Food Allergens for Manufacturers

Over the last 50 years or so, there has been a dramatic increase in the number of people who have food allergies. Currently, it is estimated that around 2% of all adults and up to 8% of children experience true food allergies, with reactions ranging from mild to severe and, potentially, even fatal. As a result, manufacturers have a responsibility to be aware of any cross-contamination that could occur on the production lines; that the 14 main allergens are clearly displayed on the label; and to ensure they have an effective allergen management system in place.

One survey, conducted by Trade Interchange, reported that up to 70% of foodservice operators are fearful of not complying with allergy and labelling legislation. As well as resulting in reputational damage, product recalls can be costly and unintentional cross-contamination is one of the key reasons behind them. Read on to find out more about the UK’s stance for protecting those at risk of an allergy reaction, tips for avoiding cross-contamination, and more about the labelling requirements for the different types of packaging.

Why are food products recalled?

Foods are usually recalled to protect the public in some way due to some form of defect with the final product, and the top recall category to date is due to undeclared allergens or inappropriately labelled items; with human error being the main contributing factor. The UK is reputed to have one of the safest food systems in the world, but the number of product recalls per annum has been fast increasing. Statistics from the Food Standards Agency suggest that there was a 36% increase between 2018 and 2019; with allergy alerts rising to 28%. However, our supply chains are now more complicated than ever before, and better technology has enabled companies to take a ‘safety first’ approach. Legal fees, collection, transport, destruction of products, and advertising recalls means that the cost to a business can be high. However, they are essential in reducing the long-term consequences of the product being on the market.

What is the difference between an allergy and food intolerance?

The main difference between an allergy and food intolerance is related to how the body responds to the substance. An allergy is when a normally harmless substance triggers a reaction in someone. They may be allergic to the product as a whole or proteins within it. When a person is allergic to a substance consumed, the body’s immune system goes into overdrive and produces chemicals such as histamine to protect it from the perceived invasion. This can occur within minutes or up to four hours after the allergen has been consumed. In some cases, a person may enter a state of anaphylaxis, and death can occur in little as ten minutes.

Additional symptoms may include:

• Respiratory issues such as asthma or swelling of the throat
• Gastrointestinal issues such as diarrhoea and vomiting
• Skin problems such as hives or dermatitis
• Rapid loss of blood pressure
• Obstruction of the airways
• Multiple organ failures.

There is currently no cure for food allergies, and the range of sensitivity to an allergen depends on a multitude of factors. These are related to the individual’s sensitivity, the type of food, the amount consumed and other activities that the individual is doing around the time of consumption. As a result, the only appropriate method of preventing this reaction is by complete avoidance. In contrast, food intolerance symptoms are usually less severe, and while this can be an uncomfortable and painful response, it does not involve the body’s immune system. The symptoms and severity of food intolerances can vary significantly, and it is dose dependant.

The 14 Main Allergens

Those who produce pre-packed food have a responsibility to adhere to legislation regarding labelling, as well as other relevant food-related laws. This states that operators must provide customers with allergen advice for both pre-packaged and loose food and drink, including declaring the inclusion of the 14 main allergens.

These include:

Celery

This includes the stalks, leaves, seeds and celeriac. It can be detected in an array of products including salads, soup stock cubes and some meat products.

Cereals containing gluten

This includes cereals such as wheat, rye, barley and oats. They are frequently found in products that contain flour, including cakes, couscous, pastry and some fried food.

Crustaceans

This category includes crab, lobster, langoustine, prawns and crawfish amongst others. People tend to be allergic to a protein found within these, and they will generally need to avoid all types of crustaceans to prevent an allergic reaction.

Eggs

An egg allergy is more common in childhood, with most people outgrowing it before they reach adulthood. It can be found in an array of foods, with ingredients containing egg including whole eggs, as well as dried egg, egg yolks or whites, egg proteins, lysozyme and lecithin.

Fish

As well as the obvious, fish can also be found in sauces such as Worcestershire sauce and fish sauce. People who are allergic to one type of fish are more likely to be allergic to other types. For example, salmon, pollock, cod and herring all share similar proteins so are likely to cross-react.

Lupin

Lupin is a type of flower, with the seeds being crushed to make lupin flour. It is sometimes referred to as lupine, lupin flour, lupin seed or lupin bean. It may be used to replace traditional flour in an array of baked goods, and it is sometimes incorporated into meat products.

