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Food Labels: Read It Before You Eat It!

For people with food allergies, food allergen avoidance is a critical part of preventing allergic reactions. Understanding how to read a food label is necessary to effectively avoid any food to which one might be allergic.

Reading a food label for allergens is different from what you might be used to. It is more than just looking at the carbs, protein, salt and calorie count. Instead, for food allergies, the ingredient list and any warning labels are the most important. However, packaged and processed foods often contain many ingredients and sometimes they are not labelled in a straightforward way. This can make reading food ingredient labels difficult and it may be hard to know how a particular ingredient relates to your allergy.  

Here are a few tips and things to keep in mind when reading a food label for food allergy:

Read the label every time. No matter how routine or mundane, it is important for individuals, parents, and care givers to remember to read every food label every time, even if it is something which is consumed frequently. For various reasons, food manufacturers often change the ingredients of their products without modifying their packaging. A common example is a chocolate bar that may be labeled “peanut free” most of the year, whereas the version made for Halloween may be labeled “may contain peanuts”. Even when eating out, it is wise to directly check the label.

Where should I look first? To someone with food allergies, reading an ingredient list can be like looking for a needle in a haystack, many listed ingredients are there for reasons irrelevant to you. Some common food allergens are listed using technical names instead of their everyday ones. For example, sodium caseinate can be used to indicate that a product contains a milk protein called casein.

Therefore, when reading a food label, start with the “contains” statement. This section is recommended with specific guidance by the Food Allergen Labeling Consumer Protection Act (FALCPA) of 2004, to identify in plain language the most common foods to which Americans are allergic. For example, the “contains” label should say “contains milk” or the ingredient list should say “sodium caseinate (milk)” instead of just “sodium caseinate”. The FASTER Act of 2021 (Food Allergy Safety, Treatment, Education, and Research) expands upon FALCPA to include sesame as a common food allergen.

For people with celiac disease or gluten sensitivity, labeling can be inconsistent. Although wheat is mandated to be labelled through FALCPA as it is one of the big eight allergenic sources, other sources of gluten (barley and rye) are not. Therefore, it may be best to look for ‘gluten free products’ if the consumer has celiac disease.

Food Allergy Label
What are the major allergenic sources that must be labeled? Currently, FALCPA indicates that the sources of commonly allergenic foods must be declared in plain English (e.g. milk, peanut, etc.) on product labels. Three options are available. A “contains” statement can be used, e.g. contains milk and peanut. The source of the ingredient can be listed in the ingredient statement, e.g. wheat flour or buttermilk (but not flour or caseinate). The source of this ingredient can be listed parenthetically, e.g. caseinate (milk) or natural flavor (peanut).

1.    Milk (from cow). However, someone allergic to cow’s milk would likely react to milk from sheep, goats and maybe camels.
2.    Eggs (from chickens). However, someone allergic to chicken egg would also likely react to eggs from other birds.
3.    Fish (fin fish including bass, flounder, trout, cod, salmon, shark and skate)
4.    Crustacean shellfish (shrimp, lobster, crab)
5.    Tree nuts (for example: almonds, cashews, pistachios, pecans, walnut, hazelnut; but the FDA also requires the specific identification of tree nuts that are less commonly allergenic such as coconut, shea nut and pine nuts).
6.    Peanuts (also called ground nut by some)
7.    Wheat (any form, includes spelt, kamut)
8.    Soybean (soy)
9.    Sesame

Ingredients of these most common nine allergens must be labeled with clearly recognized English names of the food source as listed above.

The “contains” statement is “voluntary”, but if used, must include ALL of the allergenic ingredients from the list of eight allergenic sources as described in item 14 of the 2006 guidance document.

Are there exceptions to FALCPA labelling? It is also important to realize that mustard and molluscan shellfish, such as oysters, clams, mussels or scallops, are not required to be labeled as a major allergen under FALCPA and FASTER. They are required for labeling in Canada. However, even in United States, these foods must be declared on the ingredient list if they have a technical or functional effect in the product with the exception that they can be hidden in terms such as flavorings on occasion. They cannot be identified in the “contains” statement so consumers must look for them in the ingredient list.

FALCPA affects all packaged foods sold in the United States: conventional foods, vitamins and dietary supplements, infant formula and foods, medical foods, and all retail and food-service products packaged for sale.

Exclusions from FALCPA include: prescription and over-the counter drugs, personal care items (such as cosmetics, shampoo, mouth wash, toothpaste or shaving cream), pet foods and supplies, any food products regulated by the United States Department of Agriculture (USDA) Food Safety and Inspection Service (FSIS) (meat and poultry products and whole eggs), any food product regulated by the Alcohol and Tobacco Tax and Trade Bureau. Although the USDA FSIS encourages food companies to follow FALCPA, they are not obligated to do so.

Some things made from certain food sources are exempt from labels. For example, highly refined oils from soybean are exempt from source labeling. Raw agricultural products (corn, rice) may contain low levels of a different allergenic crop (soybean, wheat) due to shared farm equipment and are not labeled. Some ingredients including spices and colorants do not have to be labeled unless they are any of the big nine allergens.

How dangerous are precautionary labels or “may contain” statements? You may also see Precautionary Allergen Labels (PAL), more commonly known as “may contain” statements. In contrast to the regulations imposed by FALCPA, PALs are voluntary, not standardized, and not mandated by law in the United States or any other country. Companies may use PALs to signify that there may be some risk of unintentional contamination of their product with certain allergens. Some foods labeled with PALs have little or no contamination, for others it can be fairly high or on occasion. Similar to PALs, restaurants may provide precautionary statements (e.g. “We cannot guarantee that…”). The inconsistency and vagueness of PALs are particularly problematic because they do not provide you with a clear sense of how risky ingesting the food is. A contrasting analogy can be made during risk evaluation of crossing the street. Anyone can be at risk of an accident when crossing a road, but usually it is obvious how much traffic there is and how dangerous it might be to cross at any given time (e.g. walk sign versus stop sign). Therefore, until there are better and more standardized PAL practices, many choose to avoid foods that have a PAL or “may contain” statement.  

Because PAL statements are voluntary, many different wordings are used in PAL statements. If PALs are used, they are legally required to be truthful and not misleading. No matter the language, it does not change the amount of risk. Common examples of PALs include (where X can be peanut, tree nut, egg, milk, etc.):

a. May contain X
b. Made in a facility that uses or processes X
c. Made on shared equipment with X
d. Not guaranteed to be free of X

Food Allergy Label

What about international food labels, or when I travel? Food products made in other countries still have to comply with FALCPA if they are officially imported into and sold in the United States. Other countries have different labelling practices and laws.  

In addition to the nine allergens covered by FALCPA and FASTER, in Canada additional allergens are mandated to be labeled in “contains” statements: molluscan shellfish (snails, octopus, clams and scallops), mustard and sulfites (a preservative). In Japan, buckwheat, peanut, milk, egg, shrimp and crab must be labeled.

Final Tips:
•    Work with your healthcare providers to ensure you have a good understanding of your or your child’s allergies and what allergens and foods to avoid.
•    Read every label every time.  
•    Be aware of exceptions to FALCPA and FASTER, including when eating foods outside of the United States.
•    Understand that precautionary labeling is voluntary and all PAL statements are equal in their potential risk.
•    Clear communication is essential.
      o    Ask questions of restaurant staff and let them know what is safe to eat.
      o    Do not be afraid to ask questions when eating in someone else’s home.

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