Comments to European Food Safety Authority on Food Allergens

The European Food Safety Authority’s (EFSA) proposed guidance document on food allergenicity follows up on previous guidance documents aimed at mitigating potential risks from food allergies. In this case the focus is on important food sensitivities that are not, strictly speaking, allergenic, known as non-IgE-mediated immune adverse reactions. But the draft departs from previous guidance documents in failing to provide practical information useful to regulators. Instead it suggests burdensome analyses to produce information regulators cannot use to improve food safety beyond the level that comes from much simpler and less costly approaches currently available and widely used.