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13 Aug 2020

Econ Digest

New CODEX standards for allergen management throughout the food production chain

At the recent 43rd Session of Codex Alimentarius Commission meeting, the issue of improving food safety management in the food production chain were discussed, for which operators including upstream producers, processing plants, retail stores and restaurants must prepare, as CODEX is preparing to announce new standards in the “Code of Practice for Food Allergen Management of Food Business Operators”. The new standards, which have been proposed for development since 2017, will likely come into force around the end of 2020. CODEX lists a total of eight categories of foods containing allergens: gluten-containing cereals, milk and dairy products, tree nuts, peanut, soybean, shelled animal products (e.g., shrimp, crab) and sulfur at concentrations greater than 10 mg./kg.


The new standards differ from the requirements of the GMP/HACCP system, which defines physical, chemical and microbiological hazards, while the new CODEX standards have added allergens and specified the methods for allergen control, such as being aware of the existence of allergens in all activities, specifying methods for cleaning machines and tools, and staff training, as well as considering the legal requirements of each country and the groups allergic to each allergen. These make the management of allergens arising from food production more efficient and cover the entire food production chain.


In practice, the CODEX standards are international criteria that all countries will adopt. Even though it is not a legal requirement, in the event of an international trade dispute, the CODEX standards will be referred to as the basis for dispute resolution, meaning that operators in the food production chain must meet the standards as they are essential.


              Food safety is a global concern, while the World Allergy Organization assesses that the population of people with food allergies is likely to be at least 240 million people, and allergen contamination of food is also one of the most common food recall problems. Based on 2019 food product recall statistics for each country [1] (including the US, UK, Canada, Australia, New Zealand and others), the most common cause for recalling food products is hazards from mislabeling (accounting for approximately 49% of the total products), mainly due to un-indicated allergens. The top three most recalled products are ready-to-eat meals, frozen meals, and milk and dairy products. For Thailand, six kinds or products have been recalled, one of which is allergens in processed food products. The business impacts resulting from the recalls is that the products may be subject to legal proceedings by the consumer protection law of the importing country, such as through removing products from the market, investigating the cause of the error, destruction or returning it to the country of origin, etc., which will cause losses for businesses.


Therefore, exporters of instant foods, processed foods and ready-to-eat meals must prepare for this issue, because the Thai export market will adopt stricter measures on controlling allergen contamination, along with Japan, the US and EU, as well as China, which is currently less stringent but is moving toward being more stringent. However, since Thai food exporters already comply with GMP and HACCP standards, KResearch sees that initially, the CODEX standards will cause operators to bear higher overhead costs in food production and may affect net profits or gross margins in the short term, as the operators may need to separate production lines, design or develop new production procedures, train employees, and take care of tools, machines, packaging, transportation, etc., to avoid allergen contamination in the entire production chain. Nevertheless, taken as a whole, this factor alone is not likely to affect the outlook of Thai food exports to the world market (KReasearch expects Thai food exports to the world market to be worth around USD25,820-27,180 million in 2020, a contraction of -5.0% to 0.0%).


Domestic consumers will also be taken care of, reflected in the fact that food products imported must comply with these new standards for sale in the country, because they are regulated and supervised by the relevant government authorities, in particular the National Bureau of Agricultural Commodity and Food Standards (ACFS) which will set the standards for agricultural products and food imported from abroad to comply with international standards such as GMP, HACCP, and CODEX. Currently, Thailand’s annual food imports are worth approximately USD11 billion per year.

[1] Bureau of Food Safety Extension and Support, Office of the Permanent Secretary for Ministry of Public Health

Source: National Bureau of Agricultural Commodity and Food Standards, Fish Inspection and Quality Control Division, Department of Fisheries, Bureau of Foreign Agricultural Affairs in Canberra, compiled by KResearch

Remarks: Japan recommends 20 additional foods that should be listed as additional allergens: 1. Beef 2. Gelatin 3. Pork 4. Chicken 5. Banana 6. Kiwi 7. Walnut 8. Soybean 9. Peach 10. Orange 11. Yamatoimo (yams) 12. Apple 13. Masutake 14. Awabi or abalone 15. Squid 16. Ikura 17. Salmon 18. Mackerel 19. Sesame 20. Cashew nut

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