Labelling

Refined Oil Labeling Exemption

In the United States, the FDA does not require the top 8 allergens to be labeled on refined oil. This is due to research that shows that refined oils have been so heavily processed that only a minute amount of the food allergen protein remains.

Canada does not agree with this refined oil labeling exemption so all oils, regardless of their refinement must be declared if a top 11 food allergen is their source. However, if you are traveling in the USA, please note this different requirement when you are reading ingredients or discussing your food allergies with restaurant staff.

Foodservice and Produce Labeling Exemption

Food items pre-packaged and sold for foodservice such as vending, restaurants and cafes are required to provide ingredient labeling. However, labeling is exempted for an item that you order and have made for you whether that is in a café, restaurant, or deli section of a grocery store.

Fresh produce is exempt from the labeling but is no longer allowed to be sprayed with sulphites due to documented asthma reactions in susceptible individuals. However, sulphites are still allowed to be sprayed on fresh cut potatoes. Fresh grapes, if sprayed with sulphites to inhibit mould growth, must have less than 10 ppm of sulphites.

Alcohol Labeling Exemption

Because alcohol and spirits are not regulated by the CFIA, they are not required to follow the food allergen declaration regulations.

Sulphites are often added to wine and must be declared. Additionally, fermentation during wine making creates naturally occurring sulphites so even organic wines without added sulphites will have sulphites naturally occurring in the wine. If those naturally occurring sulphites reach levels of 10 ppm or more, they must be declared.

Agricultural Exemptions

Under CFIA rules, any item that has 2 or more ingredients must have an ingredient statement on it which includes the declaration of major allergens.

Under the agricultural exemption, crops require no ingredient label if they are a single ingredient (i.e. corn, wheat, oats). Due to North American farming practices, agricultural cross contamination is widespread and and accepted as common although the risk to allergic consumers is considered to be low.

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. 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.

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.

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 labeling laws or certified by any 3^rd party organization. So “allergy free” labeling 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, even though this is discouraged by the CFIA.

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.

Beyond voluntary labeling 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 labeling laws that specify the threshold and food producers follow this in the labeling/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 called VITAL 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 VITAL program has now determined threshold amounts for the top 14 food allergens.

So what does that mean for food allergens? The task force both reviewed and conducted scientific research to determine at what level food allergens must be present in a specific serving/weight of food 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 labeling 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 Canada will accept the recommended thresholds of this international team. However, Australia and New Zealand have already begun implementing the thresholds for food manufacturing and the FDA in the USA is currently reviewing them, as is the European Union.

Gluten Free Certifications are voluntary for food manufacturers and are not required by any labeling laws. Therefore, a manufacturer may indicate that a product is gluten free on the label without any certifications as long as that statement is true according to the gluten free labeling regulation. The new US regulation defines gluten free as a food under 20 parts per million (ppm) of gluten containing grains. Gluten free certifications are often more stringent and require testing to 5-10 ppm.

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.

There are now 3 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 13 000 products as of February 2013. 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 their FAQ page at:  http://www.gluten.net/Programs/industry-programs/gluten-free-certification-organization/faq-gfco

The second program is quite new and from Quality Assurance International (QAI) that many might recognize as a leader in Organic Certification. They also require that certified products test below 10 ppm.  http://www.qai-inc.com/media/docs/gluten_free_certification.pdf

The 3rd program called the Gluten Free Certification Program (GFCP) is the only Canadian specific program as it was originally created in coordination with the Canadian Celiac Association. However, it is now owned by a food safety company and is called BRCGS. The BRCGS requires that certified products test below 10 ppm.

"Genetic Engineering" refers to a technique by which the genetic material of an organism is changed in a way that does not occur naturally by multiplication and/or recombination. This is often referred to as Genetically Modified or a Genetically Modified Organism.

As a responsible and reputable food manufacturer, we are dedicated to producing safe, high quality products. We recognize that people do have concerns about the acceptability of genetic modification (GM/GMO), particularly the potential effect on the growing epidemic of food allergies and intolerances. We believe that consumers should have the choice to avoid GM foods and we therefore source and document only non-GM ingredients for our products.

Ingredient Sourcing
Our natural flavours have been identified as having genetically modified versions on the market. To avoid potential GMOs in our flavorings, several years ago we switched our natural flavors away from the corn-based ethyl alcohol which is traditionally used in flavours. Instead, we use organic certified cane sugar alcohol. Organic certification does not allow for the use of any GMOs. Therefore, our flavours are fully documented as Non-GM.

Recently, genetically modified apples have become available using a genetic engineering technique called CRISPR. The apples we use are fully documented as not genetically engineered.

Labelling
Because of farming practices, wind patterns and insect activity, no responsible food manufacturer can categorically state that their products are 100% free from genetic modification.

For this reason, many governments worldwide allow designated tolerances in non-GM labelled foods. Canada does have federal labeling guidelines for a non-GM claim. While it is voluntary, once a Canadian manufacturer makes a non-GM claim, it is now required to be true and verifiable to the National Standard as enforced by the Canadian Food Inspection Agency.

Since we do make the statement on each Libre Naturals product package that GMOs are not in our dedicated Canadian facility, we are accountable to this standard and document all traceability for this claim.

We do support the aims of the Non-GMO Verification Project. What we do not support is placing verification logos on products whose ingredients have no GM strains available, thus confusing consumers unnecessarily and reducing the validity of such claims.   In Canada, this kind of marketing is also against food labelling regulations. For this reason, we have chosen not get Non-GMO Verification and put the logo on our labels.