Allergen labeling continues to be unclear, often outlawed, causing serious health risks to consumers with food allergies and intolerances.
These conclusions are reached in a very recent study by Utrecht University that measured the (lack of) effectiveness of precautionary statements on prepackaged food labels. (1)
Allergen labeling, there is a loophole
The Food Information Regulation (reg. EU 1169/11), like the so-called allergen directive (dir. 2003/89/EC), requires the specific indication on the label of the presence of one or more of the 14 categories of allergenic substances and ingredients listed in its Annex II (see image). With graphic evidence-for example, in capital and/or bold and/or underlined font-to the key word identifying each allergen, in the ingredient list. (2)
Precautional Allergen Labeling (PAL) is, in turn, used to alert consumers to the possible presence in the product of certain allergens that were not deliberately placed there (e.g., ingredients, additives) but may have resided there due to cross-contamination (environmental and process).
The lightning rod of precautionary labeling
The unacceptable lack of clear requirements on how to formulate the precautionary warning, in EC guidelines, has encouraged the spread of three different approaches to precautionary labeling on the possible presence of allergens:
– ‘may contain allergen X‘. And this is the only permissible indication, as noted, (3)
– ‘may contain tracesofallergen X‘,
– ‘made in a plant that also processes allergen X.’
Even more serious is the designation of allergens through category names not allowed by Regulation (EU) No. 1169/11 (All. VII, Part B), rather than by their specific names. E.g.‘nuts with shell‘ instead of walnuts, almonds, hazelnuts, etc. But also ‘gluten-containing grains‘ instead of wheat, barley, rye, oats and their hybridized strains.
Allergen labeling, the Utrecht study
The study conducted at the University of Utrecht (Netherlands) measured the effectiveness of allergen labeling on 18 prepackaged foods. The researchers developed dummy samples, with fancy brands not on the market, in order to prevent conditioning related to previous consumption experiences.
The sample consisted of 238 individuals over-16, with and without diagnosed food allergies, asked to shop for a person with a food allergy.
Allergen labeling unclear to 1 in 2 consumers
The results of the study are alarming. Approximately 50% of allergic and nonallergic participants expressed uncertainty about allergen information.
The statement‘May contain allergen X‘, predictably, scored highest for comprehensibility.
The phrase‘made in an establishment that also processes allergen X,’ on the other hand, is understood as indicating a lower risk than the other two locutions in use. A dangerous underestimation, because inadvertently contaminated prepackaged foods can contain significant levels of allergenic proteins and pose high risks to allergic consumers.
Confusion and underestimation of risk
A serious critical issue that emerged in the Utrecht study is the different perception of food safety risk, between allergic and nonallergic individuals.
Paradoxically, nonallergic consumers express more caution and also consider the absence of any indication of the possible presence of allergens to be problematic. Allergic consumers who participated in the study, conversely, came to underestimate some precautionary warnings.
Review and danger of food allergies
‘Allergic consumers . may have incurred serious risks with these products, on multiple occasions, and may have had no reaction. Thus, understandably, they develop a dismissive attitude toward risk.
In our view, this finding is a strong indication that allergy information sends wrong signals to those people who want and need to understand the meaning of this information.” (1)
A previous Utrecht University prospective study of allergic adults found that nearly half of the participants experienced unexpected allergic reactions, with mostly moderate or severe reactions. And most of the reactions (41%) involved prepackaged foods.
Marta Strinati and Dario Dongo
Notes
(1) Bregje C. Holleman et al. (2021). Poor understanding of allergen labeling by allergic and non-allergic consumers. Clinical and experimental allergy. https://doi.org/10.1111/cea.13975
(2) Dario Dongo. Allergens, guidelines. GIFT(Great Italian Food Trade), 9/15/17. https://www.greatitalianfoodtrade.it/etichette/allergeni-linee-guida
(3) Dario Dongo. May contain allergens, ABC. GIFT(Great Italian Food Trade). 24.6.18. https://www.greatitalianfoodtrade.it/salute/può-contenere-allergeni-abc
(4) Michelsen-Huisman AD, van Os-Medendorp H, Blom WM, et al. (2018). Accidental allergic reactions in food allergy: Causes related to products and patient’s management. Allergy. 2018;73(12):2377-2381. https://doi.org/10.1111/all.13560 Full text of the study available at https://onlinelibrary.wiley.com/doi/10.1111/all.13560
Professional journalist since January 1995, he has worked for newspapers (Il Messaggero, Paese Sera, La Stampa) and periodicals (NumeroUno, Il Salvagente). She is the author of journalistic surveys on food, she has published the book "Reading labels to know what we eat".
Dario Dongo, lawyer and journalist, PhD in international food law, founder of WIISE (FARE - GIFT - Food Times) and Égalité.
