Allergen labelling in the EU and US
April 2010

South Africa has published the Regulations on Labelling and Advertising of Foodstuffs (R.146) under the Foodstuffs, Cosmetics and Disinfectants Act, 1972 (Act No. 54 of 1972) on 1 March 2010, which includes the eight common allergens which need to be managed. These are egg, cow's milk, crustaceans and molluscs, fish, peanuts, soybeans, tree nuts and any significant cereals (wheat, rye, barley, oats and their crossbred hybrids).

The World Cup is virtually at our doorstep, so we need to consider the allergen needs of our international visitors. For your convenience we have summarised the allergens that are regulated in the EU and US. Regarding the United Kingdom (excluding Northern Ireland), the EU Directive 2000/13 (and the earlier directives) has been implemented into UK legislation.
These allergens are regulated because statistically these allergens are the ones which most people show an allergic response to.

ALLERGENS REQUIRING MANDATORY DECLARATION IN THE EUROPEAN UNION

According to COMMISSION DIRECTIVE 2007/68/EC (27 November 2007), 14 allergens must be declared in the European Union:

1. Cereals containing gluten (i.e. wheat, rye, barley, oats, spelt, kamut or their hybridised strains) and products thereof, except:
(a) wheat-based glucose syrups including dextrose(1);
(b) wheat-based maltodextrins(1);
(c) glucose syrups based on barley;
(d) cereals used for making distillates or ethyl alcohol of agricultural origin for spirit drinks and other alcoholic beverages.

2. Crustaceans and products thereof.

3. Eggs and products thereof.

4. Fish and products thereof, except:
(a) fish gelatine used as carrier for vitamin or carotenoid preparations;
(b) fish gelatine or Isinglass used as fining agent in beer and wine.

5. Peanuts and products thereof.

6. Soybeans and products thereof, except:
(a) fully refined soybean oil and fat(1);
(b) natural mixed tocopherols (E306), natural D-alpha tocopherol, natural D-alpha tocopherol acetate, natural D-alpha tocopherol succinate from soybean sources;
(c) vegetable oils derived phytosterols and phytosterol esters from soybean sources;
(d) plant stanol ester produced from vegetable oil sterols from soybean sources.

7. Milk and products thereof (including lactose), except:
(a) whey used for making distillates or ethyl alcohol of agricultural origin for spirit drinks and other alcoholic beverages;
(b) lactitol.

8. Nuts, i.e. almonds (Amygdalus communis L.), hazelnuts (Corylus avellana), walnuts (Juglans regia), cashews (Anacardium occidentale), pecan nuts (Carya illinoiesis (Wangenh.) K. Koch), Brazil nuts (Bertholletia excelsa), pistachio nuts (Pistacia vera), macadamia nuts and Queensland nuts (Macadamia ternifolia), and products thereof, except:
(a) nuts used for making distillates or ethyl alcohol of agricultural origin for spirit drinks and other alcoholic beverages.

9. Celery and products thereof.

10. Mustard and products thereof.

11. Sesame seeds and products thereof.

12. Sulphur dioxide and sulphites at concentrations of more than 10 mg/kg or 10 mg/litre expressed as SO2.

13. Lupin and products thereof.

14. Molluscs and products thereof.

(1) and products thereof, insofar as the process that they have undergone is not likely to increase the level of allergenicity assessed by the EFSA for the relevant product from which they originated.

ALLERGENS REQUIRING MANDATORY DECLARATION IN THE UNITED STATES

According to the FOOD ALLERGEN LABELING AND CONSUMER PROTECTION ACT OF 2004 (Title II of Public Law 108-282) (August 2, 2004), 8 allergens must be declared in the United States:

1. Wheat and products thereof (1)
2. Eggs and products thereof (1)
3. Crustacean shellfish and products thereof (1)
4. Fish and products thereof (1)
5. Tree nuts and products thereof (1)
6. Peanuts and products thereof (1)
7. Milk and products thereof (1)
8. Soybeans and products thereof (1)

(1)Any highly refined oil derived from a food specified above and any ingredient derived from such highly refined oil is exempt from labelling.