Precautionary Labelling for Allergens in Pre-packaged Foods

Questions and Answers Regarding the Labelling of Food Allergens - Precautionary Statements

As a result of recent recalls, the Canadian Food Inspection Agency (CFIA) and Health Canada are reviewing precautionary statements for food allergens and making recommendations regarding their use on the labels of pre-packaged foods. Precautionary statements are voluntary declarations on the labels of pre-packaged foods that alert consumers with food allergies to the potential presence of the allergen in the food.

In 1994, Health Canada issued a policy on the use of precautionary statements. Since that time, the food industry has used a variety of statements that do not always accurately reflect the appropriate health risk for individuals with food allergies. Health Canada is currently updating their policy to remove terms, such as "may contain traces of X" and restrict the options for precautionary statements. The proposed options for precautionary statements are:

• "may contain X"; or
• "not suitable for consumption by persons with an allergy to X", where "X"; is the name by which the allergen is commonly known.

Further, where suppliers have labelled raw material with a precautionary statement, manufacturers are advised to use the same statement on the finished product label unless it can be demonstrated that the allergen in the finished product is not likely to represent a health risk.

Where precautionary statements are warranted, Health Canada and the CFIA are advising the food industry to take a proactive approach and change the labels on pre-packaged foods to include one of the two precautionary statements outlined above during the course of 2007 and 2008.

Although precautionary labelling is voluntary, enforcement action will be taken when allergens are not clearly represented on pre-packaged foods and a potential health risk has been identified. Enforcement action can include product seizure, detention and recall, and may include prosecution.

Precautionary Statements

Precautionary statements may be used by food manufacturers and importers on the labels of pre-packaged foods where, despite all reasonable precautions, the presence of allergens in the food is unavoidable. Precautionary statements may not be used in lieu of good manufacturing practices and legal requirements.

Precautionary statements may not be used when an allergen is added directly or indirectly to a food. The allergenic ingredient must be accurately declared in the list of ingredients on the label.

Food Allergens

Most allergic reactions are caused by the following foods and their derivatives.

• Peanuts
• Tree Nuts (almonds, Brazil nuts, cashews, hazelnuts [filberts], macadamia nuts, pecans, pine nuts, pistachios, walnuts)
• Soy
• Milk
• Eggs
• Wheat
• Seafood (fish, crustaceans, shellfish)
• Sesame Seeds
• Sulphites

The CFIA is advising the food industry to review their allergen prevention practices and the use of precautionary statements.

The Use Of Food Allergen Precautionary Statements On Prepackaged Foods (Health Canada)

For more information, contact your local CFIA inspection office.

September 25, 2007