Grocery e-commerce has been selling more and more prepacked food in the past years. In 2023, the Codex Committee on Food Labelling (CCFL) has launched a consultation process to gather input around the e-commerce of food.
Technological advancements, but also the unforeseen circumstances brought by the COVID-19 pandemic, have boosted internet sales and home delivery of food, leading the market to a steep diversification. Regardless of the circumstances or mode of purchase, people with food allergies need accurate and timely information about food composition and allergens present in food.
Food allergen labelling is essential to protect the health of consumers with food allergy. Therefore, foods supplied through internet sales/e-commerce must undertake the same information requirements as foods sold in stores. In actual terms, all ingredient information must be provided both at the point of e-commerce sale and the point of delivery.
With this aim achieved, EFA actively worked with its community of members to ensure that other key provisions serve food allergy patients. These include:
Takeout foods should also be labelled
EFA stressed that the scope of the guidance must include also food pre-packaged at the point of sale, which applies to many online purchases (e.g. when ordering from a pizza or burgers restaurant).
Small foods also count
Regarding information exemption for small units of food, EFA strongly believes that this should not apply to online commerce. As this is a provision referring to physical products with small packaging that cannot contain all the information, such an exemption should not apply in an e-commerce context, as webpages do not have a space limit.
Fresh foods, fresh review date
EFA considers it important that information on e-pages mention the ‘last review date’, where retailers state the last time they reviewed the allergen information.
Let’s say no to labels we don’t understand
As for the presentation of mandatory information, EFA supports the use of language that is easily understood by consumers in the country in which the food is marketed and to which it may be delivered. This is a principle arising directly from the existing EU law (Regulation 1169/2011 on food information for consumers).
Unitended allergens are allergens too
Consumers with food allergies need to be aware of allergens both as ingredients and in case of unintended allergen presence through Precautionary Allergen Labelling (PAL), the label for which is voluntary. As hidden allergens are also allergens, EFA strongly calls for PAL statements to become mandatory, including compulsory education for Food Business Operators (FBOs) and other involved actors.
EFA looks forward to the next steps of this important consultation process and working together with Codex experts towards guidance that fully reflects the needs of food allergy patients to be safe when buying food from e-commerce channels.
You can find the full EFA responses to these consultations here:
April 2023: eCommerce consultation (step 3)
October 2023: eCommerce consultation (step 5)
Find more information about our work on food labelling on our website.