Lilla Bee "nut-free" label disclaimer

I had a very annoying food allergy experience today, and I just need to vent somewhere where people will understand. I've been researching nut-free baking mixes that I could buy in a local store (Denver area) without having to order online, and I came across the brand Lillabee. They advertise themselves as "nut free"...it says "nut free" boldly on the label, on their website, etc. So, although I diligently check labels, I purchased a Lillabee baking mix on a grocery run without reading the ingredients.

As I was unpacking my groceries, I gave the box another look. And there it was. Under the ingredient label in small, unbolded print, was a disclaimer:

"Very strict manufacturing processes are followed to maintain the purity of the ingredients in a facility that also processes wheat, dairy, and nuts."

WHATTT???!!!!!

I do appreciate the use of "strict manufacturing processes", and I understand that this is probably still a safe product. However, shared facilities are generally not within my comfort zone, nor are they in many others' comfort zones. I find it highly irresponsible to advertise your products explicitly as "nut-free" when there is still a chance of cross-contamination. I sent the company the following e-mail hoping for clarification. I'll update this post when I have a response.

To whom it may concern:

I recently purchased one of your products based on the "nut-free" guarantee printed boldly on the front label. I suffer from a life-threatening allergy to tree nuts, and while I diligently read labels, I neglected to read your ingredient list until I got home because I was just so excited to have found a nut-free baking mix. Imagine my surprise when a cursory glance at the label informed me that you are NOT in fact a nut-free facility.

I realize everyone has different comfort zones, but eating products that are manufactured in a facility with tree nuts is outside of mine. I would like to know more about your manufacturing processes. For instance, are your tree nuts in a completely segregated part of the facility where your baking mix is manufactured? Are the products all in one big facility but run on separate, dedicated nut-free lines?

I sincerely hope I am misunderstanding your labeling because I think it is extremely irresponsible to advertise yourself as "nut-free" if you are NOT using segregated facilities. If all your claim of being "nut-free" is guaranteeing is that there are no nuts in the ingredients, then you're no different than any other product that doesn't contain nuts but is processed in shared facilities (i.e., Betty Crocker, Dunkin Hines, etc.). Please provide me with clarification on this issue. It is truly a matter of life and death for those who react violently to even the most minute cross-contamination.

Thank you in advance,
Andrea

By Comments on Fri, 11-15-13, 01:25

I think that the owner wrote you a lovely, genuine reply. That aside... ARE YOU KIDDING ME!!!!? How can a company claim to be "nut free," when they know better? Great there are no actual nuts in the recipe. However, there is NO way to completely clean those machines. Anyone who has ever watched production in a facility knows this. 1000 batches could be fine. Then the 1001 batch happens to include that errant nut that escaped cleaning. Do they really want to take the chance of some one dying for what's essentially a marketing ploy? The only reason to slap the words, "nut-free" on the packaging is to appeal to those of us who desperately seek out nut free options. They should be ashamed of themselves for putting that claim on the package, regardless of the loophole in the FDA regulations. One could read the label and then make a risk analysis based on the that. My son is severely allergic to peanuts and tree nuts. I scrutinize every single label. That said, I am more casual when a product claims to be "nut-free." This post reminds me that I need to be diligent - always.

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By andrealg on Fri, 11-15-13, 02:49

I totally agree! No matter how cautious we are, it's only natural to feel relieved to come across something that is explicitly labeled as "nut free" and it can cause us to let down our guard. I sent the owner one more email (below), just to reiterate my concerns and explain my position a little more. Hopefully this company will take it to heart.

Jared,

Thank you for your prompt and thorough response. I hope I did not come across as rude in my original correspondence. I am just frazzled from dealing with this life-threatening allergy for most of my life. As you said, my daily dietary choices are fraught with worry, so I do everything I can to avoid products that even have the slightest chance of cross-contamination. Of course, that is not always possible, and I refuse to live my life in a bubble, but when I can, I avoid things that are potentially life-threatening to me.

I truly appreciate your breaking down your manufacturing process for me. It has helped me to be informed, and I do not feel your products are in my comfort zone. I did not mean to disparage you or your company by comparing you to the big names like Betty Crocker, etc. What I meant by that statement is that they (or many of them – Betty Crocker and Hershey, at least) also use best practices to ensure no cross-contamination. They also use the enzymatic cleaner and do spot testing. Some of those companies even use dedicated lines but still process nuts in their facilities, and because of this, they label for cross-contamination, as you do.

