An analysis of food allergen recalls in the UK

A significant piece of work has been published in relation to food allergen recalls in the UK over a recent five-year period.

It is open access, written by Sim Ray Yue of Queen’s University Belfast (plus colleagues), and although I’ll give some highlights and thoughts in note form below, I would urge you to give it some time if you can.

Here it is: Food allergen recalls in the United Kingdom: A critical analysis of reported recalls from 2016 to 2021.


Some key figures:

Over 1,000 food and drink recalls took place during the period of the research, with 58% being food allergen-related recalls, over a quarter of which involving multiple allergens.

Milk accounted for a quarter (25%) of the allergenic food groups involved (over 40%, in fact, of the allergen recalls involved milk as the allergen or one of the allergens), followed by cereals containing gluten (17%) and tree nuts (11%).


The key reasons for the allergen recalls are interesting too. Here they are:

Omission of the ‘top 14’ allergen from the list of ingredients (40%)

Cross-contamination (19%)

Mis-packaging (17%)

‘Top 14’ allergen mentioned in list of ingredients — but un-emphasised (10%)

Non-English labelling of allergens (7%)

Mistaken Free From Claim (7%)


The eight food business operators with the highest frequency of food recalls were not surprisingly, the main supermarkets — in order, Lidl, Waitrose, Tesco, Sainsbury’s, Asda, Co-Op, Morrisons, and Booths. Lidl issued 37 recalls involving 62 products, with 25 of recalls (68%) not having the ingredient list labelled in English.


Changes are coming

The paper’s authors say: “Apart from two maximum limits in EU/UK food law for regulated food hypersensitivity food groups, ‘gluten-free’ with a limit of 20 mg/kg gluten and sulphites with a limit of 10 mg/kg as SO2 … other ‘free-from’ labelling statements remain non-specifically regulated under general food law. ”

A ‘free from’ claim which turns out to be untrue is of course a particular worry to those with food allergy. The writers note that there is a lot of work being currently done regarding precautionary allergen labelling (PAL) and additional allergen thresholds, which could have a significant impact on labelling legislation, with drastic changes potentially due.

They add: “The implications of these developments include current ‘free-from’ and ‘gluten-free’ statements that may need to be revised. There is currently no regulation for other ‘free-from’ foods. Thus, this study is timely in providing a baseline analysis of recall data prior to potentially far-reaching changes in food allergen risk analysis, risk management, and legislation.”


Problems and definitions … 

Other points which caught my eye included these two statements:

“A ‘gluten-free’ statement is potentially confusing if it leads consumers to expect gluten-free foods to contain no gluten at all.” (It can of course contain up to 0.002% of gluten.)

“The ambiguity of a PAL statement while relevant to wheat-allergic individuals on a ‘gluten-free’ product suitable for those with coeliac condition is … confusing.” (I’ve written about this before, in relation to Goody Good Stuff.)

I do feel the second of these is partly solvable by brands being specific (eg “may contain traces of gluten-free wheat starch”), but the first does bring into question the issue of what ‘free’ means in relation to allergens and ingredients.

‘Gluten free’ was essentially redefined by legislation to mean 0–20 parts per million gluten. It does not mean ‘zero’ gluten, nor ‘free’ in any absolute sense. And the legislation specified that the term used should be ‘gluten free’ and not ‘free from gluten’ or ‘no gluten’ or ‘without gluten’ or any other variation. Most coeliacs now understand this, but will those with food allergy if we extend the idea to other allergens?

I have written about the importance of tight, clear definitions in allergy discourse before — see my article “It’s Time to Define” — and I’ve never felt that they are as important as they are now.

We see terms such as ‘allergy friendly’, and ‘gluten friendly’, and ‘allergy free’ bandied about casually — but what do they mean? Is there a difference between ‘dairy free’ and ‘milk free’ — and if so, what is it? We still don’t have a definition of what ‘free from food’ is, and when it comes to the often-misinterpreted word ‘vegan’, all we have is the Vegan Society’s definition, but not a legally watertight one. As the research team observed, ‘plant based’ and ‘vegan’ issues have been involved in a few (albeit not many) recalls, but I expect those to increase in number unless we pin these definitions down.

I’m growing increasingly of the view that we need to define a term or expression — or else ban it.

We should also consider outlawing variations of those we choose to define, to prevent brands forever inventing their own expressions and terminologies to individuate themselves from competitors. Lives are at risk. We need standardisation. I saw “freedom from gluten” today on a label. When the law specifies you should say “gluten free” why, food brands, are you just not sticking to “gluten free”?

My view is that tightening up definitions will help focus minds and reduce future recalls. It is work that needs to be done alongside the PAL and threshold work, and I sincerely hope the lawmakers and regulators are listening.

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