You are here

Allergen Labeling on Food Products

Publication Number: P3551
View as PDF: P3551.pdf

The Food Allergen Labeling and Consumer Protection Act (FALCPA), which took effect on January 1, 2006, requires food manufacturers to use common names to identify major allergens. Allergen declaration is required on products regulated by the Food and Drug Administration (FDA), U.S. Department of Agriculture (USDA), and state regulatory authorities (e.g., Mississippi Department of Agriculture and Commerce, Mississippi State Department of Health, Mississippi Department of Marine Resources). Additionally, FALCPA’s labeling requirements extend to cottage food products and foods packaged by retail or foodservice establishments.

Food allergies are a serious public health concern that affects adults and children of all ages. Food allergies affect 32 million Americans and are reportedly increasing in prevalence. There is no cure for food allergies. True food allergies are immune-mediated systemic allergic reactions to certain foods that can cause serious illness or death. Although more than 160 foods have been identified to cause food allergies in sensitive individuals, the “big eight” most common food allergens account for 90 percent of all food allergies. In the U.S., only these eight most common food allergens are subject to FALCPA labeling requirements.

Major Food Allergens

In the United States, there are eight major food allergens, also known as the “big eight.” These eight foods and their components (including major ingredient sub-ingredients) are considered to be major food allergens under FALCPA and must be declared on food product labels. Note that major food allergens (as discussed on pages 20–24 of the FDA Labeling Guide), even if they are present only in trace amounts, must be declared. They include:

  • Milk
  • Eggs
  • Fish

The specific species of fish must be declared (e.g., bass, cod, flounder). See Guidance for Industry: The Seafood List.

  • Crustacean Shellfish

The specific species must be declared (e.g., crab, lobster, shrimp). See Guidance for Industry: The Seafood List.

  • Tree Nuts

The specific type of nut must be declared (e.g., almonds, pecans, walnuts). See Guidance for Industry: Questions and Answers Regarding Food Allergens (scroll down for a list of tree nuts).

  • Wheat
  • Peanuts
  • Soy


If your food product contains any of the major eight food allergens, they must be declared on the product label. Here, we will look at sugar cookies as an example using the ingredients listed below. Ingredients must be listed in descending order of predominance by weight, meaning the ingredient that is used the most by weight is listed first, next most used is listed as second, and so forth.



Enriched flour

wheat flour, malted barley, niacin, reduced iron, thiamin mononitrate, riboflavin, folic acid



Partially hydrogenated cottonseed oil


High fructose corn syrup








Natural and artificial flavoring





sodium acid pyrophosphate, monocalcium phosphate



Mono- and diglycerides


You have two options for listing allergens on product labels.

Option 1. Include the name of the food source in parenthesis following the common or usual name of the major food allergen in the list of ingredients in instances when the name of the food source of the major food allergen does not appear elsewhere in the ingredient statement for another allergenic ingredient. In the sugar cookie example, wheat, milk, eggs, and soy are specifically stated and listed within the ingredients, so an additional “contains” statement is not required.

Example nutrition facts label for Option 1 with an ingredients list but no "contains" statement.


Option 2. 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 ingredients, in a type size that is no smaller than that used for the ingredient list.

Example nutrition facts label for Option 2 with an ingredients list with this statement: Contains: Wheat, Milk, Egg, and Soy.

Food Recalls

There are three recall classes for food products, and they are categorized according to the level of hazard involved (Table 1). Undeclared allergens are one of the leading causes of food recalls in the United States in both FDA- and USDA-regulated products. Undeclared allergens are a Class I recall, which means they are required to be recalled due the seriousness of the hazard.

Table 1. Recall classification.

Class I

Class II

Class III

Dangerous or defective products that predictably could cause serious health problems or death. Examples include: food found to contain botulinum toxin, food with undeclared allergens, a label mix-up on a lifesaving drug, or a defective artificial heart valve.

Products that might cause a temporary health problem, or pose only a slight threat of a serious nature. Example: a drug that is under-strength but that is not used to treat life-threatening situations.

Products that are unlikely to cause any adverse health reaction but that violate FDA or USDA labeling or manufacturing laws. Examples include: a minor container defect or lack of English labeling on a retail food.

