13 May, 2019

Should we announce allergens due to cross contamination on the label?

Announcing ingredients that can cause consumer allergies is mandatory in the European community, that is, all substances that are in Annex II of Regulation (EU) No. 1169/2011, must be communicated on the product label, even if they are still present in said food even if it is modified.

However, there is no regulation of its own to communicate allergens due to cross contamination in the labeling. This information is considered voluntary.

According to the Spanish Agency for Consumer Affairs, Food Safety and Nutrition AECOSAN, which depends on the Ministry of Health, “the food company can make use of preventive labeling provided that, after having made a prior assessment of the risks and after applying preventive measures , consider the existence of a cross-contamination with allergens inevitable”.

That is why, as indicated in article 36, said information:

1. will not mislead the consumer
2. it will not be ambiguous or confusing for consumers, and
3. it will be based, as appropriate, on the relevant scientific data.

Although neither the Spanish nor the European Regulation 1169/2011 provides food information on how to declare the presence of cross-contamination allergens and that they slip into the packaging of the product in an improvised way, said regulation provides that the European Commission can undertake in the future measures to indicate how to make the voluntary declaration of the presence of traces.

Likewise, AECOSAN emphasizes that it is the responsibility of the companies themselves to apply the necessary protocols to avoid such contamination, as established by Regulation (EC) No. 852/2004 on the hygiene of food products and Regulation (EC) No. 178/2002 on food safety made available to consumers.