Opinion of the Economic and Social Committee on the "Proposal for a Directive of the European Parliament and of the Council amending Directive 2000/13/EC as regards indication of the ingredients present in foodstuffs"
Date: 2002-01-16
Institutions: European Economic and Social Committee
Subjects: allergy, consumer information, foodstuff, labelling, packaging, public health

3.4.2002

EN

Official Journal of the European Communities

C 80/35

Opinion of the Economic and Social Committee on the ‘Proposal for a Directive of the European
Parliament and of the Council amending Directive 2000/13/EC as regards indication of the
ingredients present in foodstuffs’

(2002/C 80/07)

On 14 November 2001, the Council decided to consult the Economic and Social Committee, under
Article 95 of the Treaty establishing the European Community, on the above-mentioned proposal.

The Section for Agriculture, Rural Development and the Environment, which was responsible for
preparing the Committee’s work on the subject, adopted its opinion on 4 December 2001. The rapporteur
was Mrs Davison.

At its 387th plenary session (meeting of 16 January 2002), the Economic and Social Committee adopted
the following opinion by 89 votes to three with three abstentions.

1.

Introduction

2. General remarks

1.1.
This Commission proposal is intended to ensure that
all consumers are informed on the full content of the food
they are eating and to enable consumers with food allergies to
identify any allergenic ingredients that may be present.

it

The proposal will abolish the ‘25 % rule’ which
1.2.
currently means that
the
components of compound ingredients that make up less than
25 % of the final food product. The proposal means that all
ingredients intentionally added will have to be included on the
label.

is not compulsory to label

2.1.
The Economic and Social Committee very much
welcomes the Commission proposal. It deals with the two
important issues of consumer information and protection
from allergic reaction to food. A recent survey shows that the
list of ingredients is the second most important labelling
information identified by consumers (1). Consumers want to
know what they eat.

The proposal includes derogations — not applicable

1.3.
to additives or allergens:

a) where the composition of the compound ingredient is
defined in current Community legislation (e.g. chocolate,
jam), and constitutes less than 5 % of the finished
products;

b)

preparation of sauces or mustards constituting less than
5 % of the finished product;

c) mixtures of spices and herbs constituting less than 2 % of

the finished products;

d) where the compound ingredient is a foodstuff for which
a list of ingredients is not required under Community
legislation.

1.4.
Finally, the proposal includes a list of ingredients liable
to cause allergies or intolerances that will have to be listed
whenever they are used: cereals containing gluten and products
thereof; crustaceans and products thereof; eggs and products
thereof;
fish and products thereof; peanuts and products
thereof; soybeans and products thereof; milk and dairy prod-
ucts (including lactose); nuts and nuts products; sesame seeds
and products thereof; sulphite at concentrations of at least
10 mg/kg.

2.2.
The Committee is very concerned by food allergies,
which are a serious public health problem. The number of
people presenting with food allergies is increasing all the time,
and scientific knowledge of foods causing allergies is growing.
It is estimated that 8 % of children and 3 % of adults are
affected. Adverse effects extend from illness and reduced
quality of life to life threatening allergic reaction (2). The dose
of food allergen required to induce an immunological reaction
varies, but in many instances it can be very low. Currently,
there is no medication that cures food allergies. Strict avoidance
of the allergy-causing food is the only way to avoid a reaction.
There are other sources of information, but these individuals
rely largely on food labels to keep themselves and their
children healthy.

(1) European wide study performed in 1998/1999 by the University
of Leuven (B). The study covered the 15 EU Member States, with
the participation of more than 13,000 persons.

(2) During a food-allergic reaction, the immune system mistakenly
believes that a harmless substance, in this case a food item, is
harmful. In its attempt to protect the body, it creates specific IgE
antibodies to that food. The next time the individual eats that
food, the immune system releases massive amounts of chemicals
and histamines in order to protect the body. These chemicals
the
trigger a cascade of allergic symptoms that can affect
respiratory system, gastrointestinal tract, skin, or cardiovascular
system.

C 80/36

EN

Official Journal of the European Communities

3.4.2002

2.3.
It is therefore of vital importance that people suffering
from food allergies have access to the full composition of food
products and can be sure that the product does not contain
the components they must not ingest.

2.4.
The abolition of the 25 % rule will allow consumers to
have the full list of the products contained in the products.
Under the existing 25 % rule, components of compound
ingredients that make up less than 25 % of the final product
(like the sausage topping on a pizza) do not have to be listed.

The Committee would draw attention to the extremely
2.5.
urgent need for research on this area as a public health issue
as well as a labelling one. For example, why is the emergence
of allergies increasing? What can we do to alter the trends?

2.6.
Nevertheless, there is concern about the exceptions
allowed in the proposal. Community legislation defines the
composition of the compound ingredients for various products
(e.g. chocolate and jam). Also, allergies to spices have been
reported, and ingredients included in mixtures of spices
constituting less than 2 % of the final product do not have
to be listed on the product. Consumers suffering from
hypersensibility to products not commonly known as allergens

Brussels, 16 January 2002.

will remain with the handicap of not being informed that the
product they are buying contains a component that can
provoke an adverse reaction.

2.7.
The Committee understands that these exceptions have
been included by the Commission with the aim of avoiding
excessively complex legislation and taking account of the
technical constraints placed on food manufacturers. However,
as explained in the previous point, the Committee’s reser-
vations arise mainly from the fear that these derogations may
not fully achieve the objectives aimed at by the Commission.

2.8.
The Committee stresses the fact that risks of food
allergies are not limited to pre-packed food and hence the
whole range of foodstuffs has to be taken into consideration.
Consumers too have to share responsibility if they want to
control risk.

2.9. With regard to the list of allergenic ingredients or
substances which must always be labelled, the Committee
welcomes the introduction of a procedure enabling the quick
updating of the list whenever necessary. The Commission will
be able to amend the list subject to the opinion of the Standing
Committee on Foodstuffs. New allergens are emerging, and it
is important that this list is kept up to date.

The President

of the Economic and Social Committee

Göke FRERICHS