Álláspont a „Guidelines relating to the provision of information on substances or products causing allergies or intolerances as listed in Annex II of Regulation (EU) No 1169/2011 on the provision of food information to consumers” elnevezésű útmutató tervezethez
According to point III.1. a) of the Guideline,
„Nevertheless, in some cases, the specific names of foods or names of ingredients in the list of ingredients could be as comprehensible for the consumer as the generic ones provided in the Annex II. This is in particular true for substances listed under the name referring to a category of foods, as for example fish or molluscs. As the objective of the provision of Article 21(1)(a) is to enable the consumer to identify the food ingredients which are likely to trigger the allergic reactions, incases as mentioned above,providing the names other than those listed in the Annex could be allowed.
For example: “cod” instead of fish; “oyster”, “mussels” instead of molluscs.
Other possible examples:
-Milk: butter, cheese
As the consumer understanding of the name of the foods in question is likely to vary among the Member States, an assessment on a case-by-case basis is necessary. Given the important risk associated with food allergies, if there is any doubt about the understanding of the consumer and the possibility of cross reaction between species, the generic names listed in Annex II should be provided and emphasized.”
In our opinion, it is necessary to delete the cited provisions. Enabling the use of different phrases than those in Annex II listed leads to confusion with particular regard to the legal compliance of the food businesses.