From 27 September to 1 October, EFA participated in the 46th annual meeting of the Codex Committee on Food Labelling (CCFL). As part of the wider Codex Alimentarius Commission structure, the CCFL addresses food labelling issues and develops relevant global standards and guidelines. With our Observer status since 2019, EFA actively contributes to the CCFL meetings by representing the voice of the food allergy patients in Europe.
Drawing from this year’s rich agenda, the CCFL46 meeting focused on several ongoing processes around food allergen labelling. Discussions tackled the revision of the allergen labelling provisions in the General Standard for the Labelling of Prepacked Food (GSLPF) and the proposed guidance on Precautionary Allergen Labelling (which EFA addressed here), as well as the impact of online food shopping.
E-commerce of food: How to ensure proper allergen labelling?
Online sales of goods, including food, is a market sector that is flourished over the last decade in Europe, especially as a result of the restrictions linked to the COVID-19 pandemic.
However, e-commerce of food should be as regulated as food sold physically. Shifting to digital means to sell food should not neglect food safety. For people with food allergies, food sold digitally should be coupled with timely and accurate food information, including on the presence of allergens.
On the CCFL46 meeting, EFA submitted a written statement to the Chair of the meeting addressing several points on the draft guideline that was discussed:
- Ensure that all ingredient information is provided both at the point of e-commerce sale and the point of delivery (instead of merely the latter as the draft guideline read). This is vital for consumers with food allergies, as they must be able to take informed choices based on whether the food is safe for them to consume or not.
- Unlike with physical retailers, where small units of food packages are exempted from providing ingredient information because of limited labelling space, there is no such limitation for e-commerce sales. Therefore, online food business operators should disclose the full ingredient list, independently of the size of the product.
- Regarding cases where ingredients may alter due to recipe adjustments, EFA stresses the need to always have accurate and up-to-date ingredient information (including Precautionary Allergen Labelling, when necessary) so that consumers with food allergies can take informed food choices at the time of purchase.
- In cases of minor variations where an ingredient is substituted by another that performs a similar function, EFA noted that the draft does not foresee to include information about minor variations unless a class name is used, and therefore stressed why mandatory allergen labelling is considered necessary to ensure safety.
- EFA suggested the expansion of the guideline for internet sales/e-commerce to also apply to non-prepacked food.
Finally, EFA reiterated its willingness to contribute to the work of the CCFL and the Codex Alimentarius Commission more broadly in a constructive way, providing continuous feedback from the perspective of patient/consumers‘ needs.
You can access the full EFA statement here.