Act Now on Allergens

Complying with the new labeling rules

On January 1, 2006, new federal allergen labeling rules went into effect. People’s Food Co-op (La Crosse, Wis.) became aware of these new regulations on about December 15, 2005, when information arrived by mail inside of a Food Marketing Institute member update. We were behind the 8 ball.

Quickly we gathered the troops and went to work on a plan. PFC has a sizeable foodservice operation, and we knew that it would take some time to accomplish what needed to be done. We believe that as a co-op we have a responsibility to be leaders in our community on this labeling issue.

About two years ago we switched from latex to vinyl gloves in the store in order to reduce the chance for allergic reactions. As we embarked on this new labeling project, we learned that there were more things we could do to mitigate risks to our most sensitive shoppers.

We found as we reviewed the nearly 2,500 items that we produce and/or label here in the store, that most of the confusion that could arise for our shoppers centers around our use of “compound” ingredients in our food service operations. For example, ingredients such as mayonnaise, Vegannaise, tamari, or even ‘mock crab’ present the greatest opportunity for a shopper with an allergy to miss the fact that they might react to one of these “ingredients.” It doesn’t always register when seeing tamari listed as an ingredient that wheat can be a component. Our research also taught us a few things, like the fact that white fish used to create “mock” crabmeat is soaked in shellfish oil and therefore could trigger an allergic reaction even though the product is based on a fin fish rather than a shellfish.

We realized, when we put the spotlight on the issue, that many shoppers make assumptions: because the ingredients we use in some recipes are assumed to be standard, they therefore may not read the ingredients listing carefully. A great example is pesto. PFC makes its pesto with walnuts (rather than pine nuts), which can be a big trigger to folks who make a bad assumption. The allergen labeling allows us to be very clear.

This project took a lot of hours and the involvement of most of our management team (IT, executive and sous chefs, deli manager, grocery manager, bulk buyer, cheese buyer, and operations manager), and we ran into challenges along the way. We reviewed every single recipe, and in some cases made decisions to change a production method to eliminate a potential allergen. Part way through the project we found that we needed to reformat our scale labels to fit the additional text because on some particularly complex items we ran out of space! We also ran into situations where some smaller scale producers of bulk product were themselves not yet in compliance, and getting the information we needed to do an accurate job of labeling was a challenge.

But the process has helped make this issue more “top of mind” in our store. Our staff has requested additional training about food allergies to help them have a greater understanding of the dangers and how they can help. A local allergist has agreed to provide this training.

Labeling Specifics

As of January 1, 2006, packaged foods labeled with an ingredient statement must include allergen information if they contain ingredients, flavorings, colorings, or incidental additives that are, or contain, a major food allergen. The major food allergens that must be labeled are: milk, egg, fish, shellfish, wheat, soy, peanuts, and tree nuts. Additionally, the particular type of nut, fish or shellfish must be identified in the allergen statement (e.g., walnut, hazelnut, crab, shrimp).

You may identify allergens in either of two ways:

  1. Immediately after or next to the list of ingredients, use a statement reading, “Contains [followed by the name of the food source from which the major food allergen is derived].” Example: “Contains milk and wheat.”

The statement must identify the sources of all major food allergens contained in the food, even if some of the allergens are immediately identifiable in the ingredient list. The type size of the allergen statement must be equal to or larger than the list of ingredients.

  1. Place the common or usual name of the major food allergen in the list of ingredients, followed in parentheses by the name of the food source from which the major allergen is derived.

Required when the name of the major food allergen does not appear elsewhere in the ingredient statement. Example: “natural flavoring (egg, soy)” or “natural flavor (milk).”

An ingredient statement (and, therefore, allergen information) is required for the following foods:

  1. Packaged foods with two or more ingredients. A deli sandwich made to order is not considered packaged, but one that is made ahead of time and sold from a grab ’n’ go case is considered packaged.
  1. Food not intended for immediate consumption that is pre-portioned and packaged by the retailer prior to display. For example a cake baked and frosted at the store sold in packaged form.
  1. Food sold in bulk from self-service bins. Ingredient information must be provided on either the bulk bin in plain view of the customer or on a card, sign, or other medium.

Allergen labeling is not required for:

  1. Unpackaged foods or foods given to the consumer only in a sanitary wrapper.
  1. Foods prepared or portioned according to a customer or employee order, whether or not the food is intended for immediate consumption (e.g., ice cream cone, pizza, salad bar, deli salad from a service case).
  1. Foods regulated by the U.S. Department of Agriculture (e.g., meat, poultry).
  1. Raw agricultural products in their natural state (e.g., raw fruits and vegetables).
  1. Highly refined oils and ingredients containing these oils.

When cross-contamination cannot be avoided by good manufacturing practices, you may use a “May contain [specific allergen(s)]” statement to notify consumers about the possible presence of an allergen in a food product.


Michelle Schry is general manager at People’s Food Co-op in LaCrosse, Wisconsin ([email protected]).

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