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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.

  1. List which major allergens actually enter each room.
  2. Declare ingredients under FALCPA first.
  3. Write PAL only for documented residual risk.
  4. 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

CheckWhy it matters
PAL does not name an ingredient already absent and uninvolvedA fiction advisory is misleading.
Ingredients still have Contains or list namesPAL is not a FALCPA alternative.
Wording is specific“May contain almond” beats “may contain nuts and seeds and more”.
Process changes update PALA 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?
No. It wants PAL, if used, to be truthful.
Is “made in a factory that also handles peanuts” better?
It can be clearer than “may contain”. It is still advisory, not an ingredients declaration.
Should I PAL everything to be safe?
No. Over-warning hides the real risks and can be misleading.

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.