The short answer

U.S. law names 9 major food allergens: milk, eggs, fish, crustacean shellfish, tree nuts, peanuts, wheat, soybeans and sesame. Sesame became the ninth on January 1, 2023 under the FASTER Act. Every packaged food and dietary supplement sold in the U.S. must declare any of these it contains — either in the ingredient list or in a “Contains” statement. A missing allergen is a common reason for FDA detention (FDA charge “ALLERGEN”) and for recalls.

The 9 major food allergens

  • Milk
  • Eggs
  • Fish
  • Crustacean shellfish
  • Tree nuts
  • Peanuts
  • Wheat
  • Soybeans
  • Sesame

Two ways to declare allergens

The Federal Food, Drug, and Cosmetic Act allows two methods. You can use either one, or both:

MethodExampleNotes
In the ingredient listIngredients: wheat flour, sugar, butter (milk), lecithin (soy), tahini (sesame)Put the allergen source in parentheses after an ingredient whose name does not already show it.
“Contains” statementContains: wheat, milk, soy, sesame.Placed right after or next to the ingredient list. If you use one, it must list all the major allergens in the product.
✅ Use the exact allergen words: “milk”, not “dairy”; “wheat”, not just “gluten”; “soy” or “soybeans”; “egg”, not “albumin” on its own.

Name the type for tree nuts, fish and shellfish

For three allergen groups, the law requires the specific type:

What changed in FDA’s 2025 allergen guidance

On January 6, 2025, FDA finalized the fifth edition of its food allergen Q&A guidance. Three points matter for exporters:

  1. 1Coconut is no longer a “tree nut”FDA no longer treats coconut, kola nut, shea nut, chestnut, ginkgo, hickory, beechnut, butternut, chinquapin, palm nut or pili nut as tree nuts for allergen labeling. Coconut still goes in the ingredient list, but it should not appear in a “Contains” statement as a major allergen.
  2. 2Milk from goats and sheep is “milk”Milk from goats, sheep and other domesticated ruminants counts as the allergen milk. Name the animal: for example “whey (goat milk)” or “Contains: sheep milk”.
  3. 3Eggs from ducks, quail and other birds are “eggs”Name the bird: for example “Contains: duck egg”.

Example: a cheese from Greece

A feta made from sheep and goat milk must declare milk and name the animals, for example: “Ingredients: pasteurized sheep milk, goat milk, salt, cultures, rennet. Contains: sheep milk, goat milk.” A label that says only “sheep’s cheese” with no allergen declaration is misbranded.

“May contain” statements

Precautionary statements such as “may contain peanuts” or “made in a facility that also processes sesame” are voluntary and not required by U.S. law. FDA’s guidance says:

“May contain” is not a substitute for good allergen control at the factory. FDA’s preventive controls rules expect facilities to manage allergen cross-contact.

Common mistakes on imported labels

⚠️ Highly refined oils made from an allergen (for example highly refined soybean or peanut oil) are excluded from the definition of a major food allergen. Cold-pressed, expeller-pressed or unrefined oils are not excluded — check with your oil supplier.
Is your allergen declaration right?

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Frequently asked questions

What are the 9 major food allergens in the US?

Milk, eggs, fish, crustacean shellfish, tree nuts, peanuts, wheat, soybeans and sesame. Sesame was added on January 1, 2023 under the FASTER Act.

Is coconut a tree nut for FDA labeling?

No, not since FDA’s final allergen guidance of January 6, 2025. Coconut must still be listed as an ingredient, but it is not declared as a tree nut allergen.

Do dietary supplements need allergen labeling?

Yes. Packaged foods and dietary supplements must declare the major food allergens they contain, including sesame.

Is “may contain” required?

No. Precautionary allergen statements are voluntary. They must be truthful and must not replace the required declaration of allergens that are intentional ingredients.

Sources

Dates and requirements checked against FDA sources on November 11, 2026. This article is general information, not legal advice.