Allergen and allergy risk assessment, allergen management, and gaps in the European Food Information Regulation (FIR): Are allergic consumers adequately protected by current statutory food safety and labelling regulations?

Abstract

Individuals suffering from IgE-mediated food allergies are obliged to systematically eliminate the culprit allergen from their diet. To support allergic consumers in avoiding food allergens to make informed and safe purchasing choices, the European Union (EU) Food Information Regulation (FIR) imposes a requirement to label the 13 most common allergenic foods (food groups) as ingredients in pre-packed and non-pre-packed foods.The as yet unregulated labelling of unintended presence of allergens has lead to a widespread use of precautionary allergen labelling (PAL) – despite established allergen management in many companies. This PAL significantly hampers making a safe food choice, or renders it largely unfeasible, since it is not possible to estimate the actual extent to which allergens are present in a product. Not only food-allergic consumers, but also the food industry, physicians, dieticians/nutritionists, as well as food regulators and law enforcement officers would benefit from a standardized labelling regulation for unintended presence of allergens.The following position paper highlights the chances of such a regulation on the basis of available data and the analytical methods for detecting allergenic components in the context of effective allergen management. On the basis of evidence-based allergen and allergy-risk assessment, the use of PAL should be restricted to only those allergens that are unavoidable and which represent an unacceptable risk for allergic consumers, e. g., when allergens are present at levels that exceed a clinically meaningful reference dose or in the case of unintended presence of particulate allergens (e. g., nuts or sesame seeds).