From 2009 to 2010, Health Canada consulted with key stakeholders, including the Canadian public, on policy options to improve the use of precautionary labeling (also known as “may contain” labelling) in identifying the potential presence of allergens in packaged foods. Currently, “may contain” labeling is used on a voluntary basis in Canada, as well as in many other countries, including the U.S.

The proposed options for improving the policy ranged from keeping “may contain” statements voluntary to making them mandatory by law.

The findings of the consultation:

• None of the proposed options for the policy renewal reached a clear consensus among stakeholders. Perhaps not surprisingly, individuals voiced a preference for fully regulating “may contain” labels, whereas the food industry would prefer not to be required to use the precautionary labels.
• The majority  (65% of all participants) felt comfortable with the “mixed voluntary / regulatory approach.” This approach would mean that manufacturers and importers would not be required to use “may contain” labeling, but new laws would regulate the way the labels are used when a company chooses to use them.
• The concerns expressed towards non-regulated approached were largely related to the potential for misinterpretation of the absence of precautionary statements (i.e. not knowing if safety has been assessed when no precautionary statement is present). That said, the non-regulated approaches were identified as less costly and their implementation was viewed as being achievable in a shorter period of time, as well as providing more flexibility to the food industry.
• The main concerns expressed towards regulated approaches were related to the lack of allergen thresholds, the sense of false security that the mandatory nature of a measure could produce among individuals with food allergies, and the time and costs associated with the implementation of mandatory measures across the industry.  The main advantages identified for the regulated approaches were both the accountability of the food industry and the provision of a fair and common market being assured by imposing the same standards across Canada and for domestic and imported foods.
• Participants said the biggest issues that concern them are:
  1) the overuse of allergen precautionary statements (for example, precautionary statements believed to be used when there is no real risk, for legal protection, etc.)
  2) consumer difficulty in interpreting the level of risk posed by a product using these statements (or example, when precautionary statements are absent, when they express different level of risks or because of too many different wordings, etc.).
• 80% of respondents to the online consultation indicated that their single biggest issue is not knowing if safety has been assessed when no precautionary statement is present.

To read the full summary of Health Canada’s public consultations about precautionary food allergen labeling, click here.

1990 Petition from Allergy/Asthma Information (AAI) patient group asking Health Canada (HC) for complete allergen labelling on food products.

1993 HC and Agriculture and Agri-Food Canada formed a joint committee to develop a science-based list of foods causing severe allergies and sensitivities.

October 15, 1994 Pre-publication of a regulatory proposal in Canada Gazette, Part I, for mandatory label declaration of sulphites present in foods at a level ≥10 ppm.

March 11, 1996 Consultation document sent for comment to stakeholders (food and beverage industry, health professionals, patient & consumer groups) about proposed labelling of allergens and gluten sources.

March 31, 1998 Canadian Food Inspection Agency (CFIA) issued an advisory letter to food manufacturers, importers and distributors encouraging voluntary labelling of proposed allergen list.

1999 Common Allergenic Foods and Their Labelling in Canada-A Review, written by Zarkadas, et al. published in the Canadian Journal of Allergy and Clinical Immunology 1999:4:118-141.

2003 A Business Impact Test (BIT) commissioned by HC and CFIA to consult with industry on potential costs of implementing allergen labelling.

February 19, 2004 HC issued letter announcing: “Proposed Regulatory Amendments to Enhance Labelling of Priority Allergens in Foods”, to be published in Canada Gazette, Part 1, in mid-2004 and asking for stakeholder feedback.

September 27, 2004 Letter from HC to stakeholders that fining agents derived from milk, egg and fish used in standardized alcoholic beverages will be exempt from label declaration, but that labelling of priority allergens, gluten and sulphite would apply to beer and wine.

March 23, 2007 CFIA issued allergen labelling alert to industry.

June 2008 Allergy and celiac organizations support write-in campaign, led by Allergic Living Magazine, urging the federal government to pass food labelling regulations drafted by HC. Over 4000 letters sent to the Prime Minister.

July 22, 2008 HC issued letter urging manufacturers to declare major food allergens, gluten sources and added sulphites ≥10ppm

July 26, 2008 Amendments to Food and Drug Regulations for allergen, gluten and sulphite labelling, were published in Canada Gazette, Part 1, with a 120 day consultation period.

July 26, 2008 Minister of Health Tony Clement announced: “The Government of Canada is taking action to protect the health and wellbeing of Canadians with food allergies and celiac disease…these new proposed labelling requirements will provide Canadians with the information they need to manage their own allergies, and give parents greater assurance about the food they give their children who may have allergies.”

July-November 2008 Over 140 comments submitted from the food and beverage industry, consumers, patient groups, health professionals, and other governments, for review by HC.

