In January the FDA released its final guidance regarding food allergens and their labeling requirements. This update includes notable changes, but don’t worry, ReciPal has already added functionality to make sure all labels can easily stay compliant with the new requirements. Issues with allergen declarations are the number one cause of FDA product recalls. Getting this part right is crucial both for the safety of your consumers and that of your business. In this article we’ll cover everything you need to know about the FDA’s new allergen labeling requirements and show you exactly how to make these updates within ReciPal.

What you need to know

We’re going to cover three major allergen categories where new information from the FDA’s final guidance may mean that updates to your labels are necessary - milk, eggs, and nuts. If any of your products contain these ingredients it’s important that you understand how they should now be properly labelled.

Keep in mind, this final guidance does not mean you have to throw out any existing labels. The FDA allows for a reasonable transition period to any new standards, so if you recently printed a bunch of new labels it's ok. However, you will want to get any future iterations aligned with these updates as soon as possible to avoid issues. Here is the FDA's statement about making updates to your labels:

We understand the implications of making label changes and that firms have been relying on previous guidance. Given those circumstances, FDA recognizes that product labels might be corrected the next time they are printed.

Milk

The big change here is that you must include the type of milk. If you’re just using cow milk then nothing is changing about how the allergen will be labeled and listing it as “milk” is correct. However, milk from other animals (goat, sheep, etc.) must be specifically labeled in the ingredient statement, allergen declaration, or both. For example, in the ingredient statement you’d list, “goat milk” or “whey (goat milk)”. In the allergen declaration you’d say, “Contains goat milk”.

Eggs

Consistent with the change to milk, eggs also now require the type of egg to be declared. Again, nothing is changing for eggs from chickens. But for eggs from birds other than chickens, the bird source must be declared in the ingredient statement, the allergen declaration, or both. For example, “duck egg” and “ovalbumin(duck egg)” in the ingredient list. Or, “Contains duck egg” in a separate allergen declaration.

Nuts

For nuts, the FDA has limited the declaration to the following only: almond, black walnut, Brazil nut, California walnut, cashew, filbert/hazelnut, heartnut/Japanese walnut, macadamia nut/Bush nut, pecan, pine nut/pinon nut, pistachio, and English and Persian walnut.

Some nuts that previously had to be declared as allergens are no longer allowed to be listed. You cannot declare the following nuts in the contains statement: coconut, beech nut, butternut, chestnut, chinquapin, gingko nut, hickory nut, pili nut, and shea nut. This removes some controversy as many people had objected to coconuts being considered a tree nut.

Updates in ReciPal

We’ve made it easy to stay up to date with the FDA allergen changes. Our system automatically detects allergens based on the ingredients you select. While the allergen information will automatically be set, you have the ability to make any updates if necessary. Now for contains statements on milk and eggs, we give you a check box to indicate the source as well as a text field for more obscure categories.

For nuts, we’ve updated the categories users can select (removing coconut). Also, in our “other” category for tree nuts if you enter a nut that is now not allowed to be declared in the “contains” statement we provide a warning message.

Don’t mess around with allergens

For labeling purposes, nothing is taken more seriously than proper allergen labeling. At ReciPal, our experts are on top of all the changes working to seamlessly integrate new requirements into the framework of our product. Unlike some other nutritional database analysis software, we take extra precautions to make sure labels produced follow all of the rules. And part of that is just keeping our users up to date on the changing landscape. So if you have any questions let us know!