Cottage Food Allergen Labeling Requirements (FDA 9 Major Allergens)
Allergen labeling is a legal requirement and a critical safety issue for anyone selling food products, including cottage food producers. The FDA recognizes nine major food allergens that must be clearly declared on your label whenever they are present in a product. Failing to disclose allergens can put customers with food allergies at serious risk and expose you to significant legal liability.
Last updated: July 2026
The FDA's 9 Major Food Allergens
As of January 1, 2023, the FDA recognizes nine major food allergens that must be declared on food labels sold in the United States. These are milk, eggs, fish, shellfish, tree nuts, wheat, peanuts, soybeans, and sesame. Sesame was added as the ninth major allergen under the FASTER Act and became mandatory for food labels in 2023.
If your cottage food product contains any of these allergens as an ingredient or as a sub-ingredient of a compound ingredient, you are required by law to disclose it clearly on the label. This applies even if the allergen is present in a very small amount, because trace amounts can still trigger life-threatening reactions in sensitive individuals.
How to Format an Allergen Statement on Your Label
There are two accepted methods for declaring allergens on a food label. The first is the parenthetical method, where you identify the allergen source directly within the ingredient list.
For example, you might write "enriched flour (wheat)" or "casein (milk)" to clarify the allergen source of an ingredient whose common name does not make it obvious. The second method is the "Contains" statement, which appears immediately after the ingredient list and lists all allergens present.
For example, "Contains: Wheat, Milk, Eggs, Peanuts." Many producers use both methods together for extra clarity. Whichever approach you use, the allergen declaration must be prominent, clearly legible, and accurate.
Tree Nuts Require Individual Identification
Tree nuts are one allergen category that requires additional specificity on labels. When your product contains tree nuts, you must identify which specific type of tree nut is present rather than simply writing "tree nuts." Examples include almonds, cashews, walnuts, pecans, pistachios, macadamia nuts, Brazil nuts, hazelnuts, chestnuts, and coconut (which the FDA classifies as a tree nut).
If a product contains multiple types of tree nuts, each must be individually named. This level of specificity matters because some individuals are allergic to certain tree nuts but not others, and vague labeling does not give them the information they need to make safe purchasing decisions.
Fish and Shellfish Also Require Specific Identification
Similar to tree nuts, fish and shellfish must be identified by their specific species on the label rather than using only the general category name. For fish, you must name the type, such as salmon, tuna, tilapia, or cod. For shellfish, you must specify the type, such as shrimp, crab, lobster, or clams.
This matters because cross-reactivity among fish and shellfish species varies, and a person allergic to shrimp may not react to crab, or vice versa. While most cottage food products do not contain fish or shellfish, this rule becomes relevant for savory items, crackers, or specialty baked goods that use seafood-based seasonings or flavorings.
Cross-Contact and Voluntary Disclosure
Cross-contact occurs when an allergen is unintentionally transferred from one food to another through shared equipment, surfaces, or storage. While the FDA does not currently require mandatory cross-contact labeling, many cottage food producers voluntarily include advisory statements such as "Made in a facility that also uses peanuts" or "May contain traces of tree nuts." These voluntary disclosures are not a substitute for proper allergen declarations for intentionally included ingredients, but they can help protect customers who have severe allergies and need to know about shared-kitchen risks. If you bake in a home kitchen shared with family members who use allergens, voluntary cross-contact disclosure is a responsible practice.
Sesame Labeling Under the FASTER Act
Sesame became the ninth major allergen on January 1, 2023, under the Food Allergy Safety, Treatment, Education, and Research (FASTER) Act. If your cottage food products contain sesame in any form, including sesame seeds, sesame oil, sesame flour, tahini, or sesame paste, you must now declare it as an allergen on your label.
Sesame can appear in many forms and under many names, including benne seeds, gingelly oil, and til, so read ingredient labels of your input products carefully. If you updated your labels before 2023 and have not reviewed them for sesame compliance since, now is the time to do so.
Common Questions
Check the label of every packaged ingredient you use and collect every FDA major allergen it declares, then combine them into a single "Contains" statement for your finished product — you do not repeat the statement per component.
For example, if your cake mix contains wheat and soy, and your frosting contains milk, your combined statement reads "Contains: Wheat, Soy, Milk." List each allergen only once even if multiple ingredients contribute it.
Yes. Allergens present in any ingredient, including pre-made mixes, must be declared on your label.
If the cake mix you use contains wheat, milk, or soy, those allergens must appear in your allergen disclosure even though you did not add them separately. Review the ingredient list of every component you use, including mixes, chocolate chips, and flavorings.
You are not strictly required to use a separate "Contains" statement as long as your ingredient list clearly identifies each allergen source using the parenthetical method. However, a "Contains" statement in addition to the ingredient list makes it much easier for allergy-conscious shoppers to quickly identify risks, and it is considered best practice.
No. A "may contain" advisory statement is a voluntary cross-contact disclosure and cannot replace a required allergen declaration.
If an allergen is intentionally included in your product, you must declare it explicitly. Using only a "may contain" statement when an allergen is actually in the product would be a mislabeling violation.
Contact the manufacturer of that ingredient and ask them directly. Many ingredient suppliers can tell you whether their product contains or was produced on shared equipment with major allergens.
If you cannot confirm the allergen status of an ingredient, err on the side of disclosure. It is always safer to declare an allergen that may or may not be present than to omit one that is.
Create Accurate Allergen Labels for Your Cottage Food Products
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