Food labels play a crucial role in helping people with food allergies avoid ingredients that could trigger serious reactions like anaphylaxis. However, these labels can sometimes be confusing, especially when they use terms like "may contain." This phrase is commonly used to indicate the potential risk of cross-contamination, but its meaning can be unclear. Unlike mandatory allergen warnings, the use of “may contain” is voluntary, and there are no clear legal standards defining what it means.

Understanding food labeling laws, such as the Food Allergen Labeling and Consumer Protection Act of 2004 (FALCPA), can help you make informed decisions while grocery shopping. Here’s what you need to know to stay safe and informed.

Food Labeling Requirements by Law

The U.S. Food and Drug Administration (FDA) strictly regulates food labels to help protect people with allergies. They require food companies to provide a detailed ingredient list, ensuring consumers can see exactly what is in their food. When a product contains one of the most common major food allergens, companies must also include clear allergen warnings to help protect those with allergies.

The top nine causes of food allergies include:

• Cow’s milk
• Eggs
• Fish
• Peanuts
• Sesame
• Shellfish (including crustacean shellfish like shrimp or lobster)
• Soybeans
• Tree nuts (such as pecans and hazelnuts)
• Wheat (which may also trigger reactions in people with gluten sensitivities)

If any of these allergens are present in a product, it must be clearly indicated on the packaging. Notably, sesame was recently added to the list of major allergens under The Food Allergy Safety, Treatment, Education & Research (FASTER) Act of 2021, which amended FALCPA. Therefore, products produced before Jan. 1, 2023 may contain sesame without a specific allergen warning.

Making Sense of Food Label Claims

People with food allergies should first review the list of ingredients before purchasing or trying a new product. This list is typically located just beneath the “Nutrition Facts” label. In addition to the ingredient list, many food products include separate allergen warnings, such as “Contains wheat, eggs, etc.” In some cases, products might list a lesser-known version of an allergen in parentheses, such as albumin (egg). All three types of food labeling are regulated by law under FALCPA.

For people with allergies to ingredients outside the top nine allergens, finding necessary information can be more challenging. For instance, flavoring agents or other ingredients may be listed under broad terms like “natural flavors,” which may not clearly identify potential allergens.

To stay safe, it’s crucial for individuals with food allergies to familiarize themselves with the alternative names of their allergens. For example, people allergic to milk should know terms like whey or casein. The Food Allergy Research & Education website offers resources, including a guide to alternative allergen names, to help consumers identify hidden allergens on food labels.

Understanding the Risk of Cross-Contamination

The term “may contain” is not regulated by law in the U.S. It serves as a precautionary warning that some brands voluntarily include on food labels to inform customers of potential risks. Typically, this label is used when foods are produced in the same facility as products containing allergens. For instance, a company that makes both granola bars and crackers may state that the crackers “may contain peanuts” if the granola bars include peanuts, even though peanuts aren’t an actual ingredient in the crackers. Despite thorough cleaning of equipment, there’s still a possibility of cross-contamination or accidental mixing of ingredients. This could pose a risk for people with severe allergies or those needing gluten-free options.

Unfortunately, “may contain” statements can be less reliable because they are not mandatory and carry no legal enforcement. Similarly, labels such as “processed in a facility that also processes peanuts” are also voluntary and lack a standardized legal definition.

One member shared how they manage concerns of cross-contamination: “I’ve had a peanut allergy since childhood. If that’s the only food allergy, there are still a lot of choices for you: fruits and vegetables, cow’s milk products, meats, etc. The main problem is with baked goods, where there’s a risk of cross-contamination. Read labels carefully. If you are buying from a bakery counter, you can’t necessarily rely on the word of the person there. To be safe, just avoid that altogether. And unfortunately, most ice cream is processed in places with peanuts, so you need to be very careful reading labels there. But there are still options open for you.”

People with food allergies should always be reasonably cautious about foods that could have been cross-contaminated. If in doubt, it’s often best to avoid the risk altogether for optimal food safety.

Challenges of Label Reading

“Read ingredient labels, folks,” a MyFoodAllergyTeam member shared. “I was given a salad for lunch from our local food bank, and luckily, I read the ingredient label. Potatoes in the shaved cheddar cheese topping feel like the latest ’whodunit’ to examine every bite for my mouth.”

Some members of MyFoodAllergyTeam have found it difficult to remember to check labels consistently. “Just had to dig my EpiPen out. I just hope I don’t have to use it. I ate half a bag of sweets. Halfway through thought, these don’t taste right. Better check. I could not believe it, coconut. Never used an EpiPen before. Just hope I can figure it out.”

Others struggle with the time-consuming nature of reading labels carefully while shopping. “Grocery shopping is always a bit stressful, but I have learned to go at off times to avoid crowds and dirty looks, and I pause to read EVERY label!” a member shared.

Even when they remember to check every label, some members feel frustrated when they can’t find the information they need. “I am upset that I can’t figure out the majority of food labels,” one member wrote. “The term ‘natural flavors’ isn’t helpful. I keep having reactions from foods I think might be OK until I dig deeper.”

One member found apps that help them interpret labels. “I use several apps to help with reading labels: Fooducate, Ipiit, and ShopWell,” they shared. “Sometimes, I use them all while I’m in the store. It takes the guesswork out of understanding labels. I enter in my allergies, and they do the rest.”

You can also contact food manufacturers directly to ask about food allergen labeling and manufacturing practices for specific packaged foods.

Other precautions to keep in mind include:

• Claims like “peanut-free” aren’t regulated and don’t guarantee a completely safe product.
• Manufacturing processes and recipes can change without warning, so always check familiar foods before assuming they’re still safe.
• Products from other countries don’t necessarily follow the same labeling laws as the U.S.

If you're finding it challenging to interpret food labels, don’t hesitate to seek professional guidance. Your allergist and a registered dietitian nutritionist can offer valuable advice. Some grocery stores even have in-store dietitians who can assist you while you shop.

Talk With Others Who Understand

On MyFoodAllergyTeam, the social network for people with food allergies and their loved ones, more than 41,000 members come together to ask questions, offer support and advice, and connect with others who understand life with food allergies.

Have you had an unexpected allergic reaction to a food item you thought was safe to eat? What are your tips for checking food packaging and avoiding cross-contact with allergens? Share in the comments below, or start a conversation by posting on your Activities page.