Food Allergen Labeling in Canada: Inside the Issue
In anticipation of the labeling regulations that took effect August 4, 2012, Claire Gagné, Senior Editor of Allergic Living, prepared the following FAQ. It’s based on e-mailed answers from Health Canada officials and a telephone interview with Marilyn Allen, a food allergy consultant to Health Canada and Anaphylaxis Canada.
Q. What will be different on the labels of the food products I purchase once the new regulations come into effect?
A. Right now when you look a label on a pre-packaged food, you see a listing of ingredients. However, sometimes ingredients can be “hidden.” For example, if an ingredient is a component of another ingredient, it doesn’t need to be listed. A company could list “flavouring” without specifying what makes up that flavouring.
Another way an ingredient can be hidden is by using a name that’s hard to identify. Examples include casein for milk, albumin for egg and tahini for sesame.
Under the new regulations, assuming they pass, companies must ALWAYS declare the presence of a priority allergen, gluten or added sulphites (when the total amount is 10 parts per million or more) in packaged foods. Also, they must state priority allergens in plain language (i.e.: milk, eggs, sesame).
Q. What are the priority allergens?
A. This is the list of priority allergens in Canada:
2. Tree nuts (Almonds, Brazil nuts, cashew nuts, hazelnuts, macadamia nuts, pecans, pine nuts, pistachios, walnuts)
6. Crustaceans, Shellfish
10. Sesame Seeds
11. Mustard (New)
In addition, gluten (from barley, oats, rye, triticale or wheat, including kamut or spelt) and added sulphites (when present in a total amount of 10 parts per million or more) would be subject to the same rules as the priority allergens.
Q. Why was mustard added as a priority allergen under Health Canada’s review of the regulations?
A. Health Canada published proposed labeling regulations in July of 2008. At that time, the public was allowed to comment and suggest changes. More than 140 comments were received, and some were from people asking for mustard to be considered a priority allergen. Some people also requested that onions and garlic be added to the list.
After the comments were received, Health Canada developed criteria by which foods can be evaluated to see if they should be priority allergens. This criteria says that when evaluating a potential priority allergen, Health Canada will look at the severity of reactions to the food, the data available on the prevalence of the allergen, as well as potential exposure to the food in Canada.
In the case of mustard, there wasn’t a lot of evidence to show that mustard allergy was widespread, however those who were allergic to it had severe reactions, and mustard itself is grown in Canada and widely used in packaged foods.
In the case of onions and garlic, it was found that reactions to those foods were less severe, and there was minimal risk of exposure to hidden garlic and onion.
Q. How will the allergens be identified on the label?
A. Originally, the proposed regulations stated that the priority allergens would have to either be listed within the ingredient list or in a statement at the end of the ingredients with the wording “Allergy and Intolerance Information – Contains:”
After the review of public comments, Health Canada has decided that if the manufacturer chooses to put the information at the end of the list of ingredients, simply using the word “Contains:” before listing ingredients would be more user friendly for customers and manufacturers.
Q. What products do these new labeling rules apply to?
A. The new labeling regulations will apply to all pre-packaged food sold in Canada. However, it does not apply to food prepared and sold on the same premises. For example, a package of candy prepared from bulk bins and sold at the same store, or a chicken roasted at the supermarket. However, if any of these foods have an ingredient label on them, the label must adhere to the regulations.
Q. Are there new labeling rules for alcohol?
A. Yes. These regulations apply to alcohol as well. If any alcohol sold in Canada contains a priority allergen (including sulphites) it must be declared on the label.
In the original proposed regulations (published in Canada Gazette Part 1), there was an exemption for standardized beverages (for example, beer, wine, rum, whiskey and gin) made with fining agents derived from eggs, milk or fish. After the comment period, Health Canada removed this exemption, and now all alcohol will have to list any priority allergens it contains. [*Just before passing the regulations, Health Canada granted the beer industry an exemption from allergen/gluten labeling.
Q. What about wax coatings on produce?
A. In the proposed regulations, there was also an exemption on wax coating on produce, which can be made with milk, soy or other allergens and may contain gluten. However, this exemption was removed after the comment period.
However, this applies only to produce that has been pre-packaged, not to produce sold individually (as most is sold). Also, the pre-packaged produce is not required to have a label listing all of the ingredients in the wax coating, rather, only the priority allergen must be declared.
The Canadian Food Inspection Agency has issued guidance to the industry requesting that they not use priority allergens in wax coatings.
Q. I have a sulphite allergy. What do I need to know about labeling?
A. Under the proposed regulations, sulphites that are present in a food product at a level of 10 parts per million or higher would have been required to be listed in a “Contains:” statement at the end of an ingredient list. This differs from the priority food allergens, which could be listed either within the ingredient list, or a separate “Contains” statement after the list.
After the review of public comments, Health Canada has determined that sulphites can either be listed within the list, or at the end.
Q. When do companies need to start abiding by these rules?
A. The amended regulations come into effect Aug. 4, 2012, following a transition period for manufacturers and importers. However, Health Canada is urging companies to clearly label priority allergens on their packaged goods before that date where possible.
Q. Do these rules apply to statements like “This product may contain” (specific) allergens?
A. No, these rules do not apply to “may contains” and other similar statements. Health Canada is reviewing its policy on these statements and will be holding public consultations in the future. It has held public consultations and will be publishing findings in the future.
Links of Interest:
Additional Sources: Health Canada information pages.
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