17 November 2023
A ‘clean label’ product is one with a simple, transparent and easy to understand ingredient list. For many consumers, this means a product with minimal ingredients, clear allergen advice and no hidden surprises in compound ingredients that is easy to decipher. While the aim is to keep ingredient lists short, it is often necessary to utilise several ingredients to achieve particular goals such as processability, shelf-life and texture. This comes with a challenge for the allergic consumer who need to be able to navigate and understand long ingredient lists.
When we think of clean labels, we often think of the drive stemming from consumers demanding more transparency and perceived healthier food choices. However, it also has implications for consumers who have food hypersensitivities. Reading long lists of ingredients can add extra stress when purchasing products – this is especially challenging if the reader’s hypersensitivity is from a food not listed as one of the 14 declarable allergens. For such consumers, there is also a risk of food ingredients potentially being hidden within compound ingredients. This highlights that need for careful and thorough checking by the consumer and is understandably a source of anxiety, especially when they are faced with a lengthy list of the ingredients.
Precautionary Allergen Labelling (PAL) also has a part to play. This is the voluntary statement or information provided on the product to communicate where there is potential for unavoidable allergen cross-contamination risks. With more ingredients, there is more potential that PALs will be carried through the supply chain to the finished product, further limiting choices for a consumer with a food hypersensitivity. The Food Standards Agency (FSA) Technical Guidance has two examples of PAL statements “may contain allergen x” or “not suitable for someone with x allergy”. Whilst these are the recommendations, it is still common to come across lengthy and perplexing PAL statements. These extended PAL statements explaining that the food product is produced in a factory containing x allergen, but not on the line and is using shared equipment, may be challenging for a consumer without experience in a food manufacturing setting to understand.
Allergic reactions can be fatal and as allergy rates in the population increase, the need for clear and accurate labelling is highly apparent. A further fundamental aspect is having thorough risk assessments and implementing validated controls to reduce the need for PAL. If the outcome of a risk assessment deems that PAL is necessary, communicating this clearly and concisely to the consumer is key. Whilst this is only one aspect of allergen management, safeguarding the health and well-being of individuals with food hypersensitivity is crucial.