The dangers of unclear labels

Food producers have a duty to their customers to inform them about what the product contains because unwitting consumption of some ingredients can have fatal consequences.

Labels in the news – The case of Pret A Manger

Although EU regulations require prepacked foods to have a label containing the ingredients list including food allergens, for non-prepacked foods the allergens can be provided as written (menu, chalkboard, on-pack) or oral information (customers are provided with food allergens information by the person who packed the product). In the UK, the non-prepacked food regulation also applies to Prepacked for Direct Sale (PPDS). Pies and sandwiches made and sold in-store fall within this category [2] [8] [9] [10].

In July 2016, a 15-year-old British girl died after an allergic reaction due to a Pret a Manger baguette containing sesame seeds. The package, classified as prepacked for direct sale (PPDS), did not include any allergen information. There was no requirement for these foods to have full allergen labelling on packaging, although allergen information must be readily available to customers if they ask a member of staff.

This, and other similarly tragic cases, have led to Pret a Manger opting for a full-ingredient food labelling policy [11] [12] and the practice has been adopted more widely, reflecting the danger of inadequate food labelling. From 1 October 2021, the UK Food Standards Agency (FSA) will require all manufacturers to provide information about allergens on food labelling on all Prepacked for Direct Sale (PPDS) products and allergenic ingredients will be highlighted [13].

The aim of food labelling regulations is to guarantee that the customer has an opportunity to find out exactly what the product contains. All EU member states are required to apply allergens regulations and impose penalties on manufacturers that don’t comply [2].

What is a food allergen and what are the medical implications?

A food allergen is any component of food that may cause an allergic reaction. It is often a protein. When you have a food allergy your body’s immune system responds in an unusual way to the allergen, creating an allergic reaction that may be mild but can, less frequently, be very severe [5].

Food allergies should not be confused with intolerances even though they may share similar symptoms. Intolerances are caused by atypical digestive responses to certain food types, and mainly affect the stomach [6].

The most common symptoms of an allergic reaction are:

• itch in the mouth, throat or ears
• urticaria (a rash, or hives)
• angioedema (swelling of face, eyes, mouth, tongue)
• nausea/vomiting and abdominal pain/diarrhoea
• fever

The most severe food allergy response is anaphylaxis which can be fatal. Symptoms include:

• difficulties breathing
• trouble swallowing or speaking
• fainting/collapse [7]

Food allergens legislation

In the EU, food manufacturers are required to indicate the presence of allergenic ingredients both in prepacked and non-prepacked foods [1]. However, individual member states may adopt national measures regarding the way in which food allergens are presented on non-prepacked foods since it might not be on the label but given orally [4] – which is what led to the Pret A Manger case we looked at above.

There are 14 allergens that must be indicated [2]:

• Cereals containing gluten – including wheat, rye, barley, oats
• Crustaceans – such as prawns, crabs, lobster, crayfish
• Eggs
• Fish
• Soybeans
• Milk (including lactose)
• Tree Nuts – including almonds, hazelnuts, walnuts, cashews, pecans, Brazil nuts, pistachios and macademia nuts
• Peanuts
• Celery (including celeriac)
• Mustard
• Sesame seeds
• Sulphur dioxide/sulphites (if they are at a concentration of more than 10mg/kg or 10ml/L in the finished product)
• Lupin
• Molluscs – such as mussels, whelks, oysters, snails, and squid.

In pre-packed foods, as well as appearing on the ingredient list, EU Regulation (No. 1169/2011) states that any listed allergens must be highlighted in some way, either in bold, in a different colour or underlined. And in addition to this requirement, if an allergen is not directly present but there is a risk of cross-contamination, food labels should state this using phrases such as ‘may contain…’ or ‘not suitable for someone with […] allergy’ [3].

Example of an ingredients list with food allergens in bold ©UoR

A food allergy sometimes is life-threatening; understanding how to read food labels is necessary to avoid any food allergens. Have you noticed how these are emphasised from the rest of the ingredient’s lists?

Which option of highlighting – such as bolding or underlining – do you think is the most effective?