… but they do contain dairy!
If you follow me on Facebook you may recall last month I posted a picture of the labelling behind a packet of Cadbury’s Mini Rolls, with highlighted bold text reading “THESE CAKES DO NOT CONTAIN DAIRY CREAM”.
Milk, however, was clearly widely present in the product – as can be seen, several ingredients are milk-based – so this product was no friend to any milk-sensitive consumer. But could the message lead someone to make a mistake – perhaps not a clued-up food allergy mum, but a less practised grandfather, aunt or family friend?
As you can see from the Facebook responses, prominent allergy advocates were concerned. Nathalie of The Intolerant Gourmand thought it “dreadful labelling”. Vicky at Most Marvellous Baking said “makes no sense at all” and “What an extraordinary thing to put on the packaging”. “Misleading” chorused several others. I agreed, and was urged to contact the manufacturers – which I did.
It took a while, but after a bit of chasing I have finally received a response from Premier Foods – and I’m pleased to say it’s extremely considered. I’ll reproduce it virtually in full below:
We appreciate the question being asked, and believe it is the unintended consequence of addressing two separate regulatory requirements.
The inclusion of the statement has as its basis a long standing regulatory requirement around product composition – quite distinct from allergen labelling. The statement has been present for many years and pre-dates when we started making Cadbury cakes.
It has its origins with specific regulations designed to protect the ‘passing off’ of dairy products and protect consumers from being mislead as to the composition of products.
With regard to cream or crème there is a specific legal definition for cream which requires the use of dairy fat, which is not present in mini roll filling. The use of the term crème on mini rolls was originated by Cadbury when they manufactured the product. It was qualified on pack by the phrase “These product do not contain dairy cream” which we still use when the term crème appears on pack.
Whilst we note the point you make, as the accompanying photo shows the product is described as ‘Chocolate flavoured sponge with a vanilla crème filling, covered in milk chocolate’. Furthermore, the ingredient list – which is recognised in the regulations as the ‘go to’ place for allergen information – includes four references to the presence of milk or ingredients derived from milk.
On balance, taking the presentation as a whole, the likelihood of the product being considered ‘dairy free’ is low.
However, we do recognise that the presence of the statement prompted your enquiry and we are open to the idea of exploring the options of presenting this information differently.
So, in a nutshell, the non-dairy cream (i.e. creme) must be declared as such to avoid misrepresentation – but as Premier Foods say, they’re willing to consider other options.
For me, I guess the obvious solution is to incorporate the non-dairy declaration into the list of ingredients – “vanilla flavour non-dairy creme”, I think, would do the trick – and remove the prominent ‘DO NOT CONTAIN DAIRY CREAM’ statement.
What do you think?