In the interests of ensuring that important allergen information is clear and legible for consumers, FIC also specifies a minimum font size for the text of allergen names in ingredients lists. Manufacturers will be required to ensure that the “x-height”—literally the height of an “x” character and its equivalents—is at least 1.2 millimeters (mm). For smaller products (where the packaging or container’s largest surface is less than 80 centimeter2), the x-height may be reduced to 0.9 mm.
All Stages of Food Chain
An additional big change for food business operators is that all the specific regulations stipulated above no longer solely apply to pre-packaged foods but also to all businesses providing foods at all stages of the food chain—food intended for the final consumer, foods delivered by mass caterers, foods intended for supply to mass caterers, catering services provided by transport leaving from the EU Member States (e.g. airline catering), and distance selling (i.e. Internet).
For foods sold non-pre-packed, such as through a restaurant or café, there is some flexibility about how the information is delivered—it could be orally, for example—but it must be made clear to consumers both that the information is available (and available pre-purchase in the case of distance-selling), and how they can obtain it. Whether this is through notes on menus, signs in restaurants, or through other means is up to the individual businesses, but they must demonstrate they have a policy in place complying with FIC and it’s verifiable on challenge.
An important nuance for food manufacturers to note is that the guidance above refers only to allergenic ingredients deliberately included in the food product, as opposed to allergens that may have been accidentally introduced through cross-contamination. Information about the latter may be provided by manufacturers on a voluntary basis according to FIC. The regulation does have specific provisions however to enable individual member states to agree on common phraseology for voluntary advisory statements such as “may contain” or “not suitable for.” There is also a provision to adopt action levels for advisory labeling when these are agreed by member states.
What About Gluten?
Another major change to familiar labeling conventions that manufacturers must adopt regards how cereals containing gluten are labeled. Gluten, a protein found in wheat and other cereal grains, is one of the 14 allergens that are subject to mandatory labeling requirements. Rather than just labeling “gluten” in the ingredients list, the new regulation requires that the name of the cereal is listed and highlighted in the ingredients, i.e. wheat gluten or barley flour. It is particularly important that this labeling is clear and accurate, as it may be consulted by consumers with a range of different dietary requirements: wheat allergy, celiac disease, or allergies or intolerances to one or more individual cereals such as rye or barley.
The results of implementing FIC should be positive for the industry as well as consumers: A standardized system to be followed across all product categories, potentially fewer product recalls, and less confusion across the board about what products are suitable for allergic consumers are all advantages for the food industry. However, it is crucial for manufacturers to ensure that they are in compliance with the new Regulation before December, both to avoid the legal consequences of noncompliance, and in order to reap the benefits of harmonization of labeling practices. The more knowledge that food industry professionals have about the new guidelines and the principles underlying their introduction, the smoother will be the transition into new FIC-compliant allergen labeling.
Flanagan is a senior consultant, food safety and allergens at RSSL. Reach him at [email protected].
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