -­ 13 Clarity and Legibility
• For prepacked foods, mandatory information to appear directly
on the package or on a label attached to it
• Mandatory food information to be available and easily
accessible for all foods
• Mandatory information to be marked in a conspicuous place, be
easily visible, clearly legible and, where appropriate, indelible. It
should not be hidden, obscured, detracted from or interrupted by
other written or pictorial matter
• To ensure clear legibility, use characters with a font size where
the x-­height is at least 1.2mm
• In the case of packaging or containers, the largest surface of
which has an area of less than 80 cm2, the x-­height of the font
size to be at least 0.9mm

10. Article 21 of the FIC
• Allergens declared in the list of ingredients with a
clear reference to the name of the substance or
product as listed in Annex II
• In the absence of a list of ingredients, allergens to be
declared using a ‘contains’ statement followed by the
Annex II.food
• If the product contains the allergen in more than one
form then all forms of the allergen should be indicated
• If the name of the food clearly refers to the substance
or product concerned and there is no ingredients list
there is no need for a contains statement

11. How a label can change

12. What’s on a label? – prepacked food

13. Distance selling
For food offered for sale online, by telephone
or catalogue etc, mandatory food allergen
information to be made:
• available before the purchase is
concluded (i.e. appearing on material
supporting the distance selling or other
appropriate means clearly identified by
the food business operator)
• available upon delivery in writing (eg.
stickers on takeaway food containers)

14. Article 36 Voluntary information
• The Commission has option to introduce new rules
on the following voluntary information:
Ø ‘information on the possible and unintentional
presence in food of substances or products
causing allergies or intolerances’
• Precautionary allergen warnings (“may contain”) can
still be used
• Permits the introduction of agreed phrases or
allergen reference doses for the accidental presence
of allergens in prepacked foods

15. Article 44 non-­prepacked food
• A new requirement for allergen ingredients
information to be provided for non-­prepacked foods
and food provided prepacked for direct sale
• Foods are offered to sale to the final consumer or to
mass caterers without prepackaging, or where foods
are packed on the sales premises at the consumer’s
request or prepacked for direct sale, the provision of
the information about allergenic ingredients is
mandatory
• The UK has introduced a national measure to enable
to provide this information orally

16. Article 44 –non-­prepacked foods
• Oral information must be indicate clearly that such
information can be obtained upon request.
• Oral information must be accurate, consistent and
verifiable upon challenge
– Is there a process in place to enable consistent
information to be provided? Refer queries to the
nominated person(s)
– Verifiable ingredients information on a chart, recipe
book, ingredients information sheets, scrap books
with labels

17. Article 44 –non-­prepacked foods
• Could declare allergen ingredients information
through a contains statement, charts, tables etc.
– i.e. chicken tikka masala – Contains: milk,
almonds (nuts)
• Consider Article 12 and 13 on accessibility of
mandatory information -­ Marked in a conspicuous
place, easily visible, clearly legible
• Signposting is required when information is not
provided written and upfront. It should be where
consumer would expect to find allergen information
e.g in a folder, on menu board, at till or on the menu
card

18. Signposting to allergen info (example)

19. Providing allergen information

20. Article 44 – non-­prepacked food
• How are dietary requests communicated from front to
back of house? e.g. use of chef cards, order tickets,
receipts
• Preparing foods for allergic consumers-­ what process
is in place
• Do you use Safer Food, Better business (SFBB)
“Safe Method: Allergy”?
• Are you making specific claims i.e. gluten free
– How this claim is verified or validated
– Would no gluten containing ingredients (NGCI)
statement be better? – more factual rather than
attributed to a set level

21. Regular reviews, keep it current
Food businesses need to have processes in place to
ensure the information they provide is accurate
• Regularly review the ingredients information
• Where ingredients change, review the accuracy of
the recipe
• Do your garnishes or dressings change the
allergenic profile? Check!

22. Communication is key
Accuracy is dependent on correct labelling, updating
allergen information, updating staff and consumers
• The person buying the food
• The person handling the food
• The person taking the order
• The person ordering the food

23. Communication is key
• Engage with serving staff
• Extra precautions can be made
• Recipes change
• Ingredients change

24. Communicating the changes
• Joint messaging, conferences, workshops and
training
• Engagement with our interested parties
• Speaking at conferences, seminars and
exhibitions, articles for trade publications etc
• Food allergen information and updates
(consumers and for food businesses) on the
regulation can be obtained from:
http://www.food.gov.uk/policy-­
advice/allergyintol/label/

25. Communications
Joint messaging
Consumer leaflet and Chef Cards
Allergy Awareness Week (28 April – 4 May 2014)

26. E-­ learning
Access free training on:
http://allergytraining.food.gov.uk/

27. http://multimedia.food.gov.uk/multimedia/pdfs/
publication/foodallergies-­sfbb-­0513.pdf
SFBB – allergy safe method

28. http://multimedia.food.gov.uk/multimedia/pdfs/publication
/thinkallergy.pdf

29. Supporting businesses – non-­
prepacked
Developed in collaboration with
food industry and consumer
support organisations
http://multimedia.food.gov.uk
/multimedia/pdfs/publication/
loosefoodsleaflet.pdf

30. Supporting businesses –
prepacked food
http://multimedia.food.gov.uk/
multimedia/pdfs/publication/all
ergy-­labelling-­prepacked.pdf

31. Further information
• FSA allergy pages (guidance, advice, leaflets on allergen
labelling: www.food.gov.uk/business-­industry/allergy-­guide
• Allergy E-­learning http://allergytraining.food.gov.uk/
• Allergy resources, templates, posters, leaflets:
www.food.gov.uk/allergen-­resources
• Safer Food Better Business for Caterers – Food allergies
www.food.gov.uk/multimedia/pdfs/publication/foodallergies-­sfbb-­
0513.pdf
• General FIR information to be found on GOV.uk
• Consumer advice
http://food.gov.uk/multimedia/pdfs/publication/allergy-­leaflet.pdf
• BRC-­FDF guidance for prepacked foods
www.brc.org.uk/downloads/Guidance%20on%20Allergen%20Lab
elling.pdf

32. Guidance on new allergen rules
FSA technical guidance –
www.food.gov.uk/news-­updates/news/2014/6140/
sme-­allergen-­guidance
European Commission guidance –
http://ec.europa.eu/food/food/labellingnutrition/foodlabell
ing/proposed_legislation_en.htm

33. Further assistance
FSA Website
http://www.food.gov.uk/science/allergy-­intolerance/label
Allergens enquiries mailbox
FoodIntoleranceEnquiries@foodstandards.gsi.gov.uk
Please join the conversation on Twitter
food.gov.uk/twitter #14Allergens

34. and finally…
ü Speak to colleagues
ü Share knowledge
ü Develop good working practices