During Allergy Awareness Week (26-30 April 2021) we published our first podcast episode.
In this video Rachel Ward, IFST's Scientific Policy Director and Deborah Kendale, IFST's Business Development Director discuss the current UK and EU legislation in place to help prevent the risk of allergic reactions. They also explain the new allergen labelling requirements that will apply from 1 October 2021.
RACHEL WARD: Hello everyone, I’m Rachel Ward, Scientific Policy Director
DEBORAH KENDALE: and I’m Deborah Kendale, Business Development Director at IFST.
DEBORAH KENDALE: Within this discussion, we aim to help businesses and consumers understand how food allergies arise, the current UK and EU legislation to help prevent risk of allergic reactions and the new allergen labelling requirements that will apply from 1 October 2021. We hope you find this conversation insightful and interesting.
DEBORAH KENDALE: Twenty-twenty-one comes with vital changes in allergy legislation, particularly with the implementation of Natasha’s Law coming into action on 1 October 2021.
Before we explain the existing food labelling laws and incoming laws, Rachel will take us through the different types of food hypersensitivity and how they occur.
RACHEL WARD: Did you know that food hypersensitivity can be split into two types?
1.Food allergy and
Food allergy is a hypersensitive reaction to a food which is triggered by the immune system.
•Hypersensitive reactions involving Immunoglobulin-E antibodies cause allergic reactions to milk, peanut, soya, or eggs.
•Hypersensitive reactions involving non-Immunoglobulin-E antibodies cause gluten hypersensitivity or coeliac disease.
Whereas, food intolerance, also known as non-allergic food hypersensitivity, includes a range of reactions where people can have difficulty in digesting certain foods, for example lactose intolerance which occurs when a person’s body does not produce enough lactase enzyme to digest lactose when dairy products are consumed.
DEBORAH KENDALE: Thanks for the explanation of the types of food hypersensitivities, Rachel. If a person has a food hypersensitivity, for example to nuts, what physical symptoms can they experience?
RACHEL WARD: If a person consumes a certain food to which they have an Immunoglobulin-E mediated immune hypersensitivity to, they may experience adverse reactions ranging from mild tingling sensations or swelling, to vomiting and diarrhoea or wheeze. These symptoms can progress rapidly into symptoms that are potentially serious or even life-threatening such as breathing restrictions, aggravation of asthma, dizziness, collapse, shock and in some cases death. Symptoms of food allergy begin shortly after ingestion of the food (a few minutes to an hour or so).
DEBORAH KENDALE: Does this also occur for those diagnosed with coeliac disease?
RACHEL WARD: Coeliac disease is a different because it is not a food allergy or intolerance, it is an autoimmune disease. When a person, diagnosed with coeliac disease, consumes food containing gluten, an immune response involving non-Immunoglobulin E antibodies is triggered which, over time, damages their small intestine lining and prevents nutrient absorption. This intestinal damage often causes diarrhoea, fatigue, and bloating. It can also lead to serious complications such as anaemia, osteoporosis, nervous system injury, infertility, and an increased risk of some cancers. In children, the malabsorption of nutrients can affect their growth and development, besides causing the symptoms seen in adults.
DEBORAH KENDALE: Having identified the difference between allergies and intolerances, what is the best method for a person with food allergies to protect their health?
If someone has been diagnosed with any food hypersensitivities the only method to protect their health is to avoid eating the specific foods which they are sensitive to.
There are various medicines to help manage adverse reaction symptoms such as anti-histamines and in case of serious reactions, adrenaline but there is currently no cure.
DEBORAH KENDALE: Is that their only option? What risk management measures are being taken to protect the consumer from coming into contact with food allergens?
RACHEL WARD: There are a small number of key foods that are responsible for the majority of the food allergy public health burden. Regulatory authorities have identified these allergenic foods by the following criteria: they are the most potent, provoke severe reactions at low doses, and the most prevalent or most frequently occurring in the population. For these critical allergenic foods of public health importance, there are mandatory risk management measures in place to protect consumers from inadvertently consuming of food allergens and subsequent adverse allergic reactions
RACHEL WARD: This includes mandatory declarations of the presence of food allergens in foods and food risk management system controls to ensure there is no undeclared presence of potential allergens in foods.
DEBORAH KENDALE: What if a food allergen is not declared?
RACHEL WARD: The presence of an undeclared food allergen is considered inherently illegal and unsafe. Any foods that contain an allergenic food or its derivative which are on the mandatory labelling list, must be clearly declared to alert the sensitive individual to avoid eating it. This allergen alert must be made available before consumption or exposure so people at risk have the opportunity to identify and avoid the relevant allergenic foods that may cause them harm.
RACHEL WARD: You can usually find allergen declarations written either on the pack or on store shelf labels. They can also be through verbal declarations by food business staff and/or through self-visual observation of food allergen presence.
DEBORAH KENDALE: That is helpful to know. Before we discuss new allergen labelling requirements that will apply from 1 October 2021, please tell us more about the current UK and EU food information legislation for food allergen labelling.
