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Hi! I'm Amy Jones Anichini, Founder
and CEO and
we're on to Checklist Item #7: Understand what the FDA requires food manufacturers to disclose to you on their food labels, as
well as what is optional to disclose. So basically
this checklist item is: understand what the food label is REALLY telling you. There's a lot of confusion about this topic but it is really
fairly simple. You just have to know what the rules are, so here are the rules. The FDA requires a food manufacturer to do two things.
1: They require a manufacturer to list every ingredient that is actually contained in the food
2. For every ingredient that is either one of the Top 8 food allergens, or contains the
protein of one of the Top 8 food allergens, they have to tell you that in language that's really easy to understand.
That's it! That is all the Food Allergen Labeling and Consumer Protection Act (FALCPA) requires a food manufacturer to do. Pretty simple, right?
No (laughs out loud). There's a lot of latitude with what food manufacturers can do and that's for a good reason.
So let's just talk through some of the things you have probably seen on a food label
and some questions you might have - they're questions that I had when I first started exploring this. So, does the FDA require
a food manufacturer to use bold face in the ingredient listing when the ingredients are
food allergens? No! But some of them do anyway.
How about this: does the FDA require food manufacturers list food allergens in a separate line below the ingredient list? No! But some do anyway
Let's see, what might be another one. Does the FDA require a food manufacturer to
say to you, "Hey, consumer, look in this one specific place on any label
produced by any food manufacturer, if you want to know if it's safe for you" - are they required to do that? No! They're not.
So, what this might be telling you is the answer to this next question, which is,
as a food allergic consumer, or the parent of a food allergic child, do you have to read every ingredient on every label each and every time you buy food?
Yes! (laughs out loud). Now I know that might sound overwhelming, but once you've done it a couple of times you'll be scanning in no time and it really
gets pretty easy. So, why do you have to read every label every time?
Well, for two reasons. 1. Labels aren't consistent from one manufacturer to another
because the FDA provides a lot of latitude for how they can get this information to you.
So you have to read the full label to know: "Is there wheat in this? I don't know, nothing's bolded - I better read the whole thing to see if there's wheat,"
and so on. 2. Another reason why, as a consumer, you have to read every label every time is
because ingredients change. I mean, I'm a food manufacturer myself, and I know, that in the first three months of
starting our food brand, I changed - one of my cookies - I changed the recipe three times and I had to re-do the label.
So it happens. Even with huge food manufacturers it happens, so you've got to read every time just to be sure there hasn't been a change.
OK now one of the things that I mentioned was, "Top 8" food allergens. Let me just tell you what those are and I'll give you my interpretation about
why the FDA only really covers the "Top 8." OK, so here they are.
1. Milk
2. Eggs
3. Fish
4. Crustacean shellfish
5. Tree nuts
6. Peanuts
7. Wheat
8. Soybeans
OK. Now, why does FALCPA only really pertain to
those Top 8 food allergens? For a couple reasons. First, they're the most commonly diagnosed food allergens.
There are hundreds of foods that people could be allergic to, but those eight are the ones people are most likely to be diagnosed with.
Not only are they the most common, they are also the most likely to cause a severe
allergic reaction. And again, bear in mind we're not doctors - this is just our interpretation based on our research.
So, there it is. Food manufacturers are requred by the FDA to do just
two things: 1. They have to tell you every ingredient that is actually contained in the food that you're buying
and 2. For any ingredient that is either one of those Top 8 food allergens, or contains the protein
of one of those Top 8 food allergens, they have to tell you that in language that's easy for you to understand.
Let me give you a quick example of that.
Let's say you're reading a food label and you see the word "albumin." Albumin is basically egg protein. So a food manufacturer has to say,
they have to tell you that that's egg. So, they can have the word "albumin" on the label, but in some way on the label
they need to say "egg" or "derived from egg" or "contains egg protein," or something of the sort.
The word "egg" would also have to appear.