Labelling

This information is has been researched from a variety of resources believed to be trustworthy and based on scientific research. It is provided only as a resource and is not intended as medical advice or endorsement. If you believe that you have a food allergy or intolerance, it is very important to discuss your concerns with a medical professional.



Food Allergen/Gluten Labelling

Canadian Food Allergens and Gluten Labelling Law

As of August 4, 2012, food manufacturers in Canada are required to label sources of the top food allergens, gluten and sulphites on their packaging.  The two acceptable ways to label these items are listed in the ingredients in common language and/or as a separate “Contains:” statement immediately below the ingredient statement.  Common language means that scientific names for ingredients such as lactoglobulin must use a word that all consumers can understand with the ingredient such as lactoglobulin (milk).  Or, at the bottom of the ingredient list, “Contains:  milk”.

Canadian food manufacturers must label the following:

Gluten

Wheat

Sulphites above 10 parts per million

Peanuts

Tree Nuts

Milk products

Eggs

Soy

Fish (finned)

Seafood (shellfish, crustaceans)

Sesame

Mustard

For specific fact sheets on each of these allergens, please see the Canadian Food Inspection Agency (CFIA) website

Symbols and words indicating that an item is free of a specific food allergen (i.e. peanut free, gluten free) or produced in a dedicated plant are voluntary but must be truthful and meet Canada’s labelling regulations.

Please note that if you are travelling outside of Canada, the top food allergens and labelling laws may be different.  Products that are considered “safe” for your food allergen in Canada may be different outside of the country.  Read ingredient labels every time.

Labelling Law Exceptions

Bulk

In Canada, bulk bins or small packages from bulk packaged in-store do not require ingredient lists.  In addition to the lack of ingredients, they are not recommended for those with life threatening food allergies or Celiac Disease due to the high potential for cross contamination.  Cross contamination occurs when bulk bins are not properly cleaned regularly, are not cleaned between product fillings and when customers use scoops from other bins.  Even gravity fed bulk bins that do not use scoops can be cross contaminated.

Foodservice and Produce

Food items sold for foodservice such as vending, restaurants and cafes are exempt from ingredient labelling.  This includes items such as prewrapped sandwiches or baked goods.  This also applies to businesses that roast meat for sale on the premises such as roast chicken.

However, if a business chooses to put the ingredient list on an item, they are now required to declare all of the top allergen and gluten sources as per the regulation.

Produce is also exempt from ingredient labels as they are a single food item.  This is of concern to those with sulphite allergies as fresh grapes may be sprayed with sulphites to inhibit mould growth.

Alcohol

Any of the top food allergens used as fining agents in wine and spirits must be declared on the label although a full ingredient statement is not required.  Beer, ale, stout, porter and malt liquor is exempt from allergen and gluten labelling based on the belief that consumers already know that these items are made from wheat or barley.

Highly Refined Oil

In June 2013, the Canadian government announced that they would no longer require allergen labelling on highly refined soy or fish oils.  If the oil used is not highly refined for these 2 major allergens, the manufacturer is expected to put a "Contains" statement on the product.  For more information, see the Health Canada announcement at:  http://www.hc-sc.gc.ca/fn-an/label-etiquet/allergen/oil-refined-huile-raffinees-eng.php

Agricultural Cross-Contamination

Due to North American farming practices, agricultural cross contamination is so widespread and common that Health Canada doesn't require agricultural products to list contamination with other crops, even if they are a top food allergen.  Health Canada explains this at:  http://www.hc-sc.gc.ca/fn-an/securit/allerg/fa-aa/co-mingling-melange-eng.php

"May Contain" Labelling

Although many food manufacturers voluntarily list May Contain statements, they are not required or regulated and there is no standard by which they are applied (although the Canadian government does have suggested guidelines).  This is left up to the food manufacturer.

Many consumers incorrectly believe that manufacturers place these statements on labels for legal purposes, not because the food contains the allergen.  Governments everywhere around the world are reviewing food allergy statements on ingredient labels after alarming studies showing that many of the food allergic ignore those warning statements. 

However, several studies worldwide have shown that many food products with “May contain” statements on them have demonstrated measurable levels of allergenic proteins.  Therefore, ignoring the warning may have dire consequences.

