The FASTER Act: Sesame Becomes a Major US Allergen in January 2023
The FASTER Act added sesame as the ninth major food allergen under US law, effective January 1 2023. Here's what changed and how food businesses need to respond.
The Food Allergy Safety, Treatment, Education, and Research (FASTER) Act, signed into law in April 2021, added sesame as the ninth major food allergen under US federal law. The change took effect on January 1, 2023, meaning all food manufacturers selling in the US must now declare sesame on their product labels and online product pages.
Why Sesame Was Added
Sesame allergy affects an estimated 1.6 million Americans and causes severe reactions, including anaphylaxis, at rates comparable to the other major allergens. Prior to the FASTER Act, sesame did not require explicit declaration — it could appear in ingredient lists under vague terms like "natural flavours" or "spices", making it nearly impossible for allergic consumers to identify. The FASTER Act closed this loophole.
What Changed for Food Manufacturers
Since January 1, 2023, any food product containing sesame sold in the US must declare it using the same methods as other major allergens: either within the ingredient list ("tahini (sesame)") or in a "Contains" statement ("Contains: Sesame"). This applies to sesame in all forms — seeds, oil, flour, paste, tahini, and sesame-derived ingredients.
The Cross-Contamination Problem
The sesame FASTER Act implementation revealed a significant industry problem: many manufacturers who didn't intentionally add sesame discovered it as a cross-contact allergen in their facilities. Rather than invest in allergen control measures, some manufacturers simply added sesame to their "Contains" declarations. This created a paradox where many more products now declare sesame, making it harder for sesame-allergic consumers to find safe options. Responsible food businesses should invest in genuine allergen control rather than blanket declarations.
What the FASTER Act Means for Online Retailers and Shopify Merchants
For Shopify merchants selling food products into the United States, the FASTER Act is not a concern limited to physical packaging alone. Online product pages are considered part of the labelling environment under FDA guidance, which means the allergen information displayed on your storefront must be consistent with what appears on the physical label. If a product contains sesame in any form and you are selling into the US market, that declaration must appear clearly on the product page — not buried in a downloadable PDF, not hidden in a footnote, and not left to the customer to infer from a list of ingredients they have to squint at.
The practical implication for merchants is that every product listing needs to be reviewed against the new sesame requirement, even for products that have been on sale for years. A sesame oil used as a flavouring component, a tahini-based sauce, or a bread product topped with sesame seeds all require explicit declaration under the new rules. Merchants who source from multiple suppliers also face the added complexity that a reformulation or supplier change upstream could introduce sesame without triggering an obvious notification. Keeping allergen data current is an ongoing process, not a one-time audit.
The consequences of non-compliance extend beyond FDA enforcement risk. Allergic consumers and their families are increasingly sophisticated about reading product pages before purchasing, and they will simply abandon a listing that does not provide clear allergen information. Trust is difficult to build and easy to lose in the food allergy community. Merchants who invest in transparent, accurate allergen labelling on their Shopify stores gain a meaningful competitive advantage among a customer segment that purchases with exceptional brand loyalty when they find a retailer they trust.
How Sesame Differs from the Original Eight Major Allergens
The eight allergens established under the original 2004 Food Allergen Labelling and Consumer Protection Act — milk, eggs, fish, shellfish, tree nuts, peanuts, wheat, and soy — had nearly two decades of regulatory and industry infrastructure built around them before sesame joined the list. Manufacturers had long-established supplier verification processes, allergen control plans, and labelling workflows for those eight. Sesame arrived as a ninth allergen into an industry that was not structurally prepared for it, which is a significant part of why the cross-contamination problem described above became so pronounced so quickly.
Sesame is also biologically distinct in ways that create unique handling challenges. Unlike peanuts or tree nuts, which are often used as discrete, recognisable inclusions, sesame is widely used in processed and flavoured forms — sesame oil, tahini paste, sesame flour — that are less visually obvious in a production environment. Workers and quality assurance teams trained to spot a peanut fragment or a cashew piece may not have equivalent instincts for identifying sesame-derived ingredients in compound sauces or marinades. This makes thorough ingredient-level supplier documentation especially important for sesame in a way that differs from some of the more familiar allergens.
There is also a labelling nuance worth understanding: unlike some other allergens where the common name is unambiguous, sesame can appear under a genuinely wide range of ingredient names on incoming supplier specifications — gingelly oil, benne seeds, til, and various transliterations of sesame from other languages all describe the same ingredient. Merchants and manufacturers sourcing internationally should ensure their ingredient review processes are specifically trained to catch these variant names, as a supplier listing "til seeds" without a parenthetical common name could technically introduce an undeclared allergen if not caught at the procurement stage.
Updating Your Shopify Product Pages for Sesame Compliance
The most common mistake Shopify food merchants make when responding to a regulatory change like the FASTER Act is to update only the products they immediately associate with sesame — the obvious candidates like hummus, tahini, or sesame snack bars. In practice, sesame appears as an ingredient or a potential cross-contact allergen in a far wider range of products than most merchants initially expect. Compound sauces, Asian-style marinades, some baked goods, certain spice blends, and even some flavoured snack products can all contain sesame-derived ingredients that are easy to overlook in a first pass through a product catalogue.
A structured approach is more reliable than a product-by-product manual review. Start by gathering the full ingredient specifications for every product you sell into the US market, then systematically search each specification document for sesame and all of its variant names. Any product where sesame appears as a deliberate ingredient or as a cross-contact risk in the supplier's own documentation needs a corresponding declaration on your Shopify product page. This process also creates a documented paper trail that demonstrates due diligence if a compliance question is ever raised, which has value beyond the immediate labelling task.
Once your allergen data is accurate and complete, the question becomes how to present it clearly on your storefront without degrading the customer experience. Inline allergen badges, structured "Contains" statements in product descriptions, and filterable allergen matrices all serve different customer needs. The goal is to make it genuinely easy for a sesame-allergic customer to determine within a few seconds whether a product is safe for them — not merely to technically satisfy the disclosure requirement while still making the information hard to find. Allergen Matrix is designed specifically to help Shopify merchants achieve both compliance and clarity at the same time.
The Broader Trend: Allergen Law Is Expanding, Not Contracting
The FASTER Act is not an isolated event — it reflects a broader, sustained trend of allergen labelling requirements becoming more comprehensive and more strictly enforced across major markets. The European Union already mandates declaration of fourteen allergens under EU Food Information Regulation 1169/2011, and both the UK and Australia operate their own distinct allergen frameworks that differ in meaningful ways from the US list. For Shopify merchants selling across multiple geographies, this creates a genuinely complex matrix of obligations where a single product may need to meet four or five different national standards simultaneously.
There is a strong likelihood that the US list will continue to grow beyond nine allergens. The FASTER Act itself required the Department of Health and Human Services to conduct a study on sesame allergy and established a framework that could be applied to other candidate allergens. Alpha-gal syndrome, related to a tick-borne sensitivity to mammalian meat products, and allergies to mustard, lupin, and molluscs are all areas of ongoing advocacy and research at the regulatory level. Merchants who build their compliance processes around a rigid, list-specific approach will face repeated disruption as the lists evolve.
Building a flexible, data-driven allergen management system is therefore a strategic investment rather than a one-time compliance fix. When the next allergen is added to a national list, merchants with structured allergen data already attached to their products can update their storefronts quickly and confidently. Merchants relying on manually written product descriptions will face the same scramble they experienced with sesame in January 2023, multiplied across every future regulatory change. Getting the infrastructure right now pays dividends across every future update.
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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.