The FSA is conducting a consultation to seek feedback from stakeholders on two food labelling issues: standards for applying precautionary allergen labelling (PAL), and best practice guidance that No Gluten Containing Ingredients (NGCI) statements should not be used. This consultation is being conducted as part of a routine review and update of the Allergen Labelling Technical Guidance.
Read on for a brief summary of the proposed issues. For a more detailed outline, visit the FSA website.
- Precautionary allergen labelling statements
Whilst the use of PAL statements is voluntary, they must be accurate and not misleading, in line with Article 36 of the FIC.
However, research shows that small and medium-sized (SME) food businesses selling pre-packed foods can be unsure of how and when to apply PAL. The best practice guidance proposed by this consultation aims to support food businesses to provide accurate information on the risk of allergen cross-contamination whilst ensuring customers are safe and able to make informed food purchasing decisions.
The proposed best practices are as follows:
- PAL statements should only be used following a thorough risk assessment
- PAL statements should specify which of the 14 regulated allergens they refer to. (For example: apply the statement “May contain peanuts and tree nuts” rather than the generic statement “May contain nuts”.)
- PAL should not be used in conjunction with a free-from statement for the same allergen. (For example: “May contain milk” should not be used in combination with “dairy free”.)
- FBOs should provide a straightforward means for consumers to contact them about their allergen cross-contact risk assessment that informs PAL. This is of particular importance for consumers with multiple/severe allergies who are concerned about a labelling change.
- No Gluten Containing Ingredients (NGCI) statements
NGCI statements have been used in menus to signal foods that are made from no gluten-containing ingredients; e.g., "This menu has been designed for a no gluten diet”. Evidence suggests that NGCI statements can mislead consumers and should be avoided. Only the terms “gluten-free” or “low gluten” can be used to describe the absence or the reduced presence of gluten.
The FSA invites comments and feedback on the proposed updates; you can have your say here, whether as a private individual, a local authority, a food business or on behalf of some other organisation/company. Responses are required by COB 22 May 2023. At the end of the consultation period (June 2023), the FSA will collate and consider any responses received, prior to amending and publishing the revised Technical Guidance.
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