P-06-1531 Mandate Comprehensive and Specific Food Labelling to Support Dietary Needs and Allergies – Correspondence from the Petitioner to the Committee, 09 December 2025
Dear all,
Thank you for the opportunity to comment on the Food Standards
Agency’s response.
1. My thoughts on the attached document
I appreciate the FSA outlining the current position regarding the
14 mandated allergens and their ongoing discussions with clinical
and allergy organisations. However, the response does not fully
acknowledge the seriousness of the issue for individuals who live
with allergies outside of the prescribed list.
For families like mine, the uncertainty surrounding food
labelling—especially when ingredients such as
“starch” are listed without specifying their
source—creates daily risk. Food is not something people can
opt out of, and clear information is essential for safety, not
convenience.
While the FSA notes that businesses can voluntarily provide more
detailed labelling, relying on voluntary measures leaves vulnerable
people unprotected. There is an implication that only the major 14
allergens justify robust protection, which leads to a difficult but
important question: If someone does not have a ‘common’
allergen, is their life less important? The current system
unintentionally creates a two-tier approach to allergy
safety.
2. Does the response adequately address the issues I raised?
Respectfully, no.
The core concern I raised was the lack of mandatory clarity around
ingredients that can be derived from multiple sources, such as
starch, oils, or thickeners. The FSA response confirms that no
changes to food labelling law are currently planned in this area.
This means uncertainty remains for people with less common or
emerging allergens—yet their reactions can be just as severe
and life-threatening as those to the major 14.
The FSA notes ongoing research on “emerging” allergens,
but no timeline, no interim measures, and no commitment to
improving source-specific labelling. This does not alleviate the
real-world risk or the everyday anxiety caused by ambiguous
ingredient lists.
3. Further questions or points I would like the Committee to
consider
• What steps can be taken now, before long-term research is
complete, to ensure greater transparency in ingredient
sourcing?
• Could mandatory source labelling be introduced for
categories like starches, vegetable oils, or thickeners, where
multiple potential allergens may be hidden?
• What mechanisms exist for incorporating lived
experience—such as families managing complex or non-listed
allergies—into the decision-making process?
• Is there a plan to review the system regularly so that
people with less common allergies are not left waiting indefinitely
for protection.
4. Additional information for
the Committee
This issue is about safety, dignity, and the ability to live
without fear. Every individual with an allergy deserves to know
whether the food they buy is safe for them. At present, many people
are forced to avoid a huge range of foods simply because labelling
is too vague to confirm whether hidden ingredients may harm
them.
I ask the Committee to consider the human impact: parents afraid to
feed their children foods that appear harmless; individuals whose
allergens fall outside the “main 14” feeling
overlooked; and the ongoing mental and financial burden of
navigating unclear labelling.
Clear, specific labelling is not an unreasonable
request—it’s a basic safety need.
Kind regards,
Jessica