groupe agraphe

March 2, 2026 · 8 min read

Compliance & Regulations

Food Allergens: How to Label Them Correctly

Dans cet article

• Where and how to indicate allergens on the label

• The wording to use to stay compliant

• The mistakes that expose your business to a recall

Canada's list of priority allergens

A bakery adds a new pistachio-cardamom cookie to its lineup, swaps in a spice blend from a new supplier, and reprints the same label template used for every other product in the line, because "nothing changed except the spices." That kind of assumption is exactly how allergen-labelling mistakes happen, which is why Health Canada recognizes a specific list of priority allergens: peanuts, tree nuts (almonds, Brazil nuts, cashews, hazelnuts, macadamia, pecans, pine nuts, pistachios, walnuts), sesame, milk, eggs, wheat and triticale, crustaceans and molluscs, mustard, soy, and fish.

Two other categories get the same level of rigour even though they aren't allergens in the strict sense: added sulphites and gluten sources (barley, rye, oats, triticale, wheat). If your product contains any of these, they need to be declared the same way.

That new-supplier scenario is worth internalizing, because it's one of the most common ways an allergen goes missing from a label, not because someone ignored the list, but because a spice blend, a coating, or a flavouring agent changed suppliers and the sub-ingredients weren't checked against the priority list before the next print run.

An allergen label rarely fails because someone ignored the rules, it fails because a supplier changed and nobody checked the list again.

Two ways to declare, one rule that doesn't bend

You have two options for declaring an allergen. The first: name the source directly in the ingredient list, using its exact common name, "wheat," not "cereal" or "plant protein."

The second: add a separate "Contains" statement right after the ingredient list. Watch for a common trap, if you use this statement, it has to list every allergen present in the product, even ones already named earlier in the ingredient list. Leaving one out of the Contains line because it's already mentioned elsewhere is a mistake we see regularly, and it can be enough to trigger a recall.

Both methods are valid. What matters is consistency: don't mix the two approaches halfway, and revalidate the statement every time the recipe changes.

Say your ingredient list already spells out "whey powder" and "egg white", technically, both allergens are declared. But if you also add a Contains statement and only list "milk," leaving out "egg" because it seemed redundant, you've created a label that reads as incomplete at a glance, and that's the version most likely to get flagged.

"May contain": good practice, not a default add-on

Many manufacturers add a "may contain traces of..." statement to flag cross-contamination risk on the production line. The CFIA recommends this practice for cases where the risk is real.

It isn't something to slap on every product just in case. It should reflect an actual risk identified in your manufacturing process. If you're unsure what applies to your specific situation, confirm it directly with the CFIA or a food safety consultant rather than guessing.

We've seen the opposite problem too: a producer adding a "may contain peanuts" warning across an entire product line, including items made in a facility that has never handled peanuts, just to feel safer. That habit dilutes the warning's meaning for the products where the risk is real, and it can needlessly cut a product out of school programs or allergy-conscious retail shelves that screen out "may contain" labels regardless of the actual risk.

Why this is the highest-stakes line on the whole label

A mislabelled allergen doesn't just risk a fine or a rejected shipment, it can put someone at risk of a serious reaction. That's why allergen-related recalls are treated with so much seriousness by the CFIA.

In our experience, the problem rarely comes from a deliberate omission. It comes from a supplier switch, a recipe tweak in the kitchen that never made it back to the label, or a Contains line copied straight from an older version of the product. The simplest discipline: revalidate allergens every time an ingredient changes, not just at product launch.

The recall process itself is disruptive in ways that go beyond the label: product gets pulled from shelves, retailers issue public notices, and the CFIA posts the recall publicly, where it stays searchable long after the corrected label ships. For a small producer, that public record can outlast the actual safety issue by years.

KEY TAKEAWAYS

Health Canada's priority allergen list covers peanuts, tree nuts, sesame, milk, eggs, wheat/triticale, crustaceans/molluscs, mustard, soy, and fish, plus sulphites and gluten sources held to the same standard.

Allergens can be declared directly in the ingredient list (using the exact common name) or in a separate Contains statement, but a Contains statement must list every allergen present, not just the ones not already named elsewhere.

"May contain" statements should reflect an actual identified cross-contamination risk, not be added as a blanket precaution.

Allergens should be revalidated every time a supplier or recipe changes, not just at product launch.

FREE GIFT

Download our Health Canada compliance checklist

Check at a glance that your labels meet regulatory requirements.

Download

One more check, before we print

Before printing new artwork or a new recipe, we always compare the ingredient list you send us against the allergen statement on the label. It's a two-minute step that saves weeks of recall.

If you change a supplier or an ingredient, let us know before printing, not after.

It sounds like a small step, but it's the cheapest insurance in the entire production process, a two-minute cross-check against a print run that, once shipped, can't be recalled from a customer's pantry.

Ready to get your price?

Reply within 24h, no commitment.

Get my price in 24h