Introduction

In the food & beverage industry, managing allergens is of utmost importance to ensure the safety of consumers. As a food & beverage business owner or start-up founder, knowing how to properly declare allergens is crucial for compliance with the UK and EU food legislations and to provide accurate information to consumers.

This blog post will provide a comprehensive guide, including the complete list of allergens, declaring allergens based on product categories, distance selling, and the use of precautionary allergen labels.

We will also explore training and resources available, as well as best practices for preventing cross-contact and effectively managing allergens in your business.

By the end of this blog post, you will have the knowledge and tools to confidently navigate allergen management and ensure the safety of your consumers.

What are food allergens?

Food hypersensitivity

Food hypersensitivity can be classified into three categories: food allergies, food intolerances, and Coeliac disease.

🔸Food allergies are triggered by allergens, which are proteins found in food that can cause an immune response in certain individuals.

Allergic reactions can manifest in various ways, including itching around the mouth, rashes, vomiting, diarrhoea, difficulty breathing, and in severe cases, anaphylaxis or even death. These symptoms can occur shortly after consuming the allergenic food or several hours later.

🔸Food intolerances, on the other hand, do not involve the immune system and are generally not life-threatening. However, they can cause significant discomfort and have long-term health implications. Examples of food intolerances include lactose intolerance and gluten intolerance.

🔸Coeliac disease is a genetic and autoimmune disorder triggered by the consumption of gluten. Gluten is a protein found in wheat, rye, and barley. In individuals with Coeliac disease, the presence of gluten leads to an abnormal immune response, damaging the gut and causing malabsorption, nutritional deficiencies, and related complications.

The 14 food allergens

To ensure the safety of consumers with food allergies, accurately providing allergen information and effectively handling and managing food allergens in designated food preparation areas is a legal requirement.

There are 14 food allergens that have been chosen because they are the most common and dangerous:

To be considered as an allergen, Sulphur dioxide needs to be at concentrations of more than 10 mg/kg or 10 mg/L.

It's important to note that other foods such as chestnuts, pine nuts, and coconut, are not classified as part of the 14 main food allergens.

The FSA offers free allergen management training and resources, which is especially beneficial for individuals who produce food and beverage products at home or in their own establishments. As a reminder, allergen management is taken into account during food hygiene inspections and ratings. 

Allergen Labelling

Whether your product falls into the category of pre-packed food, food pre-packed for direct sale (PPDS), or non-prepacked food, it is mandatory to inform your consumers about the allergens present or possibly present in your product.

The main difference between product categories lies in how you display this information to consumers. Let's take a closer look!

Pre-packed food and Prepacked for direct sale Food (PPDS)

"Pre-packed" refers to any food that is packaged before being sold.

🔸Pre-packed food refers to food that is packed by one business and supplied to another. This includes any food products found in retailers, whether they are own-label or from other brands, that have been packaged elsewhere.

🔸Pre-packed for direct sale food (PPDS) is food that is packaged on-site or in moveable and/or temporary premises (e.g. market stalls, or sales vehicles) by the same food business, in preparation for an order from the final consumer. This category can include:
🔸Coffee shop pre-packed food and drinks that consumers select themselves (e.g. from a chilled display unit), such as sandwiches, salads, and pasta pots.
🔸Pre-packed In-store bakery, deli, and cheese counters in retail stores.
🔸Fast food that is packaged before it is ordered, such as a burger kept under a hot lamp.

The pre-packed food and PPDS food must be fully labelled with the food name and a complete ingredients list, including allergenic ingredients.

7 main allergen Rules to remember

1. Allergens information must be easily accessible and visible.
2. In the ingredients list, the allergenic ingredients must be emphasised every time they appear. For example, they can be listed in bold, in capital letters, in contrasting colours or underlined.
3. In the ingredients list, allergenic ingredients must be declared with a clear reference to the allergen to ensure clear and uniform understanding. Examples:
   🔸Tofu (soya)
   🔸Tahini paste (sesame)
   🔸Butter (milk)
   🔸Cod (fish)
   🔸Wheat flour (gluten)
4. Allergen advice statements can also be used on the product label to explain how allergen information is presented on a label, for example: “Allergen Advice: for allergens, see ingredients in bold”
5. If an ingredient's name partly includes an allergen in a single word, then emphasise only the name of the ingredient corresponding to the allergen, for example, sodium metabisulphite.
6. If your product is sold in multi-packs, the allergens must be displayed on the outer packaging. Additionally, if you provide allergen information on the packaging of individual products, it must match the information on the outer packaging.
7. Vegan doesn’t mean allergen free. Vegan products must be treated like any other food with potential allergens. This includes being cautious of cross-contact, even from animal-based allergens such as egg, fish, crustaceans, molluscs, and milk.

