Allergen Labelling: Processing aids and additives

When it comes to the topic of additives, processing aids and allergens, there are some questions that often come up:

Do I declare processing aids and additives derived from common allergens?

What if the processing aid or additive has been processed to remove or degrade the compounds that cause allergic reactions or other food intolerances?

FACTS regularly advises clients on how to declare allergens on their products. We have recently seen a resurgence in interest, with a number of questions being posed to our team specifically regarding the confusing topic of indication of additives and processing aids when they are derived from allergens. Here we answer some frequently-asked questions.

Do I declare processing aids and additives derived from common allergens?

Regulation 42 of the Regulations Relating to the Labelling and Advertising of Foodstuffs (R.146/2010) clearly states that additives derived from common allergens must be declared in a product’s ingredient list. However, it is less explicit in its requirements for processing aids. The definitions for food additives and ingredients give some guidance regarding processing aids: from the definitions, it may be deduced that processing aids could potentially be considered to be food ingredients, and that they must therefore be listed (as per regulation 43). If it is found by means of a suitable risk assessment that the compound is likely to be in the final product, it must be declared.

  • 42: Notwithstanding the requirements of regulations 36 to 41, any additive or carrier for an additive, which is derived from or contaminated with a common allergen, shall indicate the origin of the common allergen in parenthesis after the name of the additive in the manner [name of additive (name of a common allergen)].
  • Food Additive: Any substance, regardless of its nutritive value, that is not normally consumed as a foodstuff by itself and is not normally used as a typicalingredient of the foodstuff, which is added intentionally to a foodstuff for a technological (including organoleptic) purpose in the manufacture, processing, preparation, treatment, packing, packaging, transport or storage of the foodstuff, and results, or may reasonably be expected to result (directly or indirectly) in such a substance, or its by­products, becoming a component of, or otherwise affecting the characteristics of, such foodstuffs, and excludes any substance added to foodstuffs for maintaining or improving nutritional qualities or any contaminants and sodium chloride.
  • Ingredient: Any substance, including any food additive and any constituent of a compound ingredient, which is used in the manufacture or preparation of a foodstuff and which is present in or on the final product, although possibly in a modified form.

What if the processing aid or additive has been processed to remove or degrade compounds that cause allergic reactions or other food intolerances?

If an additive or processing aid contains highly processed common allergen derivatives, it may pose a reduced risk to sensitive consumers. Several countries, but not South Africa, have a defined list of ingredients that are exempted from allergen labelling. The definition for common allergens incudes foodstuffs “… that has retained its allergenicity in the final product”. This implies that some ingredients may be exempted. For example, if the results of thorough, recognised, science-based risk assessment indicates that there is no risk to the consumer, declaration my not be necessary.

Examples of processed ingredients which may not retain their allergenicity: Wheat-based glucose syrups including dextrose;  wheat-based maltodextrins; glucose syrups made from barley; ethyl alcohol made from wheat, whey or nuts; fully refined soybean and peanut and tree nut oils and fats.

Stay vigilant – make sure all processing aids and additives are assessed for the presence of common allergens, and that they are appropriately declared.

For assistance with allergen-risk assessment or regulatory advice, contact us today.