‘What do you mean, there is no accreditation authority?’ demanded the South African voice on the end of the phone. ‘How can you have a marque without an accreditation authority?’
‘But ‘freefrom’ is not a marque,’ I said.
‘Not a marque?’ incredulously…. ‘But it must be – it is so widely used. Someone must oversee it.’
‘Well, no’, I said, ‘that’s the weird thing about ‘freefrom’, really. There is no such thing as ‘freefrom’ – or certainly there is nothing that can be defined as ‘freefrom’. Even though everyone talks about ‘freefrom food’, every supermarket has a ‘freefrom’ range, market research companies such as Mintel publish reams of statistics about the growth of the ‘freefrom’ market and we run both the FreeFrom Food Awards and the Freefrom Skincare awards, there is no legal or dictionary definition of freefrom.’
And indeed, this is, confusingly, the case. It turned out that my caller was keen to start marketing ‘freefrom’ food in South Africa and was anxious not to get herself into hot water with the ‘freefrom’ authorities – but found it hard to believe that no such authorities exist. And she is not alone.
Although no such survey has, to my knowledge, been done, I suspect that virtually everyone who buys food labelled as ‘freefrom’ makes the assumption that to be able to call itself ‘freefrom’ the food must be ‘free from’ – but, freefrom what? Since most shoppers are, understandably, only concerned with their own dietary restriction they will assume that it means freefrom their own problem food (gluten, if coeliac, dairy, if dairy allergic etc). But in reality, the term ‘freefrom’ on a pre-packed food means no more than the term ‘natural’ or ‘wholesome’ – it has no meaning in law and is governed by no regulations – it is, in fact, a bit of marketing hype.
In one of our discussions about criteria for the ‘FreeFrom’ Food Awards I said this to Cressida, our extremely efficient awards co-ordinator who has ‘lived’ the FreeFrom Food awards for the last three years. She was horrified…
‘We are running large scale awards for ‘freefrom’ food and I make our entrants jump through endless hoops to declare every allergen or possible source of contamination in their foods and now you are telling me that ‘freefrom’ doesn’t exist! That’s completely ridiculous – what on earth are we doing then? It’s like you’re telling me, for the first time, that Father Christmas doesn’t exist – it makes the whole thing pointless!’
In once sense she is right – but the fact that the term ‘freefrom’ itself is meaningless, does not mean that there are no regulations governing allergies and the declaration of allergies in food on sale to the public in shops and, from 2014 onwards, in restaurants, pubs and other catered outlets.
• Since the last EU Directive in 2007 any of the fourteen major allergens that are used in a food must be listed in the ingredients list (see the FSA site for details) and must be listed in such a way that they are easy to read and understand.
• Since January 2012 foods can only claim to be ‘gluten free’ if they contain less than 20ppm (parts per million) of gluten and ‘low gluten’ if they contain less than 100ppm of gluten.
• If a food pack carries a flash claiming to be free of any specific allergen (‘dairy free’, ‘egg free’ etc), then the manufacturer is liable under the general food safety regulations if it proves not to be free of that ingredient.
• From 2014 onwards any catered outlet will be obliged to provide information about allergens in their foods to all customers, although, as of now the proposal is that they should only have to tell the customer about the allergen rather than providing written information. (For more on this see my blog of November 8th.)
So what does ‘freefrom’ actually mean to those of use who work in it?
Well, for those who work in food (for ‘freefrom’ does not just cover food) it flags up the fact that the food is ‘free’ of something that you do not want to eat. Normally it is taken to refer to allergens, and mainly to gluten and dairy, but it is also used with reference to other ‘undesirable’ ingredients such as additives. So supermarkets call their ranges ‘freefrom’ to indicate that they will be free of at least one of these ingredients (usually gluten) but maybe two or three – and having ‘branded’ the item as ‘freefrom’ they will then flag it up as being specifically dairy free, or gluten free, or egg free.
In the wider context, ‘freefrom’ is normally taken to suggest that the product is free from the kind of ingredients that those who suffer from sensitivities or who are concerned about both human and environmental health might wish to avoid. So our FreeFrom Skincare Awards are only open to products which exclude chemicals such as parabens and SLS that research suggests can have serious effects on human health and the environment. Should we in due course move on to FreeFrom Housecare awards, the criteria would be the same. Such is the success of the concept of ‘freefrom’ in our ‘worried world’ that some are trying to push it further – ‘freefrom’ meat for vegetarian food is just one example, although these do not really seem to be gaining much traction.
Back in the food world though, although ‘freefrom’ has no legal meaning, it is a very powerful concept – around £350 million a year’s worth of powerful in the UK alone, and growing fast, according to Mintel’s latest report. So, even if you cannot define it – don’t underestimate it. ‘Freefrom’ is a significant force in the market place – and it is here to stay.
Sometimes a concept is more powerful than a legal definition. As soon as definitions are introduced people will find ways of circumventing them.