There had been a lot of confusion, when the new food information (EU)1169/2011 came into force end of 2014. The regulation fundamentally demanded to declare the listed allergens to protect the consumer. Unfortunately, the editors forgot to lay down how to declare native cross contacts from the Origin – means within plantations, harvest, drying or first processing. The result: some suppliers declared all allergens, others none of them. This led to uncertainty in the branch!
Cross Contaminations and Cross Contacts
There is a difference: small but significant. In the past, people talked generally about „Cross Contamination“ meaning contaminations by allergens. Today, we talk about cross contamination when an allergenic and a non-allergenic product are mingling during (European) production. Cross contacts are caused in the origin: due to unintentional input of allergens in the growing countries, i.e. due to contaminated seeds, crop rotation or wind blowing).
No more risk of Cross Contamination?
Risk of Cross Contamination in European food productions is relatively low: since many of the European food processors are working on the basis of GMP (good manufacturing practice) or are certified, they follow an Allergen Policy. Means: they have a management system to avoid cross contaminations.
Our Food Safety Management System FSSC 22000 works with precaution measurements to avoid cross contaminations. Moreover, we decided to not process allergens on our machines for recleaning or milling any more. Only in some blends we use allergens or repack them in 1 kg bags. In this case, our production plan follows certain rules. Traded goods, such as Mustard or Roasted Onions with breadcrumb coating, and Celery are stored separately. These areas underlie special cleaning and control measurements. Therefore, we can exclude a risk of cross contamination in our premises.
Cross Contacts from the Origin?
We analyzed our broad range of 52 different herbs and spices, to find cross contacts from the origin in a costly research project. As a result, we found some allergens from the origin, i.e.
– Peanuts in some root products
– Celery in some herbs
– Mustard and Gluten in Coriander and in some other seeds.
Those native cross contacts are caused in crop rotations, contaminated seeding or wind blowing from the fields. Despite of careful supplier’s selections and audits in place, we cannot exclude those cross contacts. The European Spice Association states in the positioning paper of 13th November 2017, that contacts with allergens from native sources only have to be declared if they are unavoidable and after doing a risk analyses to prevent consumers from misinterpretation.
AKO Risk Analyses
We do have entire Elisa test equipment in our own laboratory. We validate our results regularly in collaboration with accredited laboratories. In this way we have managed to build up a comprehensive data collection of different allergens found in diverse mono-products. This had been the basis for our risk analyses. The highest score had been regarded in our risk analyses. We built up reference values and classified our products.
Subsequently, we defined reference values, based on the results of VITAL 2 Risk Assessments and ALT/ALTS (guideline values for food control administration published by the Federal Ministry of Consumer Protection food and Agriculture). The Vital 2 Risk Assessment is based on reference intake quantity. Both values – Vital 2 and ALT/ALTS – have been compared and, as a matter of precaution, the lowest values of both had been considered in each way. (see more on our website http://www.ako-spice.com/ako-downloadcenter-eng/)
Therefore, we built up two safety levels in our risk analyses: the respective maximum value analyzed and the respective lowest values accepted by VITAL 2 and ALT/ALTS.
– We can omit some of the allergens we declared by now. Our new Allergen Declaration is now implemented in our specifications and online. Please visit http://www.ako-spice.com/products/ as well as http://www.ako-spice.com/ako-bio-assortment/ and http://www.ako-spice.com/spice-mix/ for more information.
Important: Please inform your Quality Department accordingly!
– In future we will only delcare „Contains + ALLERGEN“ if we add an allergen to a blend or if non-natural sulfit is added in garlic.
– Instead of „May contain traces of“ we will declare „May Contain: ALLERGEN“
Botanical products may unintentionally contain cross contacts of allergens from the origin. Those contacts can be above LOD limits. Our declaration is based on our risk assessment. The non-declaration does not mean absence of allergens. We refer to the position statement of ESA (https://www.esa-spices.org/index-esa.html/publications-esa). Our analyses or specifications do not exempt customers from carrying out own incoming goods inspections.
In case of questions, please do not hesitate to contact us.
All data given are according to our todays knowledge or opinion. They are without obligation.