Nut-free labeling is an important concept to understand, as it is often confusing at first. As someone who isn’t allergic to nuts but cares for people who are… When I first started learning about nut free labeling, I was so confused by which products were safe for nut-allergic folks and which ones weren’t. Food companies use various methods of labeling, and I had to ask my nut allergic friends a lot of questions. I hope this guide makes identifying safe snacks a little easier for the friends of the nut free community, and for families of a child with a newly diagnosed allergy.
Federal law requires most packaged foods to indicate when a product includes a major food allergen. Sometimes companies will list the top eight allergens in bold, when they’re included in the ingredient lists. The majority of times a food label will feature a “Contains label” at the bottom of the label, that lists out the eight major allergens in it’s own section. But, there’s actually no federally regulated nut free labeling. There isn’t one nut free labeling the nut free community can look for to see if a snack is safe for them to eat.
Food companies have different practices and those practices each come with a different risk assessment. Sometimes when you see a nut free labeling on packaging, it’s because the company created their own standards for what their nut free labeling means. Normally when that label is being used, it’s by a specialized snack company, purposefully catering to the nut free community.
The following six phrases are different variations of nut free labeling I’ve familiarized myself with over time.
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1. Made in a Dedicated Nut Free Facility
This is the ideal. When a company labels their product as being made in a dedicated nut free facility, it means no product manufactured in their facility includes nuts. Products created in dedicated nut free facilities are not only free from peanut and tree-nut ingredients, but they’re also free from potential exposure to cross-contamination of the facility. They have rigorous standards for what “nut free” means. And, many facilities have additional voluntary allergy safety precautions put into place — like gloves, prohibiting their employees from eating nuts at lunchtime or on breaks, and routinely having their finished products testing for allergen exposure.
Unlike standard food production facilities, dedicated nut free facilities don’t share any equipment with food that would have the potential to leave any trace of nut particles. All products made in dedicated nut free facilities are nut free.
The difference in diligence becomes important to the severely allergic members of the nut free community. Some food allergies are so sensitive that they can be triggered and set off by cross-contamination, even after a machine has been washed and sanitized. If there is any trace left over, and that trace gets inside a food product, that could be enough to trigger an allergic reaction in the severely allergic.
While some mainstream brands opt for higher standards and this nut free labeling, many companies that use this labeling are smaller and boutique. I've noticed a lot of companies that use this nut free labeling are from inside the community. To them, severe nut allergies are personal. It’s often used by entrepreneurs with family members and children that grew up with severe life-threatening allergies, or entrepreneurs that have severe life threatening allergies themselves. These companies are typically created with the needs of the nut free community at the forefront of their business mission.
I enjoy supporting entrepreneurs from within the community when I can. They understand the needs. I think the more we can support them, the more they’ll be able to continue making products that support the community.
There is a definite need for clearer allergen nut free labeling. When manufacturing processes are transparent, then the community can access the risk on their own, depending on the severity of their allergy. Oftentimes, nut allergies are very severe. The nut free community knows this, which is why nut free entrepreneurs are the ones setting this standard of cleanliness and transparency. This generation of entrepreneurs are making great products. Because this is the best nut free labeling available, I encourage you to check you my review of dedicated nut free facility snacks I recommend.
2. Labeled “Nut-Free”
The Nut Free labeling means the product does not contain nuts. However, it doesn’t guarantee the snack was made inside a dedicated nut free facility. Whether or not the nut free product was created on the same production line as a non nut free snack, is unknown. And more so, if that is the case, the sanitization policies can differ from business to business. If this is a concern for you, talk to your allergist to confirm the severity of your allergy.
Sometimes, if I am curious, I will call the company in question and ask them to clarify their allergen policy with me over the phone. I directly ask them if their nut free production machines are also used to make nut and tree-nut products. Sometimes they do, and other times the nut free products are made inside the same facility, but on a separate machine and the nut free products never have contact with the machines producing nut products.
