2 – Mandate a “Top Allergens Processed in Facility” statement
Contrary to popular belief, the FDA does not require manufacturers to disclose when any of the Top 8 allergens are processed in the same line or facility as a product.
Package advisories like “May contain traces of almonds” or “Manufactured in a facility that also processes wheat” are entirely voluntary and the FDA has nothing to say about when they should be used, how they should be worded, or where they should appear.
Some manufacturers include such warnings, some don’t, and some will warn for one Top 8 allergen (say peanuts) and not for another (say soy). Their absence does not mean the product is safe from your allergen of concern!
The FDA should mandate a single advisory appear on the label whenever a top allergen is processed in the same facility but is not an ingredient of the product. We prefer:
Top Allergens Processed in Facility: peanuts, soy.
Although this will certainly elicit strong resistance from manufacturers that prefer to keep such information hidden from the public, we believe every allergic consumer has the right to know how a product is manufactured at the point of purchase so they can gauge the risk for cross-contact themselves.
But what about those responsible companies, the ones that go the extra mile to minimize the opportunity for cross-contact by swabbing their equipment to test for protein residue and testing finished product for traces of the Top allergens processed in their facility? They are welcome to disclose their procedures on the label or direct the consumer to their website to provide such information.