The 9 Major Food Allergens in the US: A Parent's Complete Guide (FDA FALCPA + FASTER Act 2023)

Guide | US Food Allergies

The 9 Major Food Allergens in the US: A Parent's Complete Guide (FDA FALCPA + FASTER Act 2023)

Since January 1, 2023, sesame became the 9th major food allergen in the United States under the FASTER Act (Food Allergy Safety, Treatment, Education, and Research Act). If you are raising a child with food allergies, understanding what the law requires - and what it doesn't - can mean the difference between a safe meal and a medical emergency. Here is everything you need to know.

The 9 Major Allergens Under US Law

The Food Allergen Labeling and Consumer Protection Act (FALCPA), passed in 2004, established the original eight major allergens. The FASTER Act added sesame as the ninth, effective January 1, 2023. The nine are:

1. Milk - Found in dairy products, butter, cheese, cream, and many baked goods and processed foods. Hidden in ingredients like casein, whey, lactalbumin.
2. Eggs - Found in baked goods, mayonnaise, pasta, and many sauces. May appear as albumin, globulin, or lecithin (when egg-derived).
3. Fish - Includes species like salmon, tuna, cod, and tilapia. Must be declared with the specific type of fish (e.g., "contains: fish (salmon)").
4. Shellfish - Crustaceans: shrimp, crab, lobster, crayfish. Note: mollusks (oysters, clams, scallops) are NOT covered by FALCPA as a major allergen.
5. Tree nuts - Almonds, cashews, walnuts, pecans, pistachios, and others. Each specific tree nut must be named on the label.
6. Peanuts - Technically a legume, but one of the most common and severe allergens. May appear as groundnuts, mixed nuts, beer nuts.
7. Wheat - Includes all forms of wheat. Note: wheat allergy is distinct from celiac disease (see below).
8. Soybeans - Found in tofu, edamame, miso, soy sauce, and countless processed foods as soy protein or soy lecithin.
9. Sesame - Seeds, oil, paste (tahini), and flour. Added under the FASTER Act, effective 2023.

"Contains" vs. "May Contain"

• "Contains" statements are mandatory under FALCPA. If a product contains any of the 9 allergens, the manufacturer must declare it clearly - either in the ingredient list (in bold) or in a separate "Contains: wheat, milk" statement immediately following.
• "May contain" / "processed in a facility with…" statements are entirely voluntary. There is no FDA standard governing when a manufacturer must use them or what they mean. Two products with identical cross-contact risk may have very different advisory labels - or none at all.

What the FASTER Act Changed (Effective January 1, 2023)

Before 2023, sesame was not a federally mandated labeled allergen. This created a significant hidden risk: manufacturers could list sesame as part of generic ingredient terms like "spices," "natural flavors," or "mixed seasonings" - with no obligation to name it.

The FASTER Act changed that. As of January 1, 2023:

• Sesame must be declared on all food labels, the same way milk or peanuts are declared.
• The specific word "sesame" must appear either in the ingredient list or in the "Contains" statement.
• Manufacturers had until January 1, 2023 to update their labels.

An unintended consequence noted by advocacy groups: Some manufacturers, rather than reformulating products to remove sesame, chose to add sesame to their formulas and declare it - meaning some previously sesame-free products now contain sesame. If your child has a sesame allergy, re-check labels on products you previously considered safe.

For the most current guidance on the FASTER Act and sesame labeling, see FARE (Food Allergy Research & Education).

How to Read a US Food Label for Allergens

Step 1 - Find the ingredient list

Ingredients are listed in descending order by weight. Allergens must be identified in plain language within the ingredient list (e.g., "flour (wheat)" rather than just "flour").

Step 2 - Check the "Contains" statement

Immediately after the ingredient list, many products include a bolded "Contains:" line listing the major allergens present. This is the quickest scan, but do not rely on it alone - always read the full ingredient list, as errors and omissions occur.

Step 3 - Evaluate advisory statements

"May contain traces of peanuts" or "Made in a facility that also processes tree nuts" are voluntary and unregulated. They signal that a manufacturer has identified a cross-contact risk, but their absence does not mean a product is free of cross-contact risk.

Cross-contact vs. cross-contamination

• Cross-contact occurs when an allergen is unintentionally transferred to a food that does not contain it as an ingredient - for example, from shared equipment or surfaces.
• Cross-contamination technically refers to microbial contamination. In food allergy contexts, "cross-contact" is the correct term, though "cross-contamination" is used colloquially.

Celiac Disease vs. Wheat Allergy - What's the Difference?

These are two distinct conditions that both require avoiding wheat, but for different reasons:

	Wheat Allergy	Celiac Disease
Mechanism	IgE-mediated immune response to wheat proteins	Autoimmune reaction to gluten (a protein in wheat, barley, rye, and some oats)
Triggers	Wheat only	Wheat, barley, rye, and oats containing gluten
Reaction type	Can be immediate (anaphylaxis possible)	Gastrointestinal damage, systemic inflammation
Labeling protection	Covered under FALCPA "wheat" allergen	Requires "gluten-free" certification
Gluten-free label	May or may not be needed	Required - FDA mandates < 20 ppm

For celiac disease, a product labeled "gluten-free" must contain less than 20 parts per million (ppm) of gluten under FDA rules - but a product merely labeled "wheat-free" may still contain barley or rye and would not be safe for celiac patients.

Our Experience as Parents

We are Mark and Regina Pivovarov, founders of pashutFree and parents of a child with celiac disease. Reading food labels became a survival skill in our household. The FASTER Act update reminded us that food safety regulations are not static - they evolve, and so must our habits. We re-checked every product in our pantry when sesame became a declared allergen, and we found surprises. We built pashutFree because we believe every family deserves tools that make this process simpler and less stressful.

Disclaimer

We are not doctors or dietitians. The information in this article is for educational purposes only and does not constitute medical or dietary advice. If you or your child has been diagnosed with a food allergy or celiac disease, please consult a qualified physician or registered dietitian.

Sources: FARE - Food Allergy Research & Education | FDA Food Allergen Labeling