Many readers of my Nut-Free Mom Facebook page have brought up the question of food labels recently so I thought it was a good time to tackle this increasingly confusing subject.
If you are new to food allergies (and even if you've been dealing with it for awhile like I have) one of the most daunting things you experience is a trip to the supermarket. What do the labels mean? If it doesn't say anything about food allergens, does that mean it's safe to eat? What are you supposed to do, call every food company?
The answers vary, but first it helps to understand the current FDA food allergy labeling laws.
Current food allergy labeling laws: FALPCA
The Food Allergen Labeling and Consumer Protection Act of 2004 (FALPCA) ensures that foods will include "plain language" listing of the top 8 common food allergens. These are considered to be: soy, egg, dairy, wheat, fish, shellfish, tree nuts and peanuts.
The FALPCA law also requires that companies also list exactly what the allergen is, for example, they must name "pecans" if it is a tree nut or "shrimp" if talking about shellfish. It must be specific.
Here is an excellent document from the USDA that explains more about FALPCA.
A common misconception about FALPCA is that this law requires companies to add "may contains" or "processed in a facility with" or "processed on equipment with" statements. These are NOT required by law and are in fact voluntary statements placed there at the discretion of the food manufacturer. If do you see these statements, please don't discount them. A study was done of "may contains" statements and it was found that a large percentage of the time the food item in question did contain the allergen even though it was not an official "ingredient."
What does it all mean?
Where does that leave us when grocery shopping? First off, you must read every label every time because practices do change. Just because it was safe before does not mean that it's safe today. Check every item you plan to serve to an allergic person, every time.
When you see a food label with no allergy warnings and it is a "high-risk" food for nut allergies such as ice cream, candy or baked goods, that's when you may need to call the company. I always start by going online and reading allergy labeling policies -- some companies even let you search according to the exact brand name or type of food. If you call, have the UPC symbol with you--take a pic of it with your cell phone, but have it because then you will exact info for the product in question. Also, have the exact item name. (The UPC code will usually suffice if you don't have this). UPC codes are the numbers beneath the "lines" on a package so that it can scan at the grocery store. It's also known as a "bar code."
Some companies will not give you complete info. Some will tell you to avoid all of their foods. Some will even list "may contains" warnings on their web sites but not on the actual package. (Edy's brand ice cream does this, for example.) Another practice that is relatively new it to tell consumers to look for certain "ID" numbers that supposedly indicate what plant the food was made in. Ragu said this to many of us a few months ago in response to new tree nut allergy warnings on some of their sauces. Supposedly if it had a certain "code" that meant the sauce didn't have tree nut allergy risk.
To me, this is bunk. It does NOT fall within current FDA law to play roulette with consumers and I would avoid companies and/or products that try to hedge their bets this way.
Ultimately it is up to you, the consumer, to decide what you feel comfortable serving to a person with severe food allergies. If avoiding reactions is your goal, a conservative approach will serve you well. Until we have more complete labeling policies, a lot of this is going to be up to us to manage, ask questions about and deal with.
Eventually you will find the foods and companies that you feel you can trust. You will probably also find yourself making more food so that you know what goes into it.
Please note that I am unable to answer specific questions about specific food companies. I'm a consumer just like you so I would advise contacting companies directly with your questions and concerns.
Here are some additional links that describe current food allergy labeling laws:
Official food labeling law w/regard to food allergens from FDA web site
Food Labeling law explanation
Other FALPCA requirements