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Making Sense of Food Allergen Labeling

Because of the rise in food allergies and life-threatening reactions, the Food Allergen Labeling and Consumer Protection Act was passed into law. What does the law mean for parents and caregivers?

Because of the rise in food allergies and life-threatening reactions, the Food Allergen Labeling and Consumer Protection Act (FALCPA) was passed effective January 1, 2006 stating that if allergenic foods are present in a food product, that product must be labeled in one of two ways:

1) the name of the allergen, if it is not the common or usual name of the ingredient, must be included in parentheses in the ingredient list or, 2) the word “contains” followed by the name of the allergen must immediately follow or be adjacent to the ingredient list.

For example, an ingredient list may look like this: Ingredients: Enriched flour (wheat), whey (milk), lecithin (soy) and may be followed by: Contains Wheat, Milk and Soy.

To be clear, a separate “Contains...” line is optional and may not be included on a label. Also, FALCPA does not address the use of advisory labeling, like “May contain...” or “Is manufactured on shared equipment with...” What does this mean for parents and caregivers? Many people assume that if there is no allergy warning, the item is safe. This is NOT true! Reading the full ingredient list is the only way to ensure that an allergen is identified in a packaged food.

Even then, there is the risk of cross-contamination. Because “May contain...” is not mandatory, any food may contain trace allergens! Each child reacts differently and each family will have a different comfort zone based on their child’s sensitivity.

For a child like Faith Hall, cross-contamination means another trip to the hospital. Faith has had 21 anaphylactic reactions in three years. Her reaction in January 2007 resulted from trace amounts of either milk or egg from a manufacturer’s equipment. Her mom, Linda Hall recounts, “Her eye sockets turned blue, her mouth was green, she was shivering, she wasn’t speaking clearly... the attack lasted 25 minutes. She didn’t respond to the first shot of epinephrine. It was only after a second shot was administered at the hospital that she began to respond.” Faith is highly sensitive to both milk and egg. Thoroughly reading labels did not prevent Faith’s reaction because the contamination with trace allergens occurred at a processing plant and was not documented on the product label. A 2001 FDA study showed that a surprising 25% of products from small to medium-sized facilities contain this type of cross-contamination. Only education and strict adherence to good cleaning practices within the food industry will lessen the risk of reactions.

No one consciously wants to harm a child. But for people who do not live with food allergies, it is difficult to understand or remember the “rules.” A food-allergic child’s parents or primary caregivers are the best and most willing resources. Ask them for a list of Safe Snacks and another list of Unsafe Snacks that will delineate their comfort zone very clearly. The Unsafe Snack list emphasizes seemingly harmless items that could be dangerous for this child. For example, we don’t serve store bought sugar cookies or plain M&M’s in our house (may contain trace nuts).

These lists can be shared with a child’s teachers and other parents to minimize the risk of a reaction from food brought into a classroom or other group setting. Most home bakers are not aware that each ingredient has to be checked for potential allergens and preparation surfaces and tools must be thoroughly cleaned. Although homemade food items add a special touch to the school day, they are life-threatening for some children. Err on the safe side, reserve those treats for home and stick to the Safe Snack list.

Linda Hall hosts a food allergy awareness and education site, For more information on FALCPAArticle Search, visit the FDA’s web page:

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Ria Sharon is the mother of a toddler with severe peanut and tree nut allergies. She is also the founder of Check My Tag, a company that provides food allergy management products and resources at

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