The Canadian Food Inspection Agency (CFIA) is requesting public input by August 15, 2017 on the proposed changes they want to make to the Food and Drug Regulations so beer compositional standards can be updated.
One of the considerations with this consultation is to review allergen, gluten, and sulphite labelling on standardized beer. Currently, standardized beer is exempt from this labelling.
Below is our submission to the CFIA for this consultation. Have your say and provide your submission to the CFIA before August 15, 2017, click here to learn more.
July 21, 2017
Director, Consumer Protection and Market Fairness Division
Food Import Export and Consumer Protection Directorate
Canadian Food Inspection Agency
1400 Merivale Road, Tower 2
Ottawa, Ontario K1A 0Y9
Sent via email: firstname.lastname@example.org
Re: Beer Compositional Standards Consultation 2017
Food Allergy Canada is pleased to participate in the beer compositional standards consultation. We are the leading national patient organization which advocates on behalf of the more than 2.5 million Canadians with food allergies.
Food allergy is a growing public health issue and one of the leading causes of anaphylaxis (the most serious type of allergic reaction). Even a small amount of an allergen, if ingested, could cause an allergic reaction and be potentially life-threatening. As such, it is critically important that consumers with food allergies, and those who shop for them, have access to clear allergen labelling so they can make informed, safe decisions when purchasing food and beverages.
Our recommendations on the proposed amendments to the Food and Drug Regulations to update the beer compositional standards are noted below:
- List all applicable priority allergen information if changing the definition of what constitutes standardized beer
If the definition of standardized beer is changed, a provision must be added that requires all priority allergens contained in the beer to be listed in a “Contains” statement on the outside packaging of these products, and on each individual container of beer (e.g. bottle, can, keg, or on-tap container). This is particularly important if the criteria for standardized beer is expanded to include additives and flavouring ingredients, which could include priority allergens.
- Remove the exemption for priority allergen labelling for standardized beer
It is imperative that the product labelling of beer be brought in line with the 2012 Enhanced Allergen Labelling Regulations for alcoholic beverages, which requires manufacturers to declare food allergens or gluten sources either by adding a list of ingredients or using a “Contains” statement on the label.
- Enhance education and consultation
If the standardized beer formula is changed to include allergens it must be accompanied with rigorous education for industry, consumers and for those who sell and serve standardized beer.
Going forward, we ask that patient and medical groups always be consulted, along with industry, on food or beverage issues pertaining to possible allergen concerns. Food Allergy Canada is pleased to work with government, industry, the medical community, and other key stakeholders to develop reasonable policies to accommodate people with food allergies and reduce the risk of serious reactions. Our approach to reducing the risk of allergic reactions is focused on self-management, community engagement, understanding, and respect.
Enhanced Allergen Labelling Regulations
The food allergy community celebrated the 2012 Enhanced Allergen Labelling Regulations which requires priority allergens, gluten sources and added sulphites to be listed in the ingredient list or in a “Contains” statement on the labels of pre-packaged products.
At the time however, the beer industry was singularly afforded a last-minute exemption from these regulations. Food Allergy Canada joined with several other medical and patient advocacy organizations in opposing this exemption. These organizations included: Canadian Society of Allergy and Clinical Immunology, Canadian Allergy, Asthma and Immunology Foundation, Association québécoise des allergies alimentaires, Allergy/Asthma Information Association, Canadian Celiac Association, Fondation québécoise de la maladie coeliaque, and Allergic Living Magazine. According to an Angus Reid Public Opinion poll from 2011, 67% of Canadians believed labelling rules should apply to all food and beverage companies, including the brewery industry.
That exemption continues to be a concern for our community. The current consultation on the beer compositional standards provides an opportunity to rectify this issue and send an important message on food safety to millions of Canadians: people with food allergies have a right to know if there is something that can harm them in the food or beverages they consume.
The recommendations we’ve noted above are consistent with the government’s approach to provide greater transparency and openness to further strengthen Canadians’ trust in the regulatory decision-making process.
If you have any questions please do not hesitate to contact me. We look forward to further opportunities to share the views of the food allergy community on this important safety issue.
Executive Director, Food Allergy Canada