Allergen-Free, Gluten-Free and Precautionary Statements
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"(Naming the Food Allergen)-Free" Claims
Manufacturers making a negative statement or claim pertaining to the absence of food allergen sources such as "(naming the food allergen)-free" and "contains no (naming the food allergen)", must ensure there is absolutely no amount of the named food allergen source present in the product, whether through intentional or inadvertent means.
These claims are permitted on foods that have been specially formulated or are processed under special conditions to ensure the absence of the named food allergen source that may be present in a similar food. The presence of that food allergen source may be in similar products through:
- addition via ingredients or multi-generational ingredients; and/or
- cross contamination despite good manufacturing practices
Regulated parties may be asked by the CFIA to demonstrate that production systems or process controls are in place to substantiate that the claim does not mislead the consumer as to the safety of the food for consumers for whom the consumption of the named allergen would pose a potential health risk.
See Negative Claims Pertaining to the Absence or Non-Addition of a Substance for more information on claims like dairy-free and lactose-free.
Allergen-Free Claims in Conjunction with Precautionary Labelling
It is not acceptable for a "(naming the allergen)-free" claim to be used in conjunction with a "may contain (naming the same allergen)" statement on the same product. The combination of these two claims is considered to be misleading as to the composition of the food. Furthermore, it is not possible for both statements to be truthful on a single product.
There may be situations where both a "(naming the allergen)-free" statement and other types of precautionary statements (other than the "may contain" statement could be truthful at the same time. For example, it is possible that both a "soy-free" claim and "produced in a facility that also processes soy" statement could be true for a single product. In such situations, it is important to note that in no way does a precautionary allergen statement or other similar types of statements reduce a regulated party's responsibility for the accuracy of a "(naming the allergen)-free" claim. A false or inaccurate "(naming the allergen)-free" claim may be subject to enforcement action by the CFIA, regardless of whether a precautionary statement is also present.
The use of a "gluten-free" claim in conjunction with a "may contain wheat" statement, while possibly factual, should be done with caution. It is understood that "may contain wheat" could alert individuals with a wheat allergy to the presence of low levels of wheat in a gluten-free food. However, manufacturers must ensure that the product contains no intentionally added gluten sources and less than 20 ppm of gluten as a result of cross-contamination on a consistent basis, and that the other criteria for "gluten-free" claims outlined above are also met. In this instance, manufacturers are encouraged to use the statement "may contain less than 20ppm of wheat". For information on Gluten-Free claims, refer to Gluten-Free Claims.
General "Allergen-Free" or "No Allergens" claims
General claims stating only "Allergen Free" or "No Allergens" are considered to be too broad in nature and are therefore not acceptable. The list of potential food allergen sources is not restricted to the list of priority food allergens identified by Health Canada. There are over 200 food proteins that can cause adverse reactions to some segments of the population. Therefore, it is likely to create an erroneous impression to state that a product is free of allergens.
"(Naming the Food Allergen Source)-Free" Symbols
Any representation (statement, image or advertising) that states, suggests or implies that a food allergen source is not present when it is present would be considered false and misleading information under subsections 5.(1) of the Food and Drugs Act and 7.(1) of the Consumer Packaging and Labelling Act. (Naming the food allergen source)-free symbols or representations are interpreted to be the same as making a "(naming the food allergen source)-free" claim. Therefore, the same requirements apply when using such symbols or images.
It is important that such symbols or images indicate what is absent in the product. It is recommended that clarifying text, such as a "(naming the food allergen)-free" statement, accompany the symbol to ensure the symbol or image is not misinterpreted.
Wheat-Free Claims on Products Containing Canary Seed
Health Canada has issued a novel food decision permitting the sale of glabrous (hull) varieties of brown and yellow coloured canary seed. Canary seed contains proteins that may be similar to those proteins responsible for wheat allergies. For this reason, Health Canada states that it would be inappropriate for canary seed, or food containing canary seed, to carry a wheat-free claim. For more information see Health Canada's Information for Wheat-Allergic Individuals - Canary Seed.
"Does Not Contain Nuts" Claims on Products Containing Coconut
Products containing coconut can declare "does not contain tree nuts or peanuts". Coconut must be declared in the list of ingredients as per general labelling requirements.
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