Milk

Immediate cow’s milk allergy is an allergic reaction to a type of protein found in milk, and it can be severe. It tends to affect infants and young children the most, but it can continue into adulthood. A range of products contain milk, and ingredients such as casein, whey, sodium caseinate and calcium caseinate should be avoided.

Molluscs

This category includes shellfish like mussels, clams, oysters, and squid, octopus and scampi. Proteins from molluscs can also be found in oyster sauce, or fish strews. Allergic reactions are dependent on the individual, but they can be severe and possibly even fatal.

Mustard

This category includes liquid mustard, powder, seeds, and oil, and it is a popular ingredient in some types of bread, meat products, sauces, and salad dressings.

Peanuts

Peanuts are a form of legume, which is a group of foods that also includes peas, beans, and chickpeas. Peanut allergies can be severe, with serious consequence even when consuming small amounts.

Sesame seeds

People with a sesame allergy can also have a severe reaction, even if they have consumed the smallest quantity. Foods containing sesame include the use of sesame oil, seeds and tahini, as well as some types of bread, stir-fry, salads dished, and crackers.

Soya

Soya is derived from soybeans, which is another type of legume, and it may be referred to as edamame. It can be found in a wide array of foods including tofu, soy oil, soy sauce, vegetable proteins, medicines, and some baby foods.

Sulphur dioxide and sulphates

Allergies to sulphites are rare, but they can be serious. They are apparent in various foods, including processed meats, beverages, dried fruits and vegetables, fresh or frozen prawns, guacamole, pre-cut or peeled potatoes and many others. According to labelling requirements, sulphur dioxide and sulphates should be emphasised on the label if they are at a level of more than 10 parts per million. This only applies to foods where these have been added, rather than where they occur naturally.

Tree nuts

This includes including almonds, hazelnuts, walnuts, Brazil nuts, cashews, pecans, pistachios macadamia. If people are allergic to one type of nut, they are often also allergic to another form and are also at an increased risk of being allergic to legumes such as peanuts.

Types of Food packaging

Labelling requirements depend on how the food is provided, with most manufacturers predominantly dealing with pre-packed food items.

Prepacked

These are the products put into packaging before going on sale. They are ready for sale, and the product itself cannot be altered without opening or changing the packaging in some way. All prepacked foods must have a clear ingredients list present, and on this, allergens should be emphasised. Multipacks should have allergy information on the outside of the overall pack. If it is placed on each packet as well, it should be consistent with the information on the outer packet.

Prepacked for Direct Sale

This refers to foods packed on the premises where they are made and sold. It may include things like sandwiches or pastries from a bakery or delicatessen products. Previously, it was not required for these to be labelled, as it was assumed that the person who made the product would be available to answer any customer queries regarding ingredients. However, since October 2012, all food businesses that must provide clear allergen information on their labels, including an emphasis on the 14 main allergens.

Non-Prepacked (Loose) Food

Loose Foods do not need to be labelled in the same way, but businesses are required to provide allergen information. This can be communicated in various ways, and it could apply to loose items such as those at delicatessen counter or bakery as well as meals from a restaurant or takeaway.

Labelling

The allergen labelling requirements are set out in EU Food Information for Consumers Regulation (EU FIC). This law applies to all substances that are ‘present in the final product’, including ingredients as well as any additives and processing aids.

The legislation states that businesses have a responsibility to declare any potential allergens. This should be clearly written on the label, emphasising the inclusion of any of the 14 main allergens. Manufacturers should be aware of this.

For example:

Ingredients – Carrots, Water (35%), Onions (5%), Sugar, Cream (Milk) Dried skimmed Milk, Durum Wheat Semolina (42%), Celery.

How you choose to place the emphasis is up to the company. You could list them in bold, use a contrasting colour or simply underline them. An allergen advice statement can also be used to make things even clearer. For example, ‘for allergen advice, see ingredients in bold.’

However it is written, the language on the label should be easily understood, and the information must be in English. For alcoholic drinks with no ingredients list on the bottle, the label must include the allergens that it contains. For example, ‘may contain X’; with x referring to the allergen present.

Free from Gluten-free, and Dietary Preferences

Strict laws surround the free-from label, and the inclusion of this on a product is premised upon strict and rigorous controls. Most products must be completely free of the allergen, with no risk of cross-contamination, to be declared free from. The only exception is gluten-free, with gluten-free labelled products containing a maximum of 20mg.

