How to Write "Contains" Statements That Meet FALCPA Standards
A "Contains" statement is the simplest way to declare allergens under FALCPA — but there are specific rules about how it must be written and where it must appear.
The "Contains" statement is the most visible allergen declaration on a food label — but it's also one of the most commonly formatted incorrectly. Here's exactly how to write a "Contains" statement that meets FALCPA requirements.
The Basic Format
A compliant "Contains" statement follows this structure: the word "Contains" with a capital C, followed by a colon, followed by the names of all major allergens present in the product, separated by commas. Example: "Contains: Wheat, Milk, Eggs." The statement must appear immediately after or adjacent to the ingredient list, never in an isolated part of the label.
Using Common Names
FALCPA requires common names for most allergens: "milk" not "dairy", "wheat" not "gluten", "peanuts" not "groundnuts". For fish and shellfish, the specific type must be named: "salmon" or "shrimp" rather than just "fish" or "shellfish". For tree nuts, each variety must be listed: "Contains: Almonds, Cashews, Walnuts" rather than "Contains: Tree nuts".
What Not to Include
The "Contains" statement should only list major allergens — the nine covered by FALCPA. Do not add non-allergen dietary information to a "Contains" statement. If you want to flag voluntary advisory warnings like "may contain traces of peanuts", these should appear separately and should not be combined with the required "Contains" statement, as mixing required and voluntary declarations can create legal ambiguity.
Online Product Pages
Your Shopify product pages should mirror your physical label's "Contains" statement. This is not just best practice — FDA guidance for internet food sales requires pre-purchase allergen disclosure. SaltAI's allergen tools let you manage "Contains" information centrally and display it consistently across your online store.
Keep your "Contains" declarations consistent across all products.
Capitalisation and Punctuation Rules That Matter
Consistency in capitalisation and punctuation is not just about aesthetics — it signals to regulators and consumers alike that your labelling was prepared carefully and intentionally. FALCPA does not prescribe a specific font size for the "Contains" statement beyond requiring it to be conspicuous, but the capitalisation of the word "Contains" itself is a widely accepted convention that the FDA expects to see applied uniformly. Deviating from it without reason can draw unnecessary scrutiny during an audit or inspection.
Each allergen name within the statement should be capitalised as a proper item in a list, and the statement should close with a full stop. So the correct format reads: "Contains: Wheat, Milk, Soy." not "contains wheat, milk, soy" or "CONTAINS: WHEAT, MILK, SOY." While all-caps text is not technically prohibited, it can reduce readability and may complicate your label review process if you are working with co-manufacturers or regulatory consultants who expect standard formatting.
When a product contains multiple allergens from the same category — for example, two different fish species — each must be named individually within the same "Contains" statement rather than grouped under a category heading. "Contains: Salmon, Tuna" is correct. "Contains: Fish (2 varieties)" is not. This specificity requirement exists precisely because allergic consumers need exact information to make safe purchasing decisions, and generalised groupings offer no meaningful protection.
Handling the FALCPA Nine Correctly
FALCPA originally identified eight major food allergens, and the FASTER Act of 2021 added sesame as the ninth, with full enforcement beginning January 1, 2023. If your product contains sesame in any form — sesame seeds, sesame oil, tahini, or any sesame-derived ingredient — it must now appear in your "Contains" statement just as wheat or milk would. Many small food businesses were caught off-guard by this addition, so it is worth auditing every product formulation explicitly against the updated list.
The nine allergens covered are: milk, eggs, fish, shellfish, tree nuts, peanuts, wheat, soybeans, and sesame. Each of these can appear in unexpected places within a formulation. Soy lecithin, for example, is a soy derivative and must trigger a soy declaration. Ghee is a milk derivative and requires a milk declaration. Ingredient suppliers do not always make these connections obvious on their own documentation, which is why cross-referencing every ingredient against FALCPA's covered sources is an essential step before finalising any label.
