Thursday 28 August 2008

Food Labelling - Ingredient listing and allergens summary of responses

Thursday 21 March 2002

Summary of responses to public consultation

RESPONSES RECEIVED FROM:

Consumers and Consumer organisations
Campaign for Real Ale
Consumers’ Association
Euro Coop (European Community of Consumer Co-operatives)
Foodaware: Consumers’ Food Group
General Consumer Council (Northern Ireland)
Institute of Consumer Sciences
Mr M Thornett-Roston
Mrs L Anderson
Mrs V Revill
Ms A Holland
National Council of Women of Great Britain
Sustain

Support and other groups
Allergy Alliance
Anaphylaxis Campaign
Baha’i Community of the UK
Birmingham Children’s Hospital
British Dietetic Association
British medical Association (Scottish Office)
British Nutrition Foundation
Galactosaemia Support Group
Institute of Food Research
Institute of Food Science and Technology
Latex Allergy Support Group
Law Laboratories Ltd
Margaret Anderson and Associates, Consultants
Royal College of Nursing (Scotland)
Royal College of Paediatrics and Child Health
Scottish Centre for Infection and Environmental Health

Industry
Biscuit, Cake, Chocolate and Confectionery Alliance
Brewers’ and Licensed Retailers’ Association of Scotland
British Beer and Pub Association
British Essence Manufacturers Association
British Meat Manufacturers’ Association
British Sandwich Association
British Soft Drinks Association
Co-operative Group
Fishmongers’ Company
Food Additives and Ingredients Association
Food and Drink Federation
Gin and Vodka Association of Great Britain
Glenryck Foods
Health Food Manufacturers’ Association
Hotel and Catering International Management Association
Ice Cream Federation
Leatherhead Food Research Association
Meat and Livestock Commission
Marks and Spencer
National Farmers’ Union
Northern Ireland Dairy Association
Potato Processors’ Association
Scottish Federation of Meat Traders’ Associations
Tepnel BioSystems Ltd
UK Association of Frozen Food Producers
UK Vineyards Association
Unilever

Enforcers
Aberdeen City Council
Advertising Standards Authority
Chartered Institute of Environmental Health
LACOTS
North East Lincolnshire Council
Omagh District Council
Royal Environmental Health Institute of Scotland
Scottish Food Co-ordinating Committee
Trading Standards Institute

SUMMARY OF COMMENTS

Consumers and Consumer organisations

Generally welcome proposals
Consider it vitally important that allergic consumers can identify ingredients they need to avoid
Dose of food allergen required to induce immunological reaction is generally very low
Welcome abolition of the 25% rule
Consumers have a right to know, before making a purchase decision, about all the ingredients that comprise any given food
Opposed to new derogations, which will hide ingredients
Individuals can be allergic to any food
Allergies to certain spices have been reported; their presence in quantities of much less than 2% is significant to induce immunological reaction
Consumers are generally not aware of EU compositional laws and what they require or permit
Those consumers allergic or hypersensitive to ingredients not listed as allergens will be unable to select foods compatible with their dietary needs
Consumers may have ethical, religious or other reasons for avoiding ingredients/products
Listed allergens should be subject to regular review; there needs to be a procedure for updating the list of allergens quickly
See no advantage in listing ingredients making up less than 5% of the finished product in a different way to other ingredients
The "mutually substitutable" provisions may mislead; the either/or options for ingredient listing are not acceptable
All ingredients should be named, but only once: this will make ingredient lists more transparent
All ingredients of wine should be listed, not just the sulphites
Allergens should be listed for foods sold loose as well
Allergens should be highlighted in ingredients lists
Accidental contamination should also be tackled at European level

Support and other groups

Generally support the proposals
Support full ingredient listing of wines and all alcoholic drinks
Prefer to see all ingredients of foods listed
Generally opposed to proposed derogations, although some suggest they represent a reasonable compromise on the basis that they don't benefit allergens
Can't see the purpose of listing those ingredients present at less than 5% in a different order
Unhappy about the either/or derogations, which are seen as restricting choice
Listed allergens should be subject to regular review
Wheat allergy is not the same as gluten intolerance
Labelling of non-prepacked foods needs to be addressed as they are a major source of allergic reaction
Endorse efforts to identify measures to help allergy sufferers to select non-prepacked foods
The proposed list of allergens is inconsistent in its use of language: "…products" and "products thereof"
Issues around print size and legibility also need to be addressed
The use of latex in the food industry should be limited and natural rubber latex added to the list of allergens when used as a food ingredient (eg "gum base")
Tartrazine should be added to the list of allergens
Peas and pulses should be added to the list of allergens
Substances derived from ingredients listed as allergens which do not contain protein should not have to be listed as allergens

Industry

Proposals generally welcome, although some feel they are unnecessarily complex
Concerns that proposals would require labelling of ingredients no longer considered to be allergenic (food acids, sugars, glucose syrup, polyols, fully refined soya oil etc); suggest listed allergens should refer to "and products of these containing protein"
Suggestions that thresholds should be established for claims like "gluten free"
Concerns about the "warning" nature of the declarations on alcoholic drinks and suggestions that this could be better presented (eg as "produced from…")
Declaring the presence of allergenic starting materials as being present in alcoholic drinks when not allergenic could mislead; suggest fish products, like isinglass, may not be allergenic
All alcoholic drinks should be treated equitably; individual product sectors should not benefit from exemptions not applicable to other product sectors
Support suggested cut off level for sulphites
Difficult for catering businesses to ensure menu information is up to date, especially when these are produced for long periods of use, during which time the composition of foods supplied to caterers may change
Increasing the amount of information required to be given decreases the space available and, subsequently, text gets smaller and more difficult to read
Welcome the proposed timescale for making changes to labels
Need to retain the proposed new derogations
Proposal should address labelling of non-prepacked foods
The title of the list of allergens should refer to "foods and ingredients known to cause hypersensitivity", as not all of them will trigger proper allergic reaction
The listed allergens should specify the botanic names of the nuts and cereals intended to be included
At what stage is the sulphite level to be measured? It would be logical to do this at the consumption stage so that, if a product is cooked, the reduction in the level of sulphite due to cooking can be taken into account
Guidance will be needed on how the proposed list of allergens and their derivatives is to be listed in ingredients lists

Enforcement

Generally support the proposals
Suggest additional costs for enforcers unlikely to be substantial
Essential to keep the list of allergens up to date
Oppose proposed new derogations
Support full, comprehensive ingredient listing
Need to cover food sold in catering establishment
Main problems arise with non-prepacked foods
Consumers' needs should be paramount
Guidance will be needed on the 'similar/substitutable' provisions, if these are retained

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Food Labelling - Ingredient listing and allergens summary of responses

RESPONSES RECEIVED FROM:

SUMMARY OF COMMENTS

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