Food Allergen Labeling: To Exempt or Not to Exempt

Do all processed foods and ingredients derived from foods known to cause allergies need to be labeled as such, even though allergen-causing components of the foods may have been altered during processing?

The ad hoc joint Food and Agriculture Organization of the United Nations (FAO)/World Health Organization (WHO) expert consultation on risk assessment of food allergens released part four of its report, which addresses this question and describes a framework for government authorities or food business operators to consider when or if exempting these foods from allergen labeling would be acceptable.

Allergens in foods are primarily made up of proteins. When foods are processed or refined, the protein structure of the original food may be destroyed, denatured or changed such that the allergenicity of the resulting food derivative is significantly decreased, potentially making it safe to consume, even for people with allergies to the original food product. In order to determine if these food ingredients and derivatives are safe, the quality of data available on the topic and the outcome of exposure assessments of all the intended ingredients must be considered.

Experts developed a flow chart-based tool that can be used in determining if consumer safety is maintained in the face of labeling exemptions of different food ingredients and derivatives of priority food allergens. This tool was validated for derivatives already approved by countries or regions, for which there is an established history of safe consumption. Moreover, the tool can be used for any future development and evaluation of derivative exemptions, with review by competent national authorities. In brief, “When safety is established, exemption can be justified.”

The ad hoc joint FAO/WHO expert consultation on risk assessment of food allergens had a series of meetings since 2020, and all the meeting reports are available now.

Part 1 Priority food allergens

Part 2 Threshold for the priority food allergens

Part 3 Precautionary labelling

Part 4 Exemptions

Part 5 Threshold for other food allergens