I distinctly remember the first time I shopped for groceries after my son’s food allergy diagnosis. For the first time in my life, at age 30, I started reading food labels. Labels for bread, cheese, ranch dressing, crushed tomatoes, vanilla extract, cereal, everything.
You name it, I’ve read the label.
I have had two responses to this.
First, I couldn’t believe all of the dyes, chemicals, and artificial ingredients that are in our food! But that is a tangent for another day.
Second, I learned a lot about the manufacturing process. I saw things like “may contain peanuts” or “produced in a nut free facility” under the labels.
Never before had I noticed these things.
I literally felt clueless.
I was standing in the grocery aisle, holding a bag of bread, staring at the label for who knows how long. Come to think of it, the people around me probably should have been concerned that I was just staring at this bread?!
What did all of this mean? Could my son who is allergic to peanuts eat this if it says “may contain peanuts”? I had seen people in a Facebook allergy group comment on cross-contamination. I learned later that they meant cross-contact. So what was that??
And I had noticed that different allergy families had different levels of comfort for what worked for them with labels.
This is key.
Different allergy kids have different allergy needs. What works for another family may not work for you and vice versa. And this is totally ok.
I want to give you the breakdown of how labeling works here in the US. Then you and your child’s allergist can determine what guidelines you should follow for your child’s needs.
What on A Food Label is Actually Regulated?
What Companies Have to Tell You
First, here is what’s regulated by the FDA. The Food Allergen Labeling and Consumer Protection Act of 2004 made it a company’s responsibility to clearly state all ingredients used in the production of their product. They have to disclose whether or not that product contains a Top 8 (Now Top 9 to include sesame as of January 1, 2023) major allergen as an ingredient (the FDA does not regulate the Top 9 allergens in meat products, some egg products, or alcoholic beverages).
A company can choose to do this in one of two ways. They can label the allergen clearly (specifically identifying peanut, milk, eggs, etc.) in the ingredient list or they can have a “contains” section below the list of ingredients.
Declaring on the label if a product contains a Top 9 allergen in the ingredients is the ONLY legally regulated requirement for companies to declare ingredients.
FOR THE PEOPLE IN THE BACK, I REPEAT. The companies ONLY have to tell you if any of the Top 9 allergens are ingredients in their products. If you learn nothing else from this post, I need you to know that this is the ONLY legal requirement.
Everything else we discuss about food labels is unregulated and voluntary labeling.
Here is a great article from Snack Safely that dives into this further.
What Companies Don’t Have to Tell You
This means that companies are NOT required to tell you if the product was produced on equipment or in a facility that also processes any of those allergens. They are only required to tell you if it is an actual ingredient.
For some kiddos, this creates a problem called “cross-contact.” You’ll likely hear this referred to as “cross-contamination” by other food allergy parents.
Cross-contact in manufacturing is when residual protein from an allergen that was produced on equipment gets into the next product or products that are run on that same equipment. When a product is produced on the same equipment as another product, it is called, “Shared Lines.”
Here’s an example. Peanut Butter Buster Surprise Candy is produced on the manufacturing equipment. Then they clean it, switch over and start producing the non-peanut product that I want to buy. However, there is residual peanut protein from the Peanut Butter Buster Surprise that gets into my non-peanut product.
My product will not state on the label that there are peanuts in it because peanuts are not an ingredient in my product. Therefore, the company is not legally required to label peanuts.
Unfortunately, some proteins (like the nut proteins) are terribly potent. So a kiddo that is extremely sensitive to their allergen protein can react to even the smallest amount.
This is a good question for your allergist.
Consult with your allergist if you need to be concerned about cross-contact.
You will find that for some food allergy families, this is not a concern based on the medical needs of their kiddo. For others, like mine, it is a concern. Different families also have different risk tolerances. This is ok too.
Some companies do something called “precautionary labeling.” This is where you might see things like, “May Contains,” “May Contain Traces of,” “Processed on the same equipment as,” on the label.
Here is the problem, precautionary labels are COMPLETELY unregulated and voluntary.
Fare is the trusted source of information about food allergies and this is a great post from FARE that goes into more specifics on this. This article from FARE highlights that precautionary labeling has created several problems.
