Declaration of Food Allergens - Pre-Packaged Foods

The CFIA is again reminding food manufacturers, importers, distributors and retailers of their responsibility to ensure that the foods they sell are safe for all consumers, including those with food allergies.

Food Allergens

Most allergic reactions are caused by the following foods and their derivatives:

• Peanuts
• Tree nuts (almonds, Brazil nuts, cashews, hazelnuts [filberts], macadamia nuts, pecans, pine nuts, pistachios, walnuts)
• Sesame seeds
• Milk
• Eggs
• Seafood (fish, crustaceans, shellfish)
• Soy
• Wheat
• Sulphite

Label Requirements Applicable to Pre-Packaged Foods in Respect to Allergens

The Food and Drug Regulations (FDR) requires a complete and accurate list of ingredients and their components on the label of most pre-packaged foods. There are some exemptions to this requirement. For example, certain components of the ingredients used in making sandwiches may be exempt from declaration under the Regulations. However, a pre-packaged food product labelled with a list of ingredients is unsafe for people with food allergies if some of those ingredients or components are priority allergens and are not declared on the label. Failure to declare allergenic components may be contrary to Subsection 5(1) of the Food and Drugs Act and Subsection 7(1) of the Consumer Packaging and Labelling Act. These products may therefore be subject to regulatory measures taken by the CFIA, including a product recall.

In addition, the CFIA encourages identification of the plant source of ingredients (e.g. hydrolysed soy protein, wheat starch, modified wheat starch, soy lecithin) on the label.

Allergen Prevention Plans

The CFIA recommends that the food industry develop strategies, such as an allergen prevention plan², to manage the risks associated with priority allergens. The strategy should include a thorough evaluation of manufacturing and ingredient control procedures. In the case of imported pre-packaged food products, it is the importers' responsibility to ensure those products are fully and correctly labelled.

Precautionary Labelling

Despite all possible precautions, the presence of allergenic ingredients in foods cannot always be avoided. In order to assist consumers affected by food allergies, the Canadian government, in consultation with industry and allergy groups, developed a policy on precautionary labelling ("may contain" statements). This policy allows the food industry to voluntarily label products which may inadvertently contain substances capable of causing severe adverse reactions. Precautionary labelling, however, must be truthful and must not be used in lieu of adherence to legal requirements. When an allergen is likely to be present in a product, the use of precautionary labelling is not acceptable and the presence of the allergenic ingredient should be accurately declared on the label. Further information on basic labelling requirements can be found in chapter 2 of the Guide to Food Labelling and Advertising².

¹ A Tool for Managing Allergen Risk in Food Products - http://www.inspection.gc.ca/english/fssa/invenq/inform/toualle.shtml
² Guide to Food Labelling and Advertising - http://www.inspection.gc.ca/english/fssa/labeti/guide/toce.shtml

Originally issued March 23, 2007 (Information Letter To Industry)