March 11, 2009 CFIA issued reminder notice about allergen labelling.

June 2010 Health Canada’s Modifications to Schedule 1220 Regulation Amendments announced: Addition of mustard seed to list of allergens “Allergy and Intolerance Information- Contains:” statement to be changed to “Contains:” (same as USA). Fining agents derived from eggs, fish or milk used in the production of alcoholic beverages will no longer be exempt from labelling. Transition period for industry changed from 12 to 18 months.

October 2010-February 2011 Public awareness campaign begun by allergy and celiac associations urging government to pass food labeling regulations. To date, over 8500 letters/emails sent to the Prime Minister in support of regulations.

November 2010 Letters sent from allergy groups (Canadian Society of Allergy & Clinical Immunology, Anaphylaxis Canada, AAIA, AQAA, Allergic Living), Canadian Celiac Association and Dietitians of Canada urging Minister of Health Aglukkaq to pass food labelling regulations.

December 16, 2010 Minister of Health Aglukkaq met with Anaphylaxis Canada representatives and provided assurance that regulations would pass in 2011.

January 2011 Minister of Health Aglukkaq issued letters to Anaphylaxis Canada, Canadian Celiac Association and Dietitians of Canada assuring them that regulations are top priority and will be passed in early 2011.

February 1, 2011 Letters from Dietitians of Canada urged the Prime Minister to pass regulations immediately.

February 2, 2011 Open letter to Prime Minister, Minister of Health, Minister of Industry, President of the Treasury Board & Minister for the Asia-Pacific Gateway and Minister of Agriculture, urging government to pass regulations immediately. Letter was signed by:

• Canadian Society of Allergy and Clinical Immunology
• Canadian Allergy, Asthma and Immunology Foundation
• Anaphylaxis Canada• Association québécoise des allergies alimentaires
• Allergic Living Magazine
• Allergy/Asthma Information Association
• Canadian Celiac Association
• Fondation québécoise de la maladie coeliaque

February 3, 2011 Letter sent to the Prime Minister in support of passing food labelling regulations by Canada’s peak body of allergy, the Canadian Society of Allergy & Clinical Immunology

Document dated: February 9th, 2011

Compiled by Shelley Case, RD

Reading labels is a way of life when you have celiac disease. Before eating anything in a package, be sure to read the label carefully. Look for hidden sources of gluten and for other names, such as food starch, seasoning and hydrolyzed vegetable protein.

Also be on the lookout for precautionary statements. These are statements that indicate gluten may be in the food, due to cross contamination. Examples of precautionary statements include: “May contain gluten” and “Manufactured in a facility that also processes wheat.”

If you are ever uncertain about whether a food product is safe for you, call the manufacturer to confirm. When in doubt, don’t eat it.

In Canada, new regulations have been proposed that would require food manufacturers list priority allergens, including gluten, in plain language on packaging. Ingredients of ingredients that are priority allergens would also have to be listed. For example, manufacturers couldn’t simply list “modified starch” if the source of the starch is wheat.

More on Canada’s Food Allergen Regulations

Health Canada is also reviewing its gluten-free labeling requirements. Specifically, it is looking at whether a change should be made to the rule that food made with oats cannot be labeled gluten-free. This is in light of the fact that pure, uncontaminated oats are safe for most people with celiac disease and are available in Canada. More on the proposed changes.

In the United States, the Food Allergen Labeling and Consumer Protection Act, which went into effect in 2006, requires manufacturers to use plain language when listing priority allergens, and to declare all allergens either in the ingredient list, or in a “contains:” statement at the end of the list. This act encompasses wheat, but not other sources of gluten.

Currently in the United States there is no rule governing what can be called “gluten-free” on a food label. A rule was proposed in 2007, but has not been approved.

See: U.S. Proposed Rule on Gluten-Free Labeling

Reading labels is a way of life when you or a member of your family has an allergy to sesame. Before eating anything in a package, be sure to read the label carefully. Look for hidden sources of sesame or other seeds that may be troublesome to you and alternate names shown for them.

Also be on the lookout for precautionary statements. These are statements that indicate an allergen may be in the food, due to cross contamination during processing. Examples of precautionary statements include: “May contain sesame” and “Manufactured in a facility that contains sesame.”

Allergists generally advise people with  sesame or other seed allergies to avoid all products that contain precautionary statements about their allergens. If you are ever uncertain about whether a food product is safe for you, call the manufacturer to confirm. When in doubt, don’t eat it.

In Canada, new regulations have been proposed that would require food manufacturers list priority allergens in plain language on packaging, rather than using alternate names (ie: tahini, for sesame). Ingredients of ingredients that are priority allergens would also have to be listed. For example, manufacturers couldn’t simply list “flavouring” if the source of the flavouring is a priority allergen, such as mustard.

