Guide
How to write an FDA “Contains” statement
A Contains statement is optional if every major allergen is already named in the ingredients list, but if you use one it must sit immediately after that list and name the allergens in plain English. It cannot contradict the recipe.
Reviewed against official guidance.SourcesNot legal advice.
The short answer
A Contains statement is optional if every major allergen is already named in the ingredients list, but if you use one it must sit immediately after that list and name the allergens in plain English. It cannot contradict the recipe.
Where this shows up in a real kitchen
US shoppers look for the Contains line the way UK shoppers look for bold capitals. Many small brands copy a competitor’s Contains box and never check their own kettle. That is how “Contains: milk” appears on a vegan granola, and how sesame vanishes from hummus.
The US rule
FALCPA allows the allergen to appear in the ingredients list using the common name, or in a Contains statement, or both. The Contains statement, when used, follows the ingredients list. Name tree nuts, fish and Crustacean shellfish by type. Do not use “and/or” to hedge a nut you did not put in.
How to apply it
Write the ingredients list first from weights. Highlight every major allergen. Then write Contains as a summary of those names, not a second creative document. If pecans come out of the recipe next month, the Contains line comes out the same day.
- Finish the ingredients list from the live recipe.
- Extract the major-allergen common names, with nut and fish types.
- Place Contains: immediately under the list, same panel.
- Proofread against the spec sheets, not against last week’s label PDF.
Worked example
Chocolate-chip cookies: “enriched wheat flour (wheat), butter (milk), brown sugar, chocolate chips (sugar, chocolate, cocoa butter, soy lecithin, vanilla), eggs, baking soda, salt, vanilla.” Contains: wheat, milk, egg, soy. No peanuts in the dough. A “may contain peanut” advisory is a separate cross-contact sentence, not a Contains name, unless peanut is an ingredient.
Checks that belong on this pack
| Check | Why it matters |
|---|---|
| Contains names match ingredients | A Contains allergen that is not in the list is a misbranded pack. |
| Tree nuts are specific | Contains: tree nuts is weaker than Contains: almond, pecan. |
| Sesame is present if tahini is | A 2022 habit of omitting sesame is no longer available. |
| Advisory sentences are not inside Contains | “May contain” is not a FALCPA Contains allergen. |
Putting Contains on the front as the only declaration
A heart-shaped “Contains wheat” badge on the principal display panel does not replace the ingredients list. FALCPA still wants the common name in the list or in a Contains line after it.
What LabelClear can and cannot print
Generate the ingredients line first. Add Contains as a matching summary. Do not start from a Contains box and invent the list afterwards.
Questions
Must Contains be bold?
Can I write Contains: dairy?
Do I repeat wheat if the product is named “wheat crackers”?
Official sources
Everything on this page traces back to these. Where they and we disagree, they are right — tell us and we'll fix it.
- Food Allergen Labeling and Consumer Protection Act of 2004 (FALCPA)U.S. Food and Drug Administration
- Food allergiesU.S. Food and Drug Administration
- Food Labeling GuideU.S. Food and Drug Administration
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