“Plain Language” For Food Allergen Labeling Should Augment, Not Replace, Existing Requirements, Says NFPA

(Washington, D.C.) – In comments delivered at a public meeting on food allergen labeling issues, held by the Food and Drug Administration, the National Food Processors Association (NFPA) strongly supported the use of “plain language” on food labels, but said that labeling options should be flexible and voluntary.

“NFPA believes that it is important to present information on major food allergens in terms commonly understood by consumers,” said Regina Hildwine, NFPA’s Senior Director of Food Labeling and Standards.  “Food allergen information presented in plain language terms will help food allergic consumers to recognize the foods they must avoid.  However, NFPA believes that plain language presentation options should not replace, but rather should augment, current ingredient labeling requirements.  To require such declarations would necessitate rulemaking on several standards of identity and other existing regulatory requirements, and this is unnecessary complications.”

Hildwine represented the processed food industry as a participant on three panels at FDA’s public meeting on “The Challenge of Labeling Food Allergens,” held on August 13 in Washington, D.C.

“The major food allergens, as defined by FDA, are not all single foods,” Hildwine pointed out in her remarks.  “Crustaceans, fish, and tree nuts represent classes of foods.  Within these classes of foods, food allergen information must be presented as the common or usual name of the individual food in the ingredients declaration.  For example, for crustaceans, crab (snow crab, king crab, etc.), crayfish, lobster, and shrimp are the terms that would be used.”

Hildwine also addressed the issue of supplementary or advisory labeling – so-called “may contain” statements – noting that “Any discussion of this issue must focus initially on manufacturing practices.  Food processors that prepare foods that may be exposed to inadvertent contact with the eight Major Food Allergens acknowledge that labeling is not a substitute for good manufacturing practices (GMPs).  GMPs and their resultant controls must be considered first, before labeling approaches are considered. Supplementary labels should be relatively rare, not increasingly common.”

Hildwine stated that “NFPA advocates limited and careful use of supplementary food allergen labeling.  Given the difficulties of achieving absolute certainty that there is no risk of presence of major food allergens in a variety of situations, supplementary or advisory labeling is necessary and should be permitted.”

In her comments, Hildwine cited the Food Allergen Labeling Guidelines announced by the food industry on May 31.  “NFPA believes the approaches outlined in the Guidelines will provide food allergic consumers with the necessary information they need to avoid those foods containing the allergen of concern, while also providing food processors with the necessary flexibility they require in meeting the demands of different processing situations,” Hildwine said.  NFPA led efforts by the Food Allergy Issues Alliances – a coalition of food industry and consumer organizations – to develop the guidelines.

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NFPA is the voice of the $460 billion food processing industry on scientific and public policy issues involving food safety, nutrition, technical and regulatory matters and consumer affairs. 

For more information on this issue, contact Timothy Willard, NFPA's Vice President of Communications, at (202) 637-8060, or visit NFPA's Website at http://www.nfpa-food.org/ .