Many consumers have allergic reactions to food and you need to be aware of the potential food allergies in your food product and develop your nutritional facts label to clearly state these food allergens. For those of you starting a food business , this is most important and not very difficult if you follow the steps in this article.
Listing allergens that are present in a packaged food or beverage became mandatory after passage of the federal Food Allergen Labeling and Consumer Protection Act of 2004 . The law actually went into effect on January 1, 2006.
Review of the Nutritional Facts Label
There are three required parts to designing a nutritional facts label for packaged foods and beverages.
1. Nutritional Information
3. Know Food Allergens
Just as a quick recap, the order of ingredients on food labels is prescribed by the FDA. Be very careful that all allergens are declared using an approved format. These are critical aspects of your food packaging design and if you are in doubt, consider getting a nutritional analysis professional to help .
The FDA and USDA typically will notify a food company to correct any food label error if they reside in the Nutrition Facts Panel or list of ingredients. This may result is destroying the unusable packaging inventory which is a financial consequence that can be avoided by closely following [this article]. Absolute do not omit a food allergen for it creates a public health hazard and destroys your brand equity and the consumer confidence you have worked long and hard to establish. Brand equity is so important to food & beverage brands that many companies often recall their products from all distribution channels.
Consumers who have an adverse reaction to an undeclared food allergen have sued the manufacturer resulting in monetary compensation. Worst of all is the bad publicity and negative word of mouth that results. Food brands can recover from a financial loss but hardly ever recover from bad word of mouth.
Top Food Allergens
The Act states that the 8 specific food allergens must be listed. The federal Food and Drug Administration says that they are responsible for about 90% of all food related allergic reactions.
Top 8 Food Allergens
- Nuts & Tree Nuts
- Fin Fish & Crustacean Shellfish
Nutrition Facts Panel Design Considerations for Addressing Food Labels
A product containing any form of an allergen ingredient requires food allergen labeling. Wheat flour, wheat starch, and wheat bran are examples of wheat ingredients. Similarly butter, lactose, and whey are examples of milk ingredients. Tree nuts include almonds, pecans, coconuts, and cashews. Crustacean shellfish includes shrimp, crab, and lobster. The specific tree nut and specific shellfish must be identified in the ingredients.
Where the confusion arises is one government sanctioned exception. Highly refined oils derived from allergens are exempt from this labeling. Two common food ingredients listed as "highly refined" are peanut oil and soybean oil.
Protein is the guilty party in most consumer allergic reactions to food so peanut oil and soybean oil are exempt since they are essentially pure oil with no protein.
Look at a bottle of ranch salad dressing made with soybean oil. The milk ingredients will be cited as allergens, but not the oil.
FDA Regulations - 2 Methods for Stating Food Allergens in the Nutrition Fact Label
The regulations allow for two methods of labeling. In one case a 'CONTAINS' statement which lists the allergens is positioned immediately below the list of ingredients. For example the packaging of a macaroni and cheese dinner would indicate 'CONTAINS: Wheat and Milk'. The alternate approach is to list each allergen as part of the ingredient name or in parentheses after the ingredient. The ingredient lecithin becomes soy lecithin, and butter becomes butter (milk).
Case Study of 2 Food Brands
FDA has strict Interpretation of Food Allergen Labeling. Let's use 2 case studies to illustrate this.
A manufacturer of pot pies listed flour and cheese as ingredients… but they were not identified as wheat and milk allergens. Over 1700 hundred units of product were recalled costing thousands of dollars and potentially damaging their reputation with the grocery retail buyer and the supermarket consumer.
A large bakery produced pecan streusel pies. 'Pecan' was part of the product name, but the nut was inadvertently not listed as an ingredient. The bakery recalled 6,152 pies, again, at great expense.
One must be very thorough in identifying and listing allergens. Food and beverage manufacturers experience more regulatory harm by omitting allergens than by all of the other mistakes they make in nutrition labeling.
Consider getting 3rd part help in creating your nutritional facts label to insure you comply with FDA regulations on the top 8 food allergens. Consumers that get allergic reactions to food you produce may not be your customers after this and the bad word of mouth to your brand may be impossible to reverse.