Advisory Labels: May Contain Confusion
The authors say that advisory labels can lead to risk-taking behavior in consumers. Someone may think they’re “safe” to consume products with an advisory label simply because they’ve done so in the past without reacting – but in reality, as the study showed, even two different lot numbers of the exact same product can have varying allergen levels, let alone products from different companies.
As well, many consumers incorrectly believe that the specific wording used is associated with a different level of risk: a previous report by the FDA found that both allergic and non-allergic consumers believed a product with the shorter “may contain [allergen]” warning was more likely to contain that allergen than products with a longer warning, such as “made in a facility that also processes ….”
“This is definitely a hazardous practice,” notes Taylor of FARRP, since advisory labels are completely voluntary. While labeling of the Top 8 allergens (Top 11 in Canada) is required if any of them is in an ingredient of a product, advisory labels for unintended inclusion of an allergen (this can occur in processing) remains voluntary. There are no rules governing when a manufacturer must include an advisory label, or which words to use.
In the same vein, just because a food item says it may contain “traces” of peanuts doesn’t mean that any peanut present will be a trace amount. In fact, there is no standardized definition for the word “trace”, says Taylor, so, like the other advisory statements, there is no reason to believe that a product with this warning would be less likely to cause a reaction.
“This choice of advisory labeling term is probably one of the worst, because consumers may believe that it signifies a lower risk,” says Taylor.
He says that until something is done about the current state of advisory labeling, it’s best for food-allergic consumers to avoid products with any of the warning variations. Moving forward, he says the FDA should be encouraged to improve advisory labeling.