Food allergens: staying ahead of the curve of scientific and regulatory challenges

8 March 2024

Manufacturers play a pivotal role in ensuring consumer safety, particularly regarding food allergen labelling. They must identify and disclose all allergens present in their products while complying with relevant market legislation. Two key areas – scientific and regulatory challenges – require constant attention. Staying ahead in these continuously evolving environments is essential for product compliance and consumer protection.

Food allergens | Regulatory challenges | Leatherhead Food Research

Rise in new allergens

The prevalence of food allergies and allergenic ingredients is rising globally, attributed to the use of new by products in food manufacturing, as is the case for kiwifruit.

The ongoing scientific research titled ‘Update on the global prevalence and severity of kiwifruit allergy: a scoping review’ conducted by the UK’s Institute of Food Science and Technology’, highlights that allergic reactions to kiwifruit have been documented for over four decades. These reactions have become increasingly prevalent with the expanding use of this fruit in various food manufacturing processes, such as production of jams, jellies, vinegar, ice creams, confectionery, and syrups.

Currently, kiwifruit is not globally recognised as an allergen unlike milk, soy, and peanut. However, in certain markets, manufacturers can voluntarily declare kiwifruit as an allergen. This means that while some food producers may choose to include kiwifruit in their allergen labelling declaration, it is not legally required. This practice can be observed in Taiwan and Japan where allergen labelling for kiwifruit is voluntary.

Non-harmonisation and confusion across markets

The constant development across markets, imposes two new challenges: non-harmonisation and lack of clarity.

Non-harmonisation leads to complexity for food manufacturers. For example, Australia and the US both use the “Contains” statement for allergen declaration, but they do not recognise the same allergens.

Consider molluscs for example: they are recognised as allergens in Australia, requiring declaration in the ingredient list and mandatory inclusion of a “Contains” statement for molluscs and products thereof. However, molluscs are not recognised allergens in the US, prohibiting the use of a “Contains” statement for these ingredients in this market. This divergence poses a labelling challenge for both importers and exporters.


Mislabelling allergens is also a significant concern for manufacturers. This year, numerous products were recalled due to undisclosed allergens. One key issue is whether allergens mentioned in the product name must still be declared in the ingredient list. In the EU and UK, if a food product is marketed under a name like “cheese” or “cream” which clearly refers to the presence of an allergen, in this case milk, as the product does not need an ingredient list, there is no legal requirement to declare the allergen on the label. However, if the product name clearly refers to an allergen and an ingredient list is provided, whether voluntarily or not, the allergen must be emphasised within the list of ingredients. Similarly, if the name of a food clearly refers to an allergen but the product also contains other allergens, those allergens must be emphasised in the list of ingredients. This enables consumers to make informed choices about food that is safe for them.

Thus, the rise in new products, variations in allergen recognition, and complex legislation emphasize the vital need for manufacturers to stay abreast of regulations globally to ensure their products comply. Advocating for clearer, consistent labelling is imperative for industry transparency and enhancing the safety of individuals with food allergies.

How Leatherhead can help

At Leatherhead Food Research our scientific and regulatory affairs team can support with allergen labelling in Taiwan, Japan, Australia, US as well as other parts of the world. Please contact us at [email protected] to find out how we can support you.

Regulatory Insight Report

Members of Leatherhead Food Research will have exclusive access to our upcoming Regulatory Insight Report titled 'Allergen Declaration: Regulatory Compliance in Food Labelling'. This report is one of five new additions to our membership benefits in 2024. It delves into allergen declaration and regulatory compliance in food labeling, providing detailed insights into international regulatory requirements across 30+ markets worldwide. Anticipated release to members is scheduled for September 2024. For further details on this report and the advantages of joining Leatherhead Food Research, please don't hesitate to reach out.

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