More on Canada’s New Food Allergen Regulations.

In the United States, the Food Allergen Labeling and Consumer Protection Act went into effect in 2006. FALCPA requires manufacturers to use plain language when listing priority allergens, and to declare all allergens either in the ingredient list, or in a “Contains:” statement at the end of the list.

The allergens included in this regulation are milk, eggs, fish, shellfish, tree nuts, wheat peanuts and soybeans. These regulations do not include sesame and mustard, unlike the proposed Canadian regulations.

Separate legislation requires companies to declare sulphites if they are present at more than 10 parts per million, or if they had a technical or functional effect in the food.

Both Canada and the United States are studying ways to regulate the precautionary statements used on packaged food labels.

When a family member has an allergy, reading is protection.

Reading the ingredients on every packaged food label becomes a way of life when you have food allergies and are at risk of anaphylaxis. Labels have to be carefully before a food is sampled by the allergic family member. While labels are supposed to by law be written in plain English, look for hidden sources of allergens and other less obvious names for allergens (such as “casein” or “whey” for milk).

Also be on the lookout for precautionary statements. These are statements that indicate an allergen may be in the food, due to cross-contamination during production. Examples of precautionary statements include: “May contain wheat” and “Manufactured in a facility that also processes tree nuts.”

Allergists generally advise people with allergies to avoid all products that show such statements about their allergen(s) – dubbed “may contains” – because they often “do contain” the allergen.

If you are ever uncertain about whether a food product is safe for you, call the manufacturer to confirm. When in doubt, don’t eat it.

In Canada, new regulations come into effect in August, 2012 that would require food manufacturers list priority allergens in plain language on packaging, rather than using alternate names (ie: arachidic acid, for peanuts). The ingredients within listed ingredients that are priority allergens would also have to be shown. For example, manufacturers couldn’t simply list “flavouring” if the source of the flavouring is a priority allergen, such as mustard.

More on Canada’s New Food Allergen Regulations.

In the United States, the Food Allergen Labeling and Consumer Protection Act went into effect in 2006. FALCPA requires manufacturers to use plain language when listing priority allergens, and to declare all allergens either in the ingredient list, or in a “Contains:” statement at the end of the list.

The allergens included in this regulation are milk, eggs, fish, shellfish, tree nuts, wheat peanuts and soybeans. These regulations do not include sesame and mustard, unlike the new Canadian regulations.

Separate legislation requires companies to declare sulfites if they are present at more than 10 parts per million, or if they had a technical or functional effect in the food.

Both Canada and the United States are studying ways to regulate the precautionary statements used on packaged food labels.

Reading labels is a way of life when you or a member of your family has a tree nut allergy. Before eating anything in a package, be sure to read the label carefully. Look for hidden sources of nuts and alternate names for it.

Also be on the lookout for precautionary statements. These are statements that indicate an allergen may be in the food, due to cross contamination during processing. Examples of precautionary statements include: “May contain tree nuts” and “Manufactured in a facility that contains tree nuts.”

Allergists generally advise people with tree nut allergies to avoid all products that include precautionary statements about their allergen. If you are ever uncertain about whether a food product is safe for you, call the manufacturer to confirm. When in doubt, don’t eat it.

In Canada, new regulations have been proposed that would require food manufacturers list priority allergens in plain language on packaging, rather than using alternate names (ie: Bertholletia excelsa instead of brazil nut).

The ingredients within listed ingredients that are priority allergens would also have to be shown. For example, manufacturers couldn’t simply list “flavouring” if the flavouring included a priority allergen, such as almond extract.

More on Canada’s New Food Allergen Regulations.

In the United States, the Food Allergen Labeling and Consumer Protection Act went into effect in 2006. FALCPA requires manufacturers to use plain language when listing priority allergens, and to declare all allergens either in the ingredient list, or in a “Contains:” statement at the end of the list.

The allergens included in this regulation are milk, eggs, fish, shellfish, tree nuts, wheat peanuts and soybeans. These regulations do not include sesame and mustard, unlike the proposed Canadian regulations.

Separate legislation requires companies to declare sulphites if they are present at more than 10 parts per million, or if they had a technical or functional effect in the food.

Both Canada and the United States are studying ways to regulate the precautionary statements used on packaged food labels.

Reading labels is a way of life when you or a member of your family has an allergy to sulphites, the food additive. Before eating anything in a package, be sure to read the label carefully. Look for hidden sources of sulphites and alternate names for it.

If you are ever uncertain about whether a food product is safe for you, call the manufacturer to confirm. When in doubt, don’t eat it.

