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FDA Major Food Allergens

Quick answer

FDA major food allergens are the nine foods that U.S. law singles out for allergen labeling: milk, eggs, fish, crustacean shellfish, tree nuts, peanuts, wheat, soybeans and sesame. They are often called the big 9 allergens. An ingredient that contains protein from one of the nine counts as a major food allergen too, with an exception for highly refined oils. Every packaged food that FDA regulates must name each one it contains on the label.

FDA major food allergens shown as nine foods: a glass of milk, eggs, a fish, a shrimp, almonds, peanuts, wheat, soybeans and sesame seeds
The nine foods on the U.S. list
01

The FDA allergen list: 9 major allergens and what each covers

The list sits in the definition of "major food allergen" in the FD&C Act. FDA's guidance spells out how wide each entry reaches. Some are broader than the everyday word, and some are narrower.

Major allergenWhat FDA countsNot covered
MilkMilk from domesticated cows, goats, sheep and other ruminants
EggsEggs from domesticated chickens, ducks, geese, quail and other fowl
FishBony fish (cod, salmon, tuna, tilapia), cartilaginous fish (shark, rays, skates) and jawless fish
Crustacean shellfishCrab, lobster, shrimp and other crustaceansMolluscan shellfish: oysters, clams, mussels, scallops
Tree nutsOnly the 12 entries on FDA's tree nut list (below)Coconut and 11 other nuts, removed
PeanutsPeanuts
WheatAny species in the genus Triticum, which FDA says includes common, durum and club wheat, spelt, semolina, einkorn, emmer, Khorasan and triticaleBarley, rye and oats
SoybeansSoybeans
SesameSesame
21 U.S.C. 321(qq) · FDA Allergen Q&A, Edition 5, A.1, B.9, B.10, C.1, C.3, C.7, C.9The statutory list, molluscan shellfish, the three categories of fish, FDA's reading of milk and eggs, the tree nut table and the species that count as wheat.
02

From the big 8 to the big 9

The Food Allergen Labeling and Consumer Protection Act of 2004 (FALCPA) named eight foods. FDA notes that, when the law passed, those eight accounted for 90 percent of food allergies and serious allergic reactions in the U.S.

The FASTER Act of 2021 then wrote sesame into the same definition as the ninth. Since then every FDA requirement for major food allergens, on labels and in manufacturing, covers sesame as well. You will still hear "big 8" in older material: it means the list without sesame.

The nickname is common enough that USDA's Food Safety and Inspection Service titles its allergy page "Food Allergies: The 'Big 9'".

FDA, Food Allergies · 21 U.S.C. 321(qq)(1)The eight foods under FALCPA, their share of allergies at the time, and sesame added by the FASTER Act.
FALCPA, the law behind the list →
03

FDA's tree nut list

"Tree nut" has no single botanical definition, so FDA keeps a table of the tree nuts it treats as major food allergens: the ones where a robust body of scientific evidence supports it.

Common or usual nameScientific name
AlmondPrunus dulcis
Black walnutJuglans nigra
Brazil nutBertholletia excelsa
California walnutJuglans californica
CashewAnacardium occidentale
Filbert/HazelnutCorylus spp.
Heartnut/Japanese walnutJuglans ailantifolia var. cordiformis
Macadamia nut/Bush nutMacadamia spp.
PecanCarya illinoinensis
Pine nut/Pinon nutPinus spp.
PistachioPistacia vera
Walnut (English, Persian)Juglans regia
FDA Allergen Q&A, Edition 5, C.7, Table 1The tree nuts FDA considers major food allergens, with their scientific names.
04

What came off the list: coconut and 11 other nuts

FDA's fifth edition of its allergen guidance shortened the tree nut list. These are no longer major food allergens:

  • Coconut
  • Beech nut
  • Butternut
  • Chestnut
  • Chinquapin
  • Cola/kola nut
  • Ginkgo nut
  • Hickory nut
  • Palm nut
  • Pili nut
  • Shea nut
  • Lichee nut
  • They stay in the ingredient list by their usual name, like "coconut" or "chestnuts", unless an exemption applies, such as a coconut flavor declared as "natural flavor"
  • They come out of the "Contains" statement, which is reserved for major food allergens
  • Manufacturers no longer need to treat them as major food allergens in their manufacturing controls
  • An old label that still lists coconut in its Contains line is out of date. FDA says a sticker over it is an option
FDA, Frequently Asked Questions: Food Allergen Labeling Guidance for Industry · FDA Allergen Q&A, Edition 5, C.8The nuts removed from the list, how to label them now, the effect on manufacturing controls, and updating old labels.
05

Where the list reaches further than people expect

  • Goat, sheep and other ruminant milk counts as milk. FDA wants the animal named: "goat milk" in the ingredients, or "Contains goat milk"
  • Duck, goose and quail eggs count as eggs, named the same way: "duck egg", or "Contains duck egg"
  • Lactose and ghee often carry some milk protein. When they do, they are declared as milk
  • Milk protein made by fermentation, for example in engineered yeast, still counts as derived from milk and must be declared
  • Major food allergens in dietary supplements count, in capsules, powders and softgels alike
FDA Allergen Q&A, Edition 5, B.1, B.2, B.7, B.16, C.1 to C.4Milk from other ruminants, eggs from other fowl, lactose and ghee, proteins produced by fermentation, and supplements.
06

Allergens that are not on the list

FDA counts more than 160 foods that can cause allergic reactions. The labels of foods made with those don't have to name the allergen source the way the law requires for the nine, but each ingredient still appears in the ingredient list by its common or usual name.

Not a major allergenWhat the label still has to do
Oysters, clams, mussels, scallopsList them in the ingredients by name
Coconut and the other removed nutsList them in the ingredients, keep them out of the Contains line
Barley, rye, oats (gluten)Listed as ingredients; "gluten-free" is a separate voluntary claim with its own rule
SulfitesDeclared when the food has 10 parts per million or more total sulfites
FD&C Yellow No. 5Declared on every product that contains it
Cochineal extract and carmineDeclared on the label

Can the list grow? FDA can't change the nine in the law; that took an act of Congress for sesame. FDA can, by regulation, require labeling of other allergens hidden in spices, flavorings, colorings and incidental additives. It has also published guidance on how it evaluates the public health importance of allergens beyond the nine.

FDA Allergen Q&A, Edition 5, A.2, A.3 · 21 U.S.C. 343(x) · FDA, Food AllergiesAllergens beyond the nine, FDA's power under 403(x), and the labeling of gluten, sulfites, Yellow No. 5, cochineal and carmine.
FDA Gluten-Free Label Requirements →
07

Putting the list to work on your label

The list tells you what to look for. How you declare each one has its own pages:

Allergen labeling requirements: the two ways to declare →Allergen statement: how to write the Contains line →"May Contain" Allergen Labeling →

Our label maker checks your recipe against all nine, sub-ingredients included, and asks which nut, fish or shellfish you used so the Contains line names it. Coconut is not flagged as a tree nut, in line with FDA's current list. If an ingredient brings in an allergen we can't see, like a sauce with soy, tap it and it joins the Contains line.

Allergen Warning Label Maker →
Questions

Questions

Milk, eggs, fish, crustacean shellfish, tree nuts, peanuts, wheat, soybeans and sesame. They are the nine major food allergens defined in the FD&C Act.

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