Are Allergens Discreetly Being Added to Our Foods?
Yes, you read that correctly. It’s hard to believe—after all, 33 million Americans have food allergies (almost 10% of us!)—but it’s happening.
Before we explore why, let’s do a quick regulatory recap.
Food Safety Modernization Act (2011)
For nearly all matters concerning food safety, including allergen testing, FDA-regulated food manufacturers follow the Food Safety Modernization Act (FSMA).
FSMA introduced significant reforms to the nation’s food safety laws. For the first time, food manufacturers were required to develop and maintain a written “food safety plan.” FSMA also gave the FDA discretionary authority to approve or reject these plans, giving auditors considerable interpretive power over which food safety plans would pass muster.
Food Allergen Labeling and Consumer Protection Act (2004)
The Food Allergen Labeling and Consumer Protection Act (FALCPA) is an amendment to the Federal Food, Drug, and Cosmetic Act. FALCPA mandates that nationally-distributed packaged foods containing any of the “top eight” major food allergens—fish, shellfish, wheat, soy, peanuts, tree nuts, milk, and eggs—must be identified in plain language (easily readable) and listed in either the ingredients section OR in a “contains statement” (usually following the ingredient list). At the time of the FALCPA allergen labeling passage, these eight foods accounted for 90 percent of food allergies and serious allergic reactions in the U.S.
FASTER ACT (2021)
In April 2021, the Food Allergy Safety, Treatment, Education, and Research (FASTER) Act was signed into law. It added sesame to the list of top allergens (now nine!) that must be declared on federally-regulated packaged products in the U.S. and went into effect on January 1, 2023.
In January 2025, the FDA released new allergen, food safety, and plant-based alternative labeling guidances, which narrow the labeling requirements of tree nuts—now excluding coconut, shea, pili, palm, hickory, ginkgo, cola/kola, chinquapin, beech, butternut, and chestnut.
So, why are we adding allergens again?
Let’s talk about why some common allergens are being added to our foods—sometimes with little warning.
At the end of 2024, Chick-fil-A was in hot water after adding pea starch to their famous waffle fry recipe, claiming the change promoted prolonged crispiness. Though pea starch is not a major allergen, those with legume allergies, such as peanuts, may be at risk. Read more here.
After the FASTER Act took effect, Chick-fil-A added sesame to the ingredient lists for white buns and multigrain brioche buns, stating they could not guarantee their production lines were free of sesame. Wendy's menu includes items that also contain sesame, including their buns and French toast sticks. Olive Garden began adding sesame flour to their beloved breadsticks. After much backlash, they updated their recipe to be sesame free.
In 2020, Pearson’s, a well-known candy manufacturer, began listing peanuts, almonds, and pecans on the ingredient label of their mint patties. While they highlighted that the new recipe offered “thicker” and “fresher” mints, they did not highlight the nut additions on their packaging. The food allergy community caught this oversight and raised immediate alarm.
In March 2016, Kellogg’s announced they would begin adding peanut flour to several Keebler and Austin-brand sandwich crackers, and boy, was there backlash! Among the concerns voiced, the most prominent was the risk long-time purchasers might not re-check the label. Hostess likewise added peanut flour to their Ho Ho and Suzy Q snack cakes around this same time.
There’s been much speculation as to why food manufacturers are adding common allergens to products whose recipes, in many cases, haven’t changed in decades.
Some speculate food manufacturers may be trying to skirt regulatory requirements to avoid compliance costs. Others suggest manufacturers may be adding nuts and other allergens to increase the amount of protein in these foods to make them healthier.
According to Dr. Bert Popping, food safety expert, “Food allergen management at the manufacturing level can be difficult—especially when you have different food products sharing the same line. In some cases, even after thorough cleaning, there can be incidental allergen contamination at various levels. Since legislation varies widely, and many existing regulations are discretionary, some manufacturers might be inclined to add the allergenic ingredient to their product to eliminate ambiguity; others may add advisory warnings like ‘may contain’ statements.”
I’ll end here on a personal note.
For YEARS, one of my favorite health food stores carried chocolate-covered almonds that my entire family loved. I was ecstatic when we discovered them because they checked all our boxes: no dairy or gluten for mom, no peanuts or other tree nuts for sister (she can safely eat almonds and is encouraged to by her allergist), and no high fructose corn syrup or ingredients I can’t pronounce (I’m a bit of a health nut).
I’m embarrassed to admit I bought these almost weekly, so I didn’t necessarily check the label each time. On one particular trip, I noticed a tiny callout on the front of the package that stated NEW RECIPE. The food allergy mom in me (naturally) grabbed the package and flipped it over immediately. I was crestfallen to find not only had milk been added to the recipe but corn syrup had as well. WHY… 😔
I found myself disappointed for two reasons. First, because these almonds would no longer work for my family. And second, a brand we trusted might be making changes in the hopes of lowering production costs.
Sadly, I’ve heard many stories like this—close calls, if you will—where a trusted brand changes the ingredients and not always for the betterment of our health.
Hopefully, the backlash that ensued from these incidents underscores the importance of properly communicating ingredient changes to the packaging and label and serves as a good reminder to ALWAYS check the label. Even if they’re your tried-and-true fave snack.
— Meg and the Amulet Team
This is an updated version of an article originally posted in December 2021.