by Jeanne Yacoubou, MS

VRG Research Director

In August 2011, we received an email from someone asking if calcium carbonate derived from oyster shells could be in food products. She relayed to us a correspondence she had received by the United States Food and Drug Administration (FDA) which stated that “It is possible to have food products contain calcium carbonate that was derived from shells.”

The VRG surveyed several major soy and rice beverage manufacturers and vitamin companies to determine how common oyster shell is in their products today. We were informed in September 2011 by Heather, a customer service representative at SoyDream®, a Hain Celestial® product, that “all SoyDream® non-dairy beverages in the US and Canada are vegan,” and “the calcium carbonate is sourced from rock.”

Christie, a customer service representative with Eden Foods®, maker of EdenSoy®, told the VRG in October 2011 that their calcium carbonate is “from a non-animal, mineral source.”

Dee, a representative of Natures Promise® products, told us in September 2011 that the calcium carbonate in their soy and rice beverages is “from limestone.”

The VRG also contacted Caltrate® and CitraCal®, two major calcium supplement companies. Representatives told us that “There are no animal ingredients” in Caltrate®; and that their calcium carbonate is “from the earth.” We were also informed that the calcium carbonate in CitraCal® is derived “from limestone.”

The FDA correspondence received by our reader also contained this statement: “If there is someone that has an allergy to shellfish, we would suggest staying away from products or supplements that contain calcium carbonate.”

The writer was puzzled by this FDA recommendation that appears overly cautious in light of FDA’s own regulations (see below). The VRG contacted two separate offices at the FDA several times by phone and email over a three-month period to ask about the labeling of calcium carbonate. We did not receive a response.

The writer was curious to know if, perhaps mandated by the Food Allergen Labeling and Consumer Protection Act of 2004, (FALCPA), a product containing shellfish-derived shell components had to be labeled as containing a “major food allergen.” In fact, the vitamin company, Country Life®, labels its Calcium Magnesium Zinc with L-Glutamic Acid® dietary supplement containing calcium carbonate as “contains shellfish (oyster shell).” This “contains” statement appears as those required by FALCPA. http://www.country-life.com/moreinfo.cfm?Category=7&Product_ID=93

Without confirmation from the FDA, it appears to the writer that it is not mandatory under FALCPA for a food, beverage, or dietary supplement company to label products containing calcium carbonate derived from oyster shell as containing shellfish (“a major food allergen”). Looking more closely at the regulation itself, the wording explicitly states that it is the “protein” in the major food allergen that causes the allergy and, if present, must be labeled. If the mineral portion of shells is separated from the portion containing some carbohydrate and protein components naturally present in shells, the exclusively mineral calcium carbonate shell components are excluded from this labeling requirement. (Using analogous reasoning, FALCPA excludes highly refined soy oil from labeling requirements since it would not contain soy protein, another “major food allergen.”)

Furthermore, FALCPA clearly states that “crustacean shellfish” is the potential shellfish allergen. Oysters are not crustaceans. (Shrimp and lobster are.) Oysters (and clams) belong to the class of “shellfish” known as mollusks. For this reason alone, neither oyster protein nor oyster shell would need to be labeled under FALCPA, even though companies may, (and often do), disclose any oyster component in their products voluntarily.

It would be helpful to vegans if FALCPA required shell labeling but it does not. When there is a question about the source of calcium carbonate in a food, beverage, or dietary supplement, vegans must contact the products manufacturer. To learn more about FALCPA, readers may visit this page on the FDA website:
http://www.fda.gov/Food/LabelingNutrition/FoodAllergensLabeling/default.htm

The contents of this article, our website, and our other publications, including The Vegetarian Journal, are not intended to provide personal medical advice. Medical advice should be obtained from a qualified health professional. We often depend on product and ingredient information from company employees or company statements. Information does change and mistakes are always possible. Please use your own best judgment about whether a product is suitable for you. Further research or confirmation may be warranted.

For more information on food processing methods and food ingredients and to purchase our Guide to Food Ingredients, please visit our website at http://www.vrg.org/ingredients/index.php

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