For individuals and families affected by food intolerance and allergies, nutrition label accuracy is the lifeline that makes the difference between indigestion, frequent bathroom trips and even anaphylactic shock. The Food Allergen Labeling and Consumer Protection ACT (FALCPA) requires that food manufacturers clearly label the eight major food allergens: milk (from cows), eggs (from chickens), fish, crustacean shellfish, tree nuts, peanuts, wheat & soybean. However, those struggling with allergies or intolerances apart from those major allergens have to diligently read between the lines on food labels, become aware of the multiple ingredients that contain that allergen (for example those with corn allergies also need to steer clear of corn by-products such as dextrins, maltodextrins, dextrose & fructose). Vague ingredient listings like “natural flavorings” can contain anything derived from a plant or animal including a variety of chemical additives, such as preservatives, and can be the culprit of many food reactions. The recent change in food labeling requirements makes choosing safe foods even more difficult. The FDA recently issued a “Temporary Policy Regarding Certain Food Labeling Requirements During the COVID-19 Public Health Emergency: Minor Formulation Changes and Vending Machines.” The policy guideline adjustment allows for food manufacturers to make ingredient substitutions during the COVID-19 Pandemic without reprinting accurate food labels if the substituted ingredient: 

• Does not cause any adverse health  effects or include any of the 8 major food allergens.
• Represents two percent or less of the weight of the finished food product.
• Is not a major ingredient in the product
• Is not a characterizing ingredient in the product’s name.
• Does not dis-credit any statement or claims about the product on the label.
• Does not have a significant impact on the finished product.

With the COVID-19 pandemic, it is understandable that food supply issues could become an obstacle to maintaining existing food product formulas. However, making changes to the ingredient list without also updating the nutrition labels can have a disastrous and even life threatening impact on individuals struggling with food allergies, in particular those apart from the major eight recognized in the FALCPA. When selecting foods with a food allergy in mind during the COVID-19 Panedmic, simpler products with fewer ingredients are a safer choice until the standard nutrition label policies are back in place.

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