Allergen Labeling Guide for Prepared Meal Businesses
Allergen mislabeling is a serious compliance risk. FDA requires disclosure of top 9 allergens. This guide is for meal prep, catering, and delivery services.
CAUTION: Allergen mislabeling can result in recalls, fines, or serious harm to customers.
Always verify with a food safety professional.
The Top 9 Major Food Allergens
These account for 90% of food allergies and must be disclosed even in trace amounts.
Note: Sesame was added as the 9th major allergen in 2023. Many businesses still miss this one.
How to Disclose Allergens on Labels
Option 1: "Contains" Statement (Recommended)
Clearer and easier for customers to spot quickly.
Option 2: Parenthetical in Ingredient List
Acceptable but less prominent than "Contains" statement.
The "Contains" statement must appear immediately after the ingredient list.
Cross-Contamination Warnings
"May contain" or "Processed in a facility that also processes [allergen]" statements are not required by FDA but recommended for liability protection, especially in shared kitchen environments (ghost kitchens, co-packers).
Common in shared commercial kitchens where cross-contact is possible.
Common Allergen Labeling Mistakes
Missing Sesame (newly added 2023)
Incomplete Disclosure
Vague Language
Frequently Asked Questions
Do I need to list allergens if they're obvious (e.g., milk in yogurt)?
Yes. All major allergens must be disclosed, even if obvious.
What if I'm not sure if there's cross-contamination?
Use a precautionary statement ("May contain [allergen]"). Better safe than liable.
Are gluten-free claims regulated?
Yes. "Gluten-free" claims have specific FDA requirements (under 20 ppm gluten).