The 9 major food allergens are milk, egg, fish, crustacean shellfish, tree nuts, wheat, peanuts, soybeans, and sesame.
Key takeaways
- Check current ingredient information before filling a bin.
- Keep self-dispensing labels visible to customers.
- Update cards when ingredients change.
- Confirm notification requirements with your regulator.
If your shop sells food from bulk bins, scoop stations, or open trays, allergen information is part of your restocking work, not just a line printed on a box. This post names the 9 major food allergens, quotes what U.S. Food and Drug Administration (FDA) sources say about labeling unpackaged and bulk food, and offers practical habits for staff who fill and refill containers. Where a point comes from an FDA page, we link it so you can read the full page yourself.
Nothing here is legal advice. The quotes come from FDA pages; consult your applicable regulator. Check with that regulator before you change a label, a sign, or a notice.
Which foods are the 9 major food allergens?
FDA's notice on the sesame addition to the 2022 Food Code gives the list in these words: "With the addition of sesame, the list of major food allergens is: milk, egg, fish, Crustacean shellfish, tree nuts, wheat, peanuts, soybeans and sesame." ( FDA, Addition to the 2022 Food Code - Sesame added as a Major Food Allergen)
Keep this list in front of you when you check a product, a recipe, or a bin. Use the full names when you write labels or talk with customers. A general word such as "nuts" can leave a customer guessing about which food is in the product, so name the specific food where you can.
What changed when sesame was added?
FDA's consumer update says, "Sesame joins eight other foods already declared as major food allergens by federal law." ( FDA, Allergic to Sesame? Food Labels Now Must List Sesame as an Allergen; FDA, The FASTER Act: Sesame Is the Ninth Major Food Allergen)
For a shop, that means sesame sits on the list with the other eight, and it should be checked just as carefully. Because sesame can appear in products that staff may not connect with it, check every product's ingredient list for sesame rather than relying on the product's name. The same habit applies to the other eight foods. Memory is a poor substitute for a current label.
What does FDA say about unpackaged food?
FDA's notice on the 2022 Food Code addition says that unpackaged foods served or sold to consumers within a retail food establishment must have written notification to consumers of the presence of major food allergens as an ingredient in the unpackaged food items. ( FDA, Addition to the 2022 Food Code - Sesame added as a Major Food Allergen)
Two parts of that sentence matter for a shop. The first is the setting: the words "served or sold to consumers within a retail food establishment" name the places the notice is about. The second is the trigger: the notice applies to major food allergens present as an ingredient in the unpackaged item. That means the question is what the food contains as an ingredient.
Ask your regulator what notification format and placement it accepts before you choose a format.
If your shop sells unpackaged food from a counter, a tray, or a bin, treat the written notification as part of setting up the product, not an afterthought. Decide what the notification will say before the product goes out on the floor, and update it when the ingredient list changes.
How should bulk self-serve foods be labeled?
For a self-dispensing bin, FDA's notice says the label needs to name the food source of each major food allergen in it. The notice says, "Bulk foods that are available for consumer self-dispensing need to be prominently labeled in plain view of the consumer with the name of the food sources from which the major food allergens are derived unless the food source is already part of the common or usual name of the ingredient." ( FDA, Addition to the 2022 Food Code - Sesame added as a Major Food Allergen)
Take the sentence one phrase at a time. "Prominently labeled" and "in plain view of the consumer" describe placement and visibility. Put the label where a customer choosing from the bin can read it without asking for help.
"The name of the food sources" is the core requirement. The label names the source each major food allergen comes from. The exception applies when the food source is already part of the common or usual name of the ingredient. For example, the common name of peanut butter already includes peanut, so the source is already in the name.
For bulk foods served by staff, confirm the labeling format with your regulator before you set up a counter.
How do packaged items made at retail get labeled?
Under FDA's notice, food items packaged at retail for sale to consumers must declare the major food allergens they contain, including sesame, on the label. ( FDA, Addition to the 2022 Food Code - Sesame added as a Major Food Allergen)
This is a different case from bulk and unpackaged food. Each packaged product needs its own check against its recipe, because one product's label does not cover another.
Staff who prepare packaged items should keep an ingredient record for each product, so the label can be checked against the recipe at the time it is printed. The same record helps when a recipe changes, because the label should follow the recipe, not last month's version of it.
For separate printing checks, see our guide to retail barcode labels.
Why does a list of 9 matter when other foods can cause allergies?
The list of 9 is not a complete picture of food allergies, because FDA says that "More than 160 foods have been identified to cause food allergies in sensitive individuals." ( FDA, Food Allergies)
For your shop, a customer's question about a food outside the 9 deserves a real check, not a quick dismissal. Look at the label or the supplier's ingredient information before you answer. A question about one food is a good reason to review the card for that bin as well.
Where can the 9 allergens hide in a shop?
