accurate or within specified tolerances.
Some of the risks of noncompliance are
consumer illness, product recalls, lost
consumer faith, agency warning letters,
increased regulatory surveillance, and
When it comes to claims, growing in
demand on baked goods are “
allergen-free” claims or “gluten-free” claims.
More frequently, schools are requesting
that students bring treats that are “
peanut free” or “nut free.” Substantiating
these claims comes at a high risk. While
gluten is not one of the eight major allergens, “gluten free” is one of the only
“free from” claims that has been defined
by the U.S. Food and Drug Administration (FDA) with established testing
thresholds. In general, allergen-free
claims are unregulated, and there is no
standard across the industry.
Once all the ingredients in the
product have been identified, you can
determine what allergens need to be
declared on the label. The Food Aller-
gen Labeling and Consumer Protection
Act of 2004 requires food manufacturers
to label food products that contain an
ingredient that is, or contains, protein
from a major food allergen in one of
The first option for food manufactur-
ers is to include the name of the food
source in parentheses following the
common or usual name of the major
food allergen in the list of ingredients.
This can be done in instances when the
name of the food source of the major
allergen does not appear elsewhere in
the ingredient statement. For instance,
Ingredients: Enriched flour (wheat flour,
malted barley, niacin, reduced iron, thiamine
mononitrate, riboflavin, folic acid), sugar,
hydrogenated soybean oil, and/or cottonseed
oil, whey (milk), eggs, vanilla, natural and
artificial flavoring, salt, leavening (sodium
acid pyrophosphate, monocalcium phosphate), lecithin (soy), mono- and diglycerides
The second option is to place the
word “Contains,” followed by the name
of the food source from which the major food allergen is derived, immediately
after or adjacent to the list of ingredi-
ents, in type size that is no smaller than the type size used for the list of ingredients.
For instance, Ingredients: Enriched flour (wheat flour, malted barley, niacin, reduced iron,
thiamine mononitrate, riboflavin, folic acid), sugar, hydrogenated soybean oil, and/or cottonseed oil, whey, eggs, vanilla, natural and artificial flavorings, salt, leavening (sodium acid
pyrophosphate, monocalcium phosphate). Contains Wheat, Egg, and Milk.
The FDA food allergen labeling policy does not require that labels have a supplemental allergen statement, such as a “may contain” statement, although they are
common within the bakery industry due to the nature of the bakery environment in
which common manufacturing lines are used throughout the production day. While
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