In EU, as well as in USA and other countries with different allergens requirements (e.g. Japan), the choice of the legislator is to specifically consider as “allergens” – for labeling purposes – only the so called “major allergens”: substances which account for the major % of food allergies found in the local population.
It could happen that some allergies are not considered (think of garlic, strawberries…) by the legislator, so it is up to the consumer to check the ingredient list (where everything should be declared).
Those evaluations could nonetheless change in time, as explained by the EU Commission.
Question for written answer to the Commission
Tomáš Zdechovský (PPE) – 15th June 2016
Subject: Allergy to apples
Allergy to apples is affecting more and more people. It is an allergy which can manifest itself at any age.
The most common symptoms include tingling lips and itching or sore throat, as well as swelling or sneezing. A research project called SAFE was conducted across Europe to explore the occurrence of combined apple-pollen allergies. The research shows that the new varieties of apple have a greater impact on those affected.
The research also suggests that there is a geographical division between south and north, and that there are two specific types of apple allergy. In the north there are people allergic to raw apple pulp, while people from the south are allergic to the skin in all of its forms, whether raw or cooked.
The research shows that the form the allergy takes is influenced not only by the amount of the allergen in the apple, but also by the variety of apple and the storage conditions.
Has the Commission conducted any research into apple allergy and its impact on European consumers or is it planning to conduct such a research?
How is the EU protecting its consumers against this allergy?
Answer given by Mr Moedas on behalf of the Commission – 1st September 2016
Research on allergies has been supported by the European Commission since the 5th Framework Programme, when the Safe project was funded. Currently, five projects are dealing with allergies to apples (Safe, Fast, Caramel, iFAAM, Europrevall) with total EU funding of more than EUR 28 million. Horizon 2020 also offers the possibility to receive funding to carry out research on apple allergy (see Horizon 2020 Research and Innovation Participant Portal).
Regulation (EU) No 1169/2011 requires, for all food, the mandatory provision of information on the presence of allergens whenever they are used in food as an ingredient. It also requires that such information must be emphasised on food labels through a typeset that clearly distinguishes it from the rest of the list of ingredients. The EU list of allergens is provided in its Annex II and has been established on the basis of a scientific opinion adopted by the European Food Safety Authority. According to this, the substances of Annex II are considered as part of the most common food allergens and there is ample evidence to support their inclusion into the list.
The regulation foresees a systematic re-examination of the allergen list and, when necessary, it is updated on the basis of the most recent scientific knowledge. At this stage, there are no available scientific data to support the inclusion of apples into the allergen list.
Nevertheless, when apple has been used as an ingredient in food, its present products, used in the production or preparation of food and still present in the finished product, must be stated in the list of ingredients
(Source: EU Parliament)
FOOD LAW LATEST 
Hello, Cesare – Ingredient labels contain ALL ingredients, yes – so apples (or other foods) may be identified by allergen sufferers by reading the label. But information provided to consumers for loose food is required to include the allergens in each dish, not ALL ingredients. Most restaurants’ Matrix (aka food information file) list only the allergens in each dish. How best would a restaurant provide accurate information to those allergic to apples – or garlic – or any other food?
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Hi Valerie,
Huge restaurants chains have the electronic means to manage all ingredients, if they want. Small/family owned restaurants are not well placed to manage the issue on the contrary.
They have a lot of variety in menus, many semi-prepared and compound foods stored and handled, small spaces in kitchen that ease cross contaminations.
The only way to answer quickly to consumers’ demand about presence of a non-regulated allergen is to have a register (on paper of electronic) of all the ingredients/raw materials purchased (info on ingredients and allergens should be given also in the B2B phase to other food business operator). Otherwise you cannot answer their needs and lose the clients or – worse – put their safety at risk.
Someone could object that many consumers do not really know the difference between allergens and intolerances, or disguise as intolerances their personal nutrition beliefs (“milk is bad”, “gluten is bad” and so on…): but as restaurant owner you cannot never know if you are facing an allergic subject (= risk of anaphylaptic shock = death), a simple intolerance or a personal belief. So you’ve got to be ready.
For this kind of carelessness we had a 5 years old UK boy dead in Italy, few months ago.
Anyway, non listed allergens should not be declared on the menu (for each dish or in any other way) by the law. It could be a voluntary choice, but we have hundreds of potential allergens. So, in my opinion, there is no point in writing down 100 pages menus full of ingredients list :), far more better to be really prepared.
Cesare
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