RACHEL WARD: The current UK and EU food information legislation requires mandatory allergenic ingredients declarations for a defined list of foods known to provoke severe allergic reactions. Especially those which cause severe reactions at low levels and commonly trigger food hypersensitivities such as milk, egg, fish, mustard, peanuts, lactose and for cereals containing gluten.
RACHEL WARD: Sulphites, which are commonly found in food additives and preservatives, also must be declared if the amount exceeds 10mg/kg in food. This is because sulphites can cause adverse reactions especially in people with asthma, triggering adverse reactions such as bronchospasm, lowered heart rate, flushing, vomiting, diarrhoea, and shock which can occasionally be severe.
DEBORAH KENDALE: Does this also apply to pre-packaged foods?
RACHEL WARD: Pre-packed foods in the UK and across the EU must include allergens in the ingredient declaration provided directly on the package or on a label attached to the packaging. Pre-packed foods for direct sale are foods pre-packed prior to making them available for sale to consumers or caterers.
RACHEL WARD: For distance selling of pre-packed food and for non-pre-packed food, allergen declarations must be clearly identified and provided on materials supporting the distance selling and made available both before a purchase is concluded and again at the moment of delivery.
RACHEL WARD: In the UK, food businesses selling foods sold loose and foods packed on the premises at the request of the consumer may communicate food allergen information for consumers through a variety of means to suit their business format.
RACHEL WARD: Where allergen information is not being provided upfront in a written format, clear signposting is needed to direct the consumer to where allergen information can be found, for example, by asking members of staff.
DEBORAH KENDALE: Now that we’ve defined the current food information legislation and risk management measures in place, how will these measures change with the new allergen labelling requirements that will apply from 1 October 2021?
RACHEL WARD: There are quite a few changes. From 1 October 2021 there will be new requirements for allergen declarations for pre-packed foods for direct sale (PPDS) in the UK. It will be mandatorily required for all food producers to provide the name of the food and a full ingredients declaration, including highlighting the presence of food allergens, directly on the package or on a label attached to the packaging.
RACHEL WARD: These changes are intended to improve the availability of essential food allergen information to help people with a food allergy or intolerance to make safe choices when purchasing pre-packed foods.
RACHEL WARD: Similar to pre-packed food, a consumer cannot specify what their sandwich, salad or drink must contain or see the contents for themselves before buying the product if it is already packed or wrapped before they select or purchase it.
RACHEL WARD: Allergen declarations on finished food products can only be accurate relative to their composition when clear and complete allergen declarations are provided to the food businesses producing them in the raw materials information.
RACHEL WARD: All allergenic foods placed intentionally in a food product must be easily identifiable by consumers with food sensitivities – so even if the allergenic food is present in the final product because it was used as a processing aid or as a result of carryover from a previous ingredient processing – it must be clearly declared before purchase.
DEBORAH KENDALE: What does this mean for the "may contain’ warning" on food packaging?
RACHEL WARD: Food allergens are known food hazards. So, where allergenic foods might be present as a result of unintentional cross contamination, then it is required in food hygiene legislation to apply HACCP principles and processes to identify where allergen cross-contamination might occur and determine the likelihood of that occurring. Then you can decide whether a precautionary allergen warning should be added to the ingredients allergen declaration to warn sensitive consumers to avoid the product.
DEBORAH KENDALE: Thank you for the clear explanation, Rachel.
DEBORAH KENDALE: To help you prepare for these changes, the Food Standards Agency have provided a very helpful e-training course on food allergens which is freely available on their website. You can also find useful food allergy resources on our IFST website, including a useful fact sheet on food allergens, a more detailed technical information statement and other useful resources – just visit ifst.org and search for ‘food allergy’.
RACHEL WARD: If you enjoyed this conversation, or if you have any questions or comments, please leave them below or feel free to email us at firstname.lastname@example.org and let us know what other subjects you would like us to cover in future podcasts. You can find articles and further reading, including references and links mentioned in this episode on our website at www.ifst.org/allergyconversation
Some foods can trigger both an allergic reaction and an intolerance reaction. Milk, for example, can trigger an allergic reaction to one or both of the milk proteins: casein or beta-lactoglobulin. Or someone can develop an intolerance reaction to lactose, the type of sugar found in milk and dairy products. Similarly, wheat can cause adverse hypersensitive reactions in a person with coeliac disease, but Immunoglobulin-E mediated allergic reactions in a wheat allergic person. The differences in the reactions are due to the individual persons type of hypersensitivity, not the food itself. It is also important to note that people can experience hypersensitive responses to more than one type of food.
Any foodstuff containing protein can be ‘allergenic’ and have the potential to trigger an allergic reaction in a person sensitised to that particular protein. Foods which provoke allergic reactions are very diverse. They range from animal-derived products, for example, meat, fish, shellfish, milk, and egg, to non-animal derived foods, such as tree nuts, seeds, legumes especially peanuts and soya-beans, cereals especially wheat and buckwheat, fruit such as peaches, apples, kiwi, tomatoes, and vegetables - particularly celery and carrot which belong to the Umbelliferae family. Several protein-containing food additives have also been documented to provoke Immunoglobulin-E-mediated allergic reactions, for example, carmine, which is a red food colouring pigment derived from the Cochineal scale insect.