| Comments for FDA General |
| Questions |
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1. What plain English terms would be understandable for the eight most common food allergens?
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one
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2. What source or plain English labeling format or formats would be most informative to consumers? Are the formats from the Food Allergy Issues Alliance appropriate and sufficient? Are the recommendations in the petition from the Attorneys General of nine states warranted and beneficial? Are multiple formats confusing to consumers, and if so, is there a single format that would be preferable? If so, why?
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two
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3. Should source or plain English labeling be voluntary or mandatory for the eight most common food allergens?
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three
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4. Under what circumstances, if any, should advisory labeling statements (e.g., "May contain [name of allergen]") be permitted, and what impact would those circumstances have on manufacturers and on consumers? Should the recommendations in the petition from the Attorneys General of nine states be adopted? Do the criteria from the Food Allergy Issues Alliance form a reasonable basis for determining when a manufacturer may use advisory labeling on a particular product or should other criteria be used? Why?
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four
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5. Are there better alternatives for advisory labeling than the type of wording that currently exists (e.g., "May contain [name of specific allergen]," "Made on shared equipment," "Manufactured in a facility that also processes [name of specific allergen]")? Do such statements adequately inform consumers of possible cross-contact with allergenic materials? How do consumers interpret the wording of such labeling? Should advisory labeling statements be prescriptive (i.e., one or more specific statements) or flexible?
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five
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6. Where should advisory labeling statements be located on the food label? How prominent should advisory labeling statements be on the label? Should the location and prominence of advisory labeling statements be prescribed?
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six
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7. Should the agency continue to address the labeling of individual allergenic flavorings, spices, and colors on a case-by-case basis, or should there be a generally applicable policy? Should the information on allergenic components of flavorings, spices, and colors be included in the ingredient list? Is there a better location or format for this information? Explain. For individual flavorings, spices, or colors that contain one of the eight most common allergens, should listing the common or usual name of the individual flavoring, spice, or color on the product labeling be voluntary or mandatory?
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seven
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8. What, if any, minor ingredients would manufacturers be unlikely to recognize as containing food allergens and therefore not include on the label, and what kinds of manufacturing processes would manufacturers be unlikely to recognize as introducing unintended food allergens? When products that contain food allergens will be further processed or repacked, is food allergen labeling sufficient on such intermediate products or is it necessary to have clearer labeling on intermediate products to ensure that food allergens are appropriately declared on the retail packaging of the final product? Should the agency codify its policy to specifically state that incidental additives that are food allergens are not exempt from labeling and must be declared in the ingredient statement on the label?
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eight
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9. Add any general comments on food allergen labeling for the eight most common food allergens.
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nine
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