Tech Talk - Allergen Labelling in Canada

By Daphne Nuys-Hall, Technical Director, Meat & Poultry Ontario

For those with food allergies, sensitivities or intolerances, avoiding specific foods and ingredients is an important health challenge. An allergic individual coming into contact with an undeclared allergen such as peanuts in a food product may have symptoms that develop quickly and rapidly progress from mild to severe, including anaphylactic shock and death.

What is a Food Allergy?

Food allergy is an abnormal immune response to proteins found in food. An allergic reaction can range in severity from a skin rash or itching of the mouth, to migraine headaches, a drop in blood pressure, anaphylaxis and death.

It is estimated that 1.2 million Canadians may be affected by food allergies or 1 in 25 persons. The prevalence of food allergies is approximately 5 to 6 percent in children and 3 to 4 percent in adult.

For those suffering from celiac disease, prolonged consumption of gluten could lead to long-term health complications and the only current treatment is to maintain a strict gluten-free diet. Health Canada, the Canadian Food Inspection Agency (CFIA),

allergy associations, and the medical community have identified the key substances most frequently associated with food allergies and allergic-type reactions.

• peanuts

• tree nuts (almonds, Brazil nuts, cashews,hazelnuts, macadamia nuts, pecans, pine nuts, pistachio nuts and walnuts)

• sesame

• milk

• eggs

• crustaceans and molluscs

• fish

• soy

• wheat and triticale

• mustard

• sulphites

• gluten

There is no cure for food allergies and the only way for an allergic individual to protect themselves is strict avoidance of the allergen. One of these ways is to read the label on every product they purchase, and they must rely on the food industry to manufacture safe food that is properly labelled.

In 2022 there were 226 food recalls, of which 37% were due to undeclared allergens in the product. Specifically for meat products, 53% of the recalled meat products were due to undeclared allergens. The meat industry needs to do more to protect the consumer.

What Are Your Labelling Responsibilities?

Processors will be required to clearly identify food allergens, gluten sources, and sulphites either in the list of ingredients or in a “Contains statement” at the end of the list ingredients.

There are a couple of options to declare allergens in an ingredient listing.

In the first the food allergen or gluten may be shown in parentheses in the list of the ingredients immediately following the ingredient itself –

Ingredients: Flour (wheat) • Liquid albumin (egg)

• Vegetable oil • Sugar • Chocolate chips (milk) (sugar, chocolate liquor, cocoa butter, milk ingredients, soy lecithin, salt, natural flavour).

Or immediately after the component that is shown in the list of ingredients, if the food allergen or gluten is the component or is present in the component –

Ingredients: Pastry pieces [flour (wheat), butter (milk), liquid albumin (egg), canola oil] • Sugar

• Natural flavour.

The last option is to list the food allergen or gluten on the label of a product in a contains statement that complies with the requirements restrictions outlined in of the Food and Drugs Regulations. If a “contains statement” is used on the label, all allergen, gluten and added sulphite information must appear in the statement at least once, even if that information is already shown in the list of ingredients for the product. For example:

Ingredients: Wheat flour • Water

• Vegetable oil margarine • Sugar

• Yeast • Canola oil shortening

• Potato starch • Garlic • Salt • Parsley

• Seasoning • Diacetyl acid esters of mono and diglycerides • Whey powder

• Calcium propionate

• Potassium bisulphite

Contains: Wheat • Milk • Sesame • Sulphites

In this example, all food allergens, gluten sources and added sulphites are declared at least once in the contains statement, even though wheat and potassium bisulphite (sulphites) already appear in the ingredient list.

Precautionary Statements

A precautionary or cross contamination statement is a declaration on the label of a prepackaged product that alerts consumers of the possible presence of an allergen in the food and may only be used when, despite all reasonable measures there is the unintended presence of food allergens in the food. Cross contamination statements are not a substitute for Good Manufacturing Practices.

Health Canada and the CFIA recommend using only the title below to introduce precautionary/cross contamination statement on food labels:

“May contain: [X]” or “May contain: [X]” (if it begins on a separate line)

where X is the name of the allergen prescribed source name.

As part of your business’ allergen control plan you should develop procedures to review ingredient listing on labels at least annually or when changes are made to product formulations. Verify label accuracy when changing over products, ensuring the label matches the product. Compare the ingredient declaration on the label with the ingredients on the incoming materials to make sure they match.

‘Undeclared allergens’ remains the number one reason for a product recall in Canada. Ensuring that your labels are accurate, truthful and identify any and all of the 10 priority allergens that may be present in your products is of the utmost importance. Mistakes with allergen labelling are not just costly for your business but also to the allergenic consumer.

Meat & Poultry Ontario encourages operators to contact us with any of your labelling questions or concerns.