On the subject of allergen indication, a formal issue is raised by some quarters. Is it still possible to indicate ‘spelt‘ or ‘wheat,’ or should ‘wheat‘ be specified? It is also worth asking what the priorities are, for the protection of allergic and celiac consumers.
Wheat and its surroundings, EU Regulation 1169/11
The FIC regulations
(‘
Food Information to Consumers’)
stipulates the requirement to specify the specific nature of gluten-containing grains. (1) On the label of pre-packed and pre-wrapped food products, on the sales signs of food sold in bulk, as well as in the registers and menus of communities Who also serve food for free or charitable purposes. (2)
Annex II of the FIC regulations(Substances or ingredients causing allergies or intolerances), following amendment in 2014, clarifies the reference to the genus ‘wheat’ with regard to its species ‘spelt‘ and ‘khorasan‘ (also known as Kamut). Annex II of reg. EU 1169/11 reports the word ‘wheat‘. Without even mentioning, in the official Italian language text, its synonym ‘wheat‘.
‘Cereals containing gluten, vi z:
wheat (including spelt and khorasan wheat), rye, barley, oats
or their hybridized strains and derived products, except:
(a) wheat-based glucose syrups, including dextrose;
(b) wheat-based maltodextrins;
(c) barley-based glucose syrups;
(d) grains used in the manufacture of alcoholic distillates, including ethyl alcohol of agricultural origin.”
Spelt, what name?
The European Commission, in its own guidelines On consumer information on allergens, specifies that the word ‘wheat‘ must always accompany – or alternatively, replace – the terms ‘spelta‘ e ‘khorasan‘. (4)
The Brussels Language Services, moreover, made two glaring translation errors:
1) ‘spelt‘ was translated to ‘spelta‘ (and thus, Triticum spelta) instead of ‘spelt‘(Triticum dicoccum), instead mentioned in All. II to Reg. EU 1169/11,
2) the possibility of mentioning only the word ‘spelta‘, among the various options, instead of ‘spelta (wheat)‘ or ‘wheat‘ was also mentioned among the examples. (5)
The formal application of Regulation (EU) 1169/11 in its current text, in any case, requires adding the word ‘wheat‘, in parentheses after the proper name of the ‘spelt‘. Instead, common sense would suggest overcoming misunderstandings about the names of the various species and allowing the use in Italy of the designation classic and proper, spelt, to identify a grain whose identity in our country is known to all. All the more so to consumers with wheat allergies and celiac disease who know full well that they should avoid it.
Wheat, what name?
The case of wheat is even more unique. Since time immemorial, various species of wheat belonging to the genus Triticum, of the family Gramineae, have been cultivated and consumed in Italy. The most common species are T. aestivum-which includes T. vulgare, soft wheat-and T. turgidum to which T. durum, hard wheat, belongs.
The term ‘
wheat
‘ (from Latin ‘frumentum‘) is for all intents and purposes synonymous with ‘wheat.’ And it is indeed so referred to in every vocabulary of the Italian language, as well as in national norms. For example, Presidential Decree 187/01 specifies the possibility of using ‘wheat‘ in products other than bread and pasta. (6) And that is also why the word wheat still appears on the labels of various products, from cookies to beers.
Theoretically, the term ‘wheat‘ should be replaced with ‘grain.’ Specifying where appropriate whether it is soft wheat or hard wheat. Instead, common sense would suggest action on the Italian language version of EU Regulation 1169/11, with express provision for the possibility of using both names as synonyms.
Allergens, what priorities?
Allergic consumers to wheat as those with celiac disease are well informed of the unsuitability for consumption by them of foods and beverages containing ‘wheat‘ o ‘spelt‘. Thanks also to the information campaigns proposed by associations such as Food Allergy Italia – to which our free ebook ‘1169 penis. Reg. EU 1169/11, food news, controls and penalties
‘
– and AIC (Italian Celiac Disease Association).
.
The real problems that need to be addressed-to free allergy sufferers and those with celiac disease from the real risk of serious health hazards on every occasion of buying and serving food-are quite different:
– ‘
May contain …
‘.
(7) Labels, single-selling signs, menus and registers of public establishments redound with illegitimate and meaningless statements (in) about the possible presence of any and all allergens referred to in the fateful list in Annex II of the FIC regulations. In the absence of appropriate self-control procedures, instead prescribed by the name in food safety, (8)
– public establishments.
Information on the presence of allergens in individual dishes must be provided in writing, as prescribed in the European regulation and reiterated by the Ministry of Health
. But in fact they are lacking, or completely inadequate (for the reason given in the previous paragraph), in almost all cases. Widespread irresponsibility extends to superficial feedback to specific requests from allergic consumers, sometimes leading to anaphylactic shock with even fatal outcomes.
Dario Dongo
Notes
(1) See reg. EU 1169/11, Annex II
(2) See Regulation (EU) no. 1169/11, d.lgs. 231/17
(3) See reg. EU 2014/78, Art. 1
(4) Cf. European Commission communication 13.7.2017, ‘concerning the provision of information on substances or products causing allergies or intolerances listed in Annex II of Regulation (EU) No. 1169/2011‘
(5) See Section 3.1.9, at
https://eur-lex.europa.eu/legal-content/IT/TXT/?uri=CELEX3A52017XC12132801%29
. Spelt is actually one of the three species of spelt (Triticum monococcum, T. dicoccum e T.spelta). However, its name is unknown to most consumers, with the sole exception of ancient grain connoisseurs https://www.greatitalianfoodtrade.it/salute/grani-antichi-analisi-dei-superfood
(6) See Presidential Decree 187/01, ‘Regulations for the revision of the regulations on the production and marketing of flour and pastaproducts’
(7) See, in this regard, FISMA’s (International Foundation for Allergological Medical Sciences) petitions to the Ministry of Health and MiSE, still unfortunately unanswered, at https://www.foodagriculturerequirements.com/notizie/presenza-accidentale-di-allergeni-le-richieste-della-fisma-ai-ministeri/
(8) Failures in self-control, it is recalled, must be sanctioned by health authorities under Leg. 193/07, Article 6.6. See the articles https://www.greatitalianfoodtrade.it/etichette/controlli-il-ruolo-dellamministrazione-sanitaria/
,
https://www.foodagriculturerequirements.com/archivio-notizie/domande-e-risposte/etichette-prive-di-informazione-su-allergeni-quali-sanzioni_1
,
https://www.foodagriculturerequirements.com/archivio-notizie/domande-e-risposte/allergeni-tracce-e-sanzioni-risponde-l-avvocato-dario-dongo_1
Dario Dongo, lawyer and journalist, PhD in international food law, founder of WIISE (FARE - GIFT - Food Times) and Égalité.