Armelline almond and nutmeg, are these allergenic ingredients? Their names are a serious clue, and it is imperative that clarity be provided.
La
nuts
is often evoked, in the list of ingredients, among the substances that the food ‘
may contain
‘. In manifest violation of EU Regulation 1169/11, where the exact reference to individual nuts is instead required. (1)
‘In thecase of nuts, the specific type listed in Annex II(8) must be indicated in the list of ingredients, namely almonds, hazelnuts, walnuts, cashew nuts, pecans, Brazil nuts, pistachios, macadamia nuts or Queensland nuts.’ (2)
Armellina-sometimes incorrectly referred to as ‘almond’-is instead the seed found inside the kernel of apricots and peaches. (3) Although armellins are sometimes added to almonds to give the doughs of some preparations (such as macaroons) a characteristic bitter taste, they belong to a different botanical species. (4)
Nutmeg in turn is the hulled seed of Myristica fragrans, family Myristicaceae, an evergreen tree native to the Moluccan Islands (Indonesia). Despite the partial homonymy, nutmeg is nothing like the common walnut, fruit of the tree Juglans regia, family Juglandaceae.
In labeling.
, armelline and nutmeg must be indicated in the
ingredients list
without graphic evidence (as required for almonds and walnuts). Precisely because they are not on the exhaustive list of ‘
substances or products causing allergies or intolerances
‘ referred to in Annex II of EU Regulation 1169/11.
‘
Spices
That do not exceed 2% by weight of the product’, including nutmeg, may among other things be designated by the category name ‘spices‘ o ‘mixture of spices‘ rather than by their specific designation. (5)
Allergic consumers to individual spices must therefore refrain from consuming any product that even refers to the‘spice‘ category. For more information on allergen labeling and related penalties-administrative and criminal-we refer to our ebook ‘1169 penis. Food news, inspections and penalties‘, on https://www.greatitalianfoodtrade.it/libri/1169-pene-e-book-gratuito-su-delitti-e-sanzioni-nel-food.
Dario Dongo
Notes
(1) Cf. reg. EU 1169/11, Articles 9.1.c and 21, Annex II. Just as much precision is required in the U.S. by the Federal Food, Drug and Cosmetic Act, Chapter IV, Section 403 (w) (2), as specified in the FDA Guidance at Section 201 (qq). See https://www.fda.gov/ForIndustry/FDABasicsforIndustry/ucm238807.htm
(2) See EC guidelines 13.7.17 on ‘Provision of information on substances or products causing allergies or intolerances listed in Annex II of Regulation (EU) No. 1169/2011 on the provision of food information to consumers‘, Section 3.1.13
(3) In the Venetian dialect, from which this name comes, armellino actually means apricot tree (in botany, Prunus armeniaca, family Rosaceae)
(4) The almond tree is Prunus dulcis, which also belongs to the Rosaceae family-as do most common fruit trees-but is clearly distinguished from apricot and peach
(5) See reg. EU 1169/11, Annex VII, Part B, point 7
Dario Dongo, lawyer and journalist, PhD in international food law, founder of WIISE (FARE - GIFT - Food Times) and Égalité.
