*3.1. Main Allergen Hazard*

According to the data, during the period studied, the main allergens about which notified were emitted were milk and products thereof, followed by cereals containing gluten and products thereof, sulfur dioxide and sulfites, and nuts (Figure 2), two of them (milk and nuts) being allergies with a higher prevalence in the pediatric population.

Apart from milk and its derivatives and nuts, other potential risk allergens in the pediatric population due to their high allergy prevalence, such as gluten, soy, eggs, or peanuts, were also involved in 36.4% of the notifications. On the other hand, it was found that the allergens that were the least frequently mentioned in the notifications were fish and seafood (crustaceans and mollusks), representing 1.5% and 1.9% of the notifications, respectively.

**Figure 1.** Percentage of actions taken as responses to notifications received between 1 January 2018 **Figure 1.** Percentage of actions taken as responses to notifications received between 1 January 2018 and 31 December 2021.

and 31 December 2021.

Apart from milk and its derivatives and nuts, other potential risk allergens in the pediatric population due to their high allergy prevalence, such as gluten, soy, eggs, or peanuts, were also involved in 36.4% of the notifications. On the other hand, it was found that the allergens that were the least frequently mentioned in the notifications were fish and seafood

The evolution of notifications-per-year of the main allergens that affect children and adolescents is shown in Figure 3. Globally, during the period studied, there were observed significant statistical differences between these allergen notifications (Figure 4); however, it should be remarked that, during the period of study, "milk and products thereof" remained the allergen that triggered the most notifications. Regarding differences in each allergen per year, the number of "undeclared milk notifications was significantly higher in 2019 and 2020, *p* < 0.01 and *p* < 0.05, respectively, compared to those of the year 2021, and regarding gluten notifications, the number was significantly higher (*p* < 0.05) in 2019 than in 2021. For

the rest of the allergens, no significant differences were found over the four years.

The evolution of notifications-per-year of the main allergens that affect children and adolescents is shown in Figure 3. Globally, during the period studied, there were observed significant statistical differences between these allergen notifications (Figure 4); however, it should be remarked that, during the period of study, "milk and products thereof" remained the allergen that triggered the most notifications. Regarding differences in each allergen per year, the number of "undeclared milk notifications was significantly higher in 2019 and 2020, *p* < 0.01 and *p* < 0.05, respectively, compared to those of the year 2021, and regarding gluten notifications, the number was significantly higher (*p* < 0.05) in 2019 than in 2021. For the rest of the allergens, no significant differences were found over the four years. *Nutrients* **2022**, *14*, x FOR PEER REVIEW 8 of 22

2018 2019 2020 2021

**Figure 3.** Percentage of total notifications of the main allergens affecting the pediatric population per **Figure 3.** Percentage of total notifications of the main allergens affecting the pediatric population per year.

year. Milk and products thereof (including lactose), Cereals containing gluten and products thereof Nuts Soybeans and products thereof Eggs and products thereof Peanuts and products thereof Fish and products thereof Figure 5 shows specific allergen notifications related to milk and nuts. In the case of milk and products thereof, only 20% of the related notifications specified the concrete compound present (lactose or lactoprotein), while the rest of the notifications only indicated the presence of milk. Conversely, 88% of the nut-related notifications specified the nuts involved; most of the notifications referred to the undeclared presence of almonds and hazelnuts. This information is relevant since a person could be lactose-intolerant but not necessarily allergic to a lactoprotein. If the response to a notification is a public warning (e.g., a press release), the use of the general term "milk" would not provide enough information to consumers.

Crustaceans and products thereof Molluscs and products thereof Nuts In regard to almost all of the allergens that frequently affect the pediatric population, it was detected that the RASFF notifications were mainly due to labeling errors rather than the presence of the allergen or its traces due to possible cross-contamination. Among the labeling errors detected, it was also observed that some products that included information in several languages did not inform about the presence of allergens in one language but did in another.

