The Food and Drink Federation has just set off another round of huffing and puffing amongst food manufacturers by suggesting, perfectly reasonably and correctly, that allergen labelling is a mess. Their new paper, ‘A vision for Allergen Management Best Practice in the Food Industry’ says, effectively, that although allergen management within the industry has improved this does the allergic consumer little good as there is no agreed terminology for communicating levels of risk or safety. As a result allergic shoppers often ignore ‘may contain’ and other warnings as they are so vague as to be meaningless.
The FDF are suggesting that, as some manufacturers already do, the industry should move to a more ‘risk-based’ approach, giving the consumer accurate information about the level of risk (‘made in a factory handling nuts’) so that they can make an informed decisions about whether or not they wish to take that risk for themselves.
Good idea but, for this to be genuinely helpful to the allergic shopper, two things needs to happen:
1. The industry has to agree on the terminology to be used – probably only achievable if it is imposed from above in terms of regulation – and –
2. The industry needs to have some guidelines as to what constitutes ‘risk’. As of now, the only allergen for which there is an agreed ‘risk’ level, is gluten – less than 20 parts per million having been set by the EU as the level for products to be labelled ‘gluten free’. (For more on this see the Food Standards Agency’s article in foodsmatter.com.)
Although the FSA, among others no doubt, has commissioned research to establish thresholds below which allergens such as nuts, milk, sesame etc etc will not cause a reaction, it may be years before this research produces results, if it does at all. So, for manufacturers the question remains, how can we either make, or correctly label ‘allergen free’ products when we do not know what ‘allergen free’ means?
So, allergic shoppers will continue to be not only confused but sometimes actually misled. The classic example of this, which has now been highlighted to us twice by site visitors, is Green and Black’s dark chocolate. A couple of years ago, eagle-eyed dark-chocolate lovers noticed that ‘organic whole milk powder’ had appeared at the bottom of the list of ingredients, yet the chocolate tasted exactly the same as it always had. So what was going on?
Both of our contacts wrote to Green and Black’s; one got no response, the other was pointed to the ‘frequently asked questions’ section on the G&B site. For those with seriously 20/20 vision, this is to be found, in very small lettering, at the bottom of G & B’s home page. If you then spool down to the very bottom of the page you get:
‘What has changed with our milk allergen labelling?’
Well, what has changed is that, because they use the same equipment to make their milk and their dark chocolate and because chocolate making equipment is notoriously difficult to clean, they cannot guarantee that their dark chocolate will be 100% milk free.
But instead of stating ‘made on equipment which also makes milk chocolate’ which would have described the situation accurately and given milk allergic consumers the information they needed to make an informed decision on whether or not to take the risk, Green and Black’s decide that as they ‘could not guarantee that our dark chocolate will be free from traces of milk as it is made on the same production line and we have therefore included it as an ingredient to ensure consumers, especially milk allergy sufferers, are aware of the possibility.’
But this is inaccurate, misleading and, I would suggest, illegal as they are now effectively claiming that their dark chocolate contains milk when it does not! The only consolation for those us who deplore such muddled thinking is that they have no doubt lost themselves a whole raft of milk avoiding, but not seriously milk allergic, customers who would not have been in the least bothered about a small amount of contamination, but who are not going to buy a chocolate which includes milk as an ingredient!