Resources for food manufacturers

Priority allergens were added to the Canada Food and Drug Regulations in 1999, under the Food and Drugs Act. Canadian authorities require identification of priority allergens, added sulphites and gluten sources on labels of prepacked food products sold in Canada - Canada Food and Drug Regulations (Section B.01.001).

The priority food allergens in Canada are:

• Crustaceans and molluscs
• Eggs
• Fish
• Milk
• Mustard
• Peanuts
• Sesame
• Soy
• Sulphites (food additive)
• Tree Nuts (almonds, Brazil nuts, cashews, hazelnuts, macadamia nuts, pecans, pine nuts, pistachio nuts and walnuts)
• Wheat and triticale

The gluten sources are:

• Barley
• Oats
• Rye
• Triticale
• Wheat

The requirement for priority food allergens and gluten declarations apply to all generations of ingredients (i.e. ingredients of ingredients or subcomponents) (Canadian Food Inspection Agency, 2021).

Ingredients that are derived from a food allergen, but which have been processed in a way that removes the protein are not themselves considered to be food allergens (Health Canada, 2013).  

PAL is used to indicate the potential presence of unintentional allergens that are not part of the product’s recipe. In Canada, PAL is not mandated but may be used by food manufacturers on a voluntary basis (Canadian Food Inspection Agency, 2019).

Health Canada recommends that only one statement – “May contain” – be used on  pre-packaged food products. Guidance on labelling requirements and manner of declaration has been developed by CFIA.

PAL statements are to be used only when — after implementing all reasonable measures to limit or eliminate sources of unintentional allergen presence — the allergen may still be found in the final product in an amount representing risk to the allergic consumer. PAL statements, if used, are required by Health Canada to be truthful, clear and non-ambiguous, and are not a substitute for Good Manufacturing Practices.

Also, the Food and Drugs Act and the Safe Food for Canadians Act prohibit labelling food in a manner that is misleading or deceptive; this prohibition applies to all food labels, including voluntary label elements, and the use of PAL can be questioned by the CFIA (Canadian Food Inspection Agency, 2019).