4 – Extend the recognized “Top” allergens based on updated, continually monitored criteria
The Top 8 allergens defined by FALCPA constituted the foods that 90% of the allergic community were allergic to in 2004. The incidence of food allergy has since skyrocketed and allergies to many more foods have become prevalent since.
Other countries have much broader lists of top allergens that must be disclosed separately. For example, the European Union identifies 14 top allergens including sesame, mustard, lupin, mollusks, and sulfur dioxide/sulfites not required under US labeling regulations.
The FDA should extend the FALCPA Top 9 based on continually updated criteria. That criteria should extend the requirement to cover a higher percentage of allergens beyond the 90% threshold and be updated on a periodic basis.
The changes outlined above would eliminate much of the ambiguity that plagues the allergic community today. The majority of those with food allergies would be able to look at the Contains and Top Allergens Processed statements and determine whether the product is appropriate for their consumption. Those allergic to less common foods would be able to rely on the ingredient list without having to worry about whether their allergen of concern is hidden under a category such as “spices”.
The changes would also be a boon to people with food sensitivities and those that follow other restrictive diets by disclosing a much broader array of ingredients.
Have ideas for changes you would like to see? Sound off below in the comments section. We hope to collect the best submissions and publish them in an open letter to the FDA.
- Facts and Statistics — FARE
- Food Allergen Labeling and Consumer Protection Act of 2004 (FALCPA) — US Food & Drug Administration
- H. R. 2117 (FASTER Act) — Congress.gov