It is also worth noting that ingredients introduced during processing — not just those listed in the recipe — may require declaration. If your shared production equipment is cleaned between runs but allergen cross-contact is possible, you may need to address this through your voluntary advisory statement. However, if a FALCPA allergen is genuinely present as an intentional ingredient, there is no discretion involved: it must appear in the "Contains" statement. The distinction between intentional presence and cross-contact risk is legally significant and should be clearly documented in your production records.
Placement on the Label and Proximity Rules
The FDA requires that a "Contains" statement appear immediately after or adjacent to the ingredient list. This means it cannot float freely on a back panel away from the ingredients, appear only on a website without physical label parity, or be buried in small print beneath a nutritional claims section. The proximity requirement exists so that consumers reviewing ingredients will encounter the allergen summary in the same reading flow, reducing the chance of a missed declaration.
In practical terms, most compliant labels place the "Contains" statement on the same line immediately following the final ingredient, or on the very next line with no intervening text. Some manufacturers use a slightly bolder font weight or a box border to draw attention to the statement, which is permissible provided it does not distort the text or make it less legible. What you cannot do is place the "Contains" statement on a different panel entirely from the ingredient list, even if that panel is technically still part of the label.
For products sold in multipacks or with outer packaging distinct from inner packaging, each individual unit that may be consumed separately must carry its own compliant label, including the full "Contains" statement. A master carton declaration does not satisfy FALCPA requirements for inner units. If you are scaling a product into retail or foodservice formats, this is an easy compliance gap to miss, and getting it right before printing packaging at volume will save significant rework costs down the line.
Updating "Contains" Statements When Formulations Change
Formulation changes are one of the most common sources of allergen labelling errors. When a supplier substitutes an ingredient, introduces a new processing aid, or changes a manufacturing facility, the allergen profile of your product can shift without any obvious change to the recipe on paper. Building a formal change management process that routes all ingredient and supplier updates through a labelling review is the most reliable way to catch these issues before mislabelled products reach consumers.
If you discover that a product has been sold with an incorrect or incomplete "Contains" statement, you should seek regulatory guidance promptly. The FDA takes allergen mislabelling seriously, and voluntary recalls initiated by the manufacturer are treated more favourably than those triggered by consumer complaints or third-party inspections. Documenting your discovery process, your corrective action, and your communication with the FDA demonstrates good-faith compliance and helps protect your brand in what is always a difficult situation.
From a practical standpoint, version-controlling your label files and linking each version to its corresponding approved formulation is essential. A label that was accurate twelve months ago may no longer reflect your current ingredient sourcing. Treating your "Contains" statements as living documents — subject to the same review discipline as your ingredient list — is the operational mindset that separates consistently compliant food businesses from those that encounter avoidable problems. Allergen Matrix makes this process significantly easier by centralising your allergen data so that any formulation update flows through to your label declarations automatically.
Translating "Contains" Statements for Bilingual Labels
Many food businesses selling in the United States serve communities where English is not the primary language, and bilingual labelling is increasingly common. FALCPA does not require bilingual labels, but if you choose to include a second language anywhere on your label, the FDA's position is that allergen information in the second language must be equally accurate and complete. A Spanish-language ingredient list that omits allergen declarations present in the English version would be considered misleading and non-compliant.
When translating allergen names, use the common name in the target language rather than a literal translation of the English term. In Spanish, "leche" for milk, "trigo" for wheat, and "soya" for soy are the expected terms. If you are working with a translator who is not familiar with food labelling conventions, it is worth having a bilingual food science professional review the output before printing. A translation error on an allergen declaration carries the same legal and safety risk as an error in the original English text.
For Shopify merchants selling to diverse customer bases, this also applies to your online product pages. If your store offers a translated storefront or you use a translation app, your allergen information fields should be included in the translation scope. Leaving allergen declarations in English on a Spanish-language product page creates both a compliance risk and a customer trust problem that is entirely avoidable with a small amount of additional setup.
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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.