10 Conclusions and recommendations
10.1. Level of awareness and knowledge of consumers about labelling provisions that cover allergens
10.2. Ability to successfully identify manufactured foods that contain allergens
10.3. Existing behaviours of main grocery buyers in regard to food selection
10.4. The labelling of foods and its impact on the occurrence of adverse / allergic reaction
10.5. Clarity and understanding
10.6. Recommendations
To reiterate, the objectives of the research were to:
- assess the level of awareness and knowledge of consumers ‘at risk’ of an adverse reaction, and their carers (if relevant), of the labelling provisions that cover allergens;
- assess the ability of those ‘at risk’ (if relevant) or their carers to successfully identify those foods that contain the pertinent allergens;
- understand the existing behaviours of ‘at risk’ consumers (where relevant) or their carers in regard to food selection; and
- identify whether a lack of understanding of the allergen labelling of foods contributes to the occurrence of adverse reaction in those affected, and to what degree.
The results are therefore discussed in terms of each of these objectives.
10.1 Level of awareness and knowledge of consumers about labelling provisions that cover allergens
* Respondents used food labels extensively in managing the allergies in their household and noticed that there had been changes to the way allergens were listed on food labels.
Ninety percent of respondents said they always read food labels carefully (see section 6.3).
Based on responses to question 33 about any changes that have been observed to the way allergens are listed on food labels (see section 8.2), it was apparent that around two thirds (63%) of respondents had already noticed some specific changes in the form of:
- greater use of' may contain' statements;
- the use of bold print for allergens within the ingredient list (significantly more in New Zealand than in Australia);
- more warnings about nuts (significantly more in Australia than New Zealand);
- the use of 'made on same product line or equipment' statement (significantly more in Australia than New Zealand);
- the use of blanket statements such as 'contains dairy / seeds / nuts …' (significantly more in Australia than New Zealand); and
- greater use of 'made in same factory' or 'same premises' statements.
The following sections cover issues related to the ability to identify allergens.
10.2 Ability to successfully identify manufactured foods that contain allergens
* Respondents' ability to identify food products that contain particular allergens of concern varied.
This survey found that levels of awareness or ability to identify foods that contain allergens varied considerably and depended to a large degree on the type of food allergy the person had to deal with and the terms used for the substances of concern. This assessment was based on responses to both Q14 (see section 5.1) that collected information about respondents' ability to recognise the allergen from a selection of substances and ingredient names as well as Q30 (see section 7.8), which presented simulated labels.
From a composite measure that was constructed from responses to both the food ingredients question (Q14) and the food labels question (Q30) combined, the levels of identification achieved suggest that many people with food allergies did not recognise all of the substances that could trigger a serious reaction. From this composite measure it was found that those with tree nut,milk or eggallergies were most accurate in their assessment of ingredients and / or labels, whilst those with peanuts and wheatallergies were the least accurate (see section 7.7) . For both of these two groups, there were particular issues of knowledge or recognition, for example vegetable oils and praline (possible peanut derivation), maltodextrin (mostly maize derived but some from wheat), and textured vegetable protein (mostly contains soy but wheat derivation is also possible).
10.3 Existing behaviours of main grocery buyers in regard to food selection
* Respondents had adopted strategies to manage food selection.
Two in five respondents (41%) said they had to check all product categories to make sure they avoid the substances of concern (see section 6.4).
The major ways in which respondents managed food allergies in their household were by:
- reading food labels carefully ( 90% always did this);
- buying the same brand that past experience has shown to be allergen free (62% always do this);
- never buying loose or bulk foods (43% never did this);
- buying food in sealed packages (29% always; 44% often did this); and
- checking food lists provided by an allergy support group (26% always; 24% often did this).
A quarter of New Zealand respondents (27%) said theyalwayschecked the MFD (see section 6.3).
Most respondents with peanut (80%), tree nut (72%), shellfish (72%) or fish (62%) allergies never eat the substance knowingly. In contrast, those with sulphite (48%), soy (32%), or wheat (24%) allergies said they try but cannot avoid the substance completely (see section 6.2).
10.4 The labelling of foods and its impact on the occurrence of adverse / allergic reaction
* Food labelling did have some impact on the occurrence of a severe allergic reaction.
Two in five (42%) respondents said that the person with the most serious allergy had had a severe allergic reaction since their allergy had first been identified (see section 6.1). Amongst these, the major causes were that they had accidentally consumed (36%) or had come into contact with (21%) the substance of concern. Manufactured food labels were explicitly said to have contributed to some instances by:
- unlabelled or incorrectly labelled food (14%); and
- traces of substances in unexpected products (6%).
Eight percent identified pre-prepared food as an issue for their household. There was no significant difference by membership of a support group.
Labels were seen by most (57%) to be relatively trustworthy, with a large proportion (39%) who did not know whether to trust the labels or not (see section 7.3). Respondents who were members of a support group were more likely to say they were not sure whether to trust the labels or not.
Two thirds of respondents (66%) said they were sometimes unsure about food items or particular ingredients, a further quarter (26%) said they were often unsure and 6% said they were always unsure. Only 2% said they were never unsure. Respondents who were members of an allergy support group were more likely to be uncertain of food items and/or particular ingredients (see section 7.4).
