Bakers Journal

New allergen rules explained

October 31, 2011
By Bakers Journal

October 31, 2011, Mississauga, ON – The changes coming to Canada’s food allergen labeling rules were on the agenda at a recent Baking Association of Canada information session.

Representatives from Health Canada and the Canadian Food Inspection Agency explained what the new rules will mean for bakers and answered questions during the two and a half hour session, held Oct. 27 at the Four Point Sheridan in Mississauga, Ont.

The new rules, which come into effect on Aug. 4, 2012, will require mandatory declarations about the sources of 10 priority allergens – peanuts, eggs, milk, tree nuts, wheat, soy, sesame seeds, seafood (fish, crustaceans and shellfish), sulphites and mustard – and gluten in pre-packaged foods.

Michael Abbott, a senior evaluator with Health Canada’s food allergen and intolerance assessment section, explained that the new rules are meant to address gaps that exist in the current regulations. For example, under the current regulatory regime, the ingredient label on a boxed cake mix might read as follows:


Ingredients: sugar, flour, ovalbumin, monocalcium phosphate monohydrate, sodium bicarbonate and potassium bitartrate.

However, once the new rules are in effect, the ingredient label will feature more information about allergens that may be invisible to consumers under the current system. To be in compliance with the new rules, the label for that same cake mix would have to read one of two ways:

Ingredients: sugar, flour (wheat), ovalbumin (egg), monocalcium phosphate monohydrate, sodium bicarbonate and potassium bitartrate.


Ingredients: sugar, flour, ovalbumin, monocalcium phosphate monohydrate, sodium bicarbonate, potassium bitartrate. Contains: egg, wheat.

During his presentation, Abbott stressed that any “contains” statement appearing on a product must be a complete listing of all priority allergens in a product. As a best practice, he recommends that any “may contain” statements carried on the inputs into a product should be carried forward on the label for the final product. So, for example, if the chocolate your operation uses to make chocolate chip cookies carries a “may contain peanuts” label, your cookies should carry the same warning.

This holds true for all “may contain” statements on inputs, unless you do your own testing to confirm that there is no trace of the allergen in your final product.

Abbott then handed the floor over to Dianne Del Zotto, a program specialist with CFIA’s labeling and imported manufactured food program. Del Zotto clarified which foods fall under the pre-packaged umbrella, noting that foods served by a clerk and packaged at the time of sale or packaged by consumers from self-serve bins are not considered pre-packaged products.

During her presentation, Del Zotto stressed that if you choose to declare the ingredients on an exempted product, you must ensure that the list is complete and complies with all of the appropriate regulations.

After a brief break, Yin Lee, a senior program officer with CFIA’s consumer protection division, took over. She explained the differences between ingredients and components, and how the new rules will apply to each. To illustrate, she used the example of a pizza, made with ingredients such as flour, mozzarella cheese and pepperoni. Those ingredients, she noted, are themselves made from assorted ingredients. Flour includes the components flour, niacin, thamine mononitrate, riboflavin and reduced iron, while mozzarella cheese includes milk, salt, rennet and bacterial culture, and pepperoni includes pork, sodium nitrite, dextrose, salt, spices and bacterial culture.

Lee stressed that food allergens and gluten sources must be declared when they are present as an ingredient, or as a component of an ingredient. She reiterated Abbott’s advice that any “contains” or “may contain” labels on the inputs for a product should be carried forward onto the final product.

For example the label for dried apricots with added sulphites would read as follows:

Ingredients: apricots, sulphites.

On the other hand, the label for a cookie made with apricot jam contributing less than 10 ppm of sulphites to the finished product would not have to declare sulphites on the label. This is because the jam is exempted from a component declaration by the Food and Drug Regulations. So, that label would read:

Ingredients: Rolled oats, wheat flour, …  apricot jam with pectin, baking soda.

However, if the level of sulphites in the finished product exceeds 10 ppm, then you would have to declare the sulphites on your label – the jam is still exempt from a full component declaration, however the sulphites exceed the 10 ppm threshold and must be declared.

Lee explained that these changes are intended to make it easier for consumers to spot allergens when they’re shopping. By taking some of the guesswork out of food labels, the CFIA and Health Canada hope that consumers will not unnecessarily avoid products for fear that they may contain problematic allergens.

To that end, ingredient labels will also have to identify the sources of all starches, modified starches, hydrolyzed plant proteins and lecithins. These ingredients must now be identified as hydrolyzed soy protein, corn starch and soy lecithin.

When the new regulations come into effect on Aug. 4, 2012, all pre-packaged products that are ready for sale must be in compliance. This includes all products offered for sale in a store, on display, in possession for sale (i.e. warehoused), or available for distribution whether or not the distribution is made for consideration (i.e. a sample given away for free).

For more information about the amended food allergen labeling regulations, visit .

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