Tree nut allergen labelling and testing
For individuals with tree nut allergies, even small amounts of the nut(s) to which they are allergic can trigger severe, potentially life-threatening reactions, so it is extremely important that allergen information is communicated clearly and logically.
The South African Regulations Relating to the Labelling and Advertising of Foodstuffs (R.146/2010, as amended) stipulate how and when common food allergens must be declared and controlled. This enables food-allergic consumers to make informed decisions about what foods are safe for them to eat.
The presence or absence of tree nuts in a foodstuff is required to be communicated in a specific way. Here, we unpack how FACTS advise tree nuts should be declared in different circumstances.
The grouping term ‘tree nuts’
Individuals may be allergic to specific tree nuts, not necessarily all varieties.
Therefore, tree nuts should be individually specified in your Ingredient Declaration, Precautionary Allergen Labelling (PAL), or Free-From Claim, and use of the grouping term ‘tree nuts’ should be avoided if possible.
Tree nuts as ingredients
When tree nut(s) are present as an intentional ingredient, the specific tree nut(s) should be individually listed in the ingredient list by descending order of mass.
Example:
Tree nut cross-contact
For facilities that handle multiple tree nuts, it can be both challenging and costly to manage the cross-contact risk of multiple tree nuts.
Food manufacturers tend to use precautionary allergen labelling (PAL) instead of trying to mitigate the cross-contact risk with an effective Allergen Control Plan. This not only contravenes the regulations but also limits the safe food options for consumers who have food allergies.
Example:
A risk assessment has revealed that a product is occasionally cross-contaminated with almonds, even after implementing additional controls. Therefore, Precautionary Allergen Labelling (PAL) may be applied.
The advised wording is:
Free-from claims for tree nuts
Free-from claims such as ‘tree-nut free’ and ‘peanut-free’ are strategic ways to differentiate your product and appeal to a specific consumer group. However, this claim comes with significant responsibility and requires rigorous due diligence to ensure it is consistently true and accurate. This includes having analytical evidence to substantiate the claim.
A generic ‘nut-free’ claim is very open-ended and may be confusing to consumers – does this include peanut (which is actually a legume, not a nut) and coconut? Best practice is to individually list the tree nuts that the product is free from, and provide evidence to substantiate each claim.
Example:
A product is manufactured and analytically tested to be free from almonds.
What FACTS test do I choose?
| Example | Scenario | Potentially suitable test |
| Screen a raw material for ‘tree nuts’ | My supplier handles multiple tree nuts on site, and I need to assess whether the ingredient I purchase is contaminated by one or more tree nuts. | Tree nut screen* |
| Investigate a customer complaint | A customer who is allergic to multiple tree nuts reacted to my product. We want to assess which tree nuts are present in the retention or consumer sample. | Tree nut screen* |
| Substantiate a free-from claim | We make an almond-free claim on our product and need to substantiate it via testing. | Almond test |
| Investigate a cross-contact scenario | A product line was contaminated with cashew nut flour due to shared equipment. What is the risk? | Cashew nut test |
*Screen includes: almond, Brazil nut, cashew nut, hazelnut, macadamia nut, pecan nut, pistachio nut, walnut and pine nut.
Need assistance in deciding what to test for, or how to declare allergens on your product label? Contact us to discuss in more detail.