Food specifics

Cereals that contain gluten must be listed in the ingredients using the specific name of the cereal, such as “wheat starch (gluten)” or “barley malt extract (gluten)”.

At EPICSI, we follow the best practice recommended by The British Retail Consortium (BRC) guidance, which states that all milk products in the ingredients list should be clearly marked with the allergen milk, for example, "Butter (milk)".

Some food products, such as alcoholic drinks with more than 1.2% ABV, do not require an ingredients list. However, allergens still need to be mentioned by using the word "Contains" followed by the name of the allergen. For example: "Contains: sulphites, nuts and egg".

Non-prepacked food

Non Pre-packed food refers to any food that is packaged only after purchase.

This category can include:
🔸Coffee shop food and drinks behind a counter
🔸 Salad bar, deli and cheese counters in retail stores, where consumers usually ask counter staff for a certain weight of product.
🔸 Bread or pastries in bakery shop
🔸 Meat from butchers
🔸 Food from a takeaway
🔸 Meals served in a canteen, a buffet or a restaurant.
🔸 Fast food including drive-through

Non-prepacked food does not require standard food labelling with names, ingredients, and emphasised allergens.

However, allergen information still needs to be easily accessible and visible to consumers before they place their orders. This can be done through alternative means, such as directing consumers to where the information can be found or providing a statement on a notice, menu or a label next to the product.

In buffet settings where consumers self-select the products, allergen information should be provided for each food item separately.

Additionally, to enhance consumers service and choice, a food business could opt to provide a breakdown of allergenic components within a dish instead of only listing the allergens present in the entire dish.

To ensure that your staff is knowledgeable about the allergens in the products or dishes you sell, it is advisable to provide allergen information on a chart, in a recipe book, or on ingredient information sheets that can be easily accessed by your staff.

Distance selling

Distance selling refers to the sale of food or beverage products through channels that do not involve a direct physical interaction with consumers.

These channels include online platforms (e-commerce, takeaway menus, social media stores), mail order services, telephone orders, and television shopping.

Prepacked foods, Prepacked for direct sale food (PPDS) and non-prepacked food must ensure that mandatory allergen information is available to the consumer (for free) before the purchase is concluded. This can be done directly on your website or delivery services.

Additionally, it is important to include allergen details at the time of delivery. This can be done by placing stickers on food containers (e.g., Chicken satay: "Contains: wheat, soy, fish, peanut").

Alternatively, for caterer, a menu can be provided with the order, allowing the consumers to easily identify allergenic ingredients in the food. Another option is for the member of staff from the business delivering the food to present written allergen information to the consumer.

A Precautionary Allergen Label (PAL)

A Precautionary Allergen Labelling (PAL) statement, such as "may contain", should only be included on prepacked or non-prepacked foods if there is a confirmed risk of allergen cross-contact that cannot be effectively controlled through measures like segregation and cleaning.

PAL statements should not be used together with a “free from” statement for the same allergen because a “free from” claim guarantees the absence of the specified allergen. To declare “free from”, a food business must have implemented strict controls to eliminate any risk of cross-contact.

However, a “gluten-free” statement can be used in with a PAL statement as they are not absolute claims but instead indicate that the levels of gluten in the food are below 20mg/kg.

The Food and Drink Federation offers detailed information and guidance on free-from and gluten-free claims.

Avoid cross-contact

The term "cross-contamination" refers to the accidental transfer of harmful bacteria onto a food product, while the term "cross-contact" refers to the accidental transfer of allergens.

Both can occur during the manufacturing, handling, transportation, or storage of food.

To avoid or minimise cross-contact, it is important to conduct an allergen risk assessment when you are developing new products/meals or changing existing ones and implement a thorough allergen management protocol, such as:

Storage

Store ingredients and finished products that contain allergens separately, using appropriate allergen labels.

