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Food Allergies - A Q&A

Q. What is a food allergy?

A. Food allergies are allergic reactions to food or an ingredient in a food (an allergen). Symptoms may vary in severity and most reactions occur within minutes but some may take up to several hours.

Q. What are the commons symptoms?

A. The symptoms of a food allergy stem from a response by the immune system to a food that the body incorrectly recognises as harmful. There are a range of symptoms that vary in severity from person-to-person, which can make diagnosis difficult.
Immediate symptoms include:
• coughing, wheezing, breathlessness and sneezing
• uticarial (‘nettle’) rash and hives visible on the skin
• rapid onset of itching of the eyes, nose, throat, lips, mouth, or back of throat, swelling of the lips, tongue, throat, and palate.

Other symptoms can include:
• diarrhoea, constipation, stomach cramps, eczema, vomiting, severe gas, weight loss, vitamin and mineral deficiencies.

Q. What are the common causes?

A. The most commonly known foods to cause an allergic reaction are cereals containing gluten, fish, shellfish and crustaceans, peanuts and other nuts, eggs, soybeans, milk, sesame seeds, celery, mustard, sulphur dioxide and sulphites etc. It is not only these ingredients that must be avoided but also their altered form (derivatives) that are used in food manufacture which may not be so obvious on a label.

Q. What is Anaphylaxis?

A. Anaphylaxis is the most severe type of allergic reaction which occurs in susceptible individuals. Symptoms include itching, tingling around mouth and back of throat, difficulty breathing and sudden drop in blood pressure. In severe cases, death may occur.
The most common allergens linked with anaphylaxis are nuts, fish and shellfish, eggs,
dairy products, soya, sesame seeds and wheat.

Q. What can food allergen suffers do?

A. Reading ingredient labels for all foods, to determine whether or not there are allergens
present, is crucial in managing an allergy. If there are uncertainties regarding unfamiliar ingredients or terms used on the label, contact the manufacturer or avoid eating that product.

Q. What is the legislation concerning the labelling of allergens in foodstuffs?
A. Directive 2000/13/EC on the labelling, presentation and advertising of foodstuffs was amended by Directive 2003/89/EC as regards the indication of ingredients present in foodstuffs, which required that certain allergenic ingredients and products thereof must be indicated on the label of a foodstuff. This Directive amended Directive 2000/13/EC through the addition of Annex IIIa which lists these allergens. This Annex has subsequently been updated byDirective 2006/142/EC (addition of lupin and molluscs to the list of allergens) and Directive 2007/68/EC.
This requires manufacturers to declare if certain allergens are present in a food. This relates to whether the allergen itself or its derivatives are present in the finished product.

Q. How has this legislation changed the way pre-packaged foodstuffs are labelled?
A. With few exceptions, this legislation requires that all ingredients must now be listed on pre-packaged foodstuffs and that the presence of recognised allergens must be clearly labelled.

Q. What ingredients are legally defined as ingredients known to cause allergies which must be declared on the label of the food?

A. There are 14 categories of ingredients (and products thereof) legally defined as ingredients that are known to cause allergies which must be declared on the label of the food. These are:
• celery and celeriac
• cereals containing gluten (i.e. wheat, rye, barley, oats, spelt, kamut or their hybridised strains)
• crustaceans (including crabs and prawns)
• eggs
• fish
• lupins
• milk (including lactose)
• molluscs (such as mussels and oysters)
• mustard
• tree nuts (including Brazil nuts, hazelnuts, almonds and walnuts)
• peanuts (groundnuts or monkey nuts)
• sesame seeds
• soya
• sulphur dioxide or sulphites

Q. What responsibilities lie with the food business operator?

A. Manufacturers must indicate the presence of any of the allergens specified in the list on the product label. The manufacturer must also clearly indicate on the label the name of the ingredient from which the allergen originates, e.g. lactose in the final product must indicate that milk was used in the manufacture of the food.
Alcoholic beverages (i.e. beverages containing more than 1.2% by volume of alcohol) are not required to declare a list of ingredients but must indicate the presence of any allergenic ingredients on their labels. This may be achieved through the declaration indicating the allergen in the name of the product such as ‘wheat beer’ Therefore, any declaration on the label indicating the presence of the allergen is sufficient, whether that is:
• in the list of ingredients
• the sales names
• clearly stated elsewhere on the label.

Q. Are there exceptions for labelling allergens?

A. Generally, all foods must declare any allergenic ingredients, however, there are
some exceptions. These include foods:
• that are sold loose such as over the counter sales, e.g. loose sausages
• that are packaged for direct sale (i.e. packaged on the same premises from where they are sold), e.g. delicatessen products do not have to indicate allergens.
• Where the name of the product clearly refers to the allergen, separate labelling is not required, e.g.’ cake flavoured with almonds’ will not need separate allergen labelling.
• Dairy products sold as cheese, butter or yoghurt clearly are milk - products and milk would not need to be declared separately as an allergen.

