Beyond the ‘Big 8’: Understanding uncommon allergens

When it comes to food allergens, we often hear about the ‘big eight’ – the group of allergens most commonly associated with allergic reactions. The list of common allergens in a country is generally shaped by three key factors:

• Prevalence – how common the allergy is across populations;
• Potency – the likelihood and dose at which the allergen provokes a reaction;
• Severity – the frequency with which it causes serious outcomes such as anaphylaxis.

In cases where data is limited, countries often look to local specialised clinicians or international bodies such as the Codex Alimentarius Commission for guidance in identifying priority allergens for inclusion in their regulations. Have a look at the common allergens regulated in South Africa.

But what about lesser-known foods that can also trigger an adverse allergic reaction? These are known as uncommon allergens.

What are uncommon allergens?

An allergic reaction happens when the body’s immune system misidentifies certain protein in food as harmful, causing an adverse reaction. However, the fact that a food is not classified as a common allergen in a particular country does not mean it cannot trigger a true – and in some cases, life-threatening – allergic reaction. Foods that are not included in the list of regulated common allergens that are known to trigger allergic reactions are therefore known as uncommon allergens. Examples of uncommon allergens in South Africa (although no official list exists) include goat’s milk, sesame and lupin. Notably, some of these – such as sesame and lupin – are regulated as common allergens in other jurisdictions.

For people allergic to these foods, avoidance is just as important as it is for someone allergic to (for example) peanuts or fish. Symptoms range from mild skin rashes and stomach upsets to serious reactions such as anaphylaxis.

Labelling requirements for uncommon allergens

The requirements for declaring common allergens are clearly outlined in the Regulations Relating to the Labelling and Advertising of Foodstuffs (R. 146/2010, as amended). Read more here.

A food that can trigger an allergic reaction but is not included in South Africa’s list of common allergens (e.g. lupin), and is therefore considered an uncommon allergen, must be declared in the ingredient list like any other ingredient, in descending order of mass.

R. 146 includes a specific provision for the labelling of goat’s milk, which must be declared in the same manner as common allergens. This is because its proteins are structurally similar to those in cow’s milk, and individuals allergic to cow’s milk often experience cross-reactive allergic responses to goat’s milk.

Management of uncommon allergens

While uncommon allergens are not required to be included in a formal allergen management plan for cross-contact prevention, their management remains important for consumer safety. Accurate, up-to-date and readily accessible raw material specifications are critical. This ensures that if a consumer with an uncommon allergy asks whether a product is safe for them, the information can be provided quickly and confidently. By maintaining clear records and understanding the composition of raw materials, manufacturers can help protect consumers while meeting regulatory expectations.

Export considerations

Since the list of common allergens differs between regions, companies exporting food products must carefully review the allergen regulations of each destination country. A food considered an uncommon allergen locally, such as sesame, may be classified and regulated as a common allergen in other regions – for example, sesame is a regulated common allergen in the EU, USA and Australia.

If an ingredient is classified as a common allergen in the destination country, it must be clearly declared on the exported product label and managed appropriately within your facility. As a result, your allergen management plan should cover both the allergens regulated in your local market and those recognised in the destination country, meaning that your allergen control procedures – including cleaning validation studies – must also address any additional allergens relevant to the export market.

Key takeaway

While uncommon allergens may not appear on a country’s official ‘priority’ allergen list, they could still pose serious health risks for those affected. By ensuring clear, transparent ingredient labelling and maintaining up-to-date raw material specifications, food businesses can empower allergic consumers to make safe choices – protecting both public health and brand trust.

Whether you’re dealing with common allergens or uncommon allergens, accurate management protects both consumers and your brand.
Contact FACTS for expert guidance.