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Allergen Education

Related resources

  • ExplainerHow Many Major Food Allergens Are There? The Big 9 ExplainedLearn about the nine major food allergens recognized by U.S. federal law, FALCPA, the FASTER Act, and why understanding the Big 9 is essential for food service compliance.5 min read
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Browse all resources →Featured resourcesCase studies
ExplainerFederal

Precautionary Allergen Labeling: What "May Contain" Actually Means for Restaurants

"May contain peanuts." "Prepared in a facility that also processes tree nuts." These statements are on hundreds of products in every commercial kitchen — but most operators don't know what they're actually required to do with them.

By Dylan McDonnell, Founder & CEO, Foodini | May 2026 | 8 min read

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Precautionary Allergen Labeling — PAL — is the informal name for the voluntary advisory statements manufacturers put on food packaging when there is a risk that a product may contain trace amounts of an allergen due to shared equipment or production facilities, even when that allergen is not an intentional ingredient.

What PAL Is and Isn't

  • Precautionary Allergen Labeling is voluntary. No federal law currently requires manufacturers to use "may contain" statements or any other advisory allergen language.
  • The absence of PAL does not mean a product is free from cross-contact risk. A manufacturer who does not use PAL may still produce in a facility that handles allergens.
  • PAL is distinct from allergen ingredient declaration. Under FALCPA and the FASTER Act, manufacturers are required to declare allergens that are intentional ingredients. PAL is a separate, voluntary mechanism for disclosing allergens that might be present due to cross-contact.

What Restaurants Are Required to Do With PAL Information

Under SB 68 and equivalent state laws, restaurants must disclose the nine major allergens present in the ingredients of each menu item. The allergens that must be disclosed are those contained in the item's recipe — allergens actually present as ingredients.

Whether restaurants must relay PAL statements to guests is currently more ambiguous. SB 68 requires disclosure of allergens contained in menu item ingredients. Cross-contact risks from shared kitchen equipment or production facilities are not mandated as part of SB 68's per-item disclosure requirement.

However: the absence of a legal requirement to disclose cross-contact risk does not make cross-contact risk legally irrelevant. The liability exposure from serving a guest food that triggered a reaction through cross-contact — even where that allergen was not an ingredient — is real, established, and serious.

The Cross-Contact Disclosure Recommendation

SB 68 does not specifically reference cross-contact. There's no reference made to it in the statute — meaning you're not required to give disclaimers around cross-contact under SB 68.

However: strongly, strongly recommend that you always have a cross-contact disclaimer in your allergen information.

Very few restaurants can genuinely guarantee that any menu item is free from cross-contact with every allergen. Shared cooking surfaces, shared equipment, shared fryer oil — the commercial kitchen environment creates cross-contact risk for virtually every item in virtually every operation.

The standard language covers: "our kitchen handles all major allergens and we cannot guarantee that any item is free from cross-contact." This does not eliminate liability, but it provides notice to guests and demonstrates honest allergen communication.

How PAL on Supplier Products Should Factor Into Your Allergen Data

When a product in your kitchen carries a "may contain" statement, there are two questions to answer:

Question 1: Does the product actually contain the allergen as an ingredient?

Check the ingredient list and the allergen declaration. If the "may contain peanuts" product has peanuts in its ingredient list, peanuts is an ingredient allergen that must be disclosed. If the product does not contain peanuts in its ingredients but carries a "may contain peanuts" advisory, peanuts is a cross-contact risk — not an ingredient allergen.

Question 2: How do you handle the cross-contact risk in your own kitchen?

If your kitchen handles peanuts in any preparation and uses shared equipment across preparations, your own kitchen may add additional cross-contact risk on top of the supplier's advisory. Your cross-contact disclaimer needs to cover this honestly.

The FDA's Evolving Framework

In early 2026, the FDA began exploring the science behind establishing allergen thresholds — the amounts of specific allergens below which most allergic individuals would not react. This is the foundation for a more structured approach to PAL.

Proposed reference doses include 2 mg for peanut, egg, milk, and sesame; 1 mg for most tree nuts; 5 mg for wheat or fish. If adopted, PAL statements would need to be based on risk assessments tied to threshold levels rather than applied at manufacturer discretion.

For now: treat PAL statements on supplier products as real risk information, disclose ingredient-based allergens as required by SB 68, and use cross-contact disclaimers that honestly reflect your kitchen environment.

Putting It Into Practice

  1. Collect current spec sheets for all supplier products — the spec sheet tells you declared allergens and any PAL advisory
  2. Separate ingredient allergens from cross-contact risks — these are different disclosures with different requirements
  3. Include ingredient allergens in your item-level SB 68 disclosures — these are required
  4. Include a prominent cross-contact disclaimer on all allergen menus — this is risk management best practice beyond the statutory minimum
  5. Document your kitchen's cross-contact management protocol

Foodini handles the complexity of ingredient-versus-cross-contact allergen risk across hundreds of products and menu items, so operators can meet required disclosures and communicate cross-contact risk accurately.

See how Foodini manages allergen data at every layer →

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  • Build an Allergen Management System
  • Supply Chain Security and Allergen Risk

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