Manufacture

🔸Use separate utensils, equipment, and a food preparation area (e.g. a dedicated bench top) when handling ingredients that contain allergens. Implement a colour coding system to facilitate this process.

🔸If you are using a co-manufacturer, it is advisable to have separate production facilities for specific products. If that is not possible, try scheduling the production of foods in order of least allergenic to most allergenic.

Cleaning

🔸Ensure that all utensils and equipment are thoroughly cleaned before each use.

🔸All staff involved in handling ingredients, equipment, utensils, packaging and final food products should be aware of the possibilities of cross-contact with allergens and remember to regularly wash their hands thoroughly.

Record

Allergen ingredients information should be:
🔸Recorded on product specification sheets
🔸Included on ingredient labels, and ingredients should be kept in original or labelled containers
🔸Included in recipes or explanations of the dishes provided, considering the impact when recipes change
🔸Kept up to date

Conclusion

If you are setting up a food and beverage business, or starting an R&D project, whether it's new product development or improving existing products, managing allergens can be complex and overwhelming. However, it is a necessary process to ensure the safety of your consumers.

This guide aims to provide you with more information and clarity on how to declare allergens, no matter the type of product you sell (pre-packed or non pre-packed) or the type of selling (direct to consumer or online).

While we do our best to provide comprehensive guidance, we always recommend you to do your due diligence and reach out to your local authorities or experts, like us, if you need further assistance.

If you have any questions, feel free to reach out to us, and we will be more than happy to assist you!

Link to related blogs you may enjoy

🔶 The Ultimate Guide to Starting a Successful Food Business in the UK

🔶 Ensuring Transparency and Authenticity: Best Practices for Pictorial Representation on Food & Beverage Labelling

🔶 From Concept to Market: Steps to Launching Fortified Food and Beverage Products

🔶 The Ultimate Guide to Nutrition and Health Claims for Small Food and Beverage Businesses

References

Retained Regulation (EU) No. 1169/2011 on the provision of food information to consumers (“FIC”): https://www.legislation.gov.uk/eur/2011/1169/contents 

 Regulation (EU) No. 1169/2011 on the provision of food information to consumers: https://eur-lex.europa.eu/legal-content/EN/ALL/?uri=celex%3A32011R1169 

 Retained Regulation (EC) No. 178/2002 laying down the general principles and requirements of food law (General Food Law): http://www.legislation.gov.uk/eur/2002/178/contents 

 Regulation (EC) No. 178/2002 laying down the general principles and requirements of food law (General Food Law):https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX%3A32002R0178&qid=1673953749409 

FSA, Allergen guidance for food business, https://www.food.gov.uk/business-guidance/allergen-guidance-for-food-businesses 

FSA, allergen labelling for food manufacturers, https://www.food.gov.uk/business-guidance/allergen-labelling-for-food-manufacturers

FSA, Food allergen labelling and information requirements technical guidance, https://www.food.gov.uk/business-guidance/food-allergen-labelling-and-information-requirements-technical-guidance-summary 

FSA, allergen ingredients, food labelling decision tool, https://www.food.gov.uk/allergen-ingredients-food-labelling-decision-tool 

FSA, precautionary allergen labelling checklist, https://www.food.gov.uk/business-guidance/precautionary-allergen-labelling-checklist 

FSA, precautionary allergen labelling, https://www.food.gov.uk/business-guidance/precautionary-allergen-labelling 

FDF, gluten labelling guidance, https://www.fdf.org.uk/globalassets/resources/publications/guidance/fdf-gluten-labelling-guidance.pdf 

FDF, allergen labelling, https://www.reading.ac.uk/foodlaw/pdf/uk-12024-BRC-FDF-Allergen-Labelling.pdf 

FSA, Introduction to allergen labelling changes, https://www.food.gov.uk/business-guidance/introduction-to-allergen-labelling-changes-ppds#:~:text=Prepacked%20for%20direct%20sale%20or,it%20is%20ordered%20or%20selected. 

FSA, allergen labelling changes prepared for direct sales, https://www.food.gov.uk/sites/default/files/media/document/introduction-to-allergen-labelling-changes-prepacked-for-direct-sale-ppds_0.pdf 

FDF, guidance on free from allergen claims, https://www.fdf.org.uk/fdf/resources/publications/guidance/guidance-on-free-from-allergen-claims/