FALCPA for Importers: How Foreign Food Brands Must Label for the US Market
Food imported into the United States must comply with FALCPA regardless of country of origin. Here's what foreign food brands need to know about labelling for US import.
Foreign food brands exporting to the United States — whether from the UK, Europe, Asia, or anywhere else — must comply with FALCPA allergen labelling requirements. This requirement applies regardless of how allergens are labelled in the product's home country.
FALCPA Applies to All Food Sold in the US
FALCPA's requirements apply to all food sold in the US, including imported products. A French cheese sold in a US specialty food shop must comply with FALCPA. A UK confectionery brand selling through Amazon.com must comply with FALCPA. There is no import exemption from FALCPA.
Common US vs European Label Differences
European (including UK) food labels declare 14 allergens with emphasis in the ingredient list. FALCPA requires 9 allergens declared via a "Contains" statement or common name in ingredients. Key differences: FALCPA requires a "Contains" statement adjacent to the ingredient list; European labels use bold emphasis, which satisfies FALCPA's common-name-in-ingredients method but not necessarily the "Contains" format preferred in the US. The safest approach for importers is to add a "Contains" statement to labels in addition to the EU/UK format.
The Sesame Requirement for Importers
Since January 2023, sesame must be declared on all food sold in the US. Many European products contain sesame (in bread, tahini, Middle Eastern foods) without explicit declaration as a major allergen on their home-market labels. US-market labels for these products must now declare sesame explicitly.
Labelling for Shopify US Sales
If you sell imported food through a Shopify store to US customers, your product pages must display FALCPA-compliant allergen information — regardless of the product's country of origin. SaltAI's Allergen Matrix supports US FALCPA allergen declarations for all products in your Shopify catalogue.
Manage FALCPA allergen compliance for imported food products on your Shopify store with SaltAI.
Who Is Responsible for FALCPA Compliance on Imported Products
When a foreign food brand sells into the US market, the legal obligation for FALCPA compliance does not rest with the overseas manufacturer alone. The US importer of record, the domestic distributor, and any retailer selling the product can all carry responsibility if a label is non-compliant. This means that if you are a Shopify merchant importing food products from abroad and selling them to US consumers, you cannot assume the overseas supplier has handled US labelling requirements correctly. You should verify compliance before listing any imported product for sale.
In practical terms, this means requesting label copies from your supplier before placing your first order and reviewing them against FALCPA's nine major allergen requirements. Many overseas suppliers — particularly small artisan producers in Europe and Asia — are entirely unfamiliar with US labelling law. They may have perfectly compliant labels for their home market while inadvertently omitting required US declarations. Do not assume that a CE mark, a UK Food Standards Agency approval, or any other foreign regulatory clearance provides any cover under US federal food labelling law.
If you are reformatting or reprinting labels for the US market — which is a common and entirely legitimate practice for importers — you must ensure the US-format label is the one that reaches the end consumer. Applying a compliant sticker over the original foreign label is an acceptable workaround for many importers, provided the sticker fully covers non-compliant text and clearly presents the required allergen declaration in the correct format. The FDA does not prohibit sticker overlays, but they must be durable, legible, and accurate.
Allergen Name Mapping: When Foreign Ingredient Names Cause Problems
One frequently overlooked problem for importers is the ingredient naming conventions used on foreign labels. European regulations permit certain ingredient names — including some allergen-containing ingredients — that are not immediately recognisable to a US consumer or FDA reviewer as allergen sources. For example, an ingredient listed as "spelt flour" on a German product may not automatically trigger allergen recognition among US shoppers, even though spelt is a form of wheat and therefore a FALCPA-regulated major allergen. US labels must use the common or usual English name of the source ingredient.
Similar issues arise with dairy and egg derivatives. Ingredients like "casein," "whey," "lactose," "albumin," or "globulin" are milk or egg proteins that require declaration under FALCPA even if the word "milk" or "egg" does not appear in the ingredient name itself. A foreign label might list these components by their technical names without any additional allergen callout — which is acceptable under EU or UK rules but non-compliant under US law. When reviewing an imported product's ingredient list, you must map every ingredient back to its FALCPA allergen source, not just scan for obvious allergen keywords.
