FALCPA and Tree Nuts: Why Individual Declaration Matters
FALCPA requires tree nuts to be declared by their specific common name, not simply as "tree nuts". Here is why individual tree nut declaration matters for US food labels.
"Tree nuts" as a category is listed as a major allergen under FALCPA. However, the FDA requires that when a product contains a tree nut, the specific type of tree nut must be declared by its common name — not simply listed as "tree nuts."
Why Specific Declaration Is Required
Tree nut allergies vary considerably by individual. Someone allergic to cashews may not be allergic to almonds, and vice versa. The FDA recognises that umbrella labelling of "tree nuts" does not give consumers sufficient information to make safe purchasing decisions.
The tree nuts that must be individually declared include: almonds, cashews, pecans, pistachios, walnuts, Brazil nuts, hazelnuts (filberts), macadamia nuts, pine nuts, and chestnuts, among others.
How to Declare Tree Nuts Correctly
Within the ingredient list, each tree nut must appear by its specific common name. In a Contains statement, each tree nut present must be listed individually — "Contains: almonds, cashews" rather than "Contains: tree nuts."
Shared Facility Statements
If a product is manufactured in a facility that processes multiple types of tree nuts and there is a cross-contamination risk, the advisory statement should specify which tree nuts are processed — "May contain almonds and walnuts" — rather than the generic "May contain tree nuts."
New York State Tree Nut Requirements
New York State has additional requirements around tree nut disclosure for food sold in New York, building on the FALCPA foundation. If you sell into New York specifically, review the state-level requirements alongside FALCPA.
Understanding Cross-Reactivity and Why It Shapes Labelling Policy
Cross-reactivity between tree nuts is a documented clinical phenomenon, but the patterns are not universal or predictable enough for regulators to rely on. A consumer allergic to walnuts may or may not react to pecans, which are botanically related, but that relationship cannot be assumed. The FDA's position on individual declaration is grounded in this clinical uncertainty — without specific naming, allergic consumers cannot accurately assess their personal risk from a given product.
This is why vague labelling creates genuine legal exposure for food brands, not just a compliance technicality. If a consumer suffers an allergic reaction to a product labelled only as "contains tree nuts" when the specific nut responsible for their allergy was present and undisclosed, the brand faces significant liability. Courts and regulators have consistently held that FALCPA requirements exist precisely to prevent this outcome, and ignorance of the specific rule around individual declaration is not a defence.
For Shopify merchants selling food products into the United States, this means every product description, ingredient panel, and allergen summary displayed on your storefront must reflect the correct specific names. If your supplier has provided a generic tree nut declaration on a technical data sheet, you cannot simply pass that through to your consumer-facing label. You are responsible for ensuring the declaration meets FALCPA standards before it reaches a US customer.
Common Labelling Mistakes Merchants Make with Tree Nuts
One of the most frequent errors seen in practice is the use of a single consolidated Contains statement that reads "Contains: tree nuts" without further specification. This appears on many imported products where the originating country's labelling law does not require individual declaration. When those products are sold in the US — including through an online Shopify store shipping to US addresses — the label must be corrected or supplemented to meet FALCPA standards. Selling an imported product in its original packaging does not transfer compliance responsibility away from the US-based retailer.
A second common mistake involves derivative ingredients. Marzipan, for instance, contains almonds. Praline fillings often contain hazelnuts. Pesto can contain pine nuts. When these are used as sub-ingredients in a compound product, the tree nuts within them still require individual declaration. Merchants sometimes list "marzipan" as an ingredient without understanding that the almond content must surface at the allergen declaration level. The ingredient name alone does not satisfy the requirement — the underlying tree nut must be named.
A third error involves product descriptions on Shopify product pages that are written independently of the physical label. Marketing copy that describes a product as "nut-free" or fails to mention tree nut content — even when the physical label is technically compliant — can create consumer confusion and legal risk. The allergen information visible to a customer during the purchase decision should be consistent with and at least as complete as the physical label. Keeping your digital storefront aligned with your physical labelling is a core part of responsible food retail online.