Respondents showed a preference for the disclaimer 'made on the same equipment as products containing …’, with 46% saying this statement was very useful(compared to 33% for 'may contain traces of …', and 31% for 'made in the same premises as products containing …'). However, over a third (37%) still said that the 'made on the same equipment ..' statement was not very useful (See section 7.6).
Respondents indicated that the labelling issues that caused them particular concern (section 8.1.1, question 31) in their efforts to identify suitable foods for the allergy, were:
- their own lack of understanding about what some of the ingredients actually were, due to the complex or unclear terms used i.e. identifying things like 'emulsifiers' etc as a potential source of concern;
- the use of ' may contain' statements – over-used or not clear, and restricted the choice of foods that were available;
- where some ingredients were derived from – the sources of certain vegetable oils, for example, were often not stated;
- issues that were the responsibility of manufacturers, such as unlabelled ingredients or changes to the ingredients in products; and
- issues relating to the food label, such as the location of the information or the perceived difference in labelling requirements for imported foods.
10.5 Clarity and understanding
It was apparent that there aretwo key aspectsto ensuring that food labels are effective as a means of preventing or minimising allergic reactions, namely:
- clarity;and
- understanding.
Clarity is the aspect that the food regulators and ultimately food manufacturers could consider. This involves things such as assisting those with food allergies to easily identify the substances that are of concern through:
- adopting more meaningful or accurate labelling or ‘advisory' statements. In relation to the advisory statements, there was a preference for the statement: 'made on the same equipment as products containing …' (46% of respondents said this wasvery useful) but there was also a strong request for statements that stated when allergens were not present, e.g. 'allergen-free' claims (23% of respondents spontaneously requested this);
- ensuring that the origin of particular ingredients, such as emulsifiers, vegetable oil, thickeners, etc, are shown so that potential allergens were able to be identified;
- using uniform wording in plain English for allergens (5% of respondents said uniform words should be used and 12% said terms should be in plain English). Thus, always using egg instead of ovalbumin; milk instead of casein; etc;
- using percentage labelling for allergens (5% of respondents) to indicate the level of the ingredient in the food to enable an assessment of risk (see discussion below on level of risk); and
- formatting issues,such as printing the allergen in bold or making the writing larger (16% of respondents), and standardising the location of warning statements (5% said these should be near the ingredient list, and 3% said their position should be standard).
It would appear from the results in general, that a particular issue of concern for those managing a food allergy in their household was their ability to make an informed assessment of the level of risk. Thus, the disclaimers 'may contain traces of …', and ' made in same premises as …' were seen as largely not very useful. These statements did not give any indication of the likelihood of the allergen actually being present.' Made on the same equipment as …' was seen as a better statement, because it indicated that there was a greater likelihood than for the other two, of the allergen being present, however it was still not seen as the ideal.
As this is the Benchmark survey, and changes are currently being made to food labels under the allergen labelling provisions of the Code. Some of these factors may be addressed and therefore, reactions and changes to awareness and opinions would be expected to be seen when the follow-up survey is conducted.
The second factor, understanding, was clearly an issue for consumers who are dealing with food allergies.
While ‘understanding’ is a difficult concept to measure, in this survey it was assessed by respondents’ ability to use food labels to select appropriate foods, including the ability to identify different names for the substance of concern to them. The results of this survey indicated that understanding the information on food labels plays a role in consumers’ ability to use food labels appropriately when selecting foods for allergy sufferers.
Clarity and understanding of food labelling information is not an issue confined to consumers shopping for the sub-population ‘at risk’ of food allergic reactions. The two key issues identified in this survey, clarity and understanding, are similar to the findings of ‘Quantitative research with consumers on food labelling issues’, a survey undertaken with the general population. That survey also indicated that consumers in Australia and New Zealand had difficulties using labelling information effectively to make informed food choices (FSANZ 2003).
10.6 Recommendations
The Quantitative Consumer Survey on Allergen Labelling has found that the utilisation of an allergy support group assisted greatly in improving the consumers' ability to identify the foods that were not suitable, and consequently to avoid foods that might otherwise trigger adverse or allergic reactions. It is probable therefore, that increased education occurs through support group affiliations. Hence, medical / health professionals who treat clients with severe food allergies may find that their clients could derive some additional benefit from joining such groups.
This survey indicated that respondents who were diagnosed or being treated by private clinicians or allergy specialists were significantly less likely to receive formal instructions on how to identify ingredients of concern on food labels. Thus, additional information sources directed at people shopping to avoid certain allergens, could be beneficial. Medical practitioners could be used as the intermediaries for distribution of such educational materials.
It was also apparent that those whose allergy had been diagnosed within the last 12 months had found it easier to get the information they need to help them avoid the foods of concern (see section 5.3). This could indicate that the information that is currently being provided after diagnosis might be more comprehensive or that changes to food labels themselves might already be contributing to increased ease of use. Since this survey was not conducted prior to changes to the Code, it was not possible to ascertain the level of impact that label changes have already had.
It is recommended that as part of future evaluation activity a replicate survey be conducted in two to three years time, using the same methodology. Such a survey would enable FSANZ to track whether the allergen labelling provisions of the Code are meeting the desired objective of providing adequate information in relation to food, to enable consumers to make informed choices. If a survey is not possible, an alternative approach should be considered.
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