Allergen Bureau FAQ – How should I label a commodity or product which is subject to agricultural co-mingling?

Agricultural co-mingling is the result of different crops being grown in close proximity with each other; sharing the same fields due to crop rotation; and / or sharing the same facilities for harvesting, transport and, storage despite the application of allergen controls as part of Good Agricultural Practices (GAPs). This means that the presence of variable amounts of one crop may be found in another crop. This is of particular concern in relation to the potential presence of allergens, such as cereals containing gluten, peanuts, soy and lupins. Although it is possible to apply processes to “clean” crops and reduce the concentration of co-mingled grains, seeds or pulses, these do not generally remove all traces of them and thus allergen identification and declaration is an important consideration.

Mandatory allergen labelling: The Australian and New Zealand legislation does not expressly cover labelling of the presence of allergens due to agricultural co-mingling. However, the ANZ Food Standards Code Standard 1.2.3-4 does however require named allergens (or their products) to be declared when they are present as:

(a)    an ingredient or as an ingredient of a compound ingredient; or
(b)    a substance used as a food additive, or an ingredient or component of such a substance; or
(c)    a substance or food used as a processing aid, or an ingredient or component of such a substance or food.

Allergens present due to agricultural co-mingling do not fall under the requirements for mandatory labelling in the ANZ Food Standards Code. However, this does not remove the responsibility of manufacturers to communicate to their consumers the possible presence of an allergen to which they may be sensitive. This is similar to cross contact allergens present due to manufacturing which are also not expressly required to be labelled by the legislation and where the manufacturer must consider whether these allergens should be declared voluntarily on a product label.

Precautionary allergen labelling: The VITAL Program was developed to provide a standardised science-based risk assessment for voluntary cross contact allergen labelling and it may be appropriate to apply the same principles to the presence of allergens due to agricultural co-mingling in the absence of any mandatory requirements.

An important consideration in the use of the VITAL Program for co-mingled crops is to identify the physical form of the allergen. Where a grain or pulse has been milled or crushed, the allergen may be readily and homogeneously dispersed through the resulting meal or flour. In these cases, it may be possible to apply monitoring and analysis to assess the risk of a consumer being exposed to the minimum eliciting dose (Reference Dose) of the allergen. This approach may not be appropriate where levels of the allergen are highly variable and a further more detailed risk assessment may need to be applied. It is also important to consider that when the allergen is present in a particulate form, a lower level of co-mingling may still present a significant risk, especially when one or two particles (grains, beans, seeds etc.) may comprise an eliciting dose (Reference Dose). See the VITAL Program Guide for more details.

In order to make an informed risk based decision regarding these issues, further information should be collated to consider the nature of the allergen, the likely distribution and level of the allergen and whether the commodity implicated destined for further processing or immediate use by the consumer. All these factors need to be considered to make an appropriate risk based decision.