18 February 2008 - On 30 January 2008, the European Commission adopted a proposal to make food labels clearer and more relevant to the needs of EU consumers.
The draft proposal aims to modernise and improve EU food labelling rules, so that consumers have, in a legible and understandable manner, the essential information they need to make informed purchasing choices. Under today's proposal, pre-packaged food will have to display key nutritional information on the front of the package, the European Commission said.
"Food labels can have a huge influence on consumers' purchasing decisions. Confusing, overloaded or misleading labels can be more of a hindrance than a help to the consumer. Today's proposal aims to ensure that food labels carry the essential information in a clear and legible way, so that EU citizens are empowered to make balanced dietary choices," the EU Commissioner for Health, Markos Kyprianou, said a few weeks ago as reported on FLEXNEWS.
The EU, however, also proposes that all food containing allergenic substances (such as peanuts, milk, mustard or fish) must be labelled or the presence of the allergen must be clearly indicated in another way. This is one step further than the current allergen labelling requirement, which only covers pre-packed food at the Community level.
Under the new rules, unpackaged food and food served by restaurants or catering establishments will also have to indicate the presence of allergens, to better protect those who are susceptible to reactions to such products.
Each year, millions of people across the world have allergic reactions to food. Although some food allergies cause mild and minor symptoms, others can cause severe reactions, and may even be life-threatening.
There is no cure for food allergies. Strict avoidance of food allergens — and early recognition and management of allergic reactions to food — are important measures to prevent serious health consequences.
Baring this in mind, the food industry considers food allergens as one of its most significant food safety challenges.
A few days after the adoption of the EU proposal (2 February 2008), food allergen experts gathered at a round table in Milan, Italy. The event was organized by Allegria, an Italian non-profit organization devoted to supporting research in the field of allergy and asthma.
The attendees discussed whether current laws are going in the right direction or whether another approach is needed.
At the round table, a consensus appeared to exist that, to make the EU legislation actually beneficial for consumers, something should be done about precautionary labelling.
Unclear Labels?
Precautionary labelling can be complicated and consumers may be confused, say some experts.
Luca Bucchini of Hylobates Consulting, based in Rome, talks about a survey carried out in Italy, which showed that consumers are misled with allergen statements labelled on food products. The use of “may contain”, “may contain traces of”, “produced in an establishment that also utilises...” all mean the same thing, but consumers perceive them differently.
The survey demonstrated that 85% of consumers tended to avoid ‘”may contain” statements, but 20% of them would buy products labelled as “produced in an establishment that also”, which they believe is less risky.
Moreover, says Bucchini, “products with “may statements” may contain allergens in some lots, while other lots might be allergen free: therefore, testing the product once, by small bits, may not be indicative of safety”.
Dr. Giuseppe De Giovanni, a leading expert in food labelling and a veteran of EU regulatory committees, goes on to say that a “may contain” statement almost suggests inadequate HACCP procedures.
“There is no legislation requiring precautionary labelling”, argues Dr. De Giovanni.
“What should the clinician’s advise be to parents who ask about a food without milk, but that bears the “may contain” statement?” asks Professor Alessandro Fiocchi, food allergist and head of paediatrics at the “Macedonio Melloni” Hospital in Milan.
“Our advice to parents of allergic children is no doubt to avoid foods with “may contain” statements if they refer to an allergen of concern,” replies the professor.
According to Patrizia Restani, a professor at the University of Milan, the most confusing statement for the allergic consumer, is the “without added egg” claim with the accompanying precautionary labelling “produced in an establishment which also utilises eggs”.
Both claims seem to contradict each other, but food industry representatives argue that they are on the contrary quite clear.
“Both statements are true, in fact” says Marco Trezzi on behalf of baby food manufacturer Plasmon (part of Heinz). “There is no egg in the product, but perhaps eggs are used somewhere else in the plant. Perhaps only in the canteen”
“Precautionary labelling is a matter of responsibility” claims Franco De Marchi, a scientific consultant working for Galbusera, a leading Italian bakery products firm.
”We are making sure that our products are actually allergen-free investing in specific HACCP procedures, validation of testing methods and clinical trials. We are almost there, but, until then, we have to be responsible”
Analytical Test Improvement Urged
“The way forward has to be more than a continuous improvement in the sensitivity of analytical tests” says Professor Restani.
She argues that progress in testing methods is needed but, without thresholds, this may backfire against food industry and, most importantly, against patients themselves.
“The problems for the food industry are real and establishing thresholds is important, but it will be difficult. Perhaps, at least for now, we need a more practical approach”
Currently, only Australia and New Zealand have established provisional thresholds. However, most believe evidence is still insufficient.
Food industry experts agree that specific strategies, which include analytical testing, have been needed both for producers of common foods and of dietetic products.
As for the food manufacturers, Dr. Restani insists on a laboratory and clinical protocol to ‘certify’ allergen-free foods. In other words, she argues that a priority for the producers would be to provide laboratory and clinically-certified allergen-free foods on the market.
Food Manufacturing and Cross-Contamination
Another issue of concern at the roundtable was cross-contamination during production, which is not explicitly covered by EU directives, claim the experts.
In Plasmon’s case: “We have specialised food plants for special products but egg and milk are such common ingredients that we may need to process them on the same establishment,” says Marco Trezzi.
Trezzi believes, however, that dietary food companies are in a more favourable position for the application of new rules on allergens because they often have separate facilities devoted exclusively to the production of special foods.
According to Dr. Luigi Terracciano, a paediatrician and a food allergen HACCP expert, Italian school canteens face legal hurdles and are overloaded with parents’ requests related to pseudo-allergies.
He argues: “solutions are possible, but very complex. For increasing the safety of the allergic consumer, priorities may not be obvious”.
In his presentation, he demonstrates why: “All critical points for the preparation of school meals are analysed to define rules and procedures appropriate to prevent accidental administration of food "forbidden" to allergic children. It is necessary to assess the selection of raw materials, supplies, contamination, errors storage, and preparation, distribution, serving and allocating special meals to individual child recipients. Almost all these procedures are collected in the HACCP manual which is a responsibility of the catering company, while aspects of serving and assignment of the specific meals prepared for an allergic child can sometimes be a matter for the school staff and therefore fall under the direct control of the individual school. Once the process is under control in its organizational aspects, identified and individualized for each child and for each allergy, a safe diet can be realized every day, at any time. This is complex, which requires human resources and is often put to the test by the overload of requests from parents. In many cases, unfortunately, they are not motivated by true allergies but by the tastes of their children and they also find the complacent attitude of paediatricians and nurses, certifying to the diet”.
Meanwhile, Professor Fiocchi goes on to say that the “presence of allergens can trigger severe reactions in infinitesimal quantities; food businesses must make labels more complete and more understandable. Useful, but not required, is the indication of traces resulting from cross-contamination: "may contain traces of ...". There are already efforts made by some companies that have products labelled "contains no added ..." while referring strictly to the product formula (these endorsements are absolutely voluntary decisions by companies to avoid any legal action; they can be informative but also misleading if not regulated). Does it go towards better protection of the child from allergies? Maybe yes, but it doesn’t eliminate the need to take precautions such as gradually testing products from the market (although apparently safe) at least to verify the safety of the recipe”.
Some Propositions
The experts came up with some propositions to simplify labelling laws.
Limiting and harmonising precautionary labelling, introducing harmonised graphical warning signs, more investment in allergen-free foods were some of them.
They also agreed, in general, that associations of allergic people should work more together, taking action not only at the national level, but also at the European level.