statements are sometime confusing because the wording used does not match what is declared in ‘Contains’ 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 statement is used in the absence of any declaration in the ingredient list (Coeliac ‘contains’ Aust) Mandating FSANZ should consider including statements in the Code. A&AA, ARFAID, ‘contains’ ‘contains’ statements ASCIA, Coeliac Aust, The mandated approach should be based on the AFGC and VITAL guidance documents (A&AA, Tas DHHS). SCH, Tas DHHS, Vic Depts, Clear instruction through the standard with regards to and statements are required to ‘contains’ ‘may contain’ provide meaningful information to the consumer (ASCIA). The importance of clear terminology Why clear allergen Clear naming does not just help allergen sensitive consumers make correct choices, but it is also needed to inform NZMPI, Allergy NZ declaration anyone who may purchase food or prepare food (for allergic consumers) in the home, at restaurants, for catering terminology is and any situations where food is provided or sold. important Allergy NZ also mentioned that the understanding and use of allergen information has not been collected for third parties. Lack of clarity in Allergen labelling requirements should be concise and not open to interpretation. AB, AFGC, Coeliac allergen declaration Aust, Vic Depts Businesses and consumers should not have to rely on guidance about how to make or read allergen requirements 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). There is currently no The use of plain English for allergen declarations is still voluntary, regardless of industry guidelines, and is not Allergy NZ requirement for monitored. This leads to inconsistencies, a loss of trust, and reduced ability by consumers to make informed choices using plain English (DunnGalvin et al. 2015). to declare allergens
‘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
W1070%20Supporting%20Document%202%20-%20Summary%20of%20submissions.docx