Tree nuts present their own mapping challenge for importers. FALCPA requires that the specific type of tree nut be declared — not just the generic term "tree nuts." A product listing "mixed nuts" or "assorted tree nuts" without specifying the individual varieties does not meet FALCPA requirements. If your imported product contains almonds, cashews, and pecans, all three must be identified by name, either within the ingredient list or in the "Contains" statement. This level of specificity is more granular than most European labelling frameworks require, and it is a common compliance gap for first-time importers.
Precautionary Allergen Labelling and US Market Expectations
Precautionary allergen labelling — statements such as "may contain traces of nuts" or "produced in a facility that also handles milk" — is voluntary under both FALCPA and EU food law. However, the practical expectations of US consumers and US retail buyers differ considerably from those in Europe. Many US retailers, particularly natural food chains, specialty grocers, and health-focused online marketplaces, have their own supplier requirements around precautionary statements. Understanding this landscape matters for importers positioning products in those channels.
The FDA has historically not regulated the wording of precautionary statements, though there is ongoing industry and regulatory discussion about standardising their use. For imported products, this creates a somewhat ambiguous space: your FALCPA "Contains" statement is a hard legal requirement, but your "may contain" language is a voluntary disclosure that nonetheless carries commercial and reputational weight. If your overseas supplier uses precautionary language that is vague, inconsistent, or contradicted by their own production records, US buyers will likely push back during onboarding.
For Shopify merchants selling imported food directly to US consumers, the product page is effectively part of the label. If you display allergen information online — and best practice strongly suggests you should — that information needs to be as accurate and complete as the physical label. Displaying FALCPA-compliant allergen declarations on your product pages, including any relevant precautionary statements, builds consumer trust and reduces the risk of complaints or returns from allergy-affected customers. Allergen Matrix allows you to manage these declarations centrally across your entire Shopify catalogue.
Handling Label Updates When Products or Formulations Change
Imported food products are not static. Suppliers change formulations, swap ingredient sources, update manufacturing facilities, and revise their own home-market labels — often without proactively notifying their overseas trade buyers. For importers, this creates a genuine ongoing compliance risk. A product that was FALCPA-compliant when you first listed it on your Shopify store may no longer be compliant if your supplier has quietly changed a sub-ingredient or switched to a new factory that handles additional allergens.
Building a robust supplier communication process is essential for any importer selling food into the US market at scale. This means establishing contractual requirements that suppliers must notify you of any formulation or facility change before the change takes effect, not after. It also means scheduling periodic label reviews — at minimum annually — rather than assuming labels remain accurate indefinitely. The FDA does not offer an amnesty period for importers who sell non-compliant products due to supplier changes they were unaware of; the responsibility for accuracy sits with the party placing the product into commerce in the US.
When a formulation change does introduce a new FALCPA allergen, you need to update both your physical labels and your online product listings promptly. If you have existing stock in a US warehouse or fulfilment centre that carries the old label, you will need to assess whether that stock can legally continue to be sold. Selling food with a known non-compliant allergen declaration — even legacy stock — creates regulatory and liability exposure. Managing this process efficiently across a large imported product range is one of the practical reasons that having a centralised allergen management tool integrated with your Shopify store is worth the investment.
Managing a Multi-Origin Product Catalogue on Shopify
Many Shopify food merchants do not sell products from a single country of origin. A specialty food store might carry Japanese condiments, Italian pasta, Indian spice blends, and Scandinavian biscuits alongside domestically produced items. Each category brings its own labelling conventions, ingredient name traditions, and potential allergen declaration gaps. Managing FALCPA compliance across this kind of diverse, multi-origin catalogue manually — through spreadsheets or individual product page edits — is time-consuming and error-prone.
A centralised allergen management system that integrates directly with Shopify allows you to maintain accurate, consistent FALCPA declarations across every product in your catalogue regardless of where it originates. When a supplier sends an updated specification sheet, you update the record once and the change flows through to your storefront automatically. This is particularly valuable for merchants who manage hundreds of SKUs, run regular new product launches, or operate across multiple Shopify markets simultaneously with different regional allergen requirements.
SaltAI's Allergen Matrix is built specifically for Shopify merchants managing food product catalogues that span multiple origins, formats, and regulatory frameworks. It supports US FALCPA allergen declarations alongside EU and UK requirements, so you can manage compliance for all your markets from a single dashboard without maintaining parallel systems.
Try Allergen Matrix free at saltai.app — no credit card required.
SaltAI Team
SaltAI builds focused Shopify apps for food merchants and general merchants. Every app is tested in production at a real food store — including Vanda's Kitchen — before it ships.