A growing number of food business operators, including manufacturers, retailers and caterers are making “free-from” or “allergen-free” claims for their food products. The food industry is committed to providing accurate and consistent food labelling and communication.

Consumers likely to purchase “free-from” food products fall into two groups. The first group of consumers are those suffering from, or caring for someone with, an intolerance or allergy to a particular food ingredient. For these people, the presence of even very small amounts of the allergen can be detrimental or, in the case of food allergy, possibly fatal. The second group comprises those for whom the avoidance of a particular ingredient is a lifestyle choice. Regardless of the reason for purchase the standard of a “free-from” food must be the same.

This industry guidance provides information to food business operators on the appropriate use of “free-from” food allergens claims. Relevant to both prepacked and non-prepacked foods, it provides useful guidance for food manufacturers and caterers, particularly smaller enterprises considering making “free-from” claims. This guidance should not be used as an enforcement tool but will nevertheless be helpful for enforcement bodies, who advise food businesses on best practice.

The guidance is an overview of the key considerations for making accurate and reliable “free-from” claims, and the preparatory work needed to substantiate them. This aims to ensure “free-from” is applied both accurately and consistently across the whole food industry. Some food companies may have additional requirements that go beyond legal compliance.

This guidance is not an exhaustive allergen management guide. It does not address the use of 'may contain' advisory statements, or alternative statements to “free-from” or “allergen-free”. Terms such as “free-from artificial colours/preservatives” and “meat-free” are out of the scope of this guidance.

From a consumer perspective “free-from” means a complete absence of the specified allergen in the product. However, in practice it is the scientific demonstration on an ongoing basis that the specified allergen in the food product is at a level that ensures safety and takes into account the analytical limit of detection (LoD) for a recognised and accepted laboratory test method. Scientific research is beginning to point towards levels of allergens (thresholds) below which adverse reactions are improbable. However, only those for gluten, sulphur dioxide and/ or sulphites (and lactose for infant formula only in the United Kingdom and European Union) have been transferred into regulatory limits. For true allergens, the focus is on limits for precautionary allergen labelling, rather than “free-from”.

A “free-from” claim stating the absence of a specific food allergen in any food, including prepacked and non-prepacked food (e.g. food sold loose or a menu item), must be relevant and based on a comprehensive risk assessment accompanied by rigorous controls (which may include analytical testing) to ensure that the claim is valid and not misleading. It is important that good manufacturing and/or handling practices are observed at all times with regard to the production and serving of these specialised foods.

Next page: Considerations for making a "free-from" claim?

Last reviewed: 12 Nov 2015