I didn’t think this exciting enough for a blogpost originally, so I posted it on my Facebook page instead, but as it has thrown a few people – and thereby curiously supporting the point I wanted to make – it’s become, I think, worthy of a deeper discussion.
The label in question is this one, on some Marks and Spencer tuna paté. I blogged about the new allergy labelling legislation some weeks ago. It’s been effective since December 2011 but will not be compulsory till December 2014 – we’re just starting to see it appearing on shelves now. It will require manufacturers to highlight allergens (it’s generally supposed this most likely means bold) in their ingredients lists, and to drop their ‘contains’ allergen boxes, therefore keeping all allergens mentioned once / in one place (ie the ingredients list).
Once you know this about the new legislation (ie the bolding of ingredients), at first glance, the Marks and Spencer label will strike you as a new style ‘December 2014’ label. This is because some ingredients are quite obviously in bold. But something’s wrong. Pepper is in bold. Mayonnaise is in bold, but egg is not. Mustard is not. Tuna is listed twice, and why is lemon in bold?
In fact, it’s an old school label. Why the bold, then? Because bolding has never been illegal, and some manufacturers have always been bolding. It’s just what M&S were doing on this particular label, anyway. They’ve not got around to December 2014-ising it yet …
And once you realise this – and it took me a while – things start to fall into place. The ‘tuna contains tuna’ still baffled me, but then with a little help from Kevin at GF By the Sea the last piece of the puzzle slotted into place. So:
* The ingredients of the paté are in bold.
* They are tuna, butter, mayonnaise, lemon, pepper.
* Two of these five ingredients – the tuna and the mayonnaise – are composites formed of other ingredients.
* Following the five ingredients come the breakdown of the composite ingredients for each of these two ingredients.
* The first is tuna. We’re told tuna contains tuna and sunflower oil. (No, me neither, but anyway …) (The lack of an ‘and’ on the label between the two ingredients doesn’t help.)
* The second is mayonnaise. Mayonnaise contains rapeseed, water, egg yolk, vinegar, salt … and so on. You’ll notice mustard is in there too, and it too has composite ingredients – this ‘third tier’ of ingredients is given in brackets.
* The allergy box, as you can see, is still present. ‘Old style’.
Yes, confusing. But legal.
The point I wanted to highlight with this is one which dietitian Julie of Clinicalimentary raised in her comments to my previous post.
It concerns the interim period: the next 12 months, essentially. The period where some labels will still be old school and some will be new school – the latter increasingly so. The potential for error, I think, is immense. It would be quite possible for a mustard allergic individual, getting used to new style labelling, to miss their allergen in this tuna paté. For the newly diagnosed allergic, or coeliac, or parent of either, it will not be easy; for dietitians to train these folk in reading food labelling, it will not be easy. But even the more experienced are vulnerable to slipping up in the transition phase, as this highlights.
I’m perhaps in a minority of the voices who has spoken online about new allergy labelling so far, in that, with reservations, I’m not wholly against the future system, once it's bedded in, and quite like the ‘allergens in one place’ aspect, as I mentioned in the earlier post.
But of the next twelve months, I’m pretty nervous. And all this is why.
On the bright side, the paté appears to be nut-free and gluten-free. Every cloud.