Module 4

The  EU FIC requirements mean allergenic ingredients need to be clearly emphasised within the ingredient list. Ingredients are listed in descending order of their weight, with the largest ingredient first. If an ingredient is mentioned in the name (such as chicken in chicken pie), is depicted on the label, or is usually associated with the food (as lamb is with shepherd's pie), the amount contained in the food will be given as a percentage.

Where an ingredient is made up of other ingredients (compound ingredients), with a few exceptions, these must also be declared in the ingredients list.

The use of "allergy advice boxes" to repeat mandatory information on allergenic ingredients is not permitted under the EU FIC. All allergenic ingredients contained in a prepacked product should be listed clearly within the ingredients list.

Any precautionary allergen information provide about allergens must not mislead the consumer, must not be ambiguous or confusing, and where appropriate be based upon scientific data. The use of precautionary allergen labelling when there is not a real risk could be considered to be misleading food information.

Some food manufacturers may voluntarily use labelling such as ‘produced in a kitchen which uses…’ or ‘may contain’ or ‘not suitable for…’ to communicate the risk of the unintentional presence of an allergen (e.g. milk, egg, peanuts, almonds) in a food product due to the allergen entering the product accidentally, or through cross contamination.

These statements should only be used after a meaningful risk assessment has been performed and there is considered to be a significant and real risk to the food allergic or food intolerant consumer and should not be used as a substitute for good hygiene and safety practices.

About 1% of people in the UK have coeliac disease which is a life-long autoimmune disease where the body attacks its own tissues, such as the lining of the stomach, when gluten is consumed. People with coeliac disease need to avoid foods that contain gluten to prevent potentially serious health effects. This means labelling claims about gluten in foods are very important. Foods that contain gluten include wheat, rye and barley.

The Commission Implementing Regulation (EU) No. 828/2014, Enforced in Scotland by The Food Information (Scotland) (Amendment) Regulations 2016 established levels of gluten for foods that makes a claim to be either 'gluten-free' or 'very low gluten'. These levels are:

• 'gluten-free' – 20 mg/kg of gluten.
  'very low gluten' – 100 mg/kg of gluten. However, only foods with cereal ingredients that have been specially processed to remove the gluten may make a 'very low gluten' claim.

Manufacturers and caterers can only use the phrase 'gluten-free' if they can demonstrate that, when tested, their product is 20 parts or less of gluten per million. They will also be required to demonstrate that any products claiming to be 'very low gluten' comply to the legislation.

Manufacturers and caterers producing foods with no deliberate gluten containing ingredients, but due to the high risk of gluten cross-contamination, will be unable to label foods as 'gluten-free' or 'very low gluten'. However, if steps have been taken to control gluten cross-contamination, these manufacturers may be able to indicate which foods do not contain gluten-containing ingredients. This allows people with coeliac disease to make informed choices about the food they eat based on their individual levels of sensitivity.