Due to the fact that this type of labeling is unregulated, these terms are used differently by different companies. Some products are labeled this way and do have detectable traces of the allergen.
There are products that have no precautionary labeling, but are made on shared equipment meaning they could have detectable traces of the allergen, but no warning label.
Some products have the precautionary label, but do not have detectable traces of the allergen.
As you can see, the lack of regulation creates inconsistency with the labels from product to product.
“Free From” Labels
You will also see labels that say “Nut Free, Dairy Free” etc. Again, these labels, called “Free From” labels, are also voluntary. I was floored to learn that there is no requirement for allergen thresholds (measurable amount of allergen proteins) with these labels.
There is also no requirement that these products are made in dedicated facilities or on dedicated equipment. There is a chance that a product that advertises it is “free from” a particular allergen does in fact contain the allergen due to cross-contact on shared lines.
The key takeaway is, the ONLY regulated requirement on your label is if a Top 9 allergen is an actual ingredient in the product.
Any precautionary labels or “free from” labels are unregulated and voluntary.
How a Lack of Regulation for Voluntary Labels Can Create Confusion
Here’s an example of how that can be an issue for food allergy families. Katie was trying to figure out if a chocolate bar was safe for her daughter, who has sesame and peanut allergies. For her daughter’s specific profile and medical needs, they avoid products with shared lines for those allergens.
The label did not list either of her allergens in the ingredients and also stated, “May Contain Almonds.” Therefore the natural assumption was that that it was safe for her daughter.
Because a “may contain almonds” statement means that the company would have also declared other possible Top 9 allergens like peanuts, right?
But because it was a chocolate company, and because Katie has amazing instincts, she was still skeptical. She wasn’t sold on the fact that the facility and equipment wasn’t also processing peanuts and/or sesame.
Katie called, and sure enough, customer service informed her that both peanuts and sesame were produced on the same line as the chocolate bar, meaning that this product would not have been safe for her daughter’s needs.
This is an example of how a company disclosed only the information that they wanted, but were not legally required to disclose. When Katie asked the company why they only disclosed almonds, they had no answer or explanation for her.
The answer is, it’s not regulated. Therefore, they can do that.
So even though the label said, “May Contain Almonds,” the chocolate bar would not have met the requirements for Katie’s family. It was still processed on the same line as peanuts and sesame, which is a no go for her daughter’s needs.
One more time, the ONLY regulation that companies have is to inform you if a Top 9 Allergen is an actual ingredient in the product.
You might be a family that needs to know if a product was produced in a facility or on the same equipment with your child’s allergen. Unfortunately, the only way to find out is to contact the company and ask. The precautionary and “free from” labels are not regulated and thus, unreliable.
I know, it’s ridiculous. It’s on my to-do list to get the laws changed before my kids are adults.
How Can I Find Out About Shared Lines or Shared Facilities?
You’re probably asking, “How in the world do I find out about a company’s manufacturing policies?” You check out their website. Questions about allergens are usually in the FAQs. If it’s not there, you can contact them either via email or call like Katie did.
My email usually looks something like this:
Is your product produced in the same facility that is also processing peanuts and/or tree nuts?
Lauren Awesome Mom
The answers you get will really vary. Some will just say that they are following FDA regulations about labeling their products for the Top 9. They might also say that they clean their equipment (which is code for yes, there are peanuts and tree nuts in the facility, or we are unwilling to disclose that information because we don’t legally have to).
Others are very specific, which I appreciate.
Here is an example of an email I received so you can get an idea of how complicated manufacturing is.
Thanks for reaching out with your question about our products. All of our products are in compliance with FDA regulations that require the explicit labeling of peanuts and tree nuts (Including the tree nut type i.e. coconut, walnut, etc.) if they are contained in our products. So, if you see a product and it does not list peanuts or tree nuts in the ingredient statement on the retail package, then it does not contain these allergens.
This assurance is based on the fact that each of our facilities employ strict allergen management programs. This includes employee training, supplier and ingredient approvals, and label review. There is careful production scheduling and cleaning procedures, among other practices.
The Dairy Free Fruit and Veggie Smoothie Pouches made with coconut cream contain the tree nut allergen (coconut), but are made in a separate facility from the yogurts. Fluid milk in half gallons as well as our cream products do not contain any peanut or tree nut ingredients. But they are made on the same equipment that processes tree nuts (almonds, coconut and cashews).
