Published on October 4, 2007
Food Allergen Labeling Making the ChangeJanuary 25, 2005: Food Allergen Labeling Making the Change January 25, 2005 Michelle Albee Matto Manager, Regulatory Affairs International Dairy Foods Association Food Allergens: Food Allergens Fact and Fiction of Food Allergies Food Allergen Labeling and Consumer Protection Act of 2004 Labeling Exercise Type of Sensitivities to Foods: Type of Sensitivities to Foods Non-immunological Idiosyncratic reactions Metabolic food disorders Immunological Idiosyncratic Reactions: Idiosyncratic Reactions Food Symptom Chocolate Migraine Headaches Tartrazine Asthma Sulfiting Agents Asthma Food Colors Hyperkinesis MSG Various Symptoms Metabolic Disorders: Metabolic Disorders Food component has an unusual effect on host’s normal metabolism Unable to metabolize a food component Lactose intolerance Deficiency of intestinal lactase Symptoms: abdominal pain, flatulence, diarrhea Ultimately affects 60-90% in some ethnic groups Immunological Sensitivities: Immunological Sensitivities Celiac disease (celiac sprue) Symptoms: malabsorption Wheat, rye, barley, triticale and sometimes oats True food allergy Production of specific antibodies Antibodies cause a release of cellular chemicals which produces allergic reaction Persons Reporting Food AllergyFood Allergy Center, 1998: Persons Reporting Food Allergy Food Allergy Center, 1998 Food % Individuals Dairy 40.1 Seafood 21.9 Vegetables 19.9 Fruits 19.7 Chocolate 11.1 Nuts 8.8 Meat/Poultry 6.7 Wheat 3.7 Spices 2.0 Sugar 1.7 MSG 1.7 Food dyes 1.6 Alcoholic beverages 1.6 Sulfites 1.5 Prevalence of True Food Allergies: Prevalence of True Food Allergies Infants 4-6% Young children 1-2% Adults <1% Slide9: 90% Peanut Tree nuts Milk Egg Soy Fish Shellfish Wheat 10% Hundreds of others Food Allergies Prevalence How Consumers Manage a Food Allergy: How Consumers Manage a Food Allergy Avoid offending food Label education and diligent reading Brand loyalty Food Allergen Labeling and Consumer Protection Act of 2004: Food Allergen Labeling and Consumer Protection Act of 2004 Food Allergen Labeling and Consumer Protection Act: Food Allergen Labeling and Consumer Protection Act Signed into law by President Bush in August 2004 Labeling must be implemented by January 1, 2006 (products packaged on or after January 1, 2006) Food Allergen Labeling and Consumer Protection Act: Food Allergen Labeling and Consumer Protection Act Must label ingredients that contain protein from the major food alllergens: Milk Eggs Fish Crustacean shellfish (e.g., shrimp) Wheat Peanuts Soy Tree nuts (e.g., walnuts) Must use plain English name of allergen For fish, shellfish or tree nuts, use specific species name (e.g., cod, crab or hazelnut) Must label allergenic ingredients, even if usually exempted from declaration (e.g., incidental additive) Food Allergen Labeling and Consumer Protection Act: Food Allergen Labeling and Consumer Protection Act Two methods of labeling “Contains” statement immediately adjacent to ingredient statement. Example: “Contains milk, egg and wheat” Follow allergenic ingredient in ingredient statement with name of allergen in parentheses. Exemptions: if allergen name already appears in name of ingredient (milk chocolate) or appeared earlier in ingredient statement Example: “Milkfat and nonfat milk,… flour (wheat),…natural flavor (soy)” Food Allergen Labeling and Consumer Protection Act: Food Allergen Labeling and Consumer Protection Act CURRENT LABEL Ingredients: skim milk and milkfat, sugar, flour, brown sugar, eggs, butter, soybean oil, chocolate liquor, coconut oil, vanilla extract, cocoa, guar gum, salt, cocoa butter, lecithin, carageenan and natural flavors. *Per supplier, natural flavor contains walnut Food Allergen Labeling and Consumer Protection ActNew Label(Use one of two options): Food Allergen Labeling and Consumer Protection Act New Label (Use one of two options) Ingredients: skim milk and milkfat, sugar, flour (wheat), brown