In Canada, new regulations have been proposed that would require food manufacturers disclose if sulphites are present in a product at a level of 10 parts per million or higher.

More on Canada’s New Food Allergen Regulations.

In the United States, the Food Allergen Labeling and Consumer Protection Act went into effect in 2006. FALCPA requires manufacturers to use plain language when listing priority allergens, and to declare all allergens either in the ingredient list, or in a “Contains:” statement at the end of the list.

The new regulations also apply to food allergies, and require that allergens are declared in plain language, and are disclosed when they are components of other ingredients (i.e. mustard as a component of “spices.”

More on Canada’s Food Allergen Regulations

In the United States, the Food Allergen Labeling and Consumer Protection Act, which went into effect in 2006, requires manufacturers to use plain language when listing priority allergens, and to declare all allergens either in the ingredient list, or in a “Contains:” statement at the end of the list.

The allergens included in this regulation are milk, eggs, fish, shellfish, tree nuts, wheat peanuts and soybeans. These regulations do not include sesame and mustard, unlike the proposed Canadian regulations.

Separate legislation requires companies to declare sulphites if they are present at more than 10 parts per million, or if they had a technical or functional effect in the food.

Reading labels is a way of life when you or a member of your family has a peanut allergy. Before eating anything in a package, be sure to read the label carefully. Look for hidden sources of soy or legumes and alternate names for them.

Also be on the lookout for precautionary statements. These are statements that indicate an allergen may be in the food, due to cross contamination during processing. Examples of precautionary statements include: “May contain soy” and “Manufactured in a facility that also processes soy.”

(FYI, while soy and peanuts are legumes that are priority allergens in Canada and the U.S., other legumes don’t have that same designation. Soy and peanut will be included in so-called “May contain” statements, legumes such as lentils or chickpeas won’t be.)

Allergists generally advise people with soy allergies to avoid all products that contain precautionary statements about their allergen.

If you are ever uncertain about whether a food product is safe for you, call the manufacturer to confirm. When in doubt, don’t eat it.

In Canada, new regulations have been proposed that would require food manufacturers list priority allergens in plain language on packaging, rather than using alternate names (ie: kinako, for soybean flour). Ingredients of ingredients that are priority allergens would also have to be listed. For example, manufacturers couldn’t simply list “vegetable protein” if the source of the protein is a priority allergen, such as a legume.

More on Canada’s New Food Allergen Regulations.

In the United States, the Food Allergen Labeling and Consumer Protection Act went into effect in 2006. FALCPA requires manufacturers to use plain language when listing priority allergens, and to declare all allergens either in the ingredient list, or in a “Contains:” statement at the end of the list.

The allergens included in this regulation are milk, eggs, fish, shellfish, tree nuts, wheat peanuts and soybeans. These regulations do not include sesame and mustard, unlike the proposed Canadian regulations.

Separate legislation requires companies to declare sulphites if they are present at more than 10 parts per million, or if they had a technical or functional effect in the food.

Both Canada and the United States are studying ways to regulate the precautionary statements used on packaged food labels.

Reading labels is a way of life when you or a member of your family has a peanut allergy. Before eating anything in a package, be sure to read the label carefully. Look for hidden sources of peanuts and alternate names for it.

Also be on the lookout for precautionary statements. These are statements that indicate an allergen may be in the food, due to cross contamination during processing. Examples of precautionary statements include: “May contain peanuts” and “Manufactured in a facility that contains peanuts.”

Allergists generally advise people with peanut allergies to avoid all products that include precautionary statements about their allergen. If you are ever uncertain about whether a food product is safe for you, call the manufacturer to confirm. When in doubt, don’t eat it.

In Canada, new regulations have been proposed that would require food manufacturers list priority allergens in plain language on packaging, rather than using alternate names (ie: arachidic acid instead of peanut). The ingredients within listed ingredients that are priority allergens would also have to be shown. For example, manufacturers couldn’t simply list “hydrolyzed protein” if the source of that protein included a priority allergen, such as peanut.

More on Canada’s New Food Allergen Regulations.

In the United States, the Food Allergen Labeling and Consumer Protection Act went into effect in 2006. FALCPA requires manufacturers to use plain language when listing priority allergens, and to declare all allergens either in the ingredient list, or in a “Contains:” statement at the end of the list.

The allergens included in this regulation are milk, eggs, fish, shellfish, tree nuts, wheat peanuts and soybeans. These regulations do not include sesame and mustard, unlike the proposed Canadian regulations.

Separate legislation requires companies to declare sulphites if they are present at more than 10 parts per million, or if they had a technical or functional effect in the food.

Both Canada and the United States are studying ways to regulate the precautionary statements used on packaged food labels.