Lesson 3: Allergen Labeling

Proper package labeling protects:

• Consumers
  • Proper labeling is the only way for them to know the allergen is in the product
• Companies
  • Proper labeling protects from product recalls, regulatory inquiry, and potential liability

Product labeling must be accurate for:

• Legal Compliance
  • Ensures all allergens are identified in compliance with appropriate law:
    • Food Allergen Labeling and Consumer Protection Act provides requirements for FDA regulated foods.
    • Must label for milk, egg, peanuts, tree nuts (species specific), fish (species specific), wheat, soy, sesame, crustacean/mollusks (species specific).
• ‘May Contain’ Labeling
  • ‘May contain’ or similar labeling is NOT a substitute for appropriate GMP’s.
    • Carefully consider label implications for ingredients with precautionary labels (e.g. ‘may contain’).

Allergen labeling errors are a primary cause of food product recalls.

• Consider controls that:
  • Ensure accurate printing
  • Ensure the right label or package is used for the product
  • Manage formula changes to ensure that the correct label is used during transition
• Examples of procedures:
  • Design and copy proofreading
  • Written approval of label and package proofs
  • Identity coding of printed labels and packages
  • Lack of co-mingling when shipping labels and pre-printed packages
• Preventive controls for labeling:
  • Preferable continuous review of label or wrap material during a processing run
    • e.g. bar code scanner
  • Colored striping on edges of packages stacked flat in packaging machines reduces line operator errors
  • Especially important when la bels are applied to product held in unlabeled inventory