With over 200 million people worldwide suffering from food allergies, clear product labelling is a critical issue. Making a mistake or omitting allergen information isn’t just inconvenient to the consumer; it can trigger a potentially deadly reaction. 

To protect people, governments in every region have introduced mandatory allergen labelling regulations. But these regulations vary from country-to-country, and they’re evolving all the time. 

Being allergy-compliant in every market is a major challenge for food and beverage brands – but Hooley Brown is here to help. Keep reading to discover the complexities of food ingredient listings, along with how labelling compliance expertise can help you to develop packaging that meets legal requirements in every country you operate. 

Why is food allergen labelling such a complex issue? 

The problem food and beverage brands face when labelling products is that it’s impossible to list everything that people might be allergic to. Detailed information can be listed on your website, but your packaging can only list so many ingredients before becoming difficult to read. 

In response to this dilemma, many countries have introduced mandatory allergen labelling that focusses on the products that evoke the most serious allergic reactions – like anaphylaxis. 

While anaphylactic shock can be caused by an allergic reaction to medicines, insect stings and latex, it can also be triggered by the consumption of fish and shellfish, eggs, nuts, milk and some fruits. So the importance of clear, compliant food and beverage labelling is pivotal to consumer safety. 

Sadly, we’ve seen first-hand the impact of selling food items without allergen labels. In 2021, the UK introduced Natasha’s Law following the death of 15-year-old Natasha Ednan-Laperouse, requiring all pre-packaged foods made on-premise for direct sale to provide a full list of ingredients and allergens on their labelling. 

On-site products had previously been exempted from allergen labelling in order to keep compliance costs to a minimum for small food processers and food service providers. However, legislation was amended to enforce corporate responsibility when Natasha died after eating an unlabelled chain food store baguette that contained sesame seeds – to which she was highly allergic. 

In addition to being a crucial step towards greater consumer protection, Natasha’s Law raises an important point for international food and beverage brands about the variation in allergen legislation. 

While general food allergen labelling is regulated by EU law (which the UK still follows in this sector), Natasha’s Law is specific to Britain. And across the world, there are similar nuances that need to be taken into account when launching, marketing and selling foods and beverages to the public. 

How does food allergen labelling vary country by country? 

It would be impractical to cover every single global variation in food labelling compliance in the space of one blog post, but there are some major trends that are worth highlighting – to demonstrate the challenges food and beverage brands face. 

For example, in the USA, President Biden recently signed an update to the FALCPA (Food Allergen Labelling and Consumer Protection Act) Bill, adding sesame to the list of mandatory allergens included on product labelling. The fact that sesame is only being added now seems unusual given that over 50 million burgers are eaten in the US each year, and sesame seed buns are a popular choice for many food companies and food service providers.

Other interesting food legislation variants include: 

  • Japan and Korea are the only countries where buckwheat must be listed as an allergen on product labelling
  • While milk is a mandatory allergen listing in all major markets, what “milk” constitutes varies between countries; in the EU and several other countries it’s defined as anything from the mammary gland of farmed animals, but in Taiwan only cow and goat milk must be listed, and in the US it’s the lacteal secretion from cows
  • Fish must be listed as an allergen in every major international food market – except for Japan – while only mackerel needs to be listed in Korea
  • Argentina, Chile, the GSO countries, Hong Kong, India, Malawi, Malaysia, Mexico, the Philippines, Singapore, Taiwan and Thailand do not require food and beverage brands to list wheat as an allergen on product packaging
  • Celery is only a mandatory allergen in the EU, GSO, Iceland, Liechtenstein, North Macedonia, Norway, Switzerland, Turkey and Ukraine
  • Taiwan is the only major country that insists food and beverage brands warn when products contain mango – and South Korea is the only country that lists peach and tomato as allergens
  • While EU food labelling legislation requires all shellfish to be listed as allergens, the USA only requires crustacean shellfish to be listed (not molluscan shellfish), and in the GSO countries only clams are a mandatory listing

Allergen listing requirements can also vary depending on local diets. For instance, while fish, crustaceans, eggs and milk are the key animal products highlighted in EU countries, in South Korea, beef, chicken and pork must also be included on allergen labels. This reflects that these meats are eaten much less frequently in Asia compared to the standard Western diet. 

How can food and beverage brands manage allergen labelling requirements better? 

Knowledge of international food labelling compliance is a challenge in itself. However, food and beverage brands face the added challenge of listing allergens on packaging used across multiple markets – many of which have nuances in their legislation. 

For example, coconut is not a mandatory allergen under EU food legislation, but it is under the USA’s FALCPA Bill. This means Mars, Incorporated is not required to highlight coconut as an ingredient in Bounty bars sold in Europe, but it must do so in the USA for labelling to be compliant. 

Given this level of complexity, it’s easy to see how food and beverage brands make allergen label mistakes when manufacturing products for sale across multiple markets. However, there are serious moral, health, legal and financial implications to labelling non-compliance. 

Even the most diligent, customer-driven brands can be liable to mistakes. For example, in 2019, Kallo Foods was forced to recall jars of Whole Earth 3 Nut Butter because although the label highlighted peanuts, pecans and walnuts in its list of ingredients, it did not contain a warning in English that the product may contain traces of other nuts. 

Kallo is not alone, either; undeclared allergens is the top reason for food recalls in the US and Europe

To offer an extra level of expertise and peace of mind, many brands collaborate with a food labelling compliance agency (like Hooley Brown) when creating product packaging. Leaning on the knowledge of specialist companies ensures that the latest food packaging legislation is applied to every product.

In addition to ensuring all food and beverage labels meets relevant allergen regulations without compromising the design and appeal of product packaging, a compliance specialist will also help brands decide whether to go above and beyond minimum requirements. 

For example, food and beverage companies may want to note when products have been made in the same facility as another allergen, to protect those vulnerable to severe allergic reactions from potential cross-contamination. A simple change like this can massively improve consumer confidence, as well as making sure all product labelling legislation has been covered effectively. 

Hooley Brown specialises in labelling compliance for food and beverage brands. Get in touch to discuss your requirements or follow Hooley Brown on LinkedIn for more industry insights.

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