Milk and products thereof (including lactose),Cereals containing gluten and products thereofSoybeans and products thereof Eggs and products thereof Peanuts and products thereof Fish and products thereof Crustaceans and products thereof Molluscs and products thereof The RASFF system included, in some cases, but not systematically, the quantity of the undeclared allergen in the product. With the available data, regarding milk and products thereof, it could be observed that the amount of undeclared milk (or milk ingredients) ranged between 0.35 mg/kg to 150 g/kg. The presence of lactoprotein in related notifications varied from 0.5 to 2500 mg/kg, and for undeclared lactose, quantities between 0.36 mg/kg and 15.6 g/kg were detected. In the case of undeclared peanuts, amounts between 1.2 mg/kg and 86.3 g/kg were found.

**Figure 4.** Statistical differences among the undeclared, main pediatric allergens in notifications emitted between 1 January 2018 and 31 December 2021. In grey- no significant differences; in yellow- significant differences with *p* < 0.01; in orange - significant differences with *p* < 0.005; and in brown-

significant differences with *p* < 0.001.

year.

Soybeans and products thereof

Eggs and products thereof

Fish and products thereof

Peanuts and products thereof

Crustaceans and products thereof

Molluscs and products thereof

Milk and products thereof (including lactose),

Cereals containing gluten and products thereof

Nuts

**Figure 3.** Percentage of total notifications of the main allergens affecting the pediatric population per

2018 2019 2020 2021

0 5 10 15 20 25

% of total notifications

**Figure 4.** Statistical differences among the undeclared, main pediatric allergens in notifications emitted between 1 January 2018 and 31 December 2021. In grey- no significant differences; in yellow- significant differences with *p* < 0.01; in orange - significant differences with *p* < 0.005; and in brownsignificant differences with *p* < 0.001. **Figure 4.** Statistical differences among the undeclared, main pediatric allergens in notifications emitted between 1 January 2018 and 31 December 2021. In grey- no significant differences; in yellow- significant differences with *p* < 0.01; in orange - significant differences with *p* < 0.005; and in brown-significant differences with *p* < 0.001. nuts. This information is relevant since a person could be lactose-intolerant but not necessarily allergic to a lactoprotein. If the response to a notification is a public warning (e.g., a press release), the use of the general term "milk" would not provide enough information to consumers.

**Figure 5.** Percentage of notifications related to undeclared milk and products thereof as well as nuts that specified the concrete compounds present in food products: (**a**) percentage of notifications that detailed milk-related allergens; (**b**) percentage of notifications that detailed nut-related allergens. **Figure 5.** Percentage of notifications related to undeclared milk and products thereof as well as nuts that specified the concrete compounds present in food products: (**a**) percentage of notifications that detailed milk-related allergens; (**b**) percentage of notifications that detailed nut-related allergens.

In regard to almost all of the allergens that frequently affect the pediatric population, it was detected that the RASFF notifications were mainly due to labeling errors rather than the presence of the allergen or its traces due to possible cross-contamination. Among the labeling errors detected, it was also observed that some products that included information in several languages did not inform about the presence of allergens in one language but did in another. It should also be remarked that, for the undeclared gluten notifications, 23.2% of them were for gluten-free products due specifically to their gluten content being too high. According to EU Commission Implementing Regulation No. 828/2014 of 30 July 2014 on the requirements for the provision of information to consumers on the absence or reduced presence of gluten in food, the statement "gluten-free" may only be made where the food

ranged between 0.35 mg/kg to 150 g/kg. The presence of lactoprotein in related notifications varied from 0.5 to 2500 mg/kg, and for undeclared lactose, quantities between 0.36 mg/kg and 15.6 g/kg were detected. In the case of undeclared peanuts, amounts between 1.2 mg/kg

The RASFF system included, in some cases, but not systematically, the quantity of the

It should also be remarked that, for the undeclared gluten notifications, 23.2% of them were for gluten-free products due specifically to their gluten content being too high. According to EU Commission Implementing Regulation No. 828/2014 of 30 July 2014 on the requirements for the provision of information to consumers on the absence or reduced presence of gluten in food, the statement "gluten-free" may only be made where the food as sold to the final consumer contains no more than 20 mg/kg of gluten [10]. In all of these notifications, the gluten content exceeded that limit, being in some cases close to 1000 mg/kg. This quantity was as high as 1600 mg/kg in other products that were not labeled as

The notification percentage of each food category per year is shown in Figure 6. The results show that the main categories subject to notifications related to undeclared allergens

"gluten-free," but which contained undeclared gluten.