What concerns me is that even with the most thorough cleaning, there is always that chance, however minute, of cross-contamination. I expected you to say you had a dedicated line in a facility that also uses nuts, but to hear that you don’t even use a dedicated line and do not source from “nut-free” manufacturers, in my humble opinion, makes your claim of being “nut-free” somewhat dubious.

I am a recent law school graduate. I will official be an attorney when I am sworn-in to the Colorado Bar next week. I took courses in food law while in school, so I am well-versed in the FDA’s guidelines, and I do not dispute that you are in compliance with them. What concerns me is that the FDA is far behind the curve when it comes to labeling requirements. As you likely know, it was only in the past few years that the FDA began requiring allergen labeling at all, and they still don’t require labeling for cross-contamination. I commend you for going above and beyond to label your products as manufactured in a facility that uses nuts. However, I stand by my original statements. I feel that your label should indicate that you do not use dedicated lines, and that your “nut-free” claim on the front label should have an asterisk, because many people rely on the bold front labeling alone.

But that is just my unsolicited opinion. I truly wish you and your family and company the best and I hope, again, that I don’t come off as rude. I am just concerned and weary from fighting the food allergy battle. I respect what you’re doing as a small company, and if in the future you are able to move to a dedicated facility I will certainly give your products another chance.

Best,

Andrea

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By andrealg on Tue, 11-12-13, 17:41

UPDATE:

I received a very thorough and impassioned reply to my inquiry from the owner of the company. I will paste the whole of it below, but the gist was this:

- They are a family with severe food allergies and understand the issues that go along with FA
- They do not think they are in the same category as Betty Crocker or Duncan Hines or any other “faceless, heartless, uncaring entity”
- They are a small company and can’t afford to use a dedicated facility at this time, but they stand behind the integrity of their products and their labeling
- Since their products don’t actually CONTAIN nuts, their labeling is in compliance with FDA guidelines
- Their third-party manufacturer is certified in handling food allergies

BUT:
- They DON’T even use DEDICATED LINES
- “The production line is cleaned out multiple times with an enzymatic cleaner and all contact surfaces are spot tested for the presence of any protein before production will begin of Lillabee mixes.”
- AND they don't SOURCE their ingredients from NUT-FREE manufacturers “…we also do source some of our ingredients from manufacturers that have nuts (tree & peanut) present in the same facility as well, however they all follow similar strict production standards in order to maintain the purity of their ingredients too”.

So, I stand by what I said about this company being no better than Betty Crocker, etc. As I understand it, the large companies (for the most part – Betty Crocker, at least) use similar “enzymatic cleaning of the equipment” and “best practices” to ensure integrity of production.

While I try my best to support small family-owned companies such as this, and I appreciate the thoughtful reply of the owner, I still think this is irresponsible labeling.

All that said, I have now discovered Namaste Foods. They ARE made in a dedicated nut-free facility (free of all the top allergens, I believe, and also gluten free). I purchased their chocolate cake mix and made cupcakes with it last night, and they were awesome!

OWNER’S REPLY to my letter (see my original post):

Hola Andrea;

First of all thank you so much for reaching out to us in regards to your questions about nuts and our products. I appreciate the time you took to so specifically and passionately detail out your concerns about our mixes and to ask for more information about our products. Before I say anything else I want you to know how greatly I respect the care you need to take when choosing products for yourself. You sound very informed about both your specific allergy and the production process of food products in general. I want you to know how seriously we take your concerns about the presence of potential food-allergens in our products as we have serious food allergies in our family and they were the reason my wife Indea and I started this company. Looking through your email it looks like the areas of your concern are about nut ingredients, our production facility and then the nut free description on our packaging. I will do my best here to answer each of those questions for you as specifically as I can.

Our production facility & standards:
As a small company we have taken all the steps we can to ensure the ingredient integrity of our products in order for our customers to enjoy them safely. It is our dream to one day own our own production facility but we simply cannot afford such a massive expense as a machinery and commercial real estate purchase right now. Until then we go to great lengths to ensure the ingredient integrity of our products by taking the following steps:
- We utilize the services of a highly respected contract manufacturer to produce our mixes to our specification. This manufacturer has quality control managers on staff and present at all times during any production.
- We source all of our ingredients from highly reputable US based mills and manufacturers.
- The production line is cleaned out multiple times with an enzymatic cleaner and all contact surfaces are spot tested for the presence of any protein before production will begin of Lillabee mixes.
- Our manufacturer has also been 3rd party certified in both food safety and food allergen management.
-To also specifically answer one of your questions, I will share with you that our manufacturer does not utilize a separate dedicated no-nut-ingredient production line for our mixes.

