Food Allergy Safety Allergen Labeling & Ingredient Disclosure 2 — Questions and Answers
Question 1: According to FDA regulations, a food product labeled 'gluten-free' must contain less than how many parts per million (ppm) of gluten?
- 5 ppm
- 10 ppm
- 20 ppm (Correct answer)
- 50 ppm
Correct answer: 20 ppm
FDA's gluten-free labeling rule requires that products bearing a gluten-free claim contain less than 20 ppm of gluten, the threshold considered safe for most people with celiac disease.
Question 2: Under FALCPA, when a product contains tree nuts, what must the food label specifically indicate?
- Simply list 'tree nuts' without specifying the type
- Identify the specific type of tree nut (e.g., almonds, walnuts, cashews) (Correct answer)
- List only the most common tree nut varieties present
- Use the Latin botanical name of the tree nut
Correct answer: Identify the specific type of tree nut (e.g., almonds, walnuts, cashews)
FALCPA requires that the specific type of tree nut be declared (e.g., 'almonds,' 'cashews,' 'walnuts') because individuals may be allergic to specific varieties.
Question 3: Which of the following does NOT need to be declared as a major food allergen on US packaged food labels under FALCPA?
- Sesame oil
- Soy lecithin
- Wheat starch
- Highly refined peanut oil (Correct answer)
Correct answer: Highly refined peanut oil
Highly refined oils derived from major allergens are exempt from FALCPA labeling requirements because the refining process removes allergenic proteins.
Question 4: When a compound ingredient such as 'seasoned breadcrumbs' contains a wheat allergen, the manufacturer is required to:
- List only 'seasoned breadcrumbs' without further allergen specification
- Declare the wheat allergen either in the ingredient list or in a 'Contains' statement (Correct answer)
- Add a front-of-package warning label in red text
- Remove the compound ingredient from the formulation
Correct answer: Declare the wheat allergen either in the ingredient list or in a 'Contains' statement
Under FALCPA, allergens present in compound ingredients must still be declared on the label, either within the ingredient list or via a 'Contains' statement.
Question 5: Which federal agency is primarily responsible for enforcing food allergen labeling requirements on most packaged foods in the United States?
- USDA (United States Department of Agriculture)
- CDC (Centers for Disease Control and Prevention)
- FDA (Food and Drug Administration) (Correct answer)
- OSHA (Occupational Safety and Health Administration)
Correct answer: FDA (Food and Drug Administration)
The FDA has primary jurisdiction over most packaged food allergen labeling, though USDA/FSIS oversees labeling for meat, poultry, and egg products.
Question 6: The FASTER Act, which elevated sesame to a major food allergen, required full compliance with new labeling requirements beginning:
- January 1, 2022
- January 1, 2023 (Correct answer)
- July 4, 2021
- December 31, 2023
Correct answer: January 1, 2023
Although the FASTER Act was signed into law in 2021, manufacturers were given until January 1, 2023 to update their labels to include sesame allergen declarations.
Question 7: Which type of food establishment is generally EXEMPT from FALCPA's mandatory packaged food allergen labeling requirements?
- Large chain restaurants with over 20 locations
- Retail bakeries selling pre-packaged goods in grocery stores
- Restaurants serving freshly prepared food not sold in retail packaging (Correct answer)
- Grocery store brands that manufacture their own packaged products
Correct answer: Restaurants serving freshly prepared food not sold in retail packaging
Restaurants serving non-packaged food prepared on-site are not subject to FALCPA's labeling rules, though they may be subject to other local or state allergen disclosure requirements.
According to FDA regulations, a food product labeled 'gluten-free' must contain less than how many parts per million (ppm) of gluten?