About this Video

• Video Title: El Etiquetado Precautorio de Alérgenos - Episodio nº 8
• Channel: Marife Montes Luna
• Speakers: Marife Montes Luna
• Duration: 00:44:06

Introduction

This podcast episode discusses precautionary labeling of allergens in food. The speaker explains the legal requirements for labeling unintended allergen presence due to cross-contamination, emphasizing its mandatory nature and the necessary preventative measures food operators must take. The episode also details requirements from BRC, IFS, and FSSC 22000 standards, and provides practical advice on minimizing cross-contamination risks.

Key Takeaways

• Precautionary allergen labeling (Epa) is mandatory in the EU when food operators cannot guarantee the total absence of an allergen, even if unintentionally present due to cross-contamination.
• Regulations (Reglamento 1169 and Reglamento 852/2004) mandate preventative procedures to avoid, eliminate, or reduce allergen presence to acceptable levels. The lack of complete allergen absence necessitates precautionary labeling.
• BRC, IFS, and FSSC 22000 standards contain specific requirements for allergen management, emphasizing preventative measures throughout the production process (from raw materials to finished products).
• Several preventative measures are outlined including segregated zones, dedicated equipment, thorough cleaning protocols, effective ventilation, proper transportation, supplier evaluation, employee training, and robust hygiene practices.
• The VITAL system (a voluntary tool) aids in assessing cross-contamination risks and determining the need for precautionary labeling based on allergen levels. Specific legal thresholds exist for gluten and sulfites. The use of "gluten-free" labels should be considered carefully to avoid misleading consumers.

Based on Marife Montes' podcast:

1. Legal Requirements for Declaring Unintended Allergens in EU Food Labeling:

In the EU, precautionary allergen labeling (Epa) is mandatory when food operators cannot guarantee the total absence of an allergen, even if unintentionally present due to cross-contamination. Regulations (Reglamento 1169 and Reglamento 852/2004) require preventative procedures to avoid, eliminate, or reduce allergen presence to acceptable levels. If total absence cannot be guaranteed, precautionary labeling is legally required. The podcast mentions that more precise regulations are still expected.

2. Key Requirements of BRC, IFS, and FSSC 22000 Standards Regarding Allergen Management:

BRC, IFS, and FSSC 22000 standards have specific allergen management requirements. These emphasize preventative measures throughout the production process, from raw materials to finished products. The standards require identifying allergen sources, implementing controls to eliminate or reduce risks, and validating the effectiveness of these controls. The podcast highlights that these standards, while expressed differently, share the same fundamental goals.

3. Preventative Measures to Minimize Cross-Contamination Risks:

Food operators can implement various preventative measures to minimize cross-contamination:

• Environmental Controls: Segregated zones for allergen-containing and allergen-free products, effective ventilation systems with air filtration, and thorough, regular cleaning and sanitation protocols specifically targeting allergens. Environmental monitoring to detect allergen presence is also recommended.
• Transportation Controls: Segregated transport (separate vehicles, containers, and lines) for allergen-containing and allergen-free products, along with specific cleaning procedures for transport vehicles. Clear labeling of all containers and transport vehicles.
• Storage Controls: Segregated storage areas for allergen-containing and allergen-free products, use of closed, labeled containers to prevent accidental mixing, and proper inventory rotation.
• Production Process Controls: Production scheduling prioritizing allergen-free products before those containing allergens, dedicated equipment for allergen-free products, in-process controls (visual inspections, allergen tests), and validated cleaning procedures between production runs.
• Personnel Controls: Comprehensive employee training on allergen management and good hygiene practices, strict hygiene protocols (handwashing, clothing changes), and potentially color-coded uniforms to visually track personnel movement and prevent cross-contamination. Control of employee movement between allergen-free and allergen-containing areas.

4. Legal Thresholds for Gluten and Sulfites and Permitted Phrases:

For gluten, the podcast mentions Reglamento de ejecución 828, which sets limits. Products labeled "gluten-free" must have less than 20 ppm (mg/kg) of gluten. The label "very low in gluten" can be used for products with less than 100 ppm (mg/kg) containing wheat, rye, barley, oats, or their derivatives. Other declarations like "suitable for people with gluten intolerance" or "specifically made for celiacs" are permissible if these thresholds are met.

For sulfites (dioxide and its variants), concentrations above 10 ppm (mg/kg or mg/L) require declaration on the label. The podcast notes a more extensive list of sulfite variants requiring consideration, to be found in the accompanying notes. There is no explicit mention of specific permitted phrases related to sulfites beyond that a concentration above 10ppm requires declaration.

In her concluding remarks, Marife emphasizes the importance of providing safe and harmless products to consumers. She stresses the need for clear and accurate labeling to avoid confusion and uncertainty when choosing products. She reiterates that the goal is to create an effective allergen management plan and to use labeling as a way of communicating clearly with the consumer, not as a substitute for implementing appropriate preventative measures. She invites listeners to submit questions through a form on her website for future podcast episodes. Finally, she thanks her listeners and encourages them to leave positive reviews and share the podcast.