FSANZ chief executive officer Mark Booth said the “Plain English Allergen Labelling Proposal” would address a lack of regulatory clarity that has led to unclear wording on some food labels.
This is timely as recent research by the Murdoch Children’s Research Institute (MCRI) had suggested that allergen labelling regulations in Australia need a complete overhaul, as they were not adequately protecting consumers.
“At the moment, some food allergens must be declared on food labels whenever they are present as an ingredient, food additive or processing aid. However, there are no requirements about how the declarations must be made,” said Booth.
“This is the first of two rounds of consultation on the proposal. It proposes possible changes to address the lack of clarity, including determining what terminology should be used.”
The Australian Food Standards Code currently has a mandatory requirement to label 10 allergens. However, it fails to include specifications for the terminology that should be used in the labelling.
FSANZ hopes that this proposal can help to make allergen labelling clearer, so that food allergen-sensitive consumers have clear and sufficient information in order to make informed and safe food choices.
“Simpler, clearer more easy to understand labels is the goal,” said Booth.
Issues and proposed resolutions
FSANZ has identified a number of issues relating to the use of unclear terminology for fish, crustacea and molluscs, tree nuts, and cereals containing gluten.
The regulator has also identified issues with the terminology used in mandatory label elements, such as in ingredient lists, compared to declarations made in other places on the label.
Other issues identified include the use of the technical language. For instance, some consumers may not know “sodium caseinate” is sourced from dairy.
According to FSANZ, the first consultation paper outlines approaches that could be used to make sure that allergen labelling is provided in clear, plain English.
The paper also includes a number of possible labelling changes for consideration that relate to fish and molluscs as allergens, the types of tree nuts that must be declared as allergens, as well as the declaration of wheat and gluten.
“We are seeking feedback on all of these potential changes, as well as feedback and evidence on consumer use and understanding of allergen labelling,” said FSANZ.
“Information received in response to the first consultation paper will help inform our approach to the second consultation paper, which will include draft amendments to the Food Standards Code.”
The aforementioned MCRI study pointed out that precautionary allergen labelling (PAL) is voluntary, so there is no way to tell if an unlabelled product is safe for consumption by allergen-sensitive consumers. Furthermore, the authors suggested that permissive labelling, which highlights what would be safe and suitable instead, would make it safer for such consumers.