Directive 2003/89 of the Executive Committee of the European
Parliament and Council has just been published on November 25th,
2003 (J.O. of the European Union L 308/15). It modifies the Directive
2000/13/CE concerning the indication of components making up
The slatei who are Members have till November 25th, 2004, to adopt the
required measures in order to be able to sell products in accordance
to the Directive from November 25th, 2004, onward.
The preamble stipulates the necessity for patients suffering from food
allergy to find a thorougher information » through labelling.
It hints at the most common allergens, but it does not characterize some
allergens as dangerous.
Consequently, sesame is not mentioned in this introduction, although
we find it in the list of allergenes requiring declaration if they are
contained in solid food or in drinks.
directed at in article 6, paragraph 3 bis, 10 and 11
containing gluten (mamely wheat, rye, barley, spelt, kamut
or their hybridized stocks) or the basic products of theses
and products containing seafood.
- Eggs and
products containing egg.
- Fish and
products containing fish.
and products containing groundnuts.
- Soya and
products containing soya.
- Milk and
products containing milk (included lactose).
mamely almonds (amygdalus communuis L.), hazelnuts
(Corylus avellana), nuts (Juglans regia),
cashew nuts (Anacardium occidentale), Pecan nuts (Carya
illinoiesis (Wangenh. K. Koch), Brazil nuts (Bertholletia
excelsa), pistachio-nuts (Pistacia vera), Macadamia
nuts and Queensland nuts (Macadamia ternifolia) and
products containing these nuts.
and produces containing celeriac.
and products containing mustard.
seeds and products containing sesame seeds.
dioxide and sulphites in concentration exceeding 10 mg/kg of… it
is quite sure that this list will be systematically reconsidered
and kept up to date according to most recent knowledge.
The first reconsideration will take place before November 25th, 2005.
are given in detail : if the ingredient is included in a proportion
lower than 2%, the list of the components are not part of the
list of allergens or if they belong to the categories of spices
and aromatic plants or “if the making-up is defined within
the context of a current community regulation” (? …)
The implementation of this Directive will be a progress for the patients
presenting identified food allergies. Allergists are quite aware that
this Directive ratifies the already existing knowledge, but it will be
of no help in the detection of new kinds of allergy. As in post times,
they will have to achieve realistic prick-tests with suspicious food,
from manufacturers get the whole making-up of their products, and find
out sensitization to all the components. Indeed, we must keep on hoping
that manufacturers will accept partnership and will not perversely misinterpret
the Directive, by neglecting to give information on the nature of those
ingredients that do not require it according to this Directive.