Major Food Allergens: How to Comply With Sesame Food Allergen Labeling Guidelines

Less than 1% of adults and children in the U.S. have a sesame allergy, but for those who are allergic, exposure to the seed and its derivatives can be life-threatening. As a result, regulators passed the Food Allergy Safety, Treatment, Education, and Research (FASTER) Act in 2021, requiring manufacturers and retailers to update their labeling to better warn consumers and prevent exposure to the allergen. It went into effect January 1, 2023. 

Now, sesame is federally recognized as one of nine major food allergens, on par with dairy, eggs, fish, peanuts, and others, which already require rigorous labeling. Manufacturers must ensure their compliance with the FDA’s food allergen labeling requirements for both new and existing products without interrupting operations. 

The New Food Safety Guidelines for Sesame Allergies 

Manufacturers producing products containing sesame have always been required to list it as an ingredient, but the FASTER Act greatly expanded these requirements. Now classified as a major food allergen by the FDA, manufacturers must clearly list sesame on labels even when it's a component of another ingredient, such as "spice mix" or "natural flavor." Sesame must also be included in the “Contains” or “May contain” section at the end of the packaging’s ingredient list, alerting consumers of the presence or potential presence of major food allergens in the product. 

The FASTER Act goes beyond labeling to further regulate how food and beverage manufacturers prevent cross-contact. As a result, the law impacts everything from sanitation processes to food handling protocols to the operational layout. Depending on the size of an operation, becoming compliant with these new food safety guidelines can have a major impact on production processes and budgets. 

How to Comply With New Sesame Food Safety Guidelines 

Meeting the requirements of the FASTER Act can require a wide range of changes depending on the size and scale of your production facility. Here are three steps manufacturers can take to ensure compliance: 

1. Update labeling. Labels for any products containing sesame or its derivatives must list sesame as an ingredient in every single instance it’s used. For example, products that contain tahini spice must list “sesame” in parentheses as a component of the ingredient. If the base flour of a product contains any sesame at all, sesame must also be listed as an ingredient of the flour. 

1. Bolster cross-contact prevention measures. Manufacturers should carefully review their cleaning and sanitation protocols to ensure they adequately eliminate sesame traces from equipment and surfaces between production runs. If space, budget, and scheduling allows, it’s recommended to completely separate production lines and equipment for products that contain sesame or other major food allergens. It's also important to update employee training on proper cross-contact prevention. 

1. Investigate suppliers. Beyond their own measures to prevent cross-contact, manufacturers should check with their suppliers to ensure they uphold the same food safety standards. Request documentation from vendors for insight into their own sanitation protocols and other strategies for preventing cross-contact. Find out whether they interact with sesame in their facilities. In addition, consider periodic testing of ingredients to ensure there are no trace amounts of sesame present. 

A Seamless Transition to Food Allergen Labeling and Food Safety Compliance 

Sesame is a dangerous ingredient for consumers with a sesame allergy, so complying with the FASTER Act is critical for food and beverage manufacturers to ensure public safety. Adhering to major food allergen labeling requirements can mean significant investment, ranging from basic product labeling updates to dramatic operational overhauls with segregated equipment and production lines. Following best practices reduces the risks to consumer health, product recalls, loss of reputation, and regulatory fines. However, ensuring compliance can be difficult without the expertise of a third-party consultant. 

AIB International, a trusted leader in guiding manufacturers and customers through the complex and evolving regulatory landscape, provides specific education about complying with sesame allergy regulations.