Food allergies are a drag. One in 10 American adults and one in 13 children have food allergies, according to FARE (Food Allergy Research and Education). The most common food allergies, FARE says, are shellfish, milk and peanuts … but the FDA says more than 160 foods that cause allergic reactions have been identified.
That means food processors trying to create allergen-free food—or at least properly labeling foods that contain allergens—have a big task before them, and it’s getting more complicated.
Until last year, the FDA had called out eight foods as “major” allergens:
- Tree nuts
But with the 2021 passage of the Food Allergy Safety, Treatment, Education and Research (FASTER) Act, sesame has been added to the list; enforcement will begin next year.
“Previously, sesame was included in the definition for spice, and could be declared as ‘spice’ in an ingredient list or within natural flavors,” explains Carol Zweep, consulting and technical service manager for NSF. “The FASTER Act requires that manufacturers use plain-language labeling for sesame, including declaring it by name in the ingredient list, or including it in a ‘Contains’ statement when one is present.”
Creating allergen-free food
Making food that does not contain allergens can be challenging. Dave Anderson, co-founder and executive chef of Outstanding Foods, which makes plant-based “pork” rinds, cheese balls and puffs, says avoiding allergens means thinking about food differently.
“From day one of R&D, we already knew that we did not want to have allergens in the formulation, so we did not have to modify the recipes (to remove allergens),” Anderson says. “That being said, most of our products are patterned after products containing allergens, so we do have to modify the thought process that goes into creating the formulations.”
Outstanding Foods is a plant-based company, which means it completely avoids eggs and dairy products. Their latest product, Outstanding Foods Cheese Balls, uses brown rice protein, a blend of vegetables and mushrooms, a natural seasoning blend and other plant-based ingredients, but no cheese.
Creating products like that is definitely more challenging than relying on the tried-and-true ingredients (that often are allergenic).
“At times allergen-free ingredients absolutely affect the taste and other characteristics of our products,” Anderson says. “The ingredients can create off flavors or compromised textures. It definitely makes it a little more challenging, but we are usually able to make adjustments to the formulation that solve the problem."
Some of those adjustments can mean alternative ingredients. "At times, these ingredients can be more challenging to find than more mainstream ingredients and they definitely tend toward being more expensive.”
Kelly Van Arsdale, co-founder and CEO of Spinnaker Chocolate, says his company avoided milk when making a vegan-friendly version of their milk chocolate bar.
“We use an organic, hydrolyzed, gluten-free oat flour in place of whole milk powder,” Van Arsdale says. “We chose oat powder because it imparts the least amount of flavor while maintaining the same level of creaminess and consistency.
"We did a one-for-one swap with our milk chocolate recipe and it tastes great," he continues. "We might tweak the recipe a little bit in the future, but for the first production run, we are certainly excited about the results.”
Van Arsdale says that even though he’s pleased with the results, there are differences between the vegan version and the bar that includes cow’s milk.
“It’s definitely not the same as eating a milk chocolate bar, but not in a bad way,” he says. “Many of our customers like to buy both our milk chocolate and oat milk chocolate. The flavor is different but still good in its own right. There’s a uniquely nutty and oaty flavor to the bar.”
Creating a plan
Dodging allergens involves more than just skipping the ingredients on the FDA’s major allergens list. Zweep says NSF advises manufacturers to create an allergen control plan as part of their food safety program.
“An allergen control plan is a systematic method for identifying and controlling allergens, from the incoming ingredients to the final packaged product in any food processing plant,” Zweep says. “This plan includes the identification of allergenic foods and ingredients in the product and facility, and procedures for storage, handling, processing, packaging and labeling. An allergen control plan ensures that allergen-free ingredients are sourced as well as avoid cross-contamination.”
Creating allergen-free food involves the whole supply chain, notes Joe O’Neill, vice president of sales and business development for A&B Ingredients. Ingredient suppliers must make sure their processing lines are allergen-free and the warehousing and distribution of ingredients does not result in cross-contamination.
Third-party auditors help assure manufacturers that a supplier meets those requirements, O’Neill says. “We have a robust process in place to make sure the products we deliver, if we say they’re allergen-free, are in fact allergen-free,” he says.
“For example, when you’re talking about pea protein, you can’t guarantee against one stalk of soy growing in a pea field," he notes, "but we have special analytical procedures in place to make sure that any soy in our pea protein falls below the regulatory limits set for soy-free claims. There are very sensitive assays to detect soy in food.”
When a food manufacturer wants to remove an allergen from an existing recipe, they can often tap into a range of alternatives, depending on the allergen. The considerations, however, go beyond taste. Many ingredients affect texture and processing functions as well as taste.
“When companies ask us for help to find alternative ingredients to common allergens, we drill down into the characteristics of the product and find suitable alternatives that can deliver on taste, functionality and processing,” O’Neill says.
For example, a manufacturer that wants to remove fish from an ingredient could select a plant-based protein that mimics the characteristics of fish. A&B offers potato starches that can withstand high temperatures and bind water to provide the textural qualities of seafood while being allergen-free. Or a food processor that wants to remove dairy could try a soluble pea protein.
“It’s about the engineering, selecting the right ingredients and understanding the functionality that comes with food processing,” he says. “Depending on the angle the manufacturer takes, there are usually multiple solutions.”
Meet the newest member of the allergen club
Sesame is not exactly a new allergen. According to FARE, research shows that about 700,000 Americans are allergic to sesame. But as of last year it has the distinction of joining the FDA’s list of major allergens, which, as Zweep noted, means it must be labeled properly. The updated labeling requirements apply to any food sold or distributed in interstate commerce on or after Jan. 1, 2023.
The inclusion of sesame on the FDA’s list also means that manufacturers who use sesame must meet more stringent regulations in the plant.
“As sesame will be a major allergen, food manufacturers that use sesame or sesame ingredients, such as sesame oil, will be subject to the cross-contamination regulations under the Food Safety Modernization Act,” Zweep explains. “Manufacturing facilities must implement preventive controls to minimize the risk of allergen cross-contamination during manufacturing, processing or packing.”
Of course, some manufacturers that now use sesame may decide to skip the hassle and simply remove sesame from their products. Sometimes sesame is an obvious ingredient – on the top of sesame seed buns, for example. But often it’s a hidden ingredient that imparts a certain nutty, umami-type flavor. Replacing that flavor requires some research.
“Sesame is often added to sauces, and you’ll see sesame oil as an ingredient to add flavor to dips and marinades,” O’Neill says. “We do have some options to replace sesame, depending on the application.
"If the processor is looking for flavor enhancement, we sell a product called Mediterranean Umami that can be added to savory food that enhances craveability. It’s not a direct match in terms of flavor, but if the goal is to accentuate certain notes, it can do that.”
Avoiding allergens is a worthwhile goal for many food processors, because it increases the number of potential customers. And with enough research, processors should succeed in dodging those problematic ingredients.
“With food allergies on the rise and more people being affected by them, food manufacturers are increasingly creating allergen-free products,” Zweep says.