Is a Dedicated Facility Important?

A dedicated facility is where food is manufactured without a specific top allergen used in that facility.  A manufacturer may have a dedicated facility for only one specific food allergen while another may indicate that their facility is free of several different top food allergens.

Whether a dedicated facility is important to you is highly dependent on the level of severity of your reaction, the type of products that the business is making and the allergen and gluten controls that are in place for manufacturing the product you’re eating.  It is really up to the consumer’s comfort level.

For example, a bakery that is dedicated only to gluten free products is often recommended for those with Celiac Disease because testing has clearly documented that gluten containing flours are difficult to contain and remain airborne up to 24 hours past the time that they were used.  If you’ve ever had the opportunity to tour a bakery, you’ve seen that flour is everywhere, even with good cleaning.  However, if the only gluten containing ingredient in that bakery is malt flavouring (made from barley), the facility and equipment would be much easier to clean and a safe gluten free product would be easier to provide.  A dedicated facility is therefore reduced in importance.

If you’ve got gluten sensitivity, a non-dedicated bakery may be suitable as long as there are gluten and allergen controls in place that you trust.  This might include thorough washing of the equipment between gluten and non-gluten containing products and finished product testing to ensure no gluten is in the gluten free product

For someone with a walnut allergy, a bakery using walnuts may be able to provide you with some safe products.  For example, if the walnuts are only used in a separate section of the bakery with dedicated equipment for those pastry products, you may feel comfortable enough to eat the bread made in a different section that the manufacturer tests regularly for walnut cross contamination.

Even if you’re buying products that are from a dedicated facility, that does not guarantee their safety, it simply reduces the risk.  Ingredients coming into that facility may still be accidentally cross contaminated and humans do make mistakes, no matter how careful they are.  A dedicated facility, if provided, is only one part of a thorough food allergen and gluten food safety plan that a reputable manufacturer has in place.

Allergy Free, Allergy Friendly and Guarantees

Often people refer to “allergy free” food products as those that are completely free of the top food allergens for their country.  However, any food can be a life threatening food allergen to any individual whether it is on the top food allergen list or not.  Further, the term “allergy free” is not specifically regulated by food labelling laws or certified by any 3rd party organization. So “allergy free” labelling must be approached with caution and ingredient lists should be read every time regardless of an “allergy free” label.

If a product states a specific "free" statement on the front, such as peanut free, checking the ingredient list is still highly recommended.  There are companies that have free from statements on the front of the package with may contain statements for that same food allergen on the back.

The term “Allergy Friendly” on a label often indicates that the company is producing items suitable for various food allergies and the ingredients should be read every time.

A Note About Guarantees
At one point, it was common for food manufacturers to guarantee that a product was free of a particular allergen.  However, as discussed below under Allergen Thresholds, science can’t even test down to 0 parts per million so to guarantee 100% safety is scientifically impossible.  Instead, it has now become common practice for reputable manufacturers to provide consumers with the steps they take to determine that their product is free of a particular allergen.

The Bottom Line
As a food allergic consumer, you need to always read food labels and research what reasonable allergen safeguards a company has put in place and then determine your comfort level based on that information.

Food Allergy Certification and Allergen Thresholds

Beyond voluntary labelling by food manufacturers, we do not yet have widespread food allergen certifications or defined food allergen thresholds that are considered safe with the exception of gluten and sulphites.

To put it into perspective, the threshold for gluten is 20 ppm (parts per million). Anything under 20 ppm is considered safe by the leading scientists in gluten research, even when taking into account eating many products under 20 ppm during the day - the cumulative effect. Sulphites are given the threshold of 10 ppm.  Following these accepted levels, the government can then create labelling laws that specify the threshold and food producers follow this in the labelling/marketing of their own products. 

To date, no other food allergens have been given a definitive ppm below which they are considered safe for people with food allergies.  Therefore, the current level that they are considered safe at is at the lowest amount that an allergen can be tested at using scientifically valid methods.  At this time, there are no scientifically valid tests available down to 0 ppm of a specific allergen.

In November 2011, an Allergy Task Force was put together with researchers around the globe including the widely renowned Stephen Taylor from the University of Nebraska's Food Allergy Research and Resource Program (FARRP). The task force is currently working on determining threshold amounts for peanut, milk and egg.

