Global Food Allergen Labeling Regulations

Over the past 25 years, food allergies have been recognized worldwide as an important public health issue. Specific avoidance diets remain the primary approach to the prevention of reactions among consumers with food allergies. The simple advice, for those who are allergic to peanuts or milk, for example, is just to avoid those foods or any ingredients derived from those foods. For packaged foods, ingredient statements on food labels are the key source of information for allergic consumers wishing to avoid specific foods.

Consumers with food allergies and their caregivers are likely the most diligent label readers in the marketplace, as their health and safety depend upon careful selection of food products. But, in reality, the seemingly simple advice to avoid allergenic ingredients can become quite challenging. Consumers with milk allergies must learn that casein and whey are terms that signify the presence of milk, that gluten and semolina mean wheat, and that tahina means sesame seeds, among many more examples.

General Labeling Regulations

Historically, many countries have stipulated general food labeling laws and regulations that served to protect food-allergic consumers to some degree. These general food labeling laws and regulations required that the ingredients intentionally used in the formulations of the foods should be declared on an ingredient list on the package label; however, these general food labeling provisions did not fully protect food-allergic consumers for a variety of reasons.

First, many exemptions and exceptions existed. Declaration of the sources of some ingredients was not required. Ingredients were often declared by using their common and usual names, which meant using technical terms (e.g., casein) that did not directly reveal the true source. Thus food-allergic consumers found that allergens were often “hidden” in packaged food products. Furthermore, they had to learn to identify technical ingredient terms such as “casein” that indicated the presence of specific allergenic foods. Vague terms such as “hydrolyzed vegetable protein” were allowed in some countries and these did not reveal the source. Some countries had regulations that did not require the labeling of ingredients in complex formulations when the ingredient comprised less than 25% of the finished food; other countries exempted labeling of minor ingredients comprising less than 2% of the formulation.

The History of Food Allergen Labeling Regulations

The plight of food-allergic consumers and their struggles in implementing specific food-avoidance diets were first recognized in the 1990s. Several Nordic countries developed a working paper on food allergens and labeling in 1993 that was submitted to the Codex Alimentarius Commission (CAC), an organization that oversees the Food and Agricultural Organization (FAO) and the World Health Organization (WHO) to develop food standards and guidance that could be recognized and harmonized worldwide. CAC does not promulgate regulations but does provide guidance that individual countries and regulatory jurisdictions may consider and use as they develop regulations.

In response to the Nordic working papers on food allergens, a FAO Technical Consultation was formed in 1995, which led to the development of the first global list of priority allergenic foods (see Table 1). This list was formally adopted by CAC in 1999. The CAC list of priority allergenic foods served as guidance to all countries, but individual countries had the option to adopt this list or to modify the list as they might choose.

Several comments are appropriate regarding the approaches used by the 1995 expert panel to develop this priority list of allergenic foods. In 1995, the level of published information regarding the comparative prevalence of allergies to specific foods was rather limited and primarily consisted of information on pediatric populations of allergic individuals. These data were primarily from referral centers, which see more allergic patients so extrapolation of the prevalence of pediatric allergies to the overall population may have been slightly biased. Data were lacking on adults with food allergies and on the prevalence of specific food allergies in the general population.