Claims such as ‘hypoallergenic’, ‘non-allergenic’ or ‘allergen-free’ on food products may immediately draw the attention of allergic individuals or their caregivers. However, sometimes there is a disconnect between what consumers think these various statements mean, what manufacturers mean by them, and what regulators intend them to mean.
The second truth; that any allergy sufferer will confirm, is that allergic disorders have a significant and often daily impact on quality of life. Nobody likes a runny nose or breaking out in hives. Certain allergic disorders are potentially life-threatening, and studies have shown that caregivers of children with food allergies experience similar levels of psychosocial stress to caregivers of type 1 diabetics.
What the labelling law says in SA:
In South Africa, we have regulations that set out what information must appear on food labels – the Regulations Relating to the Labelling and Advertising of Foodstuffs (R.146/2010). This regulation defines a list of foods that are considered South Africa’s ‘common allergens’: the foods that most commonly cause allergic reactions. They are: peanuts, tree nuts, cow’s milk, egg, soy, fish, crustacea and molluscs, and significant cereals, which includes the gluten-containing cereals wheat, rye, barley and oats.
It is mandatory to declare the presence of common allergens in the ingredient list on a food label. How these are declared will depend on whether the allergen is an ingredient intentionally added, or sporadically incorporated into the product due to cross-contamination (e.g. traces of peanut from a peanut-containing product may contaminate a peanut-free product if they are produced using the same equipment).
‘Uncommon allergens’ do not need to be explicitly declared on product labels in the same manner as common allergens, but information about their presence must be disclosed if the consumer requests it.
Allergen claims on food labels:
The distinction between common and uncommon allergens goes beyond ingredient labelling and extends to claims. For example, it is allowable to claim that a product is free from a specific common allergen, e.g. ‘peanut-free’, if supporting evidence in the form of analyses is available. However, there is no guidance on making claims for any uncommon allergens.
On occasion, generic ‘allergen-free’, ‘non-allergenic’ or ‘hypoallergenic’ claims are made for food products. These claims are problematic, because it is not clear to the consumer what any of these statements mean. This type of claim may be permitted on infant formulas, but would need to meet strict criteria; the regulations for foodstuffs, however, specifically prohibit the use of the word ‘hypoallergenic’ or any similar wording, unless the foodstuff is modified by chemical or genetic means so as to reduce the quantity of endogenous allergens in such a way that it is not possible to detect the presence of any possible allergen with testing suitable for the specific allergen.
There are currently no foods available that meet these requirements. A general ‘allergen-free’ or ‘non-allergenic’ claim may sometimes be used – incorrectly – to indicate that a product is free from all of the ‘common allergens’. However, the product would still not be suitable for someone with an uncommon food allergy; therefore, these claims should not be used on food products.
When you suffer from a food allergy, navigating the labels of food products can be challenging at times. Luckily, we do have regulations in place, matching those elsewhere in the world, that guide manufacturers with regard to labelling. Therefore if you look out for ‘free from claims, and steer clear of generalised ‘non-allergenic’ claims.