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Product Labeling & Label Laws
Reading the labels can be tricky, as the wording may differ from product to product. Please be aware that some food manufacturers will only label allergens if they are listed in the ingredients. If the allergen is in the building or manufactured on the same machine, they may not list the cross contamination allergy warning on the package.
It is only required by law to list the allergen warning if the product itself has the allergen listed in the ingredients. That is to say, it is voluntary for the manufacturers to do so. Some manufacturers produce products in one facility while others use several different facilities. This is why you must check the labels of each product every time you purchase it. For example, the Kellogg company manufacture products in different parts of the U.S. and labels for cross contamination. They produce the Pop-Tart brand. While some Pop-Tarts are produced in one facility in the mid-west, another can be produced in a facility in the east coast. Why is this important? One facility may use dedicated equipment while the other may have cross contamination. Your grocery store may have received shipment from both facilities. Therefore, you must read the label on each box every time even if they are the same product on the same shelf.
It is only required by law to list the allergen warning if the product itself has the allergen listed in the ingredients. That is to say, it is voluntary for the manufacturers to do so. Some manufacturers produce products in one facility while others use several different facilities. This is why you must check the labels of each product every time you purchase it. For example, the Kellogg company manufacture products in different parts of the U.S. and labels for cross contamination. They produce the Pop-Tart brand. While some Pop-Tarts are produced in one facility in the mid-west, another can be produced in a facility in the east coast. Why is this important? One facility may use dedicated equipment while the other may have cross contamination. Your grocery store may have received shipment from both facilities. Therefore, you must read the label on each box every time even if they are the same product on the same shelf.
Here are some helpful links about food labeling:
Some of our members have experience with calling the manufacturers. If you need assistance please do not hesitate to contact us.
- Food Allergen Labeling and Consumer Protection Act (FALCPA).
- You may also want to read the FAQ page of FAAN's FALCPA post to familiarize yourself with the label law.
- FAAN's How to Read a Label - an index of how to's organized by allergens.
- Kids With Food Allergies has a great post on what to ask when calling a manufacturer about their safety practices.
Some of our members have experience with calling the manufacturers. If you need assistance please do not hesitate to contact us.
LABEL SAFETY & FALCPA
In the United States, the FDA is responsible for regulating the Food Allergy Labeling and Consumer Protection Act (FALCPA). Food companies regulated by the FDA are required to label for the top 8 allergens in plain English; peanuts, tree nuts, egg, dairy, wheat, shellfish, fish and soy. However, how they label varies. It is not required by the FDA to label for cross contact (sometimes referred to as “cross contamination”) yes some companies do. Additionally, if your food allergies are not part of the top 8, like sesame or corn, you will need to thoroughly read each label, contact the manufacturer to discuss possible cross contact or avoid the product all together. Sometimes the cross contact warnings are not near the ingredients list so be sure to review the entire package for any cross contact warnings and read the entire ingredient list.
In the United States, the FDA is responsible for regulating the Food Allergy Labeling and Consumer Protection Act (FALCPA). Food companies regulated by the FDA are required to label for the top 8 allergens in plain English; peanuts, tree nuts, egg, dairy, wheat, shellfish, fish and soy. However, how they label varies. It is not required by the FDA to label for cross contact (sometimes referred to as “cross contamination”) yes some companies do. Additionally, if your food allergies are not part of the top 8, like sesame or corn, you will need to thoroughly read each label, contact the manufacturer to discuss possible cross contact or avoid the product all together. Sometimes the cross contact warnings are not near the ingredients list so be sure to review the entire package for any cross contact warnings and read the entire ingredient list.
There are several variations of labeling. Review some examples of how allergens are labeled in the US by clicking on the images below.
Download a copy of the Label Safety & FALCPA document, including the example images.
| Label Safety & FALCPA PDF |
DIFFICULTIES IN LABEL READING
As you can tell by the images above, there can be discrepancies in labeling. With those differences, comes confusion which may result in a risk for exposure. Blanket Terms Allergens can be hidden in labels with the name, "natural flavoring" or "seasoning". This is a broad term to shorten a list of ingredients used without specifying the actual ingredients. It is especially concerning to those with allergies not on the top 8. For example, those with allergies to spices and garlic. Cross Contact Another difficulty in label reading comes with cross contamination. Because it is not required to disclose cross contact information, a seemingly safe product could pose as a danger. For example, a product declaring to be milk-free may have been made in a facility that processes milk products. The company has the option to label for the cross contact with a warning. The warning may read, "may contain milk" or "made in a facility that processes milk products". However, as previously stated, this is optional. Therefore, if the product does not have the cross contact warning, then product may be unsafe for a milk allergic individual. | 
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Changes In Manufacturing Process
Food product manufacturers may change, without notice, their manufacturing practices. It is important to periodically call the manufacturer to confirm that the foods you have determined safe, have not changed due to a change in the manufacturing process.
Food product manufacturers may change, without notice, their manufacturing practices. It is important to periodically call the manufacturer to confirm that the foods you have determined safe, have not changed due to a change in the manufacturing process.
**It's important to remember that if a label is unclear, one should call the manufacturer to determine safety.**
WHAT'S NOT LABELED
Unfortunately, the FDA does not regulate all products and therefore may still pose as a risk to allergic individuals. These products may be hiding allergens and a call to the manufacturer should be made to confirm product safety. Below is a list of products that are not subject to FALCPA.
Unfortunately, the FDA does not regulate all products and therefore may still pose as a risk to allergic individuals. These products may be hiding allergens and a call to the manufacturer should be made to confirm product safety. Below is a list of products that are not subject to FALCPA.
- Products regulated by the Untied States Department of Agriculture's (USDA) Food Safety and Inspection Service (FSIS)- beef, poultry and egg.
- Fresh fruit or vegetable
- Alcoholic beverages
- Personal Care Products - lotions, shampoos, soaps etc
- Arts and Craft Supplies - Tempura paint may contain egg, Play-Doh may contain wheat etc. You may find allergen-friendly arts and craft supplies from Discount School Supplies. They have a list of products by allergens. Additionally, you may find resources in our Products page.
Sources:
U.S. Food and Drug Administration, Food Labeling & Nutrition: Guidance for Industries, including the Food Allergen Labeling and Consumer Protection Act of 2004 (Edition 4); Final Guidance http://www.fda.gov/Food/GuidanceComplianceRegulatoryInformation/GuidanceDocuments/FoodLabelingNutrition/ucm059116.htm#update
Untied States Department of Agriculture (USDA) Food Safety and Inspection Service (FSIS) Fact Sheet
http://www.fsis.usda.gov/Fact_Sheets/Allergies_and_Food_Safety/index.asp#11
U.S. Food and Drug Administration, Food Labeling & Nutrition: Guidance for Industries, including the Food Allergen Labeling and Consumer Protection Act of 2004 (Edition 4); Final Guidance http://www.fda.gov/Food/GuidanceComplianceRegulatoryInformation/GuidanceDocuments/FoodLabelingNutrition/ucm059116.htm#update
Untied States Department of Agriculture (USDA) Food Safety and Inspection Service (FSIS) Fact Sheet
http://www.fsis.usda.gov/Fact_Sheets/Allergies_and_Food_Safety/index.asp#11
