Do the allergen labeling requirements of the FD&C Act provide specific direction for declaring the presence of ingredients from the three food groups that are designated as “major food allergens (i.e., tree nuts, fish, and Crustacean shellfish?”)
Yes, the FD&C Act requires that the specific type of tree nut be declared (e.g., almonds, pecans, or walnuts). It also requires that the species must be declared for fish (e.g., bass, flounder, or cod) and Crustacean shellfish (e.g., crab, lobster, or shrimp) (section 403(w)(2) of the FD&C Act). This means the ingredient list or the “Contains” statement cannot broadly declare “tree nuts,” “fish,” or “Crustacean shellfish” as the major food allergen.