So what does that mean for food allergens? The task force has already been reviewing and conducting scientific research to determine at what level food allergens must be present to create an allergic reaction. Just because we can test a food down to 2 ppm for an allergen doesn’t mean that anyone would react to it at that level.  If, for example, it is determined that the threshold for peanut allergy reactions is 10 ppm, only food products consistently testing less than 10 ppm could be labelled as peanut free.

It could also help determine the "may contain" statements. Perhaps on occasion, a product tests at over 10 ppm. A food manufacturer could then put a "may contain peanut" on the label. If a product consistently tested above 10 ppm, the "may contain" may no longer be appropriate because peanut is consistently in the product so it must be labelled "contains peanut" or peanut must be placed on the ingredient list.

For governments, these definitive thresholds can be placed into labelling laws and governments would have the authority to recall products that are unsafe and/or conduct legal investigations and actions for producers disregarding the law.

For food producers, it means that they can also stop guessing and create specific sanitation and testing protocols for their products and food production lines.  They can also label very specifically and if indeed they are putting blanket "may contains" on all of their products, they can stop doing that and allow more of their products to become available to allergic consumers.

Unfortunately, we do not have a timeline for when this international committee will finish their research and present their findings.

Gluten Free Certification

Gluten Free Certifications are voluntary for food manufacturers and are not required by any labelling laws.  Therefore, a manufacturer may indicate that a product is gluten free on the label without any certifications.  However, for the specific term “gluten free” to be on any food label (or implication from a symbol without words), that food must meet the Health Canada requirements as a correct and true statement using the Canadian regulations of a food being under 20 parts per million (ppm) of gluten containing grains. 

Certification is not a replacement for Canada’s labelling regulations.  For those with life threatening wheat allergies, gluten free regulations may not be sensitive enough to avoid wheat.  Contacting gluten free manufacturers for complete details on their methods is recommended.

In Canada there are now 2 different recognized gluten free certifications on food and non-food products (i.e. cosmetics, drugs).

The first, from the Gluten Free Certification Organization (formed by the non-profit support group Gluten Intolerance Group out of the USA in 2005), is a simple GF symbol in a black circle with a white background.  According to GFCO’s website, they were certifying over 22 000 products in 27 countries as of June 2015.  Both individual products and facilities may be certified.  For GFCO, certification requires that all products must be testable using current accepted scientific procedures to below 10 parts per million (ppm).  GFCO does conduct audits and monitors more than just testing including the effectiveness of good manufacturing processes.  For more details, see GFCO's FAQ page.

The second program, from the Canadian Celiac Association is similar to that of GFCO’s and is the only program located in Canada.  Its logo is blue and white with the words Gluten Free and an icon of a wheat stalk with a line through it.  The program has not been operating as long as GFCO but is growing with 3 500 products certified as of June 2015.  Like GFCO, all products must test to below 10 ppm and the program audits producers to ensure that they are manufacturing according to good manufacturing practices.  Canadian Celiac Association Certification Program.

The Celiac Sprue Association (USA) does have a logo on some products but it is not a certification process that includes facility inspections.  Instead, it is a recognition seal that declares those companies have agreed to follow the criteria set by the association.  Celiac Sprue Recognition Seal

What is Celiac Friendly?

Until June 2015 in Canada, when Health Canada changed the marketing rules for gluten free oats, manufacturers were not allowed to call any product with pure oats in it gluten free either in written words or in symbols.

Yet, how were consumers to know the difference between a product made with tested, uncontaminated oats vs. conventional oats that were widely considered gluten contaminated?  So manufacturers were allowed to use other labelling terms for gluten free oats including:  pure, uncontaminated, Celiac Friendly, wheat/barley/rye free or wheat free, R5 tested, etc.  Now that these oats may be labelled as gluten free in Canada, you'll probably still see these labels for some time until all manufacturers using gluten free oats phase out their old packaging with these outdated terms.

Restaurants and other foodservice establishments that offer items without the gluten containing grains in them but cannot promise no cross contamination will often refer to their items as Celiac Friendly.

In either case, reviewing ingredient statements and discussing manufacturing and/or food preparation procedures with the business is imperative for those with Celiac Disease.