If a product is written as ‘suitable for vegans’, then it is likely that a customer would assume it does not contain any animal-based allergens such as eggs, fish or dairy. However, this is not necessarily the case, and products may still contain allergenic ingredients of animal origin because of unintentional cross-contamination. In this situation, a risk assessment should be undertaken to decipher whether the label requires a precautionary allergen statement.

Precautionary Allergen Labelling

A precautionary allergen label refers to statements such as:

• May Contain X.
• Not suitable for someone with X allergy.

Precautionary allergen labelling should be used after a full risk assessment has taken placed and deemed that the risk of contamination is present and cannot be reduced. They should always be taken seriously and only used when necessary, with some evidence to suggest that people are less likely to pay attention to them when they are overused.

Avoiding Cross-contamination

All food manufacturers have a responsibility to ensure that they have an appropriate system in place to meet allergen requirements and reduce the risk of contamination. This refers to situations in which an allergenic substance is unintentionally added to the food.

Important points to consider include:

Staff

All manufacturing businesses have a responsibility to ensure that staff are appropriately trained in allergen management and are aware of the implications of cross-contamination. This training should be kept up to date and be ongoing and appropriate procedures should be available to staff at all times. This includes information on allergens, hand washing, clothing, waste control, cleaning procedures and any dedicated equipment.

Cleanliness

Manufacturers are always responsible for maintaining excellent cleanliness and everyone should be aware of the importance of proper hygiene standards. However, it is often because of inadequate cleaning or residue from an allergen remaining on the line that products are recalled. It is not just about ensuring hygienic practices on the production line, also consider the potential risk of cross-contamination from non-food contact surfacing. Employee handling and high-pressure spraying may mean that surfaces are contaminated, with allergens then potentially being transferred onto non-allergen substances.

Product Development

Issues surrounding allergens can also be addressed when the product is in the development phase. When developing your products, consider whether an allergenic substance could be replaced or removed. Designing your product flow so allergenic ingredients can be added at the end of the production line can significantly reduce equipment exposure.

Records

At a minimum, food businesses should keep traceability records for the duration of the shelf life of the food plus twelve months. This includes a written record of the allergen ingredient information for each of the products produced. Manufacturers will also need to keep a record of raw materials used and ensure that checks are conducted if there is a change of supplier.

Packaging

Cross-contamination through packaging can be prevalent, and so any unused packaging should be removed from the machines and destroyed at the end of the production run. Manufacturers need to ensure effective post-manufacturing controls are also in place to check that labels are appropriate and that accurate information is consistently provided to the consumer.

Premises and Equipment

In an ideal world, manufacturers would utilise separate production system for specific products to reduce the potential risk of cross-contamination. If this is not possible, there needs to be a differentiation between production areas, using physical barriers, dedicated equipment and segregation areas. Avoiding the crossover of production lines as well as ensuring that the system is effective can help decrease the risk of allergen contamination. You also need to consider things like cooking oil, as this cannot be reused.

For example, chips cannot be free from gluten, if the same equipment and oil have been used to cook battered fish.

Storage

Proper storage is also essential in reducing the risk of cross-contamination, and any items containing any of the 14 main allergens should be stored in isolation from non-allergen products, preferably in clearly identified areas. For example, they could be stored in different coloured boxes or by separating storage areas.

Enforcement and Penalties

Not only can cross-contamination impact upon the financial and reputational damage of the company, an allergic reaction can make someone seriously ill, and in some instances, it can be fatal. Local authorities have a responsibility to ensure that all manufacturers are complying with the allergen information regulations. Failure to comply with advice will result in an improvement notice being issued. If the company does not meet the requirements of this notice, a penalty will be issued. In some severe cases, businesses may also face criminal prosecution. Financial penalties for manufacturing companies in direct breach of food safety laws can be high, with no fine limits in place since 2015.

Consumers have the right to be fully informed about what they are purchasing, and manufacturers are responsible for maintaining standards. Fundamentally, a poor understanding of the risk of allergens and the necessary requirements is a food safety issue, which could put the consumer’s health at direct risk. As a result, it is essential that manufacturers invest time and money into ensuring compliance to allergen requirements and that labelling is clear, informative, and includes all the 14 main allergens.