May Contain

[jlm3pc]

Occasionally, you come across items with no off-plan ingredients in the label, but then you see the "May contain less than 2% of: soy, milk, etc."

That label essentially means that the food you're eating was processed in a factory that processes other foods with those ingredients, so it's possible that your plantain chips were on a conveyor belt with some other product that had soy in it. The purpose of this "may contain" statement is to warn people who are deathly allergic to soy or dairy or whatever that it's possible that the food came in contact with those ingredients.

My question is: for the purpose of the whole 30, are these foods okay since the soy or dairy isn't actually in the food, it just might have touched the food (and even if it did, it's less than 2%)?

[jmcbn]

9 hours ago, jlm3pc said:

are these foods okay since the soy or dairy isn't actually in the food,

Yes, these foods are okay as the ingredients list always rules - however, NO COMMERCIALY PREPARED CHIPS OF ANY KIND are okay as of 1st April 2017 - seeing as how you used the plantain chips as the example in your post

[slc_melissa]

I think you may be combining two types of labeling that I have seen.

The processed on the same equipment as *ingredients* or made in the same facility as *ingredients* for allergy reasons statement 

is VERY different than the 

Contains 2% or less of *ingredients*.  (I've seen this a lot on, say, processed deli meat.)  This one means those ingredients are absolutely in that product, just in small amounts.

 

From the FDA (CFR Title 21, Sec. 101.4):

2) The descending order of predominance requirements of paragraph (a)(1) of this section do not apply to ingredients present in amounts of 2 percent or less by weight when a listing of these ingredients is placed at the end of the ingredient statement following an appropriate quantifying statement, e.g., "Contains _ percent or less of ___" or "Less than _ percent of ___." The blank percentage within the quantifying statement shall be filled in with a threshold level of 2 percent, or, if desired, 1.5 percent, 1.0 percent, or 0.5 percent, as appropriate. No ingredient to which the quantifying phrase applies may be present in an amount greater than the stated threshold.

 

Whole30 is no sugar, soy, grains, etc, not "just a small amount of them."

 

 

[SugarcubeOD]

Sorry, that's actually not quite correct... We're mixing up two labeling requirements here.

1. This product was made in a facility that also makes XYZ - these products are fine as long as there is nothing in the ingredients.

2. May contain less than 2% or Contains less than 2% is a loop hole where food manufacturers do not have to list the items IN the ingredient list, but the product still contains those items.  If the 'less than 2%' items are non compliant, then the product is not compliant.

[SugarcubeOD]

2 minutes ago, slc_melissa said:

I think you may be combining two types of labeling that I have seen.

The processed on the same equipment as *ingredients* or made in the same facility as *ingredients* for allergy reasons statement 

is VERY different than the 

Contains 2% or less of *ingredients*.  (I've seen this a lot on, say, processed deli meat.)  This one means those ingredients are absolutely in that product, just in small amounts.

 

From the FDA (CFR Title 21, Sec. 101.4):

2) The descending order of predominance requirements of paragraph (a)(1) of this section do not apply to ingredients present in amounts of 2 percent or less by weight when a listing of these ingredients is placed at the end of the ingredient statement following an appropriate quantifying statement, e.g., "Contains _ percent or less of ___" or "Less than _ percent of ___." The blank percentage within the quantifying statement shall be filled in with a threshold level of 2 percent, or, if desired, 1.5 percent, 1.0 percent, or 0.5 percent, as appropriate. No ingredient to which the quantifying phrase applies may be present in an amount greater than the stated threshold.

 

Whole30 is no sugar, soy, grains, etc, not "just a small amount of them."

 

 

Hahah... jinx!

[jmcbn]

Well spotted - my bad!! I believe the EU Foods Standards Agency encouraged a move away from this kind of labelling a few years back in a bid for complete transparency...!

[jlm3pc]

Just to clarify...the part I'm curious about is the fact that it says may contain. The "may" is the part that is crucial to this. Not the "less than 2%". If a product says "May contain soy." That doesn't mean soy is actually in the ingredients, correct? That's just for people who have serious allergies to know that it was processed in a factory that might also process products with soy in it. The FDA says:

 

Advisory labeling includes statements such as ``may contain 

peanuts'' or ``made on shared equipment'' on food packaging labels. 