Allergens in Ingredients

Allergens may be in several ingredients used in product formulations. It is important to review, assess, and include major ingredients and their sub-ingredients on product labels. Undeclared allergen recalls are often a result of new ingredients, new suppliers, misprinted labels, products in the wrong package, product reformulation, and ingredient reformulation.

Always read food labels carefully and watch for hidden allergens in your product ingredients. Hidden allergens are ingredients derived from or containing major food allergens with common names that may be unfamiliar to consumers. Table 2 lists foods associated with common allergens. Note: This is not a comprehensive list.

Table 2. Common foods and ingredients that may contain allergens.


Common Foods and Ingredients




Crumb toppings

Graham cracker crust

Hydrolyzed plant protein

Hydrolyzed vegetable protein

Mole sauce

Peanut flavoring (natural and artificial)

Fried foods

Ethnic foods: African, Asian, Chinese, Indian, Indonesian, Thai, Vietnamese, Mexican

Tree nuts

Black walnut hull extract (flavoring)

Natural nut extract

Nut distillates/alcoholic extracts

Nut oils (e.g., walnut oil, almond oil)

Walnut hull extract (flavoring)

Grated/shredded coconut


Baking mixes (most)


Cream sauces

Enriched flour



Graham flour

Modified food starch

Salad dressings (some)

Soy sauce

Vegetable gum

Vegetable starch


Almond butter


Calcium caseinate



Margarine with milk solids


Milk chocolate

Nonfat milk solids

Sodium caseinate















Salad dressings (some)



Barbecue sauce

Caesar salad and Caesar dressing


Caponata (eggplant relish)

Imitation or artificial fish or shellfish (surimi, also known as “sea legs” or “sea sticks,” is made from fish)

Worcestershire sauce (anchovies)



Cuttlefish ink (crab or clam extract)

Fish stock


Seafood flavoring

Imitation or artificial fish, crab, or lobster

Surimi, also known as “sea legs” or “sea sticks,” is made with fish, not shellfish.



Meat substitutes

Pan release (cooking spray)



Soy flour/soy milk/soy nuts

Soy protein isolate (can be found in many seasonings)

Soy sauce

Tamari (soy) sauce


Teriyaki sauce

Texturized vegetable protein


Vegetable gum

Vegetable starch

*This is not a comprehensive list.

Resources and References

Food and Drug Administration (FDA). Food Labeling Guide.

Food and Drug Administration (FDA). Guidance for Industry: Questions and Answers Regarding Food Allergens (Edition 4)

Food and Drug Administration (FDA). Guidance for Industry: The Seafood List.

United States Department of Agriculture – Food Safety and Inspection Service (USDA FSIS). Compliance Guidelines Allergens and Ingredients of Public Health Concern: Identification, Prevention and Control, and Declaration through Labeling.

MSU Extension Publications

P3545 Labeling Mississippi Cottage Food Products.

P2920 Basic Labeling Requirements for Food Products Entering Commerce.

P3542 Developing a Food Recall Plan.

This material is based upon work supported by USDA/NIFA under Award Number 2018-70027-28585.

Publication 3551 (03-24)

By Courtney A. Crist, PhD, Assistant Extension Professor, Food Science, Nutrition, and Health Promotion.

Print Friendly, PDF & Email

The Mississippi State University Extension Service is working to ensure all web content is accessible to all users. If you need assistance accessing any of our content, please email the webteam or call 662-325-2262.

Select Your County Office


Portrait of Dr. Courtney Crist
Associate Extension Professor
Food Safety, Food Science, Food Processing, Home Food Preservation, ServSafe

Your Extension Experts

Portrait of Dr. James Newton Barnes
Extension Professor
Portrait of Dr. Rachael Carter
Extension Specialist II
Portrait of Dr. Christine E. Coker
Extension/Research Professor
Portrait of Dr. Courtney Crist
Associate Extension Professor
Portrait of Ms. Elizabeth Powell Gregory North
Extension Instructor
Portrait of Dr. Ben Posadas
Extension/Research Professor
Portrait of Dr. Juan L. Silva
Portrait of Dr. Eric Stafne
Extension/Research Professor
Portrait of Dr. Jeff Wilson
Assistant Professor

Related Publications