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Guide

Peanut allergen labeling on US food packs

Peanuts are a major allergen of their own, not a tree nut. Peanut butter, peanut oil that is not highly refined, peanut flour and satay sauces need the word peanut. A “nut-free” claim that still uses peanut is both a FALCPA failure and a claim failure.

Reviewed against official guidance.SourcesNot legal advice.

The short answer

Peanuts are a major allergen of their own, not a tree nut. Peanut butter, peanut oil that is not highly refined, peanut flour and satay sauces need the word peanut. A “nut-free” claim that still uses peanut is both a FALCPA failure and a claim failure.

Where this shows up in a real kitchen

US school-lunch rules make peanut the most politically visible allergen. Packaged cookie bakeries still miss peanut in a chocolate-chunk spec, or print Contains: tree nuts on a peanut-butter cookie. Shared fryers for peanut-oil doughnuts are a cross-contact story if peanut is not an ingredient.

The US rule

Peanuts are listed separately in FALCPA. Highly refined peanut oil has a specific FDA discussion; do not treat roasted peanut oil or peanut extract as that exemption without a spec. Advisory “may contain peanut” is voluntary and must not replace declaring peanut that you added on purpose.

How to apply it

Search specs for peanut, groundnut, arachis. Declare peanut. Keep it off the tree-nut line. If you run a peanut SKU and a peanut-free SKU, physically separate them before you promise peanut-free on the second label.

  1. Find peanut in sauces, candies and oils.
  2. Declare peanut as peanut, not as tree nut.
  3. Read chocolate and cookie inclusions for peanut pieces.
  4. Keep peanut-free claims tied to a real process, not a font choice.

Worked example

A 12 oz jar of spicy peanut sauce: peanuts, soy sauce (soybeans, wheat), sugar, chili, lime. Contains: peanut, soy, wheat. No almond. A front banner “contains nuts” is sloppy; the back must say peanut.

Checks that belong on this pack

CheckWhy it matters
Satay and kung pao sauces name peanutA teaspoon of peanut butter still counts.
Contains: peanut, not Contains: nutsPeanuts are legumes under FALCPA.
Peanut-free SKUs do not share scoopsA claim is a process, not a sticker.
Refined peanut oil is not assumed exemptGet the specification.

Filing peanut under tree nuts because customers say “nuts”

Customer language is not the Act. Peanut has its own name.

What LabelClear can and cannot print

If peanut butter is in the paste, mark peanut. Do not let a UK-style “nuts” emphasis stand in for the US word peanut.

Questions

Is peanut oil always declared?
Highly refined peanut oil is treated differently from unrefined or flavored peanut oil. Read the spec; when unsure, declare peanut.
Can I say “manufactured in a facility that also processes peanuts”?
That is advisory. It does not replace declaring peanut in the recipe.
Are boiled peanuts packaged food?
Sealed retail packs yes. A stadium paper boat of boiled peanuts served to eat now is restaurant-style.

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.