Apprentice, Allergen, Advice
As the 2017 series of The Apprentice drew to a close, one of the previous winners also had a newsworthy event happening. Alana Spencer’s business – Ridiculously Rich by Alana- had a recall involving 18 products. This was because some allergens had not been listed and others had not been correctly declared as required by law.
The allergens involved were Soya, Wheat, Barley, Oats, Peanuts, Sulphites, Egg, Nuts, Milk.
The regulations regarding labelling of these allergens require any of the 14 allergens listed in EU Food Information for Consumers Regulation No. 1169/2011 to be marked differently to any non-allergen containing ingredient, although the differentiation is not specified. For example, some businesses choose to use a different colour and some use a bold lettering. I have seen packaging where it is not possible to read the allergens, because the text was dark on black packaging. These regulations require any food packed after 13th December 2014 to be labelled in accordance with the regulations. Where food is sold unwrapped, such as restaurants, these were required to be available upon request from this date. These regulations have been in force for nearly three years when the recall was made, yet a famous brand was impacted. This is an example of recalls that happen on a regular basis for allergens, where the allergens have not been labelled correctly or are omitted.
Which Allergens need to be labelled?
The allergens that are in the Regulations are:
- cereals containing gluten, such as wheat (including spelt and khorasan wheat), rye, barley and oats
- crustaceans, e.g. prawns, crabs, lobster, crayfish
- milk (including lactose)
- nuts i.e. almonds, hazelnuts, pistachio nuts, pecan nuts, walnuts, Brazil nuts and macadamia (or Queensland) nuts
- celery (including celeriac)
- sesame seeds
- sulphur dioxide/sulphites, if there are more than 10 milligrams per kg or 10 milligrams per litre in the finished product
- lupin, including lupin seeds and flour
Pre-packed food is any food that’s put into packaging before being put on sale and that cannot be altered without opening or changing the packaging. As a minimum, all food and drink sold pre packed, for sale must have the following information on the pack. The pack is as delivered to the final consumer, in the language of the country where it is sold.
- Legal name of the product.
- Ingredients declaration in descending order and highlighting any allergens, as listed in EU Regulation 1169/2011, as well as a QUID declaration. (Quantitative Ingredients Declaration)
- Any warnings about specific ingredients, including novel ingredients such as chia seeds
- Durability coding (Use by or Best Before)
- Weight or volume using metric units and indication of average weight or minimum weight.
- Name and address of the manufacturer, seller or packer
- Lot number or an indication of the batch
- Any special storage conditions (e.g. keep refrigerated)
- Any instructions for use, if necessary (e.g. cooking instructions)
The following may also have to be added, if appropriate:
- drinks with an alcohol content above 1.2% have to carry a warning
- if the product contains GM ingredients, unless their presence is accidental and 0.9% or less, there has to be a warning to this effect.
- if the product has been irradiated, a warning must be applied.
- the words ‘packaged in a protective atmosphere’ if the food is packaged using a packaging gas
- Country of origin declaration, where it is proscribed by law or to omit it would mislead the consumer.
- Nutrition declaration
There is a lot of information for the manufacturer to provide and it is essential to check any changes to formulation or ingredients, prior to use and sale.
I have extensive experience in manufacturing and supply chain compliance, with a passion for integrity and making systems as simple as possible.
I can help avoid these mistakes.
I can offer a one-day audit of a sample of your products. This will save you unlimited amounts of stress and loss of earnings with your customers.
Call me on 01886 834815 to book a 30 minute free, no obligation consultation call.