Do We Need More Allergen Labelling for Prepackaged Foods?

Taiwan is Leading the Way in New Allergen Labelling Rules

Growing concern over allergens has sparked increased labelling rules in Taiwan. Should the rest of the world follow suit?

There is a common perception that more people suffer allergies today than was the case in years gone by. To a certain extent this is true – children have a significantly reduced exposure to microbes in the developed world and are often only introduced to potentially allergenic foods, such as peanuts and eggs, at a later age.

There is also the fact that in the modern age, we are more aware of allergies, and allergic conditions that might previously have gone unnoticed are now more likely to be diagnosed.

What is in no doubt is that we are far more conscious of allergies and allergenic foods than we used to be – and the impact for those who manufacture and use custom printed labels for foodstuffs could be significant.

New regulations in Taiwan

The Food and Drug Administration of Taiwan (TFDA) announced last month that it will repeal the current allergen labelling rules, and replace them with a completely new set of regulatory requirements.

As it stands, the TFDA lists six food categories that are of allergen concern and subject to mandatory labelling: eggs, peanuts, milk, crab, shrimp and mango. The new regulations will consolidate these and expand them to the following eleven broader categories:

  • Crustacea and products thereof
  • Mango and products thereof
  • Peanuts and products thereof
  • Sesame, sunflower seeds and products thereof
  • Milk, goat milk and products thereof
  • Egg and products thereof
  • Nuts and products thereof
  • Cereals containing gluten and products thereof
  • Soybean and products thereof
  • Products that use sulphites, sulphur dioxide etc. above a certain concentration
  • Salmon, mackerel, codfish, Dissostichus eleginoides, Reinhardtius hippoglossoides and products thereof.

The TFDA has also tightened up the wording requirements to definitively state what allergens are present, instead of the more common “this product may contain” wording. But what, if any, new rules will be introduced to address the question of precautionary labelling where an allergen might unintentionally be introduced has yet to be confirmed.

European reaction

The new rules bring the regulatory framework in Taiwan closer to the existing EU rules, which list 14 categories of allergens that are broadly similar to the eleven listed above. However, it is again the question of allergens that form an intended ingredient as opposed to precautionary labelling where cross contamination from other products is possible that has caused most discussion.

FoodDrinkEurope, a trade association that represents a variety of food and drink manufacturers, has been lobbying the EU for definitive guidance on precautionary labelling. At present, member states carry out their own risk assessments and have their own rules for deciding if and when a precautionary label is needed.

A recent policy document from FoodDrinkEurope called on the European Commission to create a harmonised system for the food labelling of precautionary allergen information, using terms that are clear, standardised and easily translated. It said that the inconsistencies in the current system leave consumers unclear as to the risks they face.