Graphic evidence of the allergenic ingredients on the label only. The lawyer Dario Dongo answers

Dear lawyer,

I always read carefully your articles on the labels and on the indication of allergens, which you would say are also important to you as to all of us who have some food allergy problems in the family.

I would like to know if this label of breadcrumbs, mostly from organic ingredients, which comes from the Coop, seems to be in order. New Agriculture of Rome.

Thank you very much!

Tatiana


 

Dear Tatiana,

I had the personal opportunity to visit the Cooperativa Agricoltura Nuova, on the outskirts of Rome in that of Decima, on the Pontina road. And I can confirm their effective commitment on the various fronts that relate to sustainability, in breeding and in agriculture.

breadcrumbs-largeThe label under consideration denotes undoubtedly the operator's attention to information to the consumer relating to allergenic ingredients. Especially as it does not relate to the possible presence of 'traces of ...'additional allergenic substances with respect to the cereals precisely indicated. Wheat, barley and rye, all of which contain gluten and therefore cannot be consumed by celiac consumers, as well as by allergy sufferers to individual cereals. (1)

The EU regulation 1169/11 it prescribes however the graphic evidence of only the keywords that identify the allergenic ingredients. (2) In bold, or with capital letters, or by underlining (e.g. 'wheat flour'). So that allergic consumers can distinguish at a glance which ingredients they are vulnerable to from all others, in the appropriate list.

The label under consideration it therefore deserves to be corrected, limiting the use of bold to the words 'wheat', 'rye' and 'barley' only. It should also be remembered that the compound ingredients - as in this case, the 'organic sourdough' - must always be followed by the indication in brackets of their composition. The 'biofrimat bio' ingredient it must in turn be re-appointed with a real sales denomination (legal, usual or descriptive). Finally, the cereal of origin of the 'cruschello' must be specified.

cordiality

Dario Dongo

Note

(1) See reg. EU 1169/11, Annex II, point 1
(2) EU Reg. 1169/11, article 21.1.b and Annex II. Graphic evidence is required only once, not even in subsequent citations of the same allergenic ingredient



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