ALLERGEN
According to FDA policy, food packaging must disclose the presence of the following eight common allergens: milk, egg, fish, shellfish, tree nuts, wheat, peanuts, and soybeans. The EU FIC guidelines require the mandatory listing of 14 allergens. Moreover, these allergens must be listed directly in the ingredients section, rather than in a separate box.
The EU also has new rules for allergenic ingredient disclosures outside of traditional retail food labels; restaurants, for example, must list all allergens in a specific place, such as the ingredient list. Establishments serving food in America are still not required by law to list allergens and other ingredients, but this could change as health-conscious restaurants and chains are already changing the trends.
LABELING
FDA food labeling requirements have only changed twice since the early 1990s, once in 2006 and again in 2014. Conversely, European food labeling rules were not strictly fixed until relatively recently. The most recent provision outlines “minimum font size for mandatory information, a standard presentation of allergens and required nutritional information.”
Overall, US and EU policy for food labels are rather similar. The major differences involve the labeling of additives and GMOs. The FDA mandates that additives are listed by their common name, rather than with a European e-number; if a product label contains an e-number, it will not be allowed into the country. When it comes to GMOs, on the other hand, European regulations are quite strict, while the FDA does not even require a label to indicate their presence.
