New Year, New Allergen Declarations

Roberta ShaferJan 9, 2023

The new year brings in many new laws that go into effect in the United States . In the world of labeling and allergen declarations, the “Big 8” now becomes the “Big 9” as we add sesame to the mix. Prior to this, the United States mandated that certain allergens be declared on the label. They consisted of dairy, soy, tree nuts, peanuts, eggs, wheat, fish, and shellfish. Many countries had already required the labeling of sesame before the United States (1). It is also interesting to note that sulfites are required to be declared if they are ≥10 mg/kg (1).

The University of Nebraska has a great website devoted to the topic of allergens, and the Food Allergy Research and Resource Program (FARRP) (2). It has a great database of allergens for the consumer, regulatory or curious researchers. It also has information for food industry use, an interactive map, training, analysis, and links to information for specific food allergens. It is a great site for general knowledge or a deep dive into a specific type of allergy.

It is noteworthy that the United States and Canada have similar requirements for the declaration of allergens – with Canada adding mustard, and cereals with gluten. Many of the food recalls in both countries involve undeclared allergens. You can check out the current list of recalls for both countries on my Recall List. Canada does require that Molluscan shellfish be declared separately from Crustacean shellfish.

In 2012, the European Food Safety Authority (EFSA) was tasked with studying allergenic prevalence in European countries and throughout the world. What they found was that milk was the most common allergy worldwide, and some allergens needed more comprehensive testing to determine the prevalence. The study which is 343 pages in length has a lot of useful information, including the testing of how different processing methods affect allergens (3). The study can be found here: https://www.efsa.europa.eu/en/supporting/pub/en-506.

Many different foods that are not considered allergens in North America are listed as allergens in other countries. There are many different groups that set what allergens must be declared on labels. The EU (European Union) has one set of recommended foods, and other groups such as CARICOM (Caribbean countries), the Central American Technical Regulation has its own set of requirements. Middle Eastern countries – UAE, Bahrain, Oman, Qatar, Saudi Arabia, and Kuwait follow GSO requirements and some non-EU countries such as Iceland, Norway, the United Kingdom, Switzerland, Macedonia, and Liechtenstein follow the EU guidelines (1).

Many allergens are commonly declared by most countries, for example, dairy, eggs, fish, peanuts, wheat, soy, nuts, cereals with gluten, sesame, and sulfites. Wheat is not declared in many countries such as Fiji, Hong Kong, Malaysia, or Mexico, among others (1). However, in Brazil latex is an allergen that must be declared and in South Korea, beef, chicken pork, peach, and tomatoes must be labeled. In Australia, Royal Jelly is considered an allergen, and mangoes are in Taiwan, but not wheat (1). The answer to the prevalence can be found in the foods that are commonly grown or eaten in the region. In Europe, many people are allergic to wheat and celery, which are common foodstuffs (3). Milk and eggs, which are widely consumed throughout the world, show up in the list of most of the countries that were studied (1,3). By scanning the QR code below, you can access the interactive website hosted by FARRP.

Mustard and lupin are also two allergens that show up on the lists of many countries and if you are used to only the “Big 9”, these would be easy to miss. Producing accurate and correct labeling for exports can be a challenge for those companies that are small or have inexperienced labeling personnel. It is always a good practice to check the allergen database found at the University of Nebraska and the export and import regulations of the country where you are planning to sell or export labeled goods. These need to be checked often, as they change frequently. A good resource is https://www.fsis.usda.gov/inspection/import-export/import-export-library for the United States, and each country will have its own regulations, so make sure that you check the appropriate resource (4).