IN RESPONSE to the flurry of concern on Twitter and in Blogland over these new allergy labelling regulations, the Food Standards Agency’s Head of Allergy Branch Sue Hattersley has posted a response. You can find it here.
I’ve had a read through and I’m afraid I’m still not convinced.
Here goes:
1. She notes that the ‘contains x’ allergy boxes have never been compulsory and have sometimes included errors, meaning the ingredients list and the allergen box are contradictory. As allergic consumers we are well aware that the warning boxes are not obligatory – but my response is, why not make them so? And if there were errors before what is to stop there being errors in the new system?
2. She notes that the British Retail Consortium has issued guidance to UK manufacturers on how best to emphasise allergens within the ingredients list. Find the guidance here. In fact, this does nothing to allay my fears over inconsistency in how allergens will be highlighted. It leaves it up to the manufacturer to decide how best to do this (in bold, italics, underlined etc). While some will adopt best practice and no doubt make allergens stand out beautifully, others will think that italicising a few words within a long list is enough. It won’t be. See the comments from readers of my previous blog post for some serious concerns.
3. On the plus side, she notes that the new rules will be EU-wide and that is a good thing. At least we are left in no doubt as to whether allergens have to be declared when we are studying labels in other European countries. I welcome this standardisation across countries.
4. She insists that the compulsion to provide allergy info in restaurants, cafes and delis is “good news”. In honesty, I can’t see that much will change if retailers can deliver that information verbally and not necessarily in clear written format – too much room for error, here. I will feel no safer ordering food from a cafe or deli with this guidance than I do now.
5. Finally, she adds:
“If a business does decide to give information orally this will have to be backed up by good allergen control processes and staff knowledge, and these can be checked by local authority enforcement officers.”
In theory this is great but in reality it means very little. What are “good allergen control processes”? Is it obligatory for all food retail staff to undergo standardised training? When will they be checked by enforcement officers? When things go wrong? I am afraid I don’t have full faith in local authority enforcement either. One allergy friendly food producer I know was recently told by her local authority officer that she was “too cautious” about potential cross contamination. I wasn’t aware there was such a thing as ‘too cautious’ in this context.
Sorry to say, Food Standards Agency, I’m still not with you on this.
yesnobananas 
I completely agree with all the points you make. New labelling will not make my life easier in any way. In fact lack of allergen boxes just makes my life harder. I always read the allergen box first and if all ok then the ingredients list. Lets have allergy boxes aswell, it can’t be that difficult can it? Then we have a double “safety net” for allergens. All manufacturers should be highlighting allergens in the same way too, lets keep it as simple as possible.
Like you. I still will have no more confidence in eating out. All food establishments should have clear written ingredients lists, identifying allergens, for all food. We don’t want none of this verbal nonsense. We must be clear on this, there is absolutely no room for error.
Please, ONE mandatory procedure for both manufacturers and food establishments.
Come on FSA, lets get it right. Mistakes could cost lives.
Thanks Marie… I fear it’s too late for the FSA to take note. They seem to think (like many organisations) that ‘clarifying’ their policy and ‘responding’ to consumers’ concerns means repeating exactly what they’ve said before, just slower and louder. What I’d really like is for them to address our specific concerns and explain why they have come to those decisions and whether they might be prepared or able to rethink any of them. I’m going to be emailing foodintoleranceenquiries@foodstandards.gsi.gov.uk to detail my issues – am really hoping lots of other people do too…
Will be emailing as well, I just cannot understand or see any way whatsoever that removing the allergy boxes is a step forward. Most people with severe allergies seem to rely on them to eliminate unsafe foods before then moving on to the full list to double check. Perhaps someone from the FSA would like to go on a couple of shopping trips with allergy sufferers and see how long the trip takes by using allergy boxes to reduce the number of lists to be read compared to reading every single list carefully. Then maybe they could compare that with how long a shopping trip takes when you do not have to read the labels and perhaps realise just one of the issues we have to deal with.
Went to their reply to concerns and left the following comment:
The contains allergens statements may have been inconsistent and there may have been mistakes but they have also been great time savers. Most people with serious allergies do not rely on an ingredient not being in an ‘allergy box’ to decide that the item is safe but being able to quickly check if it is there means that you can eliminate the item without having to carefully read through the entire list. I would be interested to know if research you have carried out involved doing a full family shop? If not I suggest you try it three times. Once when you have to read every single ingredient list very carefully, once when you can use allergy boxes to eliminate items before reading the lists of those you may be able to get and once as a shopper who does not need to scrutinise every item in every list. I suspect that you would find substantial time differences between the three.
I already find it difficult to read some ingredient lists, even with my glasses. My rule is if I cannot read it I do not buy it. You talk about high lighting the allergens within a list. If you use colour have you taken into account colourblindness? Bold or italics are going to be almost impossible to spot unless the size of the font is substantially increased on some items. Will you be setting a minimum font size. If so I hope it is considerably larger than the font used on many items at present.
If a manufacturer wants to provide extra information in an easily accessible manner- allergen warning boxes- why should they not be able to. Saying that sometimes there may not be boxes is not good enough. Sometimes is better than never. In a way allergy warning boxes are a bit like zebra crossing- not always there -so you learn how to cross the road without them, sometimes misused so there are accidents but for the most part extremely helpful and a valuable addition.
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