*3.2. Food Categories and Related Allergens*

and 86.3 g/kg were found.

as sold to the final consumer contains no more than 20 mg/kg of gluten [10]. In all of these notifications, the gluten content exceeded that limit, being in some cases close to 1000 mg/kg. This quantity was as high as 1600 mg/kg in other products that were not labeled as "gluten-free," but which contained undeclared gluten. were those of cereals and bakery products (16.3%), prepared dishes and snacks (13.1%), and confectionery (9.0%), followed by others that were classified as mixed products (e.g., frozen

### *3.2. Food Categories and Related Allergens* veggie burgers) (8.5%) and soups, broths, and sauces/condiments (7.7%). In general, those categories that include food products with a higher degree of processing and number of

*Nutrients* **2022**, *14*, x FOR PEER REVIEW 10 of 22

The notification percentage of each food category per year is shown in Figure 6. The results show that the main categories subject to notifications related to undeclared allergens were those of cereals and bakery products (16.3%), prepared dishes and snacks (13.1%), and confectionery (9.0%), followed by others that were classified as mixed products (e.g., frozen veggie burgers) (8.5%) and soups, broths, and sauces/condiments (7.7%). In general, those categories that include food products with a higher degree of processing and number of ingredients proved to be the ones that collected the highest number of notifications. The specific foods included in each category, according to what is stated in the RASFF database, are presented in the Supplementary Material (Table S1). ingredients proved to be the ones that collected the highest number of notifications. The specific foods included in each category, according to what is stated in the RASFF database, are presented in the Supplementary Material (Table S1). Fruits and vegetables ranked sixth among the reported food categories. It should be clarified that the products involved were usually fruits and vegetables with different degrees of handling (sliced, grated, powder, pulp, purée, spread, and dried) or processing (dried, pickled, canned, and preserved), or vegetable mixtures.

**Figure 6.** Percentage of notifications according to food categories per year. **Figure 6.** Percentage of notifications according to food categories per year.

Figure 7 shows the relationship between the main allergens affecting the pediatric pop-

fied foods were the categories which included all common pediatric allergens (milk, nuts,

Fruits and vegetables ranked sixth among the reported food categories. It should be clarified that the products involved were usually fruits and vegetables with different degrees of handling (sliced, grated, powder, pulp, purée, spread, and dried) or processing (dried, pickled, canned, and preserved), or vegetable mixtures. *Nutrients* **2022**, *14*, x FOR PEER REVIEW 11 of 22

> Figure 7 shows the relationship between the main allergens affecting the pediatric population and their presence within each food category. The results revealed that soups, broths, sauces, and condiments, in addition to dietetic foods, food supplements, and fortified foods were the categories which included all common pediatric allergens (milk, nuts, gluten, egg, soy, peanut, fish, and seafood allergens). These categories were followed by prepared dishes and snacks as well as other mixed products which contained all allergens except peanut and seafood allergens, respectively. The types of food products included in the other/mixed products category are shown in Table A1 (Appendix A). gluten, egg, soy, peanut, fish, and seafood allergens). These categories were followed by prepared dishes and snacks as well as other mixed products which contained all allergens except peanut and seafood allergens, respectively. The types of food products included in the other/mixed products category are shown in Table A1 (Appendix A).

Milk Nuts Gluten Egg Soya Peanut Fish Shellfish¬crustaceans

**Figure 7.** Relationship between the main allergens affecting the pediatric population and their presence within each food category. **Figure 7.** Relationship between the main allergens affecting the pediatric population and their presence within each food category.

