Food businesses should establish an appropriate and proportionate policy for assessing the allergen status of ingredients that they use in their own manufacturing processes and premises, and for assessing ingredients used by their suppliers or co-packers, if appropriate.
Manufacturers should ensure that materials are ordered against a clear specification and that they ask appropriate questions of their suppliers.
Manufacturers need to be aware of the presence of the major allergens in all raw materials, particularly the potential for allergen cross-contamination from manufacturing and handling activities on the raw material suppliers’ sites, as well as earlier in the food chain during harvesting and transport.
This may be through audits or from information provided by suppliers.
Raw material suppliers (and their agents) should be aware of the hazards arising from contamination by allergens and conform to the manufacturers purchase specification.
However, commodity raw material suppliers should only use allergen warning statements on products such as spices and grains, based on an assessment of the risk of cross-contamination.
Ingredients should be fully described in specifications. For example, avoid the use of generic terms such as ‘vegetable’ oils and fats by using specified terms such as corn or rapeseed oil, especially where those allergens are listed in Annex II of EU Regulation No. 1169/2011.
When listing the ingredients, food business operators must emphasise the name of the substance/product in the ingredient list only.
The new rules will mean that an allergen warning statement such as ‘contains x…’ statement to repeat allergen ingredients information can no longer be provided. Information about allergenic ingredients will be located in a single place i.e. in the ingredients list. The use of an allergen statement to signpost and explain how allergen information is emphasised within the ingredients list is permitted. For example: Allergy Advice: For allergens, see ingredients in bold or Allergy Advice: For allergens including cereals containing gluten, see ingredients in bold.
The use of precautionary allergen statements such as ‘may contain…’ to indicate the possible presence of an allergen due to cross-contamination has not been affected by the EU FIC and its use will be permitted.
If allergenic ingredients are sieved, then the sieving unit should either be dedicated or thoroughly cleaned after sieving allergenic ingredients.
If possible, allergenic ingredients should be sieved after all other raw ingredients have been sieved for the day.