Are flavors, colors, and food additives subject to the allergen labeling requirements?
Yes. FALCPA requires that food manufacturers label food products that contain ingredients, including a flavoring, coloring, or incidental additive that are, or contain, a major food allergen using plain English to identify the allergens. • Are there any foods exempt from the new labeling requirements? Yes. Under FALCPA, raw agricultural commodities (generally fresh fruits and vegetables) are exempt as are highly refined oils derived from one of the eight major food allergens and any ingredient derived from such highly refined oil. • 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?
