Can food manufacturers ask to have a product exempted from the new labeling requirements?
Yes. FALCPA provides mechanisms by which a manufacturer may request that a food ingredient covered by FALCPA may be exempt from FALCPA’s labeling requirements. An ingredient may be exempt if it does not cause an allergic response that poses a risk to human health or if it does not contain allergenic protein. • What does FDA require in order for a product to be exempt? FALCPA states that any person can petition the Secretary of Health and Human Services for an exemption either through a petition process or a notification process. The petition process requires scientific evidence (including the analytical method used to produce the evidence) that demonstrates that such food ingredient, as derived by the method specified in the petition, does not cause an allergic response that poses a risk to human health. The notification process must include scientific evidence (including the analytical method used) that demonstrates that the food ingredient (as derived by the production method specifi