In response to growing consumer concerns over food allergens in a host of food products the European Commission last November amended Council Directive 2003/89/EC, amending Directive 2000/13/EC . This extends the requirement for ingredient listing, for pre-packaged foods, including alcoholic drinks, and aims to help those with food allergies to identify ingredients they need to avoid.
According to European allergy associations 8 per cent of children and 3 per cent of adults are affected in Europe by food allergies or food intolerance, with new allergens emerging on a regular basis.
"We are now in the process of implementing national rules," said the Scottish Food Standards Agency this week.
The Directive defines a list of 12 allergens as well as deleting the '25 per cent rule', whereby individual ingredients of a compound ingredient making up less than 25 per cent of the finished product currently do nothave to be listed.
The '25 per cent' rule was introduced into Community legislation more than 20 years ago in order to avoid inordinately long lists of ingredients and based on the principle that the consumer knows the composition of compound ingredients and can therefore deduce, for example, that jam added to biscuits is prepared with fruit and sugar.
Since this time, food production has become more and more complex, and people eat a lot more processed foods. Over the past few years, consumers have repeatedly expressed the wish to be better informed about the foodstuffs they purchase, and specifically about their composition, even if full ingredient labelling will inevitably make ingredient lists longer. Recent food safety scares have clearly reinforced this need for information.
Under the new rules, with the exception of certain minor derogations relating to compound ingredients made up of less than 2 per cent of the finished products, all ingredients will need to be listed. The derogations, which will not apply to the listedallergens, or to additives, are as follows: compound ingredients whose composition is defined in EU law (for example, jam andchocolate) need not list their ingredients.
Herbs and spices used in mixtures, need not be listed individually and ingredients will not have to be listed in descending order by ingoing weight.
The presence of similar or 'mutually substitutable ingredients' could be indicatedby use of "contains....and/or...".
According to the FSA the food industry has until 25 August 2004 to submit to the European Commission a list of ingredients derived from the listed allergenic foods which theybelieve are not allergenic - and therefore should be exempt from the requirement to label them as such - and which it has been scientifically established that it is not possible for them to cause adverse reactions.
After conferring - no later than the end of November this year - with the European Food Safety Authority, the Commission will adopt a list of those ingredients or substances which can be exempt.
The potential allergenic ingredients to be labelled are: cereals containing gluten and related products; crustaceans and products thereof; eggs; fish; peanuts; soybeans; milk and dairy products (including lactose); nuts and nut products; celery; mustard; sesame seeds; sulphur dioxide and sulphites at concentrations of more than 10 mg/kg or 10 mg/litre.
If all goes according to plan, food manufacturers can expect to be brandishing the new labels by 2005. They have just a few years to absorb the additional labelling requirements and a brief transitional period to bring product labelling into line with the new provisions.