sugar, eggs, butter, soybean oil, chocolate liquor, coconut oil, vanilla extract, cocoa, guar gum, salt, cocoa butter, lecithin (soy), carageenan, natural flavors (walnut). Ingredients: skim milk and milkfat, sugar, flour, brown sugar, eggs, butter, soybean oil, chocolate liquor, coconut oil, vanilla extract, cocoa, guar gum, salt, cocoa butter, lecithin, carageenan and natural flavors. Contains: milk, wheat, eggs, soybean and walnut. Food Allergen Labeling and Consumer Protection Act: Food Allergen Labeling and Consumer Protection Act Points to remember Under the law, highly refined oils are not considered allergens If declaration is required under NLEA regulations, the oil must still appear in ingredient statement. But, the oil does not have to be labeled as allergens. Ingredients can be exempted from allergenic status by petition or FDA determination No minimum level of allergen required for labeling Law is silent on issue of “may contains” and similar advisory statements Food Allergen Labeling and Consumer Protection Act: Food Allergen Labeling and Consumer Protection Act According to the new law, FDA must Report on allergen inspections Develop regulations for “gluten free” labeling Research “may contain” labeling Food Allergy Issues Alliance: Food Allergy Issues Alliance Food Allergen Labeling Guidelines Used as industry guidance for labeling Updating to reflect requirements of new law Criteria for “may contain” statements Available on IDFA website Food Allergen Labeling Guidelines: Food Allergen Labeling Guidelines Supplemental Allergen Statements Use “may contain” or other notation judiciously and ONLY where all four criteria are met In situations where Presence of allergen is documented Presence is unavoidable when GMP’s are followed Presence is sporadic – in some product but not all Potentially hazardous Not a substitute for GMPs Voluntary Industry Activities: Industry Activities IDFA Web Information www.idfa.org Guidance for the Dairy Industry for Controlling Cross Contamination and Proper Labeling of Food Allergens - 2003 Personal Assistance on Labeling Questions Labeling Exercise: Labeling Exercise Peanut Butter Cup Milk: Peanut Butter Cup Milk Ingredients: Reduced fat milk, sugar, cocoa (processed with alkali), peanut butter syrup (high fructose corn syrup, peanut butter, natural flavors), dextrose, corn starch, carrageenan, vitamin A palmitate, vitamin D3. Blueberry Yogurt: Blueberry Yogurt Ingredients: Cultured pasteurized Grade A lowfat milk, sugar, blueberries, nonfat milk, high fructose corn syrup, modified corn starch, natural flavor, gelatin, citrate and phosphoric acid. Sundae Cone Ice Cream: Sundae Cone Ice Cream Ingredients: milkfat and nonfat milk, sugar, fudge swirl (sugar, skim milk, corn syrup, cream, water, cocoa processed with alkali, bitter chocolate, modified tapioca starch, sodium alginate, natural flavor, salt), chocolaty coated peanuts (peanuts, sugar partially hydrogenated palm kernel oil, cocoa processed with alkali, salt, lecithin, natural flavor), chocolaty dipped waffle cone pieces (chocolaty coating [powdered sugar (sugar, corn starch), coconut oil, cocoa processed with alkali, cocoa, butter oil, salt, lecithin, natural flavor], waffle cone pieces [flour, sugar, soybean oil, salt lecithin, coconut oil]), corn syrup, natural flavor, cellulose gum, mono and diglycerides, guar gum, carrageenan, annatto color, dextrose. Garden Vegetable Cheese Spread: Garden Vegetable Cheese Spread Ingredients: Cream Cheese and Neufchatel Cheeses (Pasteurized Milk and Cream, Cheese Cultures, Salt, Carob Bean Gum), Soybean Oil, Water, High Fructose Corn Syrup, Vinegar, Dehydrated Vegetables (Bell Peppers, Carrots, Onion, Celery), Modified Food Starch, Egg Yolk Solids, Salt, Hydrolyzed Corn and Wheat Gluten, Monosodium Glutamate, Dextrose, Sorbic Acid (to Protect Flavor), Xanthan Gum, Spices, Garlic, Natural Flavor, Mustard Flour, Calcium Disodium EDTA (Protects Flavor) QUESTIONS ?: QUESTIONS ?