Allergen Education
A product can contain a major food allergen without listing it by its common name. Learn what you're actually reading on ingredient labels — and how to protect guests with allergies.
By Dylan McDonnell, Founder & CEO, Foodini | May 2026 | 8 min read
A restaurant's allergen data for every menu item is accurate — correct recipes, correct major allergen identification. But the system breaks down at the ingredient level: a supplier's product lists "hydrolyzed plant protein" on the label, not "soy" — but that hydrolyzed plant protein is soy. The allergen team reviews the menu, sees "soy allergen: none," and approves the item. The next guest who is severely allergic to soy has a reaction. The restaurant didn't lie on the menu. They didn't know what to read on the label.
This is the most common place where allergen information fails in restaurants with otherwise strong compliance systems: the connection between ingredient labels and the actual allergen disclosure on the menu.
The Food and Drug Administration requires that all packaged foods list the nine major allergens in plain language. A product cannot use only the scientific name or a derivative term. If it contains soy, it must say "soy" or "contains soy" — not hydrolyzed plant protein, lecithin (which is often soy-derived), or textured vegetable protein.
The rule is clear. Compliance, however, is not universal. Many older products, imported products, and products from smaller manufacturers use unclear labeling or derivatives. A label that says "hydrolyzed plant protein" requires the reader to know that hydrolyzed plant protein is soy — and most restaurant staff do not.
California's SB 68 does not change FDA allergen labeling rules. Suppliers are still required to disclose the nine major allergens by their common names on packaged products. But the law places the burden on restaurants: if an allergen is present in a menu item, the restaurant must disclose it on its menu, regardless of whether the supplier label makes it obvious.
This means a restaurant cannot rely solely on supplier labeling. The restaurant must:
Most restaurant staff cannot be expected to memorize derivative terms. The solution is systems: a process where allergen-sensitive ingredients are flagged during menu development, supplier labels are reviewed by someone trained to recognize derivatives, and that review is documented.
When a new ingredient enters the kitchen, the question should not be "Is soy listed on the label?" but rather "Does this ingredient contain any of the nine major allergens, including in derivative form?" The second question catches the mistakes the first one misses.
Allergen derivatives are the gap where many restaurants with otherwise compliant systems fail. The menu is compliant. The recipes are documented. But a supplier label uses a derivative term, the allergen team doesn't catch it, and the restaurant is non-compliant without knowing why.
Foodini maintains an allergen reference database that includes derivative terms, so when an ingredient is added to a recipe, the system alerts if that ingredient or its known derivatives are major allergens.
See how Foodini identifies hidden allergens and derivatives →