Authors
Title
Abstract
In the article, an overview is presented of the most important legal requirements and the requirements set out in the recognized GFSI standards, i.e. IFS, BRC and F SSC 22000 in the field of allergen management, including the product labelling obligation. In the case of legal requirements attention is mainly focused on Regulation 1169/2011 and Annex II to this Regulation, where 14 allergenic products are depicted and also on the published guidelines to this regulation. Furthermore the issue of unintended presence of allergens is discussed as are the related obligations for the producers. Precautionary Allergen Labelling (PAL) is not regulated by law and the manufacturers make their own decisions as regards the form and content of information about cross-contamination, which they place on their products; their decisions are based on the risk analysis and they utilize information and programs (e.g. VITAL – Voluntary Incidental Trace Allergen Labelling) available on the market. Some examples are given of the requirements for the determination of allergens and the unintended presence of allergens, which are in force in 8 selected countries. Then, the scope is presented of the requirements relating to allergens as set in IFS, version 6.1, BRC, version 8, and FSSC 22000, version 4.1. The BRC requirements for allergens are widely described. The entire Chapter 5.3 is dedicated to the requirements that have a crucial role when establishing and accomplishing tasks necessary to ensure food quality and safety. Both IFS and FSSC 22000
define the scope of allergen-relating requirements to a much lesser extent. Every producer is obliged to implement allergen management systems. Where the issues on labelling are included in the legislation in force, the respective labelling requirements should be applied while in the case they are not regulated by law (as in the case of PAL) it is always the manufacturer’s responsibility to market safe products, also in the context of allergens.
Keywords
allergens, cross-contamination, unintended presence of allergens, GFSI, precautionary labelling