The Nut Question:
None of our products contain nut ingredients. However, it is important for us to let anyone with severe peanut or tree nut allergies know that we do manufacture our products in a facility that also occasionally processes nuts and that's why the statement about our production facility is on our ingredient panel. To protect our customer’s safety, our contract manufacturer utilizes a system of strict best practices throughout the production timeline. Examples of this are keeping all of our ingredients segregated and in the original packaging that they were received in from their manufacturers before production within that facility, making sure that any common equipment that will be utilized is thoroughly cleaned with a cleaner which removes and destroys any surface proteins including those from nuts (the enzymatic cleaner I referred to above) and many many other steps and safeguards that go on throughout our mix's production. Another important consideration is that we also do source some of our ingredients from manufacturers that have nuts (tree & peanut) present in the same facility as well, however they all follow similar strict production standards in order to maintain the purity of their ingredients too.

Nut Free Description
- In keeping with the FDA's food labeling standards we describe our mixes as nut free because they do not contain nut ingredients and also because we know the great lengths we have undertaken to preserve the ingredient integrity of our products through our production and ingredient sourcing standards. All of our products and facilities have been inspected by the FDA and Colorado Dept of Health multiple times over the years we have been making our mixes. Part of these inspections includes the review of our labels/packaging and they have always been in full compliance. However, with all of this said, the FDA's standard does not appear to be your standard and that's how we may have come up short in your estimation. As you said in your email, that everyone has different comfort zones, we created our products to meet the needs of as many folks as we could. But no one product can be the right choice for every person and their specific intolerance's or comfort zones and that is why I feel a sense of loss when reading your strongly worded email. We were not able to meet your expectations and that was upsetting to you. That our products have brought someone anything other than a little bit of happiness makes me very sad.

I did want to take the opportunity Andrea to speak with you as someone who truly cares about your health and well being. Since you have a specific and strong reaction to the slightest trace of nuts I would advise caution in eating any packaged food, and that includes Lillabee products. As I'm sure you know, most any food products sold today (especially anything with cocoa) is probably going to be made in similar facilities to ours. Since you've already told me that you feel that any food made in a common facility as nuts is outside your comfort zone I feel strongly that in your case of using Lillabee products personally, you should let your individual experience and knowledge of your individual allergy be your guide.

As you must know from living and eating with your allergy, your knowledge of what will work for you is your best guide because as you are well aware, reactions from food products can be exceedingly difficult to predict and to pinpoint the cause of, especially in something made from products with multiple sources like a finished dessert made from a baking mix. This is because so many additional ingredients are required to be added to the mix before consumption. And as with any other baking mix there is the added complexity of also being mindful of the ingredients you add in terms of eggs/egg re-placers, butter/milk substitutes and where they were made and did someone making the rice milk eat a peanut butter sandwich that day and have peanut oil on them etc.

I do feel in my heart for you Andrea as I can only imagine how fraught all food choices can become for you, and am affected deeply by how you might often feel as if people don't take your safety as seriously as they should. I would like to assure you that the ingredients we've selected to use in our products are without exception the best we could source anywhere and that your safety and the safety of every single person that enjoys a Lillabee mix is my primary concern and daily fixation.

While I cant tell you that I would agree with your judgment of us as being just another Betty Crocker or Dunkin Hines; some faceless, heartless, uncaring entity, I do very much value and respect your opinion. I sincerely hope that I have provided you with all of the information that you require to make an informed choice. If you feel though that our efforts don't meet your expectations of what a company can or should do I am so saddened to loose both your belief and support.

In the end and whatever your judgment Andrea, I can't tell you how much I appreciate you taking the time to reach out to us and share your experience and input on how we could in your view be better. We so very much want to be the best little baking company on the planet and your direction is invaluable to us.

[The owner then included his contact info, which I have redacted, but will be happy to provide upon request if anyone else has an questions for this company.]

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By nutfreenyc on Tue, 11-12-13, 16:52

"Steve's Ice cream" does the same thing! They write nut-free on top, and then have a cross-contamination warning on the side. Very scary.

By theory on Tue, 11-12-13, 14:37

Thanks for the information! I haven't come across that brand, but I am floored they would advertise as nut-free given their manufacturing.

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