Why are so many foods with undeclared allergens making it on shelf?

Food allergen labelling faults are supposed to have vanished. Big legislation, tragic losses of life and a raft of technological advancements have all – theoretically – paved the way to a safer world for allergic shoppers.

But a world that won’t harm or kill allergic consumers, who should be confident the food they buy from supermarkets is clearly labelled with the allergens they contain, is not yet fully formed.

Labelling issues remain a common occurrence. Two alerts for undeclared allergens have been issued by the FSA just 23 days into the year – one for a dark chocolate peanut mousse containing undeclared peanuts and milk and another this week for a chicken Pad Thai with Noodles & Veggies that contained undeclared peanuts.

Both products would obviously contain peanuts – one has it in the product name and for the other, a Pad Thai, they’re a central ingredient.

But January isn’t an exception: last month the FSA issued four alerts for undeclared allergens in as many products – one for mustard, one for egg, one for wheat gluten and one for peanuts. In the reporting period for 2022/23, FSA data shows 314 allergy alerts were issued, representing 15% of total food alerts.

What needs to go on food labelling? 

The statistics are particularly worrying as the UK is nearly a decade on from the implementation of a supposedly game-changing rule – Regulation (EU) 1169/2011. It was created to help prevent these potentially deadly issues occurring by ensuring all food and drink businesses worked to the same labelling standards.

Known as Food Information to Consumers Regulation (FIC) or FIR in the UK, the legislation resulted in vast and costly legal changes to make clear what has to be shown on pack. It means labels are easier for consumers to read and spot the 14 known allergens, which must be displayed in bold if present in a packaged food product.

Additionally, food or drink products containing two or more ingredients – including additives – must show these on pack, in order of weight and with the main ingredient first.

So why do unlabelled allergens make it onto the shelf so frequently when they must be displayed?

In the case of Scratch Meals’s Chicken Pad Thai*, recalled from Tesco and Sainsbury’s, the manufacturer did not respond with specifics to The Grocer’s comment request, but pointed towards the FSA’s allergy alert.

The FSA’s responsibility, however, is to ensure the communication between the food business and the local authority raising the alert is visible to the relevant parties. As a result, the body did not provide additional information. 

For one source, the owner and founder of a medium-sized food business supplying the major supermarkets, a company not including allergen information is inexcusable. “Labelling issues could be a result of many things, it’s hard to pin down what goes wrong in other businesses from the outside,” they say. “But leaving out ingredients from a label is borderline stupidity, not negligence, because ingredients and allergens are labelling 101.”

Can allergen labelling mistakes be avoided?

For smaller manufacturers, that don’t have the same resource as big firms, it’s a case of having a watertight process in place that involves, at least, three people triple-checking labelling because human error can occur. “You can’t fill a factory with superheroes, if there’s been a design change to a label, for example, then marketing won’t be looking at the ingredients, but should know to pass the changed version to technical,” they add.

But this space for human error does not instil confidence in the food industry among consumers suffering with allergies, who are fearful of having allergic reactions to food and drink bought in supermarkets, says Allergy UK head of clinician services Amena Warner.

“Product recalls are not uncommon, which is sad and has a devastating impact on people with food allergies,” she says.

A survey of 5,000 people carried out by the charity found 82% of adults are worried about buying pre-made food in case it contains unknown allergens and 47% have had a reaction after eating incorrectly labelled food.

“We need to get this right, because the impact of getting it wrong is huge,” Warner warns. “It’s potentially fatal. There is no justification for known allergens making it into products without being labelled – whether it’s human error or not, we need to tighten procedures to make sure it doesn’t happen at all.”

*Scratch Pad Thai with Noodles & Veggies 380g SKUs with use by dates of 25.01.24, 27.01.24 and 28.01.24 were recalled. Tesco’s website listed and highlighted peanuts as an ingredient. The product wasn’t available on Sainsbury’s website at the time of publication.