Del Mar, CA (September
22, 2004) -- Food Consulting Company is advising food
companies to prepare now to meet the January 1, 2006,
mandatory compliance date for federally mandated
allergen labeling. President Bush signed the Food
Allergen and Consumer Protection Act of 2004, into law
on August 2, 2004. This act amends the Federal Food
Drug and Cosmetic Act and requires food manufacturers
to identify, in plain, common language, the presence
of any of the eight major food allergens (milk, egg,
fish, Crustacean shellfish, tree nuts, wheat, peanuts,
and soybeans) that are or might be present in any
ingredient contained in a food product.
Many food labels already bear voluntary allergen
declarations according to Karen Duester, president of
Food Consulting Company, but the information may not
satisfy the new law. “For example,” said Duester, “the
‘plain, common language’ requirement means that an
ingredient such as sodium caseinate will have to be
declared in the ingredient list as being derived from
milk.” Right now manufacturers often use chemical
names to declare certain ingredients like sodium
caseinate without declaring in ‘plain, common
language’ their associations with a major allergen.
The law also requires that labels must declare if
flavorings, colorings, and other additives are derived
from or have been in contact with a major allergen at
any time during the manufacturing process. Duester
explained that existing ingredient labeling
regulations have not called for this and so
manufacturers do not routinely declare the incidental
additives found in these ingredients even if they have
been associated with a major allergen. “Now
manufacturers will need to research ingredients to
determine or rule out exposure to allergens.”
“The distant compliance date might imply plenty of
time,” according to Duester, “but really it is just 15
months away.” Savvy manufacturers have to allow time
for research and they will want to have revised label
content ready to be incorporated into new label plates
and print runs when current label inventories expire,
or when labels are updated to reflect formulation
changes or label design changes -- all in order to
gain economic savings.
The bill has other requirements including facility
inspections and the publication of a final rule to
define and permit use of the term gluten-free on food
labels. Manufacturers can read the bill by searching
Bill Number “S.741.ENR” at
http://thomas.loc.gov.
Concerned parties can keep up-to-date on the allergen
regulation progress and other government changes
affecting food labels by subscribing to INTOUCH, a
free email newsletter available at
http://www.foodlabels.com/newsletter.htm.
Food Consulting Company, based in Del Mar, CA, and the
largest out-source provider assisting food companies
in meeting FDA label requirements, offers a full range
of food labeling services including product analysis
(both database and laboratory), nutrition facts
panels, ingredient statements, allergen information,
full label compliance packages, shelf life
evaluations, and final label reviews. Duester can be
reached through the company web site at
http://www.foodlabels.com, or by calling
800-793-2844.
# # #
© Food
Consulting Company, 2004.
