[Updated] CAC Proposes to Revise the General Standard for the Labeling of Prepackaged Food, Involving Allergen Labeling

Updated on November 29, 2024

On the meeting held during November 25 to 30, 2024, Codex Alimentarius Commission adopted the proposed revisions to CXS 1-1985 General Standard for the Labeling of Pre-Packaged Foods regarding food allergen labeling, Guidelines on the Provision of Food Information for Pre-Packaged Foods to Be Offered via E-Commerce, and Guidelines on the Use of Technology to Provide Food Information in Food Labelling.

As revealed by Circular CL 2024/88-CAC issued on November 8, 2024, Codex Alimentarius Commission is consulting on the discussion results of the 48th Session of the Codex Committee on Food Labeling. Standards/Documents involved were the allergen labeling requirements specified in General Standard for the Labelling of Pre-Packaged Foods (CXS 1-1985), and Guidelines related to information required for food products sold via e-commerce and the use of digital technology to indicate food information. Any comments can be sent back prior to November 20, 2024 through Codex Online Commenting System (OCS).

Proposed amendments regarding food allergen labeling

Definition of terms

Terms and definitions related to allergen labeling are added to the draft, including “Allergenic food”, “Coeliac disease”, “Food allergen”, and “Food allergy”. Take “Allergenic food” for example, it means a food (including ingredients, food additives and processing aids) that can elicit immunoglobulin class E (IgE)-mediated or other specific immune-mediated reactions in susceptible individuals.

The varieties and labeling requirements of allergenic food

On the one hand, sesame and products thereof are newly included as allergenic food in article 4.2.1.4. In addition, the draft lists some other food and ingredients that may be declared as allergenic foods based on risk assessment for respective populations in article 4.2.1.5.

Article 4.2.1.4 Allergenic food and food ingredients

Article 4.2.1.5 Other food and ingredients that may be declared as allergenic food based on risk assessment

When substances referenced in article 4.2.1.4 and 4.2.1.5 are intentionally added, and when sulphites are present at levels of 10 mg/kg or higher in a food (either “sulphite” or “sulfite” can be used as specified name, mentioned in 4.2.1.7), their specified names must be clearly displayed on the food label either alongside or as part of the ingredient name.

Small packages with a maximum surface area of less than 10 cm2 may be exempted from mandatory labeling items, including ingredient lists, lot identification, date marking and storage instructions, as well as instruction for use. However, such exemption does not apply to the declaration of food and food ingredients listed in article 4.2.1.4, 4.2.1.7 and where applicable 4.2.1.5.

In addition, Guidelines on the Use of Precautionary Allergen Labelling is included as a new Annex to CXS 1-1985. As per the draft, precautionary allergen labeling is a statement that warns consumers about potential unintended presence of allergens in food products. where the risk of unintended allergen presence cannot be reduced to an acceptable level. The warning must:

• Be indicated as a separate statement directly below or near the ingredient list

• Begin with "may contain" or similar wording

• List the potential allergens using their specified names as defined in article 4.2.1.4 and, where applicable, 4.2.1.5 of CXS 1-1985

Requirements regarding the labeling of food sold via e-commerce

The draft of the Guidelines on the Provision of Food Information for Pre-Packaged Foods to Be Offered via E-Commerce specifies the mandatory and optional information for the e-page of the prepackaged food sold online.

The mandatory labeling information on the e-page should follow the requirements in Section 4 “Mandatory labeling of prepackaged food” and Section 5 “Additional mandatory requirements” in CXS 1-1985 (except 4.6 lot identification and 4.7.1 related to data marking), as well as Section 3 nutrient declaration in CXG 2-1985 Guidelines on Nutrition Labelling.

The voluntary information shall follow Section 7 “Optional labeling” in CXS 1-1085.

Use of digital technology to present food information

The draft of the Guidelines on the Use of Technology to Provide Food Information in Food Labelling specifies the situations where digital labeling is accessible, as well as the principles for food information provided through electronic or digital means. Specifically, it clarifies that mandatory labeling items such as food name and information about food safety and nutrition shall not be provided exclusively through digital methods.