The presence of undeclared milk was significantly higher (*p* < 0.005) in cereal and bakery products as well as in prepared dishes and snacks. Similar behavior was detected for gluten, with its undeclared presence also being significantly higher (*p* < 0.001 and *p* < 0.05, The presence of undeclared milk was significantly higher (*p* < 0.005) in cereal and bakery products as well as in prepared dishes and snacks. Similar behavior was detected for gluten, with its undeclared presence also being significantly higher (*p* < 0.001 and *p* < 0.05, respectively) in these two food categories compared with the remainder oof the categories.

respectively) in these two food categories compared with the remainder oof the categories. Regarding these two allergens, no significant differences in the number of notifications were

were observed. However, undeclared nuts were found predominantly in the cereal and bakery products category, nuts, nut products, and seeds, as well as cocoa and cocoa preparations. It should be noted that products included in these categories, especially the bakery

observed among any of the other categories.

and cocoa ones, are frequently ingested by infants.

Regarding these two allergens, no significant differences in the number of notifications were observed among any of the other categories.

For the rest of the allergens, no significant statistical differences between the categories were observed. However, undeclared nuts were found predominantly in the cereal and bakery products category, nuts, nut products, and seeds, as well as cocoa and cocoa preparations. It should be noted that products included in these categories, especially the bakery and cocoa ones, are frequently ingested by infants.

For their parts, soy and eggs were mainly present in cereal and bakery products, as well as in prepared dishes and snacks. These results were expected since these foods are widely used as ingredients in both categories due to their technological functionalities, for example, as emulsifiers. Moreover, as both ingredients are widely used, the risk of cross-contamination within the industry is increased.

The presence of undeclared peanuts was higher in nuts, nut products, and seeds, as well as in the confectionary category. This can be easily explained due to crosscontamination because, although peanuts are legumes, their use and consumption are frequently linked with nut products (e.g., roasted, mixed nuts). Fish- and seafood-allergenrelated notifications were mainly caused by dietetic foods and food supplements, but also by prepared dishes and snacks.

It should be noted that the cereal and bakery products category, in addition to being the one that caused the most notifications, warned of the undeclared presence of all of the most frequent allergens in children, except fish and seafood allergens. Most of the notifications in this food category were due to the presence of milk and products thereof, as well as cereals containing gluten.

It is especially noteworthy that 5.9% (*n* = 50) of the notifications were caused by glutenfree products. From them, 78% were due to the presence of gluten, while the remaining 22% were due to other allergens, such as lactose, milk, soy, or nuts, such as hazelnuts. The gluten-free products mainly involved were bars, biscuits, breads, cakes, chips, cookies, crisps, flours, granolas, muffins, pastas, noodles, nuggets, pizza toppings, ice creams, and desserts, among others. It should also be noted that many of them were also organic products. Additionally, other specially designed products for allergic or intolerant patients presented undeclared allergens, as can be observed in Table 3. These results are relevant since, in the case of allergic patients, their ingestion could directly affect their health status.

**Table 3.** Percentage of notifications which included specially designed products (gluten-free, lactosefree, dairy-free, etc.) and undeclared allergens involved in each case between 1 January 2018 and 31 December 2021.


In this context, products especially designed for covering alternative dietary patterns, such as those of vegetarians and vegans, which included statements such as "veggie", "vegetarian", or "vegan", represented 4.4% (*n* = 37) of the total notifications. Of them, 64.9% referred to undeclared allergens of animal origin (56.8% milk and 16.2% egg), while 35.1% were non-animal-related allergens (mustard, nuts, soy, celery, gluten, and peanuts).

Food products specifically intended for babies were also the subject of some notifications. This was the case for infant starter milk with the presence of fish allergens; baby cereal porridge with undeclared milk, lactose, and soya; and undeclared gluten in organic, gluten-free baby food.
