Guide
“May contain” statements on US food labels
FDA does not require “may contain peanut” advisory labels. They are voluntary risk communication for genuine cross-contact you cannot reasonably eliminate. They are not a substitute for declaring peanuts you put in the recipe, and they are not a legal shield if your process is sloppy.
Reviewed against official guidance.SourcesNot legal advice.
The short answer
FDA does not require “may contain peanut” advisory labels. They are voluntary risk communication for genuine cross-contact you cannot reasonably eliminate. They are not a substitute for declaring peanuts you put in the recipe, and they are not a legal shield if your process is sloppy.
Where this shows up in a real kitchen
US brands copy “may contain traces of all nine allergens” onto every pouch. Allergic families then ignore every line. FALCPA still wants sesame named when tahini is an ingredient. An advisory that lists the whole universe is not FALCPA compliance and is poor communication.
The US rule
FALCPA covers ingredients. FDA has said precautionary allergen labeling should be truthful and not misleading. There is no US statute that forces PAL wording, unlike some countries’ stricter codes. UK FSA also treats PAL as not legally required — the honesty test is similar even though the major-allergen lists differ.
How to apply it
Map real shared equipment. If peanut butter never enters the room, do not write may contain peanut. If sesame dust is unavoidable on a bun line, an advisory can be honest after you have already declared sesame on sesame buns. Do not use PAL to avoid cleaning.
- List which major allergens actually enter each room.
- Declare ingredients under FALCPA first.
- Write PAL only for documented residual risk.
- Review PAL quarterly when the schedule changes.
Worked example
A peanut-free oatmeal cookie baked after a peanut-cookie shift on the same uncleaned tray: the oatmeal cookie must not pretend to be peanut-free. If peanut is not an ingredient, Contains should not list peanut; a specific advisory may be warranted until you split trays. Cleaning and scheduling are better than a permanent vague PAL.
Checks that belong on this pack
| Check | Why it matters |
|---|---|
| PAL does not name an ingredient already absent and uninvolved | A fiction advisory is misleading. |
| Ingredients still have Contains or list names | PAL is not a FALCPA alternative. |
| Wording is specific | “May contain almond” beats “may contain nuts and seeds and more”. |
| Process changes update PAL | A new peanut SKU on Monday is a Tuesday label job. |
A Contains line that is actually a may-contain dump
Contains: milk, egg, wheat, soy, peanut, tree nuts, fish, shellfish, sesame on a saltine recipe is not caution. It is noise, and it is inaccurate if those foods are not ingredients.
What LabelClear can and cannot print
Mark allergens that are in the paste. Use PAL only as a separate, honest sentence about the room — not as a ninth Contains name you did not bake in.
Questions
Does FDA ban PAL?
Is “made in a factory that also handles peanuts” better?
Should I PAL everything to be safe?
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 allergiesU.S. Food and Drug Administration
- Food Allergen Labeling and Consumer Protection Act of 2004 (FALCPA)U.S. Food and Drug Administration
- Food Labeling GuideU.S. Food and Drug Administration
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