It's obviously much better to get a written confirmation but if there's a particular product that you are concerned about I find clarifying with their team the best move forward. It also puts pressure on the company to be aware of the community’s needs. The last few years have brought about a huge increase in and gluten free and non-GMO labeling. And it's because the customers have demanded it. When we call and we ask for clarification it helps businesses understand that consumers are looking for clarification on specifics. And, that this information is important when they make buying decisions.
For many, the “Nut Free” labeling option will be within a reasonable risk assessment. But please talk to your allergist or ask your friend before assuming.
3. “May Contain” Label
This label is used to indicate potential cross-contamination. It’s a courtesy by whichever company includes it on their labeling as it is not required by law.
The “May Contain:” and “Contains:” labels are quite different and suggest completely different amounts of allergen exposure. The “Contains:” label means the product definitely contains the listed allergen. The “Contains:” label references the ingredients used in the making of the product. If you, your child, or your friend has an allergy to the listed ingredients in the “Contains” section, this product should be avoided.
In 2004 the FDA passed the Food Allergen Labeling and Consumer Protection Act of 2004 (FALCPA). It requires companies to list the top eight allergens in their labeling, assuming those major allergens were used in their product. But, instead of listing the common allergy categories (i.e., tree-nuts, gluten, or milk), the allergen statement might say something similar to “Contains: Walnuts, Wheat, and Whey”. Walnuts are tree nuts, wheat is gluten, and whey is milk. But the policy requires the specific ingredient to be listed, not the allergen category that the ingredient belongs to.
The “May Contain:” label does not list recipe ingredients. The “May Contain:” label lists potential allergen exposure to a product when it’s manufactured in the same facility as a product that does contain nuts (or other offending allergens). The food in question could have been exposed to nut particles from a different product that did include nuts, even though the product itself doesn’t contain any nut ingredients.
Manufacturers often have a particular cleaning and sanitization process they follow while cleaning their equipment between uses, but even after this cleaning process is complete, it’s possible for a small amount of peanut particles to remain on the equipment as the new production of products begin. This is why the allergen is listed, as a just in case courtesy to the severely allergic. Because, depending on the severity of the allergy, if a peanut particle were to hypothetically get inside a nut free food product, it could trigger an allergic reaction.
4. Made on Shared Equipment With Foods Containing Peanuts and Tree Nuts
Labeling that uses this type of phrasing is a way for companies to confirm a warning for cross-contamination. The “May Contain:” label differs in that it is saying it may. It could. It’s a nondescript insurance policy that is voluntarily given by food companies. The “Made on Shared Equipment” label is more of a direct confirmation that the product in question definitely does share equipment with nut products.
Products made on shared equipment with foods containing peanuts and tree nuts may not have any nut ingredients, but because they are sharing manufacturing equipment with other foods that do, the finished product may contain traces of nuts. If you have a severe allergy to peanuts and tree nuts, eating foods that share equipment with your allergens could trigger an allergic reaction.
Other common phrases used that would fall under this category include: “Made In A Facility That Also Processes Tree Nuts and Peanuts”, and “Made on Equipment That Also Processes Peanuts and Tree Nuts”, “Produced On Equipment That Also Processes Products Containing Milk, Peanuts, and Tree Nuts”, or “Made On Shared Equipment That Also Processes Peanuts and Tree Nuts.”
5. Omits Nut Ingredients but Doesn’t Say Nut Free
Food companies are required to let you know when a product contains one of the 8 major allergens. However, allergens not acknowledged in the top 8 can still trigger severe allergic reactions. Food Allergy Research & Education (FARE) acknowledges sesame as the ninth most common food allergen. Allergies to sesame can vary from mild to severe, and similarly to peanuts, an allergic reaction to sesame can result in anaphylaxis.
