May is Food Allergy Awareness month! To wrap up the month, we have a blog post on a common cause of food recalls: undeclared allergens on food labels. When people think of food recalls, most think of recalls due to foodborne illness. Famous recalls like the Peanut Corporation of America recall, Jensen Farms cantaloupe recall, or the 2016 recall of General Mills flour may come to mind. What fewer people consider is recalls due to undeclared food allergens. However, in 2023, the leading cause of food recalls was undeclared allergens.
Major Food Allergens
There are nine major food allergens enforced by the Food and Drug Administration (FDA). The Food Allergen Labeling and Consumer Protection Act of 2004 (FALCPA) identified the first 8 major allergens: milk, eggs, fish, crustacean shellfish, tree nuts, peanuts, wheat, and soybeans. Then in April 2021, the Food Allergy Safety, Treatment, Education, and Research (FASTER) Act declared sesame as the 9th major allergen (effective as of January 1, 2023). These 9 allergens account for 90% of all food allergies and must be declared on the labels of all foods regulated by the FDA. Examples of foods not regulated by the FDA include poultry, most meats, eggs, and alcoholic beverages.
Major food allergens must be identified using their common names, either in parentheses following the name of the ingredient in the ingredients list or in a “Contains” statement after or next to the ingredient statement. Not all products will include a “Contains” statement, so it is important for consumers to read the entire ingredient statement and check for potential food allergens. Additionally, the specific type of tree nut must be stated on the label (e.g. pecan, walnut, cashew), and the species of fish or Crustacean shellfish must also be included, as individuals may be allergic to only specific species or types of these allergens.
The ingredient statements below show the two ways to list allergens in the ingredient statement, with Example 1 showing the allergens in parentheses following the ingredient name and Example 2 showing the “Contains” statement:
Example 1*:
Ingredients: Whey protein (milk), lecithin (soy), cherry, sugar, natural flavors (almond), salt.
Example 2*:
Ingredients: Whey protein, lecithin, cherry, sugar, natural flavors, salt.
Contains: Milk, soy, almond.
*These examples were provided by a Food Allery Research and Education publication
Undeclared Allergens in Food Recalls
Food allergen recalls can be traced back to either mislabeling of products or allergen cross contact during processing. Problems can arise when labeling foods if the incorrect label is put on a food package and sold or if an allergen is not declared in an ingredient statement. During production, allergen cross contact can occur if improper cleaning and sanitation practices are followed and if production scheduling does not account for the correct product sequence for allergen control. For example, a product containing wheat can be run after a gluten free product on the same line, but not before a gluten free product without the line being closed, thoroughly cleaned, and tested for allergenic food residue post-cleaning.
Foods that do not contain allergens themselves but are made in facilities that process allergens sometimes include either “May Contains” or “Processed in a Facility” statements. However, these advisory statements are not mandatory. They are voluntary statements that manufacturers may include if there is a possibility that a food allergen could be present. For instance, a manufacturing facility may run a product containing peanuts on the same equipment for a product that does not contain peanuts. Even after cleaning the equipment, small amounts of the peanut allergen may still be present, prompting the manufacturer to voluntarily include this warning on their label.
Common Misconceptions
Many people discount the importance of allergen labeling thinking that it only impacts a small portion of people that are actually allergic to said ingredient. However, according to Food Allergy Research and Education (FARE), 33 million Americans have food allergies, including 1 in 13 children, and every 10 seconds a food allergy sends someone to the emergency room.
For small businesses producing their own products, it is important to carefully analyze all sub-ingredients when making their ingredient list. Extension Food Science makes ingredient lists and allergen statements when formulating nutrition facts panels for companies. If you need assistance with a nutrition facts panel or ingredient statement, please reach out to us at 706-542-2574 or email efs@uag.edu.
On ingredient statements, ingredients are listed in descending order based on weight, so the allergens may not necessarily be the first ingredients listed. It is important to thoroughly read the entire ingredient statement, especially if the allergens are not summarized in a “Contains” statement.
Lastly, highly refined oils derived from major food allergens do not have to be declared as allergens on food labels; however, the source of any highly refined oil must be included in the ingredient list. For example, if a product contains highly refined soybean oil, “soy” does not have to be labelled using the allergen format. However, in the ingredient statement, the common name of the oil must be included. For example, highly refined soybean oil must include “soybean oil”, not just “refined oil”.
For more information on current food recalls and allergy alerts, please see the links below:
Current List of Food Recalls:
https://www.fda.gov/safety/recalls-market-withdrawals-safety-alerts
Food Allergy Research & Education Allergy Alert and Ingredient Notices:
https://www.foodallergy.org/living-food-allergies/food-allergy-essentials/allergy-alerts