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FALCPA Creates Potential Challenges for the Food Industry

Beginning January 1, 2006, FALCPA will require labeling of any ingredient that is one or is derived from: milk, egg, fish, crustacean shellfish, tree nuts, wheat, peanuts, or soybeans.

Key points:

  1. Includes product cross-contact and flavorings, colorings, incidental additives, and packaging.

  2. Requires declaration of the specific type of nut (g., almonds, pecans, or walnuts), the species of fish (e.g., bass, flounder, or cod), and the kind of crustacean shellfish (e.g., crab, lobster, or shrimp), respectively.

  3. Only exclusions are highly refined oils and alcoholic beverages.

  4. There are two ways to label products, within statement of ingredients or in separate statement, but must include common or usual name of allergen.

  5. For example – Ingredient listing: MILK – listed with other ingredients CASEIN (MILK) or WHEY (MILK) – adding the food source in parentheses where the technical term is used in ingredient list.

  6. A statement immediately following the ingredient list – ALLERGEN INFORMATION: Contains Milk – immediately following or next to the ingredient list; or CONTAINS MILK – at the end of ingredient list.