Handling Multi-SKU Catalogues with Varying Tree Nut Content
Merchants with large catalogues often carry multiple product variants that share a base recipe but differ in flavour or mix-in ingredients. A chocolate bar range might include an almond variant, a hazelnut variant, and a mixed-nut variant containing cashews and macadamia nuts. Each SKU requires its own distinct allergen declaration that accurately reflects its specific tree nut content. Applying a blanket allergen tag of "tree nuts" across the entire range to simplify catalogue management is not compliant and puts customers at risk.
The challenge scales quickly when a catalogue runs to dozens or hundreds of SKUs. Manually reviewing and updating allergen declarations across that volume is error-prone, particularly when formulations change or new supplier batches introduce different ingredients. A structured approach — where allergen data is stored at the ingredient level and surfaced automatically to the product page — dramatically reduces the risk of outdated or incorrect declarations reaching customers. This is precisely the workflow that purpose-built allergen management tools are designed to support.
When a product contains three or more different tree nuts, the Contains statement must list each one. "Contains: almonds, cashews, macadamia nuts, pecans" is the correct format — there is no shorthand permitted under FALCPA. Merchants who manage this manually across a large Shopify catalogue will benefit from a system that enforces completeness at the point of data entry, so that no tree nut is accidentally omitted from the declaration when a product is published or updated.
Updating Declarations When Formulations or Suppliers Change
Supplier changes are one of the most common triggers for allergen labelling errors. A merchant may have a well-documented declaration for a product that has been stable for two years, then switch to a new supplier who processes additional tree nuts in their facility or uses a slightly different formulation. Without a formal review process triggered by supplier or ingredient changes, the existing declaration becomes inaccurate — sometimes without anyone in the business noticing until a complaint or incident occurs.
Best practice is to treat every supplier change as a labelling event. When a new ingredient specification sheet is received, it should be reviewed against the existing allergen declaration for every product that uses that ingredient. If the tree nut profile changes — even if a new nut is only present as a cross-contamination risk rather than an intentional ingredient — the product's declaration needs to be assessed and potentially updated. This applies to both the physical label and the digital storefront.
Shopify merchants should build a clear internal process for this: who is responsible for reviewing new supplier documentation, who has the authority to update product pages, and what the sign-off process looks like before a change goes live. Allergen declarations are not set-and-forget content. They are live compliance documents that need to track accurately with the current state of your supply chain, and tree nut declarations in particular require vigilance given the number of distinct nuts that may appear across a typical food catalogue.
Practical Steps for Shopify Merchants Selling Food to US Customers
Start by auditing your existing product catalogue for any instance where "tree nuts" appears as an allergen declaration without individual nut names specified. This audit should cover both the physical labels associated with each product and the allergen information displayed on your Shopify product pages. Where discrepancies exist between the two, resolve them before the product remains available for purchase. Pulling a product temporarily while the declaration is corrected is far preferable to leaving an inaccurate declaration live.
Next, establish a standardised format for your Contains statements across all US-facing products. Decide whether you will use parenthetical declaration within the ingredient list, a standalone Contains statement, or both — and apply that format consistently. Consistency helps your team spot errors more easily and helps customers navigate your labels more confidently. The FDA permits either method as long as the specific tree nut common name is present, so the choice is yours, but uniformity across your catalogue is good practice.
Finally, consider how your Shopify store is structured to surface allergen information. Allergen details should be visible on the product page without requiring the customer to download a PDF or navigate to a separate section of your site. Customers making purchasing decisions for themselves or for someone with a tree nut allergy need that information at the point of decision. Using a dedicated tool like Allergen Matrix to manage and display allergen data across your Shopify catalogue ensures that your declarations are accurate, consistent, and accessible — reducing both compliance risk and the administrative burden of keeping everything up to date.
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.