'May Contain' Food Allergen Labeling
Can't Be Trusted

Ingrid Hein

October 26, 2020

Food-allergic patients, allergists, and researchers are asking for a review of food allergen labeling guidelines in the European Union, particularly "may contain" labeling.

Currently, food business operators (FBOs) in the EU are required to inform and label when they use any of the 14 major allergens.

But when the allergen is not "deliberately used" by the food business, FBOs are asked voluntarily to provide precautionary allergen labeling (PAL).

That poses a problem for highly sensitive food-allergic individuals, Sabine Schnadt, representative for the German Allergy and Asthma Association, a patient advocate group, told the FAAM-EUROBAT Congress during a symposium on dose-specific issues concerning food allergies.

There are no guidelines for PAL, she said. Everyone does it differently, and nobody seems to have the same standards for what constitutes an unsafe level of an allergen. "Precaution allergen labeling needs to be regulated according to a quantitative assessment and according to reference doses," Schnadt said.

PAL Labels Can't Be Trusted

In her presentation at FAAM-EUROBAT, Schnadt discussed several studies revealing the pitfalls of PAL labelling at the patient level. She said "may contain" labeling can't be trusted.

She pointed to the accidental food allergy reactions study (J Allergy Clin Immunol. 2018;142:865-875) which revealed that 6 out of 51 (12%) packaged products analyzed were found to contain allergens not mentioned on the PAL label. Fish, crustaceans, cashew, almond, and milk, were among these.

In that study, foods were analyzed when someone in the 157-patient cohort recorded a reaction. From this group, 73 (46%) reported a food allergy reaction.

In a press release issued by the European Academy of Allergy and Immunology, study author Marty Blom, PhD, leader of the SRP Food Allergy Program at The Netherlands Organisation for Applied Scientific Research, said, "We recommend a good readable label, grouping of related allergen topics, and a uniform topic order."

Blom added that what is needed is "a single type of PAL statement and an allergen information section enabling the consumer to ask any relevant questions to protect their health and get the answers they need."

Schnadt's patient advocate group also revealed data that questions whether or not PAL food allergen labeling should be trusted.

In a laboratory analysis of products considered vegan, Schnadt's patient advocacy group found 7 out of 30 products (23%) contained milk.

"None had egg," Schnadt noted, but "we found milk in nearly a quarter of the products."

Five of those 7 products that contained milk did have a PAL "may contain milk" label, but 2 did not. One of these had a PAL message mentioning that the product may contain nuts but didn't mention the milk in the product.

This lack of consistency makes it impossible for patients to trust the labels. "Whether there is a PAL or there is no PAL does not give allergic consumers any hint if this product is safe to eat or carries a risk," Sabine said.

The Origins of "May Contain"

" 'May contain' was initially an honest attempt by manufacturers to label their products and provide information on cross-contamination arising from contact in the supply chain or the manufacturing process," Michael Walker, PhD, Laboratory of the Government Chemist, United Kingdom, said in the press release.

But "with now over 25 ways of saying 'may contain,' people with food allergies tend to not trust it or ignore it — it is not useful for them, nor to manufacturers themselves," he added.

Currently, the Codex Alimentarius Commission, a body responsible for all matters regarding the implementation of the World Health Organization's food standards program, is collecting input and looking at food allergen qualitative risk assessment, reference dose, and PAL guidelines. Recommendations are expected to emerge in the coming months.

"This is a really good way forward." Schnadt said.  "Hopefully when Codex Alimentarius comes to their conclusions and is in favor of giving PAL a framework, we in the European Union will take this up."

FAAM-EUROBAT Symposium #2: How Much Is Too Much of a Food Allergen? Presented October 16, 2020.

Ingrid Hein is a freelance health and technology reporter based in Hudson, Quebec.

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