Industry guidance for dark chocolate made on a line shared with milk chocolate, where milk can remain above the VITAL® Program Action Level. It sets out three key guiding principles and a labelling decision tree.
Published: 13 May 2019
Format: PDF, 5 pages
Cost: Free to download
About this guide
When dark chocolate is made after milk chocolate on the same line, milk can remain in the dark chocolate at variable levels, often above the VITAL® Program Action Level where precautionary allergen labelling would be recommended. The milk is not an ingredient, but its presence is predictable and cannot be eliminated or minimised sufficiently, even with good manufacturing practice. This guidance calls it an allergen risk review anomaly.
Where the three key guiding principles apply, the guidance recommends including milk as the last ingredient in the ingredient list of the dark chocolate. It was developed by a working group of the Australian Industry Group (Ai Group) Technical Committee with the Allergen Bureau, in consultation with the Australian Food and Grocery Council (AFGC), and with input from food regulators and consumer allergy organisations.
Who it’s for
- Food manufacturers who make dark chocolate on lines shared with milk chocolate
- Food businesses that label products containing dark chocolate and need to understand the allergen information from their supplier
Important to know
- The labelling approach in this guidance should only be used when an allergen risk review anomaly has been identified and all three key guiding principles apply.
- Declaring milk as the last ingredient is not a substitute for appropriate risk review. Every attempt should still be made to eliminate the allergen effectively.
- It is industry guidance. It is not binding, does not represent legal advice, and is not a substitute for GMP, HACCP or allergen risk review.
What’s inside
| Section | What it covers |
|---|---|
| Introduction and background | What the allergen risk review anomaly is, and how the working group developed the guidance with the Allergen Bureau and the AFGC, and consulted food regulators and allergy organisations. |
| The issue | Why milk remains in dark chocolate made after milk chocolate, why cleaning, flushing or duplicate lines are not practical, and why a precautionary allergen labelling statement may not be enough. |
| Regulatory view and best practice | The advice from the Implementation Sub-Committee for Food Regulation, and the industry best practice resources to use alongside this guidance. |
| Key guiding principles | Three principles and their rationale, with notes on documenting the cross contact impact on the master recipe and supporting the decision with records. |
| Decision tree | A diagram for validating an allergen risk review anomaly, used with GMP, HACCP and the key guiding principles. |
| Summary and further information | The organisations involved, and contact details for further information. |