Under the heading 'Allergen listing', the DEFRA guidance says it will not be necessary to show the word 'milk' after well-known dairy products such as cheese, butter, cream and yogurt, even when these are listed as ingredients in composite foods. However, the BRC guidance stipulates that the word milk 'will' be included after dairy ingredients in the list.
Take an example of an ingredients list on a four-cheese sauce that contains four cheeses, double cream and butter. If the word 'milk' in brackets was inserted after each of these ingredients it would appear at least six times.
In the example of a dried four- cheese sauce mix that also contains lactose and whey powder, and where the quantitative ingredient declaration percentages in brackets also appear, the result would be an extremely cluttered and confusing list, particularly with the inordinate number of brackets involved.
Because most consumers, particularly those who are allergic to milk, know that cheese should be avoided, they need go no further than the name of the food for the information they need. The BRC guidance is more flexible when it comes to labelling cheese, etc, in saying milk 'may', rather than 'will', be included on the label, but as soon as you add herbs or fruit, the word 'milk' will appear. Thus, plain Wensleydale may have no 'milk' but Wensleydale with cranberries will.
Then there is the question of voluntary product withdrawals by retailers, which might increase due to more cases where the label omits an allergen name against one of the ingredients even though the same allergen may appear after the names of other ingredients.
Take a fruit cake that may contain dried fruits containing sulphites each of which, according to the BRC, would need to show the word 'sulphites' after it. If one was omitted, would a product withdrawal be necessary? Probably not, but these days there seems to be an inverse relationship between the precautionary principle and common sense. After all, there may be one naughty child in a million who might tear apart a fruit cake, and eat nothing but the cherries.