According to the recently-published Guidance Note No. 28 – Food Allergen Information for Non-Prepacked Foods in Ireland among the food businesses affected are “Licensed premises selling alcoholic or non-alcoholic beverages including non-bottled (draught) beer and cider, wine by the glass, cocktails, smoothies or juices”.
Under the Health (Provision of Food Allergen Information to Consumers in Respect of Non-Prepacked Food) Regulations, 2014 (SI No. 489 of 2014) pre-packaged drinks will be the responsibility of the manufacturer/supplier but any drinks poured by barstaff will be the responsibility of the outlet concerned and so must have allergen information to hand in written format.
According to the FSAI, “The written food allergen information already provided for prepacked beverages (bottled, canned etc) must also be provided for the non-prepacked form which includes draught beer and cider, wine provided by the glass, cocktails, smoothies and juices. “Allergen declarations for non-prepacked beverages could be provided in a number of ways,” advises the FSAI, “For example wine lists could include sulphite information on certain wines while allergen information for other beverages could be provided adjacent to or as an addition to the price list at a conspicuous location(s) on the premises. The precise allergen information required must be in the form of ‘Contains……’.
The FSAI has already published guidance and information documents on its website and these will be updated in the coming weeks with further information to assist the food and drinks industries in complying with these new legal requirements.
In the meantime it advises making all staff aware of the 14 allergenic ingredients that must be notified to customers and putting a system in place “to identify and record the allergenic ingredients being received and handled by the food businesses to enable them to meet the food allergen declaration requirements”.
Annex IIIa of Directive 2000/13/EC lists the allergens as:
- Cereals containing gluten and products thereof
- Crustaceans and products thereof
- Eggs and products thereof
- Fish and products thereof
- Peanuts and products thereof
- Soybeans and products thereof
- Milk and products thereof (including lactose)
- Nuts ie almond, hazelnut, walnut, cashew, pecan nut, brazil nut, pistachio nut, macademia nut and queensland nut and products thereof
- Celery and products thereof
- Mustard and products thereof
- Sesame seeds and products thereof
- Sulphur dioxide and sulphites at concentrations of more than 10mg/kg or 10 mg/litre expressed as SO2
- Lupin and products thereof
- Molluscs and products thereof
The FSAI’s Chief Specialist for Food Technology Dr Patrick O’Mahony told Drinks Industry Ireland, “The new labelling requirement applies only to those 14 allergens and their derivatives. Any other known or unknown allergens are not included for the purposes of this mandatory declaration.
“However, premises concocting their own exotic drinks on their premises such as customised cocktails must provide written information on which of the 14 allergens (if any) they might include in those drinks. So, for example, if they’re adding milk or cream to a cocktail prepared on the premises this would need to be mentioned in written format somewhere within plain view on the premises.
“In that case a cocktail list could be used to list any of the 14 allergens used, or such written information could be situated elsewhere on the premises where it is conspicuous, easily accessible, clear and legible etc.”
He also pointed out that manufacturers and suppliers providing mass products to pubs etc must provide the allergen information, “… so it’s the pub’s responsibility to ensure they get this information and of course the manufacturer’s responsibility to provide it – for example for draught beer or other bulk drinks if there are any”.
Considering the short timeframe available to the licensed trade, he suggested that clear and legible hand-written notices in a conspicuous place(s) on premises detailing the allergens in various drinks would be sufficient if a quick solution was sought by premises due to the short lead-in time.
“Therefore the biggest job of work would be figuring out which of the 14 allergens are in any of the products and then putting that on a notice in hand-written or print format,” he concluded.
The carpet coverage indicated by Government has come as a surprise to nearly everyone in the licensed trade.
“I think there’s a very poor level of either awareness or preparation,” commented VFI Chief Executive Padraig Cribbin while the LVA, too, is similarly in the dark about this legislation.
“I know nothing about this legislation and neither do the members,” LVA Chief Executive Donall O’Keeffe told Drinks Industry Ireland magazine, “so we’ll look into it.”
The latest Unilever research in the UK shows that 40% of food venues there were completely unaware of the new allergen laws, never mind having to implement them.