It’s Time to Define

When words or expressions mean more than one thing, or when they’re interpreted in different ways by different groups of people, there will inevitably be some confusion.

Confusion in some walks of life may not be serious. But in the case of food allergies, hypersensitivities and coeliac disease, it often can be.

Take the word ‘vegan‘, when applied to food. Some take it to mean what it means according to The Vegan Society — which is, essentially, food made with only vegan ingredients, but in which cross-contamination with non-vegan ingredients is acceptable if unavoidable — but some take it to mean strictly milk free and egg free, and therefore milk allergy safe and egg allergy safe — and it may be neither. We know this to be a considerable risk.

Take ‘free from food‘. What is it? Is it food free from at least one of the 14 declarable food allergen groups? Is it food free from all 14? Is it merely gluten free? Is it the ‘big two’ — gluten free and dairy free? Is it the definition I favour? (“Food which is free from an allergen ordinarily present in a mainstream equivalent alternative”) Or should it be the very interesting suggestion from Dale — that the determinant of what is ‘free from’ should be the manufacturers’ intent, in that if they make it to be free from one or more of the 14, specifically for hypersensitive consumers, then it is ‘free from’? It matters, because if you don’t know what could or should be in the free from aisle, then again this is a risk (such confusion may have contributed to this tragic case).

And what is ‘dairy free‘ anyway? A dairy is a site for the processing of milk products. The allergen is called milk. Is it time to ditch ‘dairy’ in allergen contexts? I think it is — or at least we need to define what ‘dairy free’ means, because some still believe it means egg free too. 

And what about ‘100% vegan‘ — another claim I’m beginning to see with frequency? Should it mean milk free and egg free as well as entirely plant-based? What is the difference between ‘vegan’ and ‘100% vegan’ when applied to a food? Anyone?

And what about ‘allergen free‘? This is sometimes used as shorthand for ‘top 14 free’ but I’ve seen brands using this expression for products containing gluten-free oats — which I will keep pointing out are a top 14 allergen until I am blue in the face and fingers — and for products which contain pea, which although not a top-14 allergen, is most definitely a life-threatening allergen to the increasing numbers who are anaphylactic to it and struggle to avoid it. Is any food really ‘allergen free’? 


Language matters

Without legal definitions, who is intervening when brands push their marketing claims a little too far?


The 14 emphasisable allergens are clearly legally defined. The expression ‘gluten free’ is clearly legally defined. Pinning these down in law has been a tremendous help to people with food allergies and coeliac disease. But we need to extend this precision to other ambiguous language and uncertain terminology we are using in the everyday business of dealing with food for people with food hypersensitivities.

Why? Well, besides the long-standing issues I’ve outlined above, matters are going to get far messier with the arrival of precision fermented vegan milk proteins — nature-identical milk proteins synthesised using GM microorganisms. (Examples include Perfect Day and Real Deal Milk.)

Make no mistake: these remarkable innovations are coming. Environmental and ethical benefits aside, they will still be milk; and they will be arguably ‘dairy free’ milk, as they will not be processed in a dairy. The language we will be using around these ingredients, and the labelling rules that will need to be applied to products made from them, have not to my knowledge yet been determined or defined. Several requests to the Food Standards Agency have yielded an acknowledgment, but no meaningful response.

I am worried, and I think you ought to be worried too. 

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