That there are eight major allergens in the United States and fourteen major allergens in the United Kingdom and EU can cause problems to those with food hypersensitivities on both sides of the Atlantic — either when visiting one another’s countries, or when buying imported food whose labelling has not been properly adjusted to local law.
So what are the risks to those with food allergies or coeliac / celiac disease due to these differences? Let’s take a look.
In the US, the FDA’s Food Allergen Labelling and Consumer Protection Act has nominated the so-called big 8 allergens, the “Major Food Allergens”, which must always be declared on ingredients labelling or be listed after a ‘Contains’ statement. They are:
In the UK, we are governed via the FSA by the EU’s ‘top 14’ allergens, which must almost always be highlighted in ingredients labels (eg in bold):
It’s easy to assume from the above lists that the UK / EU allergens are merely the US allergens plus another six allergens. But closer inspection reveals it’s not quite as ‘tidy’ as that.
Observation 1 …
First, while all cereals containing gluten are considered major allergens in the UK / EU, only wheat is considered one in the US. Barley, rye and oats are not major allergens in America.
A consequence of this is that a US product which is free from the 8 major allergens can still contain gluten (from barley / rye / oats) while a UK / EU product free from the 14 major allergens cannot contain gluten (because it excludes all possible sources of it).
Observation 2 …
Second, the definitions of tree nuts in the US are more wide-ranging than in the UK / EU. This has, in my view, one benefit and one drawback …
The tree nuts are defined in the UK / EU as almonds, hazelnuts, walnuts, cashews, pecans, brazils, pistachios, macadamia nuts. All these are on the US list of tree nuts too, but additional named nuts are also included, namely chestnut, coconut, shea nut and a few other obscure nuts. (See full list here.)
This is good for those with allergies to these less prominent nuts, or those advised to avoid them on a precautionary basis, but could arguably be needlessly over-cautious in at least one case — that of shea nut, to which no recorded confirmed allergic reaction exists, to my knowledge.
Some of the risks stemming from these differences will relate to imported / exported foods whose labelling hasn’t been adjusted according to local laws and perhaps careless marketing by international ‘free from’ brands on social media.
But there’s also the problem of US individuals visiting the UK / EU — and vice versa. Whenever a brand describes itself as ‘free of the top allergens’ or similar, always ask yourself: do they mean US or UK / EU?
UK Coeliacs visiting the US
If you’re a British coeliac in North America, be careful to stick to only confirmed gluten-free products — ‘wheat-free’ or ‘major allergen’ free may be insufficient, because a product could contain rye or oats, for example. Remember that because barley is not on the list of allergens in the US either, ingredients such as ‘malt’ may not specify that they are from barley, so watch for this too.
UK Food Allergics visiting the US
Those from the UK with allergies to lupin, sesame, molluscs, celery, mustard and sulphites, for instance, need to exercise caution too. These will be named on lists of ingredients if included, but may not be if a derivative of them is used rather than the ‘whole’ ingredient. For instance, ‘vegetable protein’ may theoretically be sourced from lupin, whereas in the UK it would need to be declared as ‘vegetable protein (lupin)’.
Another concerning legislative loophole in the US relates to the term ‘non dairy’ — this does NOT mean dairy free. Bizarrely, ‘non dairy’ items can contain 0.5% milk in the US. This will be declared on ingredients labels explicitly, but it can be easy to get caught out if you have milk allergy.
US Celiacs visiting the UK
So-called gluten-removed beer in the EU can be labelled ‘gluten free’, so be aware that barley-based beers can be described as being gluten-free in the UK. (For a list of non-barley GF beers, click here.)
US Food Allergics visiting the UK
Watch out for those nuts considered tree nuts in the States and not considered tree nuts in the EU, should you be allergic to them — in particular coconut, which is widely used in free from foods. My article on FoodsMatter.com on non top-14 allergens might help further.