FDA's current position is that advisory labeling should not be used in 

lieu of adherence to good manufacturing practices (GMPs) because 

adhering to GMPs is essential for effective reduction of adverse 

reactions. Food that contains an allergen due to cross-contact or other 

contamination may be considered adulterated under section 402(a)(4) of 

the act (21 U.S.C. 342(a)(4)) because it has been prepared, packed, or 

held under insanitary



[[Page 38593]]



conditions that may render the food injurious to health. Thus, FDA 

believes advisory labeling should not be the norm, and manufacturers 

should strive to eliminate the presence of allergenic materials that 

are not intentionally added to a specific food product.

    However, FDA recognizes that advisory labeling is an attempt by 

manufacturers to inform consumers of the possibility that cross-contact 

may have occurred such that the product contains an allergenic 

substance. FDA is considering whether, and if so, under what 

circumstances advisory labeling should be permitted when appropriate 

manufacturing controls are not sufficient to guarantee the absence of 

allergenic substances in a particular food product. If permitted, clear 

criteria will be needed to guide the use of such statements. 

Additionally, FDA is assessing whether advisory labeling is useful to 

consumers, how consumers interpret advisory labeling statements, and 

what wording would be most understandable. To help the agency better 

understand if there is a need for advisory labeling, when it would be 

appropriate, how such statements would be used by consumers, and what 

wording would be most helpful to the consumer, the agency asks the 

following questions:

    1. Under what circumstances, if any, should advisory labeling 

statements (e.g., ``May contain [name of allergen]'') be permitted, and 

what impact would those circumstances have on manufacturers and on 

consumers? Should the recommendations in the petition from the 

attorneys general of nine States be adopted? Do the criteria from the 

Food Allergy Issues Alliance form a reasonable basis for determining 

when a manufacturer may use advisory labeling on a particular product 

or should other criteria be used? Why?

    2. Are there better alternatives for advisory labeling than the 

type of wording that currently exists (e.g., ``May contain [name of 

specific allergen],'' ``Made on shared equipment,'' ``Manufactured in a 

facility that also processes [name of specific allergen]'')? Do such 

statements adequately inform consumers of possible cross-contact with 

allergenic materials? How do consumers interpret the wording of such 

labeling? Should advisory labeling statements be prescriptive (i.e., 

one or more specific statements) or flexible?

    3. Where should advisory labeling statements be located on the food 

label? How prominent should advisory labeling statements be on the 

label? Should the location and prominence of advisory labeling 

statements be prescribed?

 

[laura_juggles]

May contain something non-compliant? Why risk it? Just get a different product. 

[SugarcubeOD]

It's not really on the moderators and members here to pick apart the legalese of the FDA labeling requirements.  As far as I'm concerned, it's probably a loophole that means that they put the ingredient in, but maybe the mixture you're getting in your almond butter won't have any...but it probably does.  Skip it to be safe.

[MeadowLily]

When in doubt, leave it out.

[slc_melissa]

(Disclaimer - I didn't read the entire FDA thing you copied out), but In the context of the less than 2% statement:

I've also seen it written as it may contain less than 2% of the following: Safflower Oil OR sunflower oil, etc.

This seems to indicate that different production facilities/different production days may use different recipes depending on factors.  So, at least one if not all of those ingredients are definitely in there.

(Also - I'm in the U.S., and I'm not at all familiar with non-U.S. labeling quirks.) 

[Carol]

I wouldn't cook a dish for a vegetarian friend that "may contain meat".  


 

[laura_juggles]

4 minutes ago, Carol said:

I wouldn't cook a dish for a vegetarian friend that "may contain meat".  


 

^^This exactly. My friend's daughter is ridiculously allergic to all legumes and nuts. When we were first figuring out reading labels for her, we quickly discovered that "may contain" means there's probably a bit of that ingredient in there and to avoid it. "Processed on the same equipment as soy/nuts/etc" is touchier and we tend to avoid those too. "Processed in the same facility as" gives a bit more leeway and she tends to be okay with those products.