TO:
FOOD MANUFACTURERS, IMPORTERS, DISTRIBUTORS AND
RETAILERS
RE:
DECLARATION OF FOOD ALLERGENS
The Canadian Food Inspection Agency (CFIA) has published two advisories
regarding labelling of allergens in foods.1, 2 The CFIA is again reminding food
manufacturers, importers, distributors and retailers of their responsibility to
ensure that the foods they sell are safe for all consumers, including those with
food allergies.
Food Allergens
Most allergic reactions are caused by the following foods and their derivatives:
Peanuts
Tree nuts (almonds, Brazil nuts,
cashews, hazelnuts [filberts],
macadamia nuts, pecans, pine
nuts, pistachios, walnuts)
Sesame seeds
Milk
Eggs
Seafood (fish, crustaceans,
shellfish)
Soy
Wheat
Sulphite
Label Requirements Applicable to Pre-Packaged Foods in Respect to Allergens
The Food and Drug Regulations (FDR) requires a complete and accurate list of
ingredients and their components on the label of most pre-packaged foods. There
are some exemptions to this requirement. For example, certain components of the
ingredients used in making sandwiches may be exempt from declaration under the
Regulations. However, a pre-packaged food product labelled with a list of
ingredients is unsafe for people with food allergies if some of those
ingredients or components are priority allergens and are not declared on the
label. Failure to declare allergenic components may be contrary to Subsection
5(1) of the Food and Drugs Act and Subsection 7(1) of the Consumer Packaging and
Labelling Act. These products may therefore be subject to regulatory measures
taken by the CFIA, including a product recall.
In addition, the CFIA encourages identification of the plant source of
ingredients (e.g. hydrolysed soy protein, wheat starch, modified wheat starch,
soy lecithin) on the label.
Allergen Prevention Plans
The CFIA recommends that the food industry develop strategies, such as an
allergen prevention plan3, to manage the risks associated with priority
allergens. The strategy should include a thorough evaluation of manufacturing
and ingredient control procedures. In the case of imported pre-packaged food
products, it is the importers' responsibility to ensure those products are fully
and correctly labelled.
Precautionary Labelling
Despite all possible precautions, the presence of allergenic ingredients in
foods cannot always be avoided. In order to assist consumers affected by food
allergies, the Canadian government, in consultation with industry and allergy
groups, developed a policy on precautionary labelling ("may contain"
statements). This policy allows the food industry to voluntarily label products
which may inadvertently contain substances capable of causing severe adverse
reactions. Precautionary labelling, however, must be truthful and must not be
used in lieu of adherence to legal requirements. When an allergen is likely to
be present in a product, the use of precautionary labelling is not acceptable
and the presence of the allergenic ingredient should be accurately declared on
the label. Further information on basic labelling requirements can be found in
chapter 2 of the 2003 Guide to Food Labelling and Advertising4.
For More Information
Atlantic - Ronald Arsenault 506-851-4880
Quebec Claude Desaulniers 514-283-3815 x335
Ontario Mary Rutherford 519-826-2948
West Terry Peters 604-666-1080
1
http://www.inspection.gc.ca/english/fssa/labeti/inform/19980331be.shtml
2
http://www.inspection.gc.ca/english/fssa/invenq/inform/20041018e.shtml
3
http://www.inspection.gc.ca/english/fssa/invenq/inform/toualle.shtml
4
http://www.inspection.gc.ca/english/fssa/labeti/guide/toce.shtml