Manufacturers may also indicate on products that they have been made in a factory where allergens are also used, even though the product does not contain such ingredients, e.g.’ may contain nuts’. This is not a legal requirement and not recommended practice over good manufacturing practices (GMP) and HACCP controls, to prevent cross contamination.
Q. Are there any exemptions from having to declare any of the ingredients listed in Annex IIIa?
A. Since it is possible that some ingredients or substances derived from allergens are not likely to pose a threat for consumers with allergies, Directive 2003/89/EC provides for the possibility of excluding from the labelling requirements ingredients or substances derived from ingredients in Annex IIIa for which it has been scientifically established that they are not likely, under specific circumstances, to trigger adverse reactions.
Following assessment by the European Food Safety Authority (EFSA) Commission Directive 2005/26/EC, as corrected by Commission Directive 2005/63/EC, listed the food ingredients and substances provisionally excluded from Annex IIIa of Directive 2000/13/EC until 25 November 2007.
Directive 2005/26/EC was repealed on 26 November 2007 by Directive 2007/68/EC amending Annex IIIa to Directive 2000/13/EC as regards certain food ingredients. On the basis of EFSA opinions and other available information, certain ingredients or substances derived from these ingredients can now be permanently excluded from Annex IIIa, as they are not considered likely to cause adverse reactions in susceptible individuals. Table 1 lists these excluded food ingredients and derived substances.
Table 1: List of food ingredients and derived substances excluded from Annex IIIa of Directive 2000/13/EC
Ingredients
Products thereof excluded
Cereals containing gluten
(a) Wheat based glucose syrup including dextrose 1;
(b) Wheat based maltodextrins 1;
(c) Glucose syrups based on barley;
(d) Cereals used for making distillates or ethyl alcohol of agricultural origin for spirit drinks and other alcoholic beverages.
 
Fish
(a) Fish gelatine used as carrier for vitamins or carotenoid preparations
(b) Fish gelatine or Isinglass used as fining agent in beer and wine.
 
Soybeans
(a) Fully refined soybean oil and fat 1.
(b) Natural mixed tocopherols (E306), natural D-alpha tocopherol, natural D-alpha tocopherol acetate, natural D-alpha tocopherol succinate from soybean sources;
(c) Vegetable oils derived phytosterols and phytosterol esters from soybean sources;
(d) Plant stanol ester products produced from vegetable oil sterols from soybean sources.
 
Milk
(a) Whey used for making distillates or ethyl alcohol of agricultural origin for spirit drinks and other alcoholic beverages;
(b) Lacticol.
 
Nuts
(a) Nuts used for making distillates or ethyl alcohol of agricultural origin for spirit drinks and other alcoholic beverages;
 
(1) And products thereof, in so far as the process that they have undergone is not likely to increase the level of allergenicity assessed by the EFSA for the relevant product from which they originated
Q. Will the list of allergens in Annex IIIa be reviewed in the future?
A. Directive 2003/89/EC required that the first re-examination of Annex IIIa take place by 25 November 2005 at the latest. This has been carried out and the Annex was updated by Directive 2007/68/EC. It is expected that the list of allergens be systematically re-examined and where necessary updated on the basis of the most recent scientific knowledge.
Q. Where on the label must the declaration of allergens be made?
A. The legislation does not specify where on the label the allergen information must appear, however, it must be clear to the consumer that the allergen is present. So, for example, if milk powder is listed in the list of ingredients it is clear to the consumer that the food contains milk. However, if casein is listed the consumer may not be aware that this is a milk protein. In this instance the word ‘milk’ in brackets could be inserted beside casein in the list of ingredients and/or a ‘contains box’ may be used. This would also apply to other unusual names such as lysozym (egg), unusual fish species or other uncommon names that may not be understood by the consumer as being allergenic.
Alcoholic beverages with an alcohol content of more than 1.2% by volume and other foodstuffs not requiring a list of ingredients under Directive 2000/13/EC, must read ‘contains’ on the label e.g. contains egg, contains wheat, unless it is clear from the name of the product that the allergen is present e.g. wheat beer.
Manufacturers may in addition voluntarily provide a ‘contains’ list on the label whether it is necessary or not.
Q. When and how should sulphites be declared on a food label?
A. Sulphur dioxide and sulphites must appear on the label under their chemical names e.g. sodium metabisulphite, where present at levels exceeding 10mg/kg or 10mg/l, expressed as SO2. Labelling the category and the additive number is not sufficient. Therefore, it is not enough to label as preservative: E220.

Further details can be found on the FSAI website www.fsai.ie