Among the matters for adoption by the 23rd session of the Codex Alimentarius Commission in June 1999 is the Codex Alimentarius Commission Draft Recommendations for the Labelling of Foods that can Cause Hypersensitivity (Draft Amendment to the General Standard for the Labelling of Prepackaged Foods). As hypersensitivity to foods is an international issue, agreement on Codex provisions in this respect would form a basis for the application of relevant labelling rules in many countries whose national legislation is Codex-based. This Draft Amendment includes compounds triggering both food allergies and intolerances, owing to their importance from a public health point of view, and the list included covers both food groups and individual foods, on the basis of the recommendations of the FAO Technical Consultation on Food Allergies.
So what does the draft amendment, Alinorm 99/22, Appendix III, now at Step 8 of the Procedure, require? It requires that the following foods and ingredients known to cause hypersensitivity are always declared as such:
• Cereals containing gluten: i.e. wheat, rye, barley, oats, spelt or their hybridised strains and products of these
• Crustacea and products of these
• Eggs and egg products
• Fish and fish products
• Peanuts, soyabeans and products of these
• Milk and milk products (including lactose)
• Tree nuts and nut products
• Sulphite in concentrations of 10 mg/kg or above
Class names that may be used in certain cases would not be authorised for such ingredients listed above unless a general class name would be more informative. Exemptions from declaration for processing aids and additives carried over into foods at a level less than that required to achieve a technological function would not be valid for processing aids or additives included in the above list.
One of the key issues is what substances are included on the list and how this list should be amended in future; the Joint Expert Committee on Food Additives
(JECFA) has indicated that it would be willing to consider further evidence on foods that may cause hypersensitivity, so providing a scientific basis and criterion for the inclusion of foods on the list. There is still some concern that some of the categories are too broad, for example 'milk and milk products'; for 'soyabean, peanuts and their products' the protein fraction may be allergenic but there was no evidence to suggest that refined or heat-treated oils have the same effect. It is felt that these issues should not delay the establishment of the list.
The 25% rule
The issue of the 25% rule has been separated from that of establishing the list of substances causing hypersensitivity for labelling purposes. The issue under debate is whether or not the 25% rule should be modified so that ingredients of a compound food are exempt from declaration only if the compound food is present at less than, say, 5%, or whether the exemption should be removed entirely, so leading to longer, more complex ingredients lists. Would reduction of the percentage be of value in this instance as many substances causing hypersensitivity act at very low levels? There would, therefore, be little scientific basis for changing the 25% limit on these grounds alone. The labelling of many other ingredients would be affected by changes in the 25% rule; therefore, this part of the draft has been returned to Step 6 for further discussion.
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