Because there’s no FDA regulations for allergens outside the top 8 to be listed in the warning section of a food label, you cannot rely on an allergen warning if your allergen is outside of the top 8. Allergens like sesame are acknowledged in the allergen section as a courtesy by some food companies. But it is not FDA regulated. If you or someone you know is allergic to an allergen not acknowledged by the FDA as a top eight allergen, or a major food allergen, you must instead rely on the ingredient section.
If your food allergen is part of the “major allergen group”: (milk, eggs, fish, shellfish, tree nuts, peanuts, wheat, and soy, then the allergen in question will be displayed under the “Contains” section of a food label, as required by the FDA.
But, if a product shares manufacturing equipment with peanut and tree nut containing foods from the same company, a company is not legally required to disclose it. A company has to warn you against the major allergens being in a recipe, they don’t have to warn against potential cross- contamination.
If you’re severely allergic or your friend is severely allergic to nuts, it’s possible an unlabeled cross contamination will trigger an allergic reaction. The risk analysis is up to the individual and their allergist.
There are various reasons why a company would not want to clarify potential cross contamination in a warning label. The article When a Manufacturer Says ‘Trust Us’ Regarding Allergens by SnackSafely gives a great explanation of the differing reasons a company is choosing to omit the “May Contain:” section from their product’s food label.
Sometimes, the products these companies are omitting clarification in don’t create their product on a machine that processes other nut related food products. Instead, certain companies will decide to use a separate part of the facility to manufacture their nut free products. In this scenario, both machines are stationed in the same facility. They may be in different areas, but they're both under the same roof.
Because policies to prevent cross-contamination are so different company-to-company, it’s difficult for the consumer to know whether or not their efforts are effective unless a company does routine trace testing. And, according to the Snack Safely article mentioned above, the FDA doesn’t require trace testing in finished products.
If there is a particular product you are curious about, you can call a company’s customer service line and ask about the company’s allergen policy, specifically in regards to their facility and the protocol they implement to protect against cross-contamination. Based on what they say, re-assess the risk from your own vantage point.
Follow the boundary that feels right for you. You decide what you feel comfortable with when it comes to what you are willing to eat and not eat. Or, the same goes for when you're the parent of a nut allergic child. You and your child’s allergist can discuss which nut free labeling is appropriate for your situation. If you’re the friend of someone with a severe nut allergy, check in with them before assuming.
6. Labeled "School Safe"
The School Safe label and classification system is used by companies to indicate a particular product of theirs is free from the eight most common food allergens. It classifies food based on what the FDA has identified as the 8 major foods allergens, but it isn’t a classification system or nut free labeling created by the FDA.
In fact, it’s a good idea to read what 8 allergens each company is claiming to be the top allergens. It mostly stays the same, but sometimes the ingredients, or the way the ingredients are classified differs. According to the FDA the eight major allergens include: milk, eggs, fish, shellfish, tree-nuts, peanuts, wheat, and soy. These are the eight foods designated as “major food allergens' by FALCPA.
School Safe products became popular to make shopping for food allergy classrooms easier. Unfortunately, the number of food allergic children is rising, and so are nut free or nut aware classrooms, and nut free or nut-aware schools. Most products using the phrase “School Safe” are created in dedicated nut free facilities, which is awesome! They’ll indicate so on the packaging. School Safe snacks are making classrooms safer for nut allergic kids as well as other food allergic kids.
Treasure Mills produces many School Safe snacks that are available in most grocery stores. To learn more about brands that are school safe and also made in dedicated nut free facilities, we recommend reading the Safe Snack Guide by SnackSafely.
Summary for These Different Kinds of Nut Free Labeling
If in doubt, open up a conversation with your nut-allergic friend or allergist. Get to know what their recommendations are regarding nut free labeling. If you are trying to learn what snacks are safe for your friend, you simply ask them. Or, start paying attention to what they eat at lunch or to the items their pantry is stocked with. Try the snacks for yourself too! You might find seed substitutes rather tasty.