Challenges and Path Forward on Mandatory Allergen Labeling and Voluntary Precautionary Allergen Labeling for a Global Company

Abstract

For food manufacturers, the label on a food package is a tool meant to alert consumers to the presence of specific allergens, allowing consumers to make informed decisions and not unnecessarily limit their food choices. Mandatory allergen labeling is used when the allergen is an intentionally added ingredient, whereas voluntary allergen labeling is used when the presence of the allergen is unintentional and may be in the finished product as a result of cross-contact. In a globalized economy, ensuring food safety is a growing challenge for manufacturers. When ingredients and technologies are sourced worldwide from multiple business partners, complexity rises, which can increase the chance for errors, leading to potential harm. Threshold science, Voluntary Incidental Trace Allergen Labelling (VITAL) reference doses, fit-for-purpose analytical technology, and common sense enable us to optimize allergen management for the benefit of allergic consumers. This is a good strategy because all stakeholders share the common goal of making foods safe and wholesome for all. Herein, we recommend that (1) senior management make science-based thresholds a priority for both regulatory authorities and the food industry; (2) VITAL 2.0 be adopted as a risk assessment and risk management tool for precautionary allergen labeling (PAL); (3) a standardized message for PAL, i.e., "may contain x," be used to make it easily understandable to allergic consumers so they can make informed food choices; and (4) validated fit-for-purpose allergen methods be used to meet analytical needs. This is an opportunity for us to speak with one voice and demonstrate that food safety is not a competitive issue, but a shared responsibility. This approach could significantly improve allergic consumers' lives.