‘Contains’ statements are sometime confusing because the wording used does not match what is declared in the ingredients list – e.g. that sodium caseinate may be in the ingredients list but milk declared in the ‘contains’ statement (Allergy NZ). In some cases a ‘contains’ statement is used in the absence of any declaration in the ingredient list (Coeliac Aust) Mandating ‘contains’ statements FSANZ should consider including ‘contains’ statements in the Code. The mandated approach should be based on the AFGC and VITAL guidance documents (A&AA, Tas DHHS). Clear instruction through the standard with regards to ‘contains’ and ‘may contain’ statements are required to provide meaningful information to the consumer (ASCIA). A&AA, ARFAID, ASCIA, Coeliac Aust, SCH, Tas DHHS, Vic Depts, The importance of clear terminology Why clear allergen declaration terminology is important Clear naming does not just help allergen sensitive consumers make correct choices, but it is also needed to inform anyone who may purchase food or prepare food (for allergic consumers) in the home, at restaurants, for catering and any situations where food is provided or sold. Allergy NZ also mentioned that the understanding and use of allergen information has not been collected for third parties. NZMPI, Allergy NZ Lack of clarity in allergen declaration requirements Allergen labelling requirements should be concise and not open to interpretation. Businesses and consumers should not have to rely on guidance about how to make or read allergen declarations, and consumer education should accompany any change to labelling requirements. In the absence of clear guidance, inconsistencies have developed which in part have been addressed by industry guidance provided by both the AFGC and the Allergen Bureau (AB, AFGC). There continues to be some confusion amongst manufacturers (in relation to labelling requirements) and consumers (in relation to label interpretation) (Coeliac Aust). AB, AFGC, Coeliac Aust, Vic Depts There is currently no requirement for using plain English to declare allergens The use of plain English for allergen declarations is still voluntary, regardless of industry guidelines, and is not monitored. This leads to inconsistencies, a loss of trust, and reduced ability by consumers to make informed choices (DunnGalvin et al. 2015). Allergy NZ
Q3. Is the term ‘fish’ being used to refer to molluscs and/or crustacea in a ‘contains’ statement (even if a mollusc or crustacean ingredient is specifically declared in the ingredient list)? Yes, this practice is occurring Some additional comments were received in addition to ‘yes’: Woolworths mentioned that its internal policy is to use the collective term ‘fish’ to describe molluscs and crustacea in the ‘contains’ statement, with the specific fish, crustacean or mollusc declared in the ingredients list. ‘May Contain’ fish/shellfish statements are another source of confusion and stress for consumers, as the specific finfish fish, crustacea or mollusc may not be able to be identified (ARFAID). AFGC, ARFAID, SCH, WW Not aware of this practice The Victorian Department of Health and Human Services records complaints related to allergens, and does not have any complaints on record about the way that "fish" is declared on products. Vic Depts Table 3: Summary of individual submitter comments on cereals containing gluten declarations Comments Details of comments Submitter Q4. Are manufacturers regularly declaring ‘gluten containing cereals’ in a ‘contains’ statement, with the specific cereal/s declared in the ingredient list? Is this information helpful for consumers with a cereal-specific allergy, or does it create difficulties for them in making correct food choices? Are these types of declarations occurring? Yes. Manufacturers do declare the specific cereals in the ingredients list along with the words "contains gluten containing cereals ...." Information on an available product was provided, where ‘wheat dextrose’ is in the ingredient list, and the label also displays a statement that the product contains ‘cereals containing gluten’ (NZMPI). A&AA, AB, ARFAID, Coeliac Aust, NZMPI, SCH, Vic Depts. No. The ‘may contains/contains’ statements only make reference to gluten, not ‘gluten containing cereals’. WW Unsure. Is likely given AFGC guidance. Allergy NZ