Check shared scoops, refills, blends and sauces, mismatched top-up bags, and products without a current ingredient statement. FARE's Common Allergens page says, "These tips for avoiding allergens will help you uncover places that top-9 allergens are hiding, so they won’t end up in your shopping cart." ( FARE, Common Allergens - Peanut, Egg, and Sesame Allergies) The points below are general habits for a shop.
- Shared scoops and tongs. A scoop that moves between bins can carry one product's contents into another. Keep a scoop with each bin, or clean it before it goes to a different bin.
- Refills from a common hopper or bag. If a bin is topped up from a container that held something else, the bin's contents may no longer match its card.
- Blends, mixes, and sauces. Recipes change. A blend that matched your card last year may contain a new ingredient now.
- Top-up bags with a different label. A bag that is not labeled to match its bin can put the wrong card on the wrong food.
- Products without a current ingredient statement. Ask the supplier for one before the product goes out on the floor.
What should a bin label say?
Here is a hypothetical example. Suppose a trail mix bin contains peanuts and sesame. Separate source naming depends on whether the ingredient names already identify peanuts and sesame, rather than whether the product name does. ( FDA, Addition to the 2022 Food Code - Sesame added as a Major Food Allergen) This example is only an illustration. Check your own products against the ingredient list and your regulator's requirements.
Keep the label short and specific. Name the source the allergen comes from, and use the same wording on the card, the shelf tag, and any sign, so that a customer and a staff member read the same thing.
Illustrative example: checking a refill
For an illustrative check of 10 bins, suppose 5 have updated ingredient statements. Compare those statements with the matching cards before refilling. For the remaining 5, ask for current statements before the products go out on the floor. The check covers all 10 bins without treating an older card as current ingredient information.
How should you handle supplier changes?
Check the allergen list again every time a supplier changes an ingredient, a recipe, or a packaging line, because an older card may no longer match the product. A simple routine helps:
- Ask each supplier to tell you when an ingredient or recipe changes.
- File the updated ingredient statement with the bin card.
- Date the card so that the next person can see when it was last checked.
- Re-check the card before the next fill, not after the bin is already on the floor.
What should restock staff check before filling a bin?
Restock staff should read the current ingredient list for every product before it goes into a bin, and write down which of the 9 major food allergens it contains. The steps below are our suggestions. They are not quoted requirements.
- Read the supplier's current ingredient statement. Do not rely on last season's label or memory.
- Mark each of the 9 major food allergens the product contains on the bin card or shelf tag.
- Compare the new supplier label with the old card before you fill.
- Check that the bag, box, or hopper the product came from matches the bin.
- Tell the floor lead when a bin's contents or allergen notes change.
Make the check part of the routine, not a special task. A short check that repeats every time is easier to keep up than a long review that happens once a year.
For ordering work alongside this routine, see our shop replenishment checks.
How should you train new staff?
Train new staff on the 9 major food allergens, the bin labels, and the restock check before they fill a bin on their own. Have them practice reading an ingredient list with you, and have them name the 9 allergens from memory. Then have them check the card for one real product while you watch.
Keep the training written down. A one-page sheet with the 9 allergens, the bin label rule, and the steps from the restock check gives new staff something to return to when a question comes up on a busy day.
What should staff say when a customer asks?
Staff should point the customer to the bin's label first, then to the supplier's ingredient information, and say so if they cannot confirm the answer. If staff cannot confirm, they should not guess.
A simple reply can be, "Let me check the label and the ingredient list for you." Then the staff member should come back with a confirmed answer, or say that the product cannot be confirmed. A short delay is better than a confident guess.
What should a restock record include?
A restock record should show the product, the date it was checked, the 9 major food allergens it contains, and the person who did the check. We suggest keeping the record on the same card or sheet as the bin, so that the next person to fill the bin sees the latest entry without searching for it.
A record that only says "checked" does not help the next person. Write the product name exactly as it appears on the supplier's statement, and note the supplier's name and the date of that statement. If you cannot find a current statement, record that fact too, and do not fill the bin until the question is answered.
Review the records once a month with the floor lead. The review is a chance to catch cards that were not updated after a supplier change, and to make sure the wording on each card matches the wording on the bin label.
How do you keep the shop floor consistent?
When a product is replaced, move the new card onto the bin at the same time, and take the old card down. A leftover card for a product that is no longer in the bin can confuse a customer as much as a missing one.
Keep a single shared place for the current allergen cards, such as a binder or a folder that staff can reach from the floor. The place does not need to be fancy. It needs to be the one place everyone checks first.
What should you do today?
Start by listing every bulk and unpackaged item in your shop, and mark which of the 9 major food allergens each one contains. Then work through the list in this order:
- Check each bin label against the FDA quotes in this post.
- Confirm that every self-dispensing bin names its food sources.
- Ask your regulator about written notification for unpackaged foods.
- Update the restock card for any product whose supplier has changed.
Which rules apply to your shop?
Your state or local food regulator is the place to confirm which rules apply to your shop.
What should you ask your regulator?
Ask your regulator which version of the Food Code applies, what written notification it accepts for unpackaged food, and whether any labeling rules are set at the state or local level.