SGS Informs on Undeclared Food Allergens as a Cause of Food Recalls

Almost every day, in one of the countries that have food allergen lists and labeling requirements, a product is recalled because an allergen was not declared on the packaging but was found in the product.

Rutherford, NJ, May 04, 2015 –(– Undeclared Allergens – A Cause of Food Recalls

17 of the first 25 US FDA food recalls in 2015 were because of undeclared allergens. For 2014, the USDA FSIS reported that 43 of the 94 recalls were because of undeclared allergens (USDA – Summary of Recall Cases in Calendar Year 2014).

To date, most of the recalls have been made because of an undeclared peanut protein in ground cumin, which had been contaminated by a peanut protein. The contaminated ground cumin was used by seasoning companies as part of seasoning in a wide range of products. The initial recall started in November 2014 and is still continuing because this raw material was used in other raw materials and finished products.

The reasons for undeclared allergen recalls vary, but have some common factors such as contamination during production, an undeclared allergen in a raw material because of product change or incorrect labeling.

Changes in Recipe Leading to Undeclared Allergen in a Raw Material

The starting point for any food safety plan is knowledge of the raw material suppliers and the products/ingredients that are being provided. Provision must also be made for prompt notification if/when the ingredient is no longer in compliance with the regulations or food safety standards.

When changes are made, or are going to be made, the ingredient company must ensure that any change resulting in an ingredient being added or even removed, especially an allergen, are notified to companies using the altered ingredient. Simply changing the ingredient statement on the label may not be sufficient.

These changes must be conveyed to the customer in a manner indicating that a change has been made. The message must be conveyed to the company receiving the product in advance of its receipt. On the receiving side, no product should ever be used without verification that it is in compliance with the specifications, and that the ingredients are as listed on the specification. Similarly, the receiver must make sure that any changes are also made on their own labeling and that the information is conveyed to their customer.

The Importance of Food Allergen Labeling and Control

Product labeling and label control is an inadequately addressed area in the food business. The business needs to start addressing labeling as if the product is a drug or drug ingredient. All ingredients must be declared, even incidental additives, when they are allergens. Labeling control ( must be rigorous to ensure that the correct and current packaging is being used. This needs to be done either manually, or better still, by a computerized control system such as bar code scanning.

Food Contamination during Production

In production, there is the risk of unintentional contamination as well as intentional contamination for economic gain, or even to create harm. It is possible to put processes in place to reduce the impact, or risk, of unintentional contamination. The most important being to make sure that rework with allergens only goes into those products that it is designed to be in. Marking and recording is essential for the control of rework. This goes hand in hand with storage and handling processes at all points, from receiving through to shipping. Allergen testing ( is required for validation and it can be useful for verification too. Testing of the finished product for potential allergen contamination may be useful as a pass/fail release but should not be relied on for replacement of allergen process controls.

For more information, please contact an SGS food safety expert.

SGS is the world’s leading inspection, verification, testing and certification company. SGS is recognized as the global benchmark for quality and integrity. With more than 80,000 employees, SGS operates a network of over 1,650 offices and laboratories around the world.
Contact Information
SGS Consumer Testing Services
Jim Cook
+1 973 461 1493
SGS Consumer Testing Services
Jim Cook
Food Scientific and Regulatory Affairs Manager
SGS North America, Inc.