Allergen labels for cottage bakers

Under US federal law, packaged food has to declare the nine major food allergens: milk, eggs, fish, crustacean shellfish, tree nuts, peanuts, wheat, soybeans and sesame. Most state cottage food laws also require allergens on your labels, so the same rules shape what you print on a bag of cookies or a loaf of bread.

The nine major food allergens

AllergenWhere bakers meet it
WheatFlour of almost every kind, including spelt and many "ancient grain" flours
MilkButter, cream, buttermilk, milk powder, milk chocolate
EggsWhole egg, egg wash, meringue, some icings
Tree nutsAlmonds, pecans, walnuts, hazelnuts, cashews, pistachios: name the nut
PeanutsPeanut butter, some chocolate and toppings
SoybeansSoy flour, soy lecithin in chocolate, some shortenings
SesameSeeded breads and bagels, tahini
Fish and crustacean shellfishRare in baking, but name the species if used

Sesame became the ninth major allergen under the FASTER Act, and has had to be declared on labels since January 1, 2023. The FASTER Act (FDA).

Two ways to declare allergens

  1. A "Contains" statement right after the ingredient list: Contains: Wheat, Milk, Eggs, Pecans.
  2. In the ingredient list itself, in parentheses after the ingredient: flour (wheat), butter (milk).

For tree nuts, fish and shellfish, name the specific type ("pecans", not just "tree nuts"). If an allergen is hidden inside another ingredient, such as sesame in a spice blend, it still has to be declared. How allergen labels work (FDA).

A cottage food label, line by line

Chocolate Chip Pecan CookiesIngredients: Enriched flour (wheat flour, niacin, reduced iron, thiamine mononitrate, riboflavin, folic acid), butter (milk), brown sugar, semi-sweet chocolate chips (sugar, chocolate, cocoa butter, soy lecithin, vanilla), pecans, eggs, baking soda, salt, vanilla extract.
Contains: Wheat, Milk, Soy, Pecans, Eggs.
Net wt. 12 oz (340 g) · Made by Sam's Kitchen, 12 Oak St, Springfield
Made in a home kitchen that is not inspected by the state health department.

Most states ask for these on a cottage food label, but the home kitchen statement's exact wording, and whether you can use a registration number instead of your address, are set by each state. Check yours before you print.

"May contain" statements

Statements like "may contain tree nuts" or "made in a kitchen that also handles peanuts" are voluntary. They should be truthful, based on a real risk of cross-contact, and never used instead of keeping allergens apart and cleaning down between bakes.

How bakerykeeper helps

  • Allergens from your recipes, never typed by hand. Each ingredient carries its allergens, and every bake works them out from its recipe, including fillings and frostings.
  • The nine US majors are covered. All nine are among the 14 allergens bakerykeeper tracks today.
  • One change updates everything. Switch chocolate chip brands and every recipe that uses them updates.

Label layouts follow UK rules today. US-format labels with a "Contains" statement are what US bakers will need, so tell us what your state asks for when you join the US list.

General guidance, not legal advice. The FDA sets the federal allergen rules, and your state sets cottage food labeling. Both have the final word.

Questions about allergen labels

Do cottage foods need a Nutrition Facts panel?

Usually not. Most cottage food products are exempt unless you make a nutrition or health claim, such as "low fat". Check your state's rules.

Is gluten one of the major allergens?

Wheat is the major allergen. Gluten is separate: if you label something "gluten-free", it has to meet the FDA's gluten-free rule, which sets a limit of less than 20 parts per million.

Do I need a "Contains" line if the ingredients already name the allergen?

Under federal rules, an ingredient whose name already identifies the allergen, like "wheat flour" or "pecans", declares it. Many bakers add a "Contains" line anyway, because it's clearest for customers, and if you use one it has to list every major allergen in the product.

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