VEGA comments on an FSA consultation on Food Labelling - Declaration of Allergens
Re: Draft Food Labelling (Declaration of Allergens) Regulations
We favor Option 3 in Annex B.
We make 2 general points with regard to labelling.
1. More detailed chemical names are needed, e.g. to indicate matters of molecular chirality or geometry that may have biological significance, e.g. D-, L-, DL-, R-, S- prefixes to names such lactic acid, malic acid, methionine etc.
2.1 The regulations need to be overhauled in the light of free-from and, e.g. dairy-free descriptions and their definitions. Thus, consumers may be surprised to find DL-lactic acid among the ingredients of a product described as dairy-free. As non-dairy alternatives are now so widely available we repeat the need in definitions for the word milk to be accompanied by an indication of the source or species from which it has been directly derived: thus human milk, cow milk, sheep milk, soya milk, rice milk…
2.2 Aversions affecting a number of consumers count as strongly by purchasers professing some form of “allergy” to perceived scientific, medical, ethical, or religious objections to ingredients, components, processing aids, or manufacturing practices as to customers affected by the presently received list of allergenic items of food.
Such consumers might be vegetarians, Jews, Muslims, Hindus, animal welfarists, and environmentalists, and opponents to GM, for instance, who may not gather from the other labelling, claims, and details that they were being unwittingly compromised. Dairy-free, for example, may be equivocal if gelatin or certain fining agents, processing aids, non-descript flavorings or greasing agents are involved in foods, and bakery products, and beverages. These reservations would exercise choices and aversions by vegetarians and people of certain religious persuasions. Some colorings and texturizing agents accepted as “safe” may be unacceptable to animal welfarists seeking cruelty-free products and averse to avoidable experimentation. Coal-tar dyes and chemicalized caramels may elicit this humane reaction.
Therefore a “may contain” warning would be apt: “This product may contain substances or involve processes objectionable to vegetarians…” Cross-contamination may occur in factories making a range of products and would offend consumers with added religiously-based aversions.