When communicated in writing, food allergens must be written in a clear and legible manner, physically or electronically, at the food product’s point of sale. The consumer must be able to easily and freely access this information prior to purchase. But in the restaurant industry, allergen declarations are often verbal.
From there, what procedure should be put into place for compliance with law EU 1169 regarding the mandatory declaration of food allergens? How do you guarantee accurate and comprehensive food allergy information for the consumer? Meeting the challenge of food allergies is not easy for those in the restaurant industry.
What does EU 1169 say in regards to verbal declarations of allergy information?
European legislation INCO 1169 permits verbal declarations of allergens, but only under certain conditions:
- at the consumer’s request, you must be able to provide this declaration must be provided without delay, free of charge, at the food product’s point of sale and prior to purchase;
- the establishment must implement a written procedure to ensure correct and consistent information;
- you must train your staff on the internal procedure, as well as the risks incurred by consumers with allergies.
If these conditions are not met, for example in the case of self-service, and there is not always someone present who can provide this information, it must be written down in compliance with EU 1169 instructions regarding food labeling.
Food allergy information: 7 questions and answers for the restaurant industry
To establish a procedure of good governance for your allergy information and ensure its verbal communication to your clients, here are 7 key questions to ask yourself and answers by Youmeal, your foodtech software for food data classification and consumer information.
- 1. Where can I find information regarding allergens that are present in my raw materials?
Où puis-je trouver les informations sur les allergènes présents dans mes matières premières ?
There are various sources of information on allergens present in raw materials: technical sheets from suppliers, product packaging, databases available on the internet such as Trustbox, Ciqual or Nubel, as well as food retailer websites.
- 2. Where can I find information about the allergens that I have used?
Où puis-je trouver les informations sur les allergènes que j’ai utilisés moi-même ?
Food allergens must be identified by the person(s) in charge of creating menus and designing recipes. Take inventory of each product used, checking for allergens and traces of allergens. They then have to be added together to obtain the allergen map of the recipe.
- 3. How can I make sure that the allergen information I give is always up-to-date?
Comment puis-je m’assurer que les informations sur les allergènes que je donne sont toujours à jour ?
This is an especially critical point. Recipes or production sites are always changing. Plus, products that are similar in appearance could contain different trace allergens just based on production batches. The producer will have changed the bar code and should also inform retailers who buy from them. But in practice, this type of process is difficult to implement: producers do not always update their data and it may also contain encoding errors. Basically, only systematic and regular monitoring will help in providing updated allergen information. Plan the time and for a dedicated person for this task. You can also subscribe to a solution like Trustbox, a platform dedicated to the exchange of product data.
- 4. Who is responsible for managing allergen information?
Qui est responsable de la gestion des informations sur les allergènes ?
Assigning a dedicated person, responsible for information on allergens, is key and can help you to avoid you the worst. In fact, a restaurant owner in breach of the law risks a fine from the FASFC, as well as increased hygiene checks at his or her own expense. You may also be prosecuted for endangering the lives of others if it is proven that you have deliberately ignored the risks of allergens. The competent authorities have already sentenced some restaurant owners to prison after an accident has occurred.
- 5. What if, due to certain circumstances, the usual recipe is suddenly not followed?
Que se passe-t-il si, en raison des circonstances, la recette habituelle n’est soudainement pas respectée ?
As a restaurant owner, you have to reanalyze the possible allergens contained in any new recipe or recipe modification and inform the end consumer. In your internal procedure, plan for this scenario and put in place the tools to reduce the risk of forgetting, in both the kitchen and the dining room.
- 6. How does the communication of information from those responsible to the end consumer actually work?
Comment se déroule la transmission des informations du responsable au consommateur final ?
The practical procedures for applying regulation EU 1169 vary from one country to another in regards to the various amendments adopted. In Belgium, restauranteurs are only required to communicate orally at the consumer’s request. In France, industry professionals must put in writing the list of allergens, by dish and in a document available to self-service consumers. In the United Kingdom, restaurant owners must provide information on allergens for each food product separately and clearly. In practice, they mention this information below each dish on the menu. Best practice for communicating allergy information from those responsible to the final consumer depends on several factors. The organization within your business, the type of services you offer to consumers or the size of your teams, for example.
- 7. Is sharing this information required at all times, even, for example, during peak times or in the case of temporary staff?
Cette transmission d’information est-elle garantie à tout moment, par exemple aussi aux périodes de grande affluence ou en cas de personnel intérimaire ?
This is also difficult. The idea of oral information in Belgium is problematic when there are changes or replacements within teams. For example, time off for vacation or sick days. How do you ensure that the back-up knows all of the allergy information and can communicate them to the consumers without risk? Written information, generated by a specific tool, is therefore the safest solution. As long as you consider last-minute recipe modifications.
Interested in a comprehensive and intuitive solution for better management of food allergy information communication? Learn more about the 5 indispensable functions of a recipe management software and discover the advantages of Youmeal for the good governance of your food data.