However, the gallons of milk and 8 fl oz milk singles have no peanuts or tree nuts present in their processing facilities.
Frozen yogurt pints do not contain any peanut or tree nut ingredients. However, they are made on the same equipment that processes tree nuts (almonds, pistachios, walnuts, pecans, macadamia nuts and coconut) and peanuts. And the frozen yogurt bars do not contain any peanut or tree nut ingredients. However, they are made on the same equipment that processes tree nuts (almonds).
Yogurt and cereal toppers do not contain any peanut or tree nut ingredients. But they are made on the same equipment that processes tree nuts (almonds, pecans, cashews, coconuts) and peanuts.
Pineapple Mango with Coconut Chia Granola Parfait contain tree nuts (coconut). They do not contain any peanut ingredients. Super fruit with Hemp and Flax Granola Parfait does not contain any peanut or tree nut ingredients. Both parfaits are made on the same equipment that processes tree nuts (almonds, pecans, cashews, coconuts) and peanuts. However, the aforementioned control measures are in place to prevent potential cross contact.
The remainder of our products (including our small cups, quarts, kids and adult smoothies, tubes, and dairy yogurt pouches) are currently produced in facilities that do not process any tree nuts or peanuts.
If you have a severe food allergy, we suggest contacting a medical professional with any concerns you may have about trying
products. Thanks again for checking in, and don’t hesitate to reach out if you have any other questions or comments.
Is your head spinning?
I actually commend this company for being this detailed. This is the information I need to know to make the right choices for my son’s needs. I am grateful that they were willing to be this specific and disclose this information. Because they legally do not have to.
But it does highlight how complicated manufacturing is. You’ll notice that the same product, but alternate SIZES of that product are produced differently. One product size is on a line with nuts, the other is not. That means a certain SIZE of the same product is ok for my son, but not the other one.
One More Complication
The other trick to the
completely insane totally logical world of food manufacturing is that you can do your due diligence to call/email the company and find out the process, but if they change that process, they legally don’t have to tell you. This means one day they could tell you they don’t run peanuts on that line and the next day they could change it.
What gets more complicated is that this entire manufacturing circus above only involves the Top 9 allergens. I know many of you are managing food allergies that are not included in the Top 9.
This is an additional challenge that Katie and I understand all too well.
I’m not trying to overwhelm you with all of this information on the complexities of manufacturing. I just want you to really understand the process behind our food so you can make the most informed decision for your child’s needs.
Your allergist can guide you on whether or not you need to be concerned with shared lines or not.
The Good News
The good news is that there are a LOT of families that have gone before us and put pressure on the market. That pressure has created a lot more companies that are moving towards dedicated facilities and dedicated lines. Yay!
In my opinion, the legal requirements behind our food manufacturing need to change. This is too confusing and challenging for families and individuals with food allergies to navigate. That’s on my list of projects.
In full honesty, we have cut back on a lot of processed foods and make quite a bit of our own food. A lot of this has to do with my first reaction to the labels, which was shock at what is actually in our food. We are trying to be more health conscious and eat fresh.
But we have also found brands that we trust and love. We continue to add new products to our list!
As you start looking for products that work for your family, I want you to know about Snack Safely. This resource is simply amazing! These folks are AWESOME and they have compiled a mega list of products where they have ALREADY vetted the manufacturing process for you and tell you what it is.
They have different lists based on allergen to narrow it down even further. Check them out here! I have found some of my family’s favorite brands this way.
I know in the beginning of your food allergy journey, figuring out label reading and the manufacturing processing can be overwhelming. For me, I literally felt like I was starting over in my understanding of how to buy groceries. It’s a lot.
It Will Get More Manageable
Now I’m a few years in and I can encourage you that it really does get easier in the sense that it becomes more manageable as you learn. You will find the brands and products that your family loves and work well for your needs. You and your family WILL be able to find lots of foods that you love.
For us, we’re working towards building a family culture that loves food in spite of some of the challenges food allergies can pose. The focus in our house is not on what we can’t eat, it’s on all the amazing food we CAN eat!
You will figure out what works for your family. We’re here for you!
What to Read Next: The Food Allergy is Not Your Fault, Momma.
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