In 2022-2023, EFA has participated in a consultation process organised by the Codex Alimentarius Commission (CAC), a WHO-FAO body setting international food standards. In particular, the CAC Committee on Food Labelling (CCFL) is revising the General Standards for the Labelling of Prepacked Food (GSLPF), and more specifically it analyses its provisions on allergen labelling, which are crucial for people with food allergy.
EFA is Observer to CAC since 2019 and follows closely the work of the CCFL, participating in several Working Groups led by this committee.
The revision of the allergen-related provisions of the GSLPF was launched following the 45th meeting of the CCFL in 2019. It was deemed as necessary step to respond to several gaps in the pre-existing standard, including to clarify the listed food and ingredients known to cause hypersensitivity; potentially update the current list to include new foods and ingredients; and address the need for further information on how allergens should be presented on food labels to ensure consumer protection.worked in close collaboration with its members in the Food Allergy Working Group, to respond to these consultations.
The most important issues that EFA food allergy community has identified for the revision of the GSLPF are the following:
- EFA supports the removal of lactose from the GSLPF list of priority allergens, as it should not be considered a single allergen. However, as lactose and milk are often confused, EFA stresses the importance of granting special attention to lactose-free products containing milk proteins. The reason is lactose-free dairy products are safe for lactose-intolerant consumers but they are not suitable for consumers with allergy to milk.
- EFA holds that specific names for the declaration of food ingredients in the priority allergens’ list are necessary. In the case of fish and crustacea, EFA suggests considering both as broad categories and not as single ingredients. The reasons is that some consumers can be allergic only to a particular fish species, while others must avoid all fish (the same is the case with crustacea). It gets even more confusing when the name of fish and crustacea species is not easily recognisable by consumers (e.g. the fish ‘tilapia’). Therefore, EFA suggests that the mandatory labelling for fish and crustacea should include both the common name of the individual fish species AND 'fish' as the specified name. The resulting labelling must appear as follows: 'fish species (fish)' example: ‘tilapia (fish)’.
- EFA acknowledges the difficulty of the debate around summary statements in the package labelling, where all allergens are mentioned in a separate labelling. However, the food allergy community of patients and carers finds those statements very convenient as they offer standardised allergen information on the label. Summary statements are useful if they are fully in line with the ingredients list. In terms of positioning, summary statements must be placed 'directly next to the list of ingredients'.
- Building on the logic of the summary statement, EFA proposes to establish a unified 'allergy statement' referring not only to the list of ingredients but also to Precautionary Allergen Labelling (e.g. may contain) where applicable, and other allergen-related information of the food product, all in one place.
- Regarding food ingredients obtained via biotechnology, for EFA this is an area that requires due consideration. In the case e.g. of a novel food created via biotechnology and therefore new to the human diets, EFA encourages to require a safety assessment, as well as a statement on potential allergic risks. Other cases where these precautions would apply before authorisation include the introduction of new insects or non-animal milk proteins into the diet, both type of products which are already known for their cross-reactivity. EFA encourages establishing an 'allergy warning statement' related to the products derived from biotechnology.
EFA is following closely the developments in this key consultation process and is ready to contribute the perspective of the European food allergy patient community in future calls for comments, in our role as Observer to Codex.
You can find all EFA responses to this Codex Alimentarius Commission (CAC) series of consultations below:
July 2022: 1st CCFL consultation
December 2022: 2nd CCFL consultation
April 2023: GSLPF consultation (step 3)
October 2023: GSLPF consultation (step 5)
More information about our work on food labelling is described in our website.