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| Allergens - Voluntary Labeling Statements |
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Under the Federal Meat Inspection Act (FMIA),
the Poultry Products Inspection Act (PPIA),
and the Egg Products Inspection Act (EPIA),
under which the Food Safety and Inspection Service (FSIS) operates, all
ingredients used to formulate a meat, poultry, or egg product must be declared
in the ingredients statement on product labeling. A product is misbranded under
the FMIA, PPIA, or EPIA when it contains ingredients that are permitted but are
not declared on product labeling.
FSIS recognizes that there are many foods and food ingredients to which some
individuals may have some degree of intolerance or possible allergic reaction.
That is why complete labeling is so critically important. FSIS supports
practices that promote accurate informative product labeling including voluntary
statements on labels that alert people who have sensitivities or intolerances to
the presence of specific ingredients. For example, a phrase such as “Contains:
milk, wheat gluten, soy” has been accepted by the Agency on labeling immediately
following the ingredients statement. Additionally, further clarification of the
source of a specific ingredient in a parenthetical statement in the ingredients
statement on labeling, e.g., “whey (from milk),” is encouraged as a means of
informing consumers who may be alerted to a more recognizable term.
In limited situations, the use of factual labeling statements about a
product’s manufacturing environment, e.g., “Produced in a plant that uses
peanuts,” may be used where good manufacturing practices, and effective
sanitation standard operating procedures (SSOPs), cannot reasonably eliminate
the unintended presence of certain ingredients. For example, where chopped
peanuts are used in making a dry Thai-style meat sauce mix, the necessity exists
for a dry processing environment and, thus, the production equipment cannot be
washed with water or other fluids. In this instance, peanut dust may become
airborne and unavoidably contaminate other meat or poultry products manufactured
in the same production area. In this situation, a statement about the
manufacturing environment, as described above, or the use of a “may contain
(name of allergenic ingredient)” statement may be used on meat and poultry
product labeling. However, this type of statement is not acceptable where it is
used as a replacement for poor SSOPs, i.e., cross-contact because of an
establishment’s failure to adequately wash equipment between the manufacture of
different lines of products. The Agency believes the indiscriminate use of such
elective statements does not promote good manufacturing practices under a HACCP
system and is not helpful for consumers. Consequently, the use of factual
statements about a product’s manufacturing environment, e.g., “Produced in a
plant that uses peanuts,” and the use of may contain statements, e.g., “may
contain peanuts” may only be used in cases where establishments show that
adequate SSOPS cannot effectively eliminate the cross contact issue.
The Agency will consider any non-misleading symbols, statements, or logos
that industry may want to include on labeling to inform consumers of the
presence of potential food allergens in meat, poultry, or egg products. Requests
to consider such features need to be submitted to the Agency as a policy
inquiry, and not as label approval submissions.
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Last Modified:
March 15, 2007
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