How do I account for types or species in my allergen dietary flags?

Certain allergens must specify which type of allergen is contained in the food. Learn how to add these to your nutrition labels!

Top 9 Major Food Allergens:

• Milk
• Eggs
• Fish*
• Crustacean Shellfish*
• Tree Nuts*
• Peanuts
• Wheat
• Soybeans
• Sesame

*The FDA mandates that if a food contains either tree nuts, shellfish, or fish, the nutrition label must include the type or species of the ingredient that is the source of the dietary flag. For instance, if a dish contains almonds the nutrition label cannot simply say tree nuts. Rather, it must explicitly call out almonds. There are two ways of handling this in Galley:

1. Create separate dietary flags for each type/species (recommended)
2. Use generic names and have Galley pull in the ingredient external names

Separate Dietary Flags

The recommended way to account for the food source of these allergens is to have separate dietary flags for each species. For instance, you would have dietary flags named almonds, shrimp, salmon, etc. Then, the allergen list will contain the explicit names of the sources.

Generic Names

If a dietary flag is named shellfish, tree nuts, or fish, Galley will add the external name of the ingredient in parentheses next to the allergen name on the allergen list. This method is good if you would like to have both the generic allergen name and the species name listed on the nutrition label. 

However, the downside of the method and why the alternative is recommended is that an ingredient's external name may not always be what you want to display on the allergen list. For example, if a recipe contains almond butter, you will want the external name of the ingredient to be almond butter on the ingredient list but list almonds on the allergen list. 

❗On January 6, 2025, the FDA released the Final Guidance for Industry: Questions and Answers Regarding Food Allergens, Including the Food Allergen Labeling Requirements of the Federal Food, Drug, and Cosmetic Act (Edition 5) which clarifies additional requirements for major food allergen labeling. 

Due to current research, the FDA only recognizes the following tree nuts as a tree nut allergen:

This means listing coconut, beech nuts, chestnuts, or any other nuts that are not listed in the above table would deem the nutrition label out of compliance due to the final guidance: 

Only the tree nuts listed in Table 1 are considered major food allergens, and, therefore, must meet the food allergen labeling requirements of section 403(w) of the FD&C Act. Because other tree nuts that are not listed in Table 1 do not have a robust body of evidence to support inclusion as a major food allergen, they should not be included in the “Contains” statement even if they are used as ingredients because the “Contains” statement is reserved for major food allergens. Tree nuts used as ingredients, but not listed in Table 1, would still be required to be listed by common or usual name in the ingredient list (21 CFR 101.4).

The allergen contains statement is strictly reserved for the presence of any of the top 9 major food allergens. This is to make it easier for consumers to determine if a food contains a major food allergen or not. 

For additional information, visit: What are allergens and dietary flags and which allergens should I include on labels to be FDA-compliant?