EU plans to create a universal labelling standard for food products came into force from December 2014 as the Food Information for Consumers Regulation (or EU FIC) became part of UK law.
The following 14 allergens must be emphasised to consumers on the product’s ingredients list or menu: celery, cereals containing gluten, crustaceans, eggs, fish, lupin (in flour), milk, molluscs, mustard, nuts (grown on trees), peanuts, sesame seeds, soya, sulphur dioxide (in dry fruit, meat products, soft drinks, vegetables, wine and beer).
If a product contains any of these allergens without having informed the consumer then this could result in a fine of up to £5,000.
Who do the regulations apply to?
These regulations apply to food business operators at all stages of the process where the food product is intended for the end consumer. This includes food delivered by caterers, sold from supermarket delis, restaurants, and airline or cruise operators.Therefore, if your business deals with food, it is essential that the consumer is made aware of any allergen information.
If your company is preparing the food, it is important to be aware of the fact that many chefs may garnish their sauces with powders or seasoning that could contain allergens. Also, in self-service restaurants contamination of serving utensils is likely so safeguards must be taken.
How can the new regulations be managed?
Creating a “recipe matrix” is a potential solution. This involves those who prepare food selecting the ingredients that they have used so that the business can write a clear recipe to follow. Once this is written, those making the food should be contracted to follow the recipes exactly or the manufacturer could be held liable.
The regulations do not cover accidental use of a contaminant, but it remains good practice to include statements such as “may contain” if the product has been prepared near to an allergen. This is particularly relevant after four year old Fae Platten went into anaphylactic shock on a plane after a fellow passenger had ignored warnings not to eat nuts on board due to the severity of Platten’s allergy.
Care must also be taken if using ready-made mixes or sauces from suppliers. This problem can be solved by making them aware of the new legislation and inserting clauses in the contracts that they will take full liability if their product supplied contains allergens that they have not notified you about. This will of course be a matter to negotiate though.
Get your kitchen in order
While these changes are now force immediately, long life products made before December 2014 will not have complied with these Regulations and, as such it may take a number of years for a completely universal system to be established. Further changes are expected, including a requirement for food to be labelled with its country of origin, so the food industry should be aware for these in the near future.
For specialist advice about food standards legislation or for dealing with claims related to food legislation contact Peter Gourri today by email PGourri@rollingsons.co.uk or telephone 0207 611 4848.