BRC Clause 5.2.1.2: "The Company shall identify and list allergen containing materials handled on site. This shall include raw materials, intermediate and finished products".
Does it mean we have to list ALL raw materials, finished products and WIP to meet this clause.
Currently we have listed only those products,WIP and raw materials which has sesame seed or nuts in them as these are considered Category A Allergens.
As we are sandwich manufacturer, if we start listing all allergens e.g milk, egg, soya, fish,crustacean etc we have to almost list all of our products.
Please share your thoughts and experience.
Regards
Martin Blue
Dear Martin,
I'm just seeing this discussion for the first time, so pardon me for any repetition or misinterpretation of your question. If you are talking about the listing of allergens which are used as an ingredient in a product (so not due to cross-contamination, thus not for the "may contain" issue) i have put down below the foods and products which HAVE to be labelled on prepackaged products due to the EU labelling directive:
So: As a result of the Labelling Directive you always have to label the allergenic foods listed in Annex IIIa or any product derived from these foods with a few exceptions shown in another section.
Allergenic foods listed in Annex IIIa:
Cereals containing gluten, (i.e. wheat, rye, barley, oats, spelt, kamut or their hybridized strains) and products thereof Crustaceans and products thereof Eggs and products thereof Fish and products thereof Peanuts and products thereof Soybeans and products thereof Milk and products thereof (including lactose) Nuts i.e. almonds, hazelnuts, walnuts, cashews, pecan nuts, Brazil nuts, pistachio nuts, macadamia nuts and Queensland nuts and products thereof Celery and products thereof Mustard and products thereof Sesame seeds and products thereof Sulphur dioxide and sulphites at concentrations of more than 10 mg/kg or 10 mg/litre expressed as SO2
. Lupin and products thereof
• Molluscs and products thereof
Examples of what this means in practice
Sulphite levels above 10 mg/kg in the ready-to-consume product must always be mentioned on the ingredient label, even if sulphites were not added intentionally into the finished product. Alcoholic beverages are not exempted from this labelling and therefore the sulphite used in their production must be declared as well. Ingredients used as processing aids, like egg white in wine production and lactose as a carrier substance for flavours must be listed.
• Similarly, if the source of a vegetable oil or a flavour is a food listed in Annex IIIa it must be specified on the label unless it is permanently exempted from allergen labelling.
List of food ingredients and substances provisionally excluded from Annex IIIa of Directive 2000/13/EC
Ingredients Products thereof provisionally excluded
• Cereals containing gluten
— Wheat based glucose syrups including dextrose (1)
— Wheat based maltodextrins (1)
— Glucose syrups based on barley
— Cereals used in distillates for spirits
• Eggs
— Lysozym (produced from egg) used in wine
— Albumin (produced from egg) used as fining agent in wine and cider
• Fish
— Fish gelatine used as carrier for vitamins and flavours
— Fish gelatine or Isinglass used as fining agent in beer, cider and wine
• Soybean — Fully refined soybean oil and fat (1)
— Natural mixed tocopherols (E306), natural D-alpha tocopherol, natural D-alpha tocopherol acetate, natural D-alpha tocopherol succinate from soybean sources
— Vegetable oils derived phytosterols and phytosterol esters from soybean sources
— Plant stanol ester produced from vegetable oil sterols from soybean sources
• Milk
— Whey used in distillates for spirits
— Lactitol
— Milk (casein) products used as fining agents in cider and wines
• Nuts
— Nuts used in distillates for spirits
— Nuts (almonds, walnuts) used (as flavour) in spirits
• Celery
— Celery leaf and seed oil
— Celery seed oleoresin
• Mustard
— Mustard oil
— Mustard seed oil
— Mustard seed oleoresin
(1) And products thereof, in so far as the process that they have undergone is not likely to increase the level of allergenicity assessed by the EFSA for the relevant product from which they originated
The EU Directive does not talk about threshold levels. The exclusions are based on scientific provided evidence (publications) where it is clear that the related product did not cause any harm to individuals. this to the opinion of EFSA.
So with respect to your company 's products: If you are producing pre-packed product, you will have to label all the ingredients incl allergens used in the recipe.
It's all about consumer protection by giving all information available
Frans Timmermans