EU Allergen Legislation29th Sept 2015

Dr Jane-Marie Hawronskyj FIFSTHead of Food Safety

EU Allergen Legislation

Regulation (EU) no 1169/2011 on The Provision of Food Information to

Consumers.• Published Oct 2011, effective Dec 2014. • Establishes the general principles, requirements and responsibilities governing food information and in particular food labelling• Applicable to food intended for the final consumer, including food delivered by mass caterers.• Primary consideration was to enable consumers to make informed decisions when purchasing food.• 46 pages long

EU Allergen Legislation

What does it mean for the Airline Industry?• Chapter 1, Article 1, Point 3• “This Regulation….shall apply to all foods intended for the final consumer, including foods delivered by mass caterers……..This Regulation shall apply to catering services provided by transport undertakings when the departure takes place on the territories of the Member States to which the Treaties apply”.

• Also applies to Crew food.

EU Allergen Legislation

What does the legislation require?

Mandatory labelling information for prepacked food • Product name (including particulars as to the physical condition of the food or any treatment it has undergone)• Ingredients list, including allergens• Quantitative indication of ingredients• Durability date•Warning statements e.g. “with sweeteners(s)”• Storage and cooking instructions, where applicable;

And………..

EU Allergen Legislation

What does the legislation require?

• The name or business name and address of the manufacturer or packager, or of a seller established within the EC • Country of origin or place of provenance, where applicable • Instructions for use, if applicable • Beverages containing more than 1.2 % by volume of alcohol, the actual alcoholic strength by volume • Lot mark - to assure traceability of the product

And………..

EU Allergen Legislation

What does the legislation require?

• Nutrition declaration provided on a voluntary basis must comply with the new requirements• From 13 December 2016, nutrition declaration will be mandatory on all pre-packed foods• Specific presentation; field of vision, font size

EU Allergen Legislation

What does the legislation require?

Mandatory labelling information for catered or non prepacked food • Allergens

EU Allergen Legislation

Catered vs Pre-Packed?

• Clarification on airline caterers & airlines as “mass caterers”• All meals, including entrees with a foil classified as catered i.e. non prepacked• Retail style items of food classified as prepacked e.g. crisps, snacks, sandwiches

BUT

Legal opinions vary

No test case in the courts (yet)

EU Allergen Legislation

EU Food Allergens List

• Lupin.• Sesame.• Cereals containing

gluten, namely: wheat, rye, barley, oats, spelt, kamut.

• Soybeans.• Celery.• Mustard.• Sulphites over

10ppm.NB: And products thereof

• Peanuts. • Nuts, namely: almonds ,

hazelnuts, walnuts, cashews, pecan nuts, Brazil nuts, pistachio nuts, macadamia or Queensland nuts

• Crustaceans.• Fish.• Molluscs.• Eggs.• Milk.

EU Allergen Legislation

Legal Labelling

•Where allergens are present, they must be either;• Listed on the packaging information.• Available by asking a member of staff.

• If information is available verbally, this indication must be given either;•On a label attached to the food, or•On a notice, menu, ticket or label that is readily discernible by an intending purchaser at the place where the intending purchaser chooses that food.

EU Allergen Legislation

SignpostingBA.com: “If you would like to find out more about the allergy information for your meal, please check the label on the packaging, or ask a member of your crew.”