Allergens on the label

Allergen labelling on a snack has two parts. The contains line lists the allergens present in the recipe. The may contain line warns of cross-contact from a shared line or shared storage. Both lines must be clear, accurate and identical everywhere they appear: on the pack, in the specification and in the file sent to a buyer.

Allergens common in bars and snacks

Every market keeps its own list of allergens that must be declared, but the lists overlap on a familiar group. In our product range the usual ones are:

• Peanuts. Declared on their own, never grouped with tree nuts, because peanuts are a legume.
• Tree nuts such as cashew, almond and walnut. Many markets require the specific nut to be named rather than a general word like nuts.
• Milk: cheese powder on snacks, milk powder and whey (a milk protein) in protein bars.
• Soy: soy protein, and the soy lecithin usually found in a cacao coating.
• Gluten: wheat and barley. Oats contain no gluten of their own but are commonly cross-contacted in growing and processing unless they come from a controlled supply.

Contains and may contain

The two lines are different in kind:

• Contains: mandatory, based on the recipe. Usually shown in bold within the ingredient list and repeated on a separate line so it is easy to find.
• May contain: voluntary in many markets, based on a genuine assessment of cross-contact risk on the line, in the warehouse and in the cleaning step between two products.

There are two opposite mistakes. The first is leaving an allergen off the contains line. That is the most serious error a food label can carry, and in many markets it triggers a recall. The second is using the may contain line as a shield by listing everything to be safe. A label like that is useless to the person who needs it, and it makes a buyer doubt whether the manufacturer controls anything at all.

Writing the may contain line properly means asking the partner facility specific questions: which line runs products with peanuts, what the cleaning procedure between two products is, whether surfaces are tested after cleaning, and where allergen-containing ingredients are stored in the warehouse.

Why clarity matters more than completeness

For the person eating, the decision takes a few seconds at the shelf. They look for a word in bold. If they cannot find it, they put the pack down. For buyers and importers, allergens are the first item on the document checklist. A mismatch between the label and the specification is grounds to reject a shipment, however good the product tastes.

For us, clarity means that a piece of information exists in one version only. The same allergen has to appear the same way on the pack, in the specification, on the product sheet and in the reply to a buyer's email.

An example: a matrix for 20 products

While preparing a file for an importer, we were asked for an allergen matrix: one row for each of our 20 products, one column per allergen, each cell marked contains, may contain or no. It exposed two inconsistencies.

The first: the specification of a Natural & Healthy nut bar said nuts, while the label listed cashew and peanut as separate items. For an international reader, nuts is not enough. Peanuts and cashews belong to different groups, and the tree nut has to be named. The specification went up a version the same day.

The second: the Let's PLAY Cheese Ball carries cheese powder, so milk sits on its contains line. The Maize Ball passes through the same seasoning step. Before filling in the milk cell for Maize Ball, we sent the partner facility exactly the four questions above. They sent back the cleaning procedure and the run schedule between the two products. The conclusion went into the matrix along with a review date, filled from a written answer rather than a guess.

How we keep the label right

A few rules we hold across all four brands:

• The allergen matrix is part of the specification and carries a version number like every other section.
• Whenever an ingredient or a supplier changes, the specification sheet and the COA (certificate of analysis) are re-read at the allergen section before approval.
• The label is never used to make a promise. We do not write allergen free, and we do not write safe for people with allergies. That is not a snack maker's place to say.

This is our value Speak Honestly in its driest form: one cell in a table, filled in correctly, and identical in every document.

If reading specification sheets and keeping every cell of a specification right sounds like your kind of work, our Fresher Product R&D role in Hanoi is open. If you are a buyer who needs the allergen matrix for our products, get in touch and we will send the current version.