Last week was Food Allergy Awareness Week, and we’re bringing attention to this growing public health concern. Food Allergy Research and Education (FARE) estimates that 32 million Americans are affected by food allergies and that the prevalence of food allergies continues to rise. With those statistics, there is a good chance you or someone you know deals with a food allergy daily. The rise in food allergy prevalence is not due to pure chance, and several theories have been put forward to explain the upward curve. The “hygiene hypothesis” suggests that children today are growing up in cleaner environments and thus are exposed to fewer germs that are able to “train” their immune systems to know what is and is not dangerous. Other theories attribute the increase in food allergies to changes in the gut microbiome, switches in diet, and certain environmental factors. Whatever the reason, food allergies are on the rise, and while many people can self-manage their allergy, food allergen labeling is key to creating a safe food supply for everyone.

Effective food allergen management

According to IFIC’s 2019 Food and Health Survey, consumers most commonly manage their food allergies by carefully reading labels (45%) or avoiding certain types of restaurants and cuisines (37%). In this vein, IFIC encourages consumers to learn how to read labels carefully, exploring various terms that less commonly describe an allergy (e.g., casein protein versus milk), as well as to know which questions to ask when eating out. To outsiders, a food allergy may not be obvious, so many people with allergies also wear a medical bracelet, carry medication, and have emergency contact information ready in case they need help.

Consumers aren’t the only ones responsible for managing food allergies. The Food Allergen Labeling And Consumer Protection Act (FALPCA) is a Food and Drug Administration (FDA) mandate that all food must be labeled if it contains one of the eight major food allergens. Manufacturers are also advised to have conscientious manufacturing practices in place to avoid cross–contact between allergens. These practices may include using different lines for products with and without a common allergen, sanitizing equipment between products, and requiring handwashing and glove–wearing of all employees.

What is precautionary labeling, also known as “May Contain”?

Some food companies also opt in to include a “may contain” statement on their products to warn consumers of possible cross–contact. This is an example of precautionary labeling. Products with these labels do not have the identified allergen in their original recipe or ingredient list, but the product may have come in contact with it during processing. This can happen if the same machine is used, for example, to make both peanut butter cookies and shortbread cookies. The shortbread cookies might have a label saying “may contain peanuts,” even though no peanuts or peanut products have been used to make the actual cookie. The FDA does not mandate that all companies use this type of labeling. Instead, it emphasizes the importance of sound manufacturing practices—like cleaning and sanitizing machines when handling food allergens—and stresses that precautionary labels should not serve as a replacement for these practices.

Barriers to understanding “May Contain”

Despite its best attempts, precautionary labeling can cause confusion. Since there is no current regulatory guidance on this type of labeling, consumers are not always clear about what the label means or how risky the product is if the person has a food allergy. A “may contain” statement might mean that a product came in contact with a known allergen, that some of the allergen accidentally touched the product, or that there was no interaction whatsoever between the product and the allergen. Alternatively, because this kind of labeling is not mandatory, some products may have come into contact with a major allergen but do not carry the warning, putting consumers unknowingly at risk.

Additionally, companies can choose to remove the precautionary label at any time, even when the product’s formula hasn’t changed. Adding another level to this confusion, especially for stressed parents and those newly diagnosed with a food allergy, is the inconsistent language in precautionary labeling, with producers using phrases such as “may contain,” “manufactured in a facility that uses,” or “processed in a facility that uses.” While these phrases all ultimately serve the same purpose, they may be interpreted in different ways.

Practical tips and recommendations

Living with a food allergy is already stressful, but unclear labeling and confusing ingredient lists can make it worse. Organizations like FARE and FAACT (the Food Allergy and Anaphylaxis Connection Team) offer resources to help dispel myths. Here are five big tips to help manage potential risk:

1. Know the less common names for relevant food allergens. The eight most common food allergens are required to be listed as their common name, but less common allergens are not held to this same level of scrutiny. According to the FDA, “FALCPA identifies eight foods or food groups as the major food allergens. They are milk, eggs, fish (e.g., bass, flounder, cod), Crustacean shellfish (e.g., crab, lobster, shrimp), tree nuts (e.g., almonds, walnuts, pecans), peanuts, wheat, and soybeans.”
2. Avoid products that do not have a precautionary label. If you cannot avoid a product, contact the manufacturer to ask if the product contains a specific allergen.
3. Imported products may not have the same labeling requirements as U.S.-manufactured products do. Avoid these products or be extra careful when considering them.
4. Phrases such as “egg-free” and “peanut-free” are not regulated. If you do not see a FALCPA-mandated label on the product, contact the manufacturer to help determine whether or not the product is safe for you.
5. Engage with others in the food allergy community and continue learning. The more you know, the safer you can keep both yourself and your loved ones.

Food allergen labeling can be confusing, but the quality of life for those with allergies can improve vastly with a bit of learning and understanding. Sharpen those allergen identifying skills to help you decide which food products pose the greatest risk and which can be safely consumed. Taking a risk with a “may contain” food product is not worth the potential contamination.

This article was written by Courtney Schupp, MPH, RD.