24 Quality Management
IFS Allergen Guidelines
New version easy to understand for practical implementation
Author: Jürgen Schlösser, email@example.com
The problems with allergen management do not stop. Every
year there are still around 300 complaints and recalls in the
European Union due to incorrectly declared allergens.
These include errors in the declaration of allergens on the
label, such as: the allergen name was not clearly stated or the explanatory
terms such as “milk” or “fish” were missing. However, allergens that
were presumably found analytically and that were not declared in the list
of ingredients create the suspicion that an added allergen has been forgotten
on the list of ingredients and leads to the product being recalled.
Often producers are surprised because they did not expect that allergen
and cannot even imagine from which of the used raw materials and
semi-finished products that allergen came from. And if you do not find
the source of entry for that allergen, quickly the correctness of the analysis
is questioned. Spontaneous allergen analysis, even by the authorities,
are still not reliable, as there are no suitable reference samples that could
indicate whether the result found is correct for this food matrix.
For that matter it is not surprising that the IFS is thinking about
having guidelines written by which the allergen management system
can be checked and made safer in order to face the issues its members
are dealing with.
In the IFS Food Standard 6.1 there were only a few chapters in which
an allergen management system was demanded:
• chapter 126.96.36.199.1: in the HACCP analysis, allergens were often classified
as a chemical risk and not as a separate risk;
• chapter 4.18: in the traceability test, allergenic products were preferred
to make the test more difficult;
• chapter 4.20: in a few sub-chapters, an allergen management system
is required to avoid cross-reactions.
With these few requirements, the IFS auditor was able to ask the following
• Have monitoring measures been defined on the basis of a risk analysis
to ensure that cross-contamination of products by allergens is
avoided from goods receipt to delivery?
• Have these monitoring measures been checked and verified for
• Is there an overview clearly showing which allergens are used in
• Are cross-contaminations effectively minimized when allergenic
products are produced?
• Are all allergens in finished goods declared according to legal
• Is there a risk analysis from which it can be deduced plausibly that
possible traces of accidentally or unintentionally appearing allergens
are noted on the packaging of finished goods?
• Are all requirements of the customers met with regard to the absence
of certain substances (e.g. gluten- and lactose-free, absence of pork)?
• Are all customer requirements regarding treatment and production
methods complied with?
At first sight only a few aspects have changed within the IFS Food
• chapter 188.8.131.52.1: the HACCP risk analysis includes the independent
risk "allergens" in addition to the other risks such as "chemical,
• chapter 4.18: allergenic rework should also be included in the traceability
test, as there have often been errors here in the past;
• chapter 4.19: the same short chapter for allergen management as in
version 6.1, to avoid cross-reactions;
• chapter 4: A decision tree for certifiers to assess exclusions within a
production in a better way. The certified company can exempt systems
or entire production lines from IFS certification, as these parts
should not be certified. The certifier can, however, decide to include
these parts of the system in the assessment for allergen management,
as they have an impact o Fig 1: “The Big 8“ from Codex Alimentarius n the systems to be certified.