Looking at an actual label for fish pie in a creamy cheese sauce with mashed potato and parsley crumb, I saw there were five different dairy ingredients: milk, Cheddar cheese, butter, cream and Gruyere cheese. Following the letter of the law, such labels will in future have to have the word ‘milk’ in brackets after the last four items in this list.
Wade through the list
The same dish also contains cod, smoked haddock, salmon and prawns, and also other ingredients containing the allergens wheat and gluten. The first four items will each have to be followed by the words (fish) or (shellfish). Currently, the label in my example has a prominent coloured allergen box with six words naming the categories of allergen present. This is so much easier to use and saves having to wade through the list of ingredients.
In recent years there have been regular occasions when products were withdrawn from sale, creating substantial food waste, when manufacturers had inadvertently omitted to indicate the presence of an allergen on the label. Now that a particular allergen, milk or fish in the above example, will have to be mentioned several times, rather than just once, would a product withdrawal have to take place if milk or fish is not mentioned after one of the dairy or fish ingredients, regardless of the fact that it is mentioned after the others?
Ridiculous
That would be quite ridiculous, but a pedant might say that a person who is allergic to milk might eat the mashed potato alone, not realising that it, or the crumb topping, contained dairy ingredients. Under the current system, a named allergen in the separate box could be taken to apply to the whole product regardless of whether it is restricted to a discrete part such as a crust or pastry and people with that allergy would avoid eating any part of the composite food.
The new rules, particularly when applied to a recipe dish with a large number of ingredients, are burdensome for the manufacturer and do not make the label any easier for the consumer to use.
This is just another example of overzealous EU rules hammered out by people who have little concept either of practicability of application by manufacturers or value to actual allergic consumers.