- 09/04/2017
- Posted by: Marta
- Categories: Questions and answers, News, Uncategorized
Dear Lawyer good morning,
The disturbance for a question about a kind of gluten-free flour that I wanted to try, more out of curiosity than anything else. When I put the groceries in the pantry, my eye fell on the ingredients list and I got a little lost. What do you think?
thank you
Loredana
The lawyer Dario Dongo, Ph.D. in food safety, answers
Dear Loredana,
The label in question actually has some critical issues.
The name 'flour mix', which is also highlighted on the label front, leads the average consumer to believe that he is dealing with a mixture of gluten-free cereal flours. Or de-gluteinized, considering the reference to the specific formulation for celiacs.
The ingredients list however it reveals the presence of only one flour - that of rice - of which the QUID is not even exposed (Quantity of Ingredients Declaration). That is to say, its quantity compared to the total of the ingredients used in the recipe. (1) In this case, an indication must be made, increasingly as the product contains other ingredients, such as potato starch (in addition to sugar), whose perceived value is certainly lower.
The name of the food it is consequently irregular, if not absent. In fact, there is a dichotomy between the name 'flour mix' - which in itself does not fit its formula - and the reference, albeit indirect, to a 'preparation'. We read in fact 'ingredients of the preparation'. In the absence of a legal or customary name, a descriptive name should therefore be offered, which is however missing.
The indication 'produced in a facility that also uses soy' it is in turn
inadmissible. As unsuitable for providing the necessary news of the so-called 'may contain'. (2) The correct term to express the potential risk of accidental contamination by allergenic ingredients is in fact 'May contain', followed by the specification of the individual allergens without referring to 'traces'.
The image on the front of the labelfinally, it can mislead the consumer about the possible presence of eggs. Since three of them are depicted in the background.
Dario Dongo
Note
(1) The indication of the quantity of the ingredient is instead a duty in this case, pursuant to reg. EU 1169/11, article 22. The exceptions set out in Annex VIII are not used
(2) OR PAL (Precautionary Allergen Labeling)
