Allergen Labeling: Writing a Contains Statement

The nine allergens and where they hide in baking

The Food Allergen Labeling and Consumer Protection Act of 2004 (FALCPA) defined the original eight major food allergens. The FASTER Act added sesame as the ninth, effective January 1, 2023. If your product contains any of them, as an ingredient or inside an ingredient, the label has to say so.

Allergen	Obvious in baking	Less obvious
Milk	Butter, cream, buttermilk, cream cheese	Whey, casein, milk chocolate, some margarines, ghee
Eggs	Whole eggs, egg wash	Meringue powder, some glazes, mayonnaise in chocolate cake recipes
Wheat	All-purpose and cake flour	Breadcrumbs, cookie crumbs in fillings, some baking mixes
Soybeans	Soy flour	Soy lecithin in chocolate chips and coatings, some shortenings
Peanuts	Peanut butter	Candy toppings, some chocolate decorations
Tree nuts	Pecans, walnuts, almonds	Almond extract, marzipan, almond flour, pistachio paste
Sesame	Sesame seeds on buns	Tahini in cookies and brownies
Fish	Rare in sweets	Anchovy in savory fillings
Crustacean shellfish	Rare in sweets	Shrimp in savory hand pies

FDA also treats milk from goats, sheep and other ruminants, and eggs from ducks, geese, quail and other fowl, as major food allergens. A goat-milk cheesecake or a duck-egg sponge needs an allergen declaration like any other.

There is one notable exception in the law: highly refined oils derived from an allergen, and ingredients derived from such oils, are not major food allergens under FALCPA. Most bakers never hit this, but it explains why some refined oils do not carry a declaration.

Two ways to declare an allergen

FALCPA gives you two options, and you can use either.

Option 1: In parentheses inside the ingredient list

Put the food source in parentheses after the ingredient’s name: “lecithin (soy)”, “whey (milk)”, “flour (wheat)”. The parenthetical can be skipped only when the ingredient’s common name already uses the name of the allergen source, like “wheat flour” or “almonds”, or when that source name already appears elsewhere in the ingredient list. “Butter”, “whey” and “sour cream” do not say “milk”, so with this method they need “(milk)” after them.

Option 2: A Contains statement

Print the word “Contains” followed by the allergen sources. FALCPA section 403(w)(1) sets two placement rules:

• It must be printed immediately after or adjacent to the ingredient list.
• It must be in a type size no smaller than the type used in the ingredient list.

For a home baker, the Contains statement is usually easier. Customers with allergies look for it, it survives recipe tweaks well, and it is the format the workbench’s label maker prints. Use one approach consistently and list every major allergen in the product. A Contains line that names some allergens but not others misleads the very customers it is meant to protect.

Name the specific tree nut, fish or shellfish

“Contains: tree nuts” is not a complete declaration. The law requires the type of tree nut (almonds, pecans, walnuts), the species of fish (bass, flounder, cod) and the type of crustacean shellfish (crab, lobster, shrimp). A praline cookie made with pecans and an almond-flour crust says:

Contains: wheat, milk, eggs, pecans, almonds.

Coconut is no longer a tree nut

FDA published a revised 5th edition of its Food Allergen Q&A guidance on January 6, 2025. It removed coconut from the tree nut list, along with beech nut, butternut, chestnut, chinquapin, cola or kola nut, ginkgo nut, hickory nut, palm nut, pili nut, shea nut and lichee nut. Older labels often say “Contains: tree nuts (coconut)”. Under current FDA guidance you no longer need that declaration for coconut macaroons. You still list coconut in the ingredients, and many bakers note it for customers who avoid it.

Worked example: banana walnut bread

Recipe ingredients for this loaf, heaviest to lightest by weight as required by 21 CFR 101.4 (your order depends on your recipe’s weights):

Ingredients: bananas, enriched flour (wheat flour, niacin,
reduced iron, thiamine mononitrate, riboflavin, folic acid),
sugar, eggs, walnuts, butter (cream, salt), sour cream
(cultured cream), baking soda, vanilla extract, salt.
Contains: wheat, eggs, walnuts, milk.

Walk through it:

1. Wheat is in the enriched flour. The sub-ingredients name wheat flour, so the parenthetical method would already be covered, but the Contains line repeats it for clarity.
2. Eggs are listed by name.
3. Walnuts are a tree nut and are named by type.
4. Milk hides in two places: butter and sour cream. Neither name says “milk”, which is exactly the case the Contains line is for.

If the same bread had chocolate chips with soy lecithin, you would add “soy” to the Contains line, which is why sub-ingredients matter. Copy them from the package label every time you buy a new brand.

Cross-contact and “may contain”

Advisory statements such as “May contain peanuts” or “Made in a kitchen that also processes tree nuts” are not required by law, and FDA says they should not be used as a substitute for following good manufacturing practices. In practice:

• Clean equipment, bowls and surfaces between allergen and non-allergen batches.
• Bake allergen-free items first in the day.
• Keep nut products in sealed, labeled containers.
• Use an advisory statement only when a real risk remains after those steps, and word it truthfully.

Some states have their own rules for cottage foods. Texas, for instance, lists major allergens among its required label items. Check your state on the cottage food laws hub, and see the full label checklist in cottage food label requirements.

Common mistakes

• Forgetting sub-ingredients. Sprinkles, chocolate chips, cookie crumbs and store-bought frosting often add soy, milk or wheat.
• Generic tree nut wording. Always name the nut.
• Separating the Contains line from the ingredients. Placing it on the back while the ingredients are on the side does not meet the “immediately after or adjacent” rule.
• Smaller type. The Contains line cannot be in finer print than the ingredient list.
• Labels that outlive the recipe. A supplier switch from one chocolate brand to another can add or remove soy and milk.

Build allergens into your recipe records

The easiest way to keep allergen labels right is to attach allergen flags to each ingredient once, in your ingredient library, and let every recipe inherit them. In the Proofsheet workbench, each ingredient carries its allergens, sub-recipes pass theirs up, and the label maker writes the Contains line from the recipe. When you change a supplier, edit the ingredient once and reprint.

Costing and labeling use the same data: weights in grams order the ingredient list and drive the cost. If you have not entered your recipes yet, start with the recipe cost calculator, convert any cup measures with the baking unit converter, and read how to price baked goods to turn those costs into prices. If you plan to add nutrition numbers too, the nutrition facts guide explains when you need them.