When you learn that you or your child have a food allergy, the hardest adjustments are learning to read ingredient labels, different ingredient names for your allergen(s), and understanding allergy warning labels. Luckily, the FDA regulates these lists, through The Food Allergen Labeling and Consumer Protection Act of 2004 (FALCPA); which makes it a little easier to understand than you would expect.

Before we start breaking down labels, here is a list of 8 major allergens per the FDA. These allergens, and any ingredients derived from these allergens, must be appropriately labeled on food products. Per the FDA, these foods are responsible for “90% of all food allergic reactions and are the food sources from which many other ingredients are derived.” (FDA - What You Need to Know about Food Allergies)

• Milk
• Eggs
• Fish (e.g., bass, flounder, cod)
• Crustacean shellfish (e.g., crab, lobster, shrimp)
• Tree nuts (e.g., almonds, walnuts, pecans)
• Peanuts
• Wheat (could also be linked to Celiac Disease)
• Soybeans

Let’s get into it!

Contains Statement

If a particular food product contains one of the major 8 food allergens that ingredient must be clearly labeled on the ingredient list or in the “Contains” statement. By “clearly”, the ingredient needs to be labeled in its common name, such as, milk, peanuts, crab; not a scientific name. The listing is not required to be in both places. This is where things can get a little confusing. Unfortunately, some companies utilize both the ingredient list and the contains statement to list the presence of allergens. This means that they may list some ingredients, such as pecans and almonds in the ingredient list, but they may list only milk in the contains statement. This could be because the ingredient “milk” is not necessarily used in the product, but another ingredient within the ingredient list also has milk, such as, “chocolate chips”. This is why it is very important to read the ingredient list in its entirety as well as the contains statement.

So, what about food group allergens, such as crustacean, Tree Nuts, or fish? If any of these food groups are present in a product, the specific item must be listed in the ingredients. For example, if there are Tree Nuts present in the product, the type of Tree Nut must be listed. So, almonds and pecans, for example. While not common, it is possible for someone to be allergic to, let’s say, crab, but not allergic to shrimp. If the declared allergen was “Crustacean Shellfish”, that wouldn’t be specific enough for someone that can’t have crab but can have shrimp.

May Contain Statement

Let’s talk about that pesky “May Contain” statement. Is it required by the FDA? No. So why is it even there? It is to help people with extremely sensitive allergies, because it’s not required, nor is it required to be accurate, it doesn’t truly help. So, what does this statement mean? This statement is just a way to say that this product was made in the same facility or manufacturing line, or near, a product that contains any top 8 allergen. The product you may be consuming doesn’t contain those ingredients, but there is a risk for cross contamination. A lot of large manufactures follow very strict cleaning processes between product manufacturing, such as testing the production lines for the presence of the allergen, measured in parts per million (ppm). The minimum ppm allowed for any allergen to be required to be declared as present is 20ppm. A lot of major facilities will test to down to 5-10ppm before producing the next product. If you suspect or know that you have an extremely sensitive allergy, my recommendation would be to call different manufacturers to determine if they process on shared lines with your allergen. Unfortunately, reaching out in this manner is the only way to know for sure if something has the potential for cross contamination.

Contacting the FDA

FALCPA was developed to keep us safe, but we are all human and sometimes labeling can be missed. If have an adverse allergic reaction to a product that isn’t labeled for your allergen, you can submit your concerns to the Consumer Complaint Coordinator for the state where the product was purchased. You can also call the FDA at 1-888-SAFEFOOD(72333663) for this, or for potential manufacturer mislabeling. You can also submit a report using the MedWatch Online Reporting form.