FALCPA vs UK Allergen Labelling: Key Differences

Food allergen labelling is a critical concern for food businesses worldwide, especially those exporting products across borders. If you’re a UK-based food business considering or already exporting to the United States, understanding the Food Allergen Labelling and Consumer Protection Act (FALCPA) is essential. 

This guide breaks down FALCPA requirements, highlights key differences with UK allergen regulations, including Natasha’s Law and PPDS foods, and provides practical tips for compliance and international trade.

Key Takeaways

• FALCPA is the US law that requires the labelling of 8 major allergens, while the UK mandates the labelling of 14.
• Natasha’s Law is a central part of UK allergen compliance, especially for PPDS (Prepacked for Direct Sale) foods.
• The UK and US allergen lists overlap but are not identical; the UK includes allergens such as celery, lupin, mustard, and sulphites.
• Exporters must ensure packaging complies with both FALCPA and UK regulations to avoid recalls or legal penalties.
• MenuSano’s labelling software supports compliance for the UK, the US, and Canada, simplifying the process for food businesses.

What is FALCPA?

The Food Allergen Labelling and Consumer Protection Act (FALCPA) is a US federal law that came into effect in 2006. Its primary goal is to protect consumers with food allergies by mandating clear labelling of specific allergens on packaged food products. FALCPA identifies eight major allergens that must be declared:

1. Milk
2. Eggs
3. Fish
4. Crustacean shellfish
5. Tree nuts (e.g., almonds, walnuts, pecans)
6. Peanuts
7. Wheat
8. Soybeans

These allergens account for the vast majority of allergic reactions in the US population. Under FALCPA, food manufacturers must declare these allergens in plain language, either in the ingredient list or in a separate “Contains” statement, to ensure clarity for consumers.

How Does FALCPA Differ from UK Allergen Labelling?

For UK food businesses, it’s crucial to understand the differences between FALCPA and UK regulations. 

The UK, under the Food Information Regulations 2014, has some of the strictest allergen labelling requirements in the world. A cornerstone of this is Natasha’s Law, legislation introduced in 2021 to protect people with food allergies after the tragic death of Natasha Ednan-Laperouse. Natasha’s Law specifically requires that all PPDS (Prepacked for Direct Sale) foods display a full ingredients list with allergens highlighted.

PPDS foods are items that are packaged on the same premises from which they are sold, such as sandwiches, salads, or baked goods prepared and wrapped in a café or bakery before being placed on display. This category has been a major focus for UK regulators, as it closes a loophole that previously left many allergy sufferers at risk.

The UK’s allergen list is broader than FALCPA’s, including 14 allergens:

• Celery
• Cereals containing gluten
• Crustaceans
• Eggs
• Fish
• Lupin
• Milk
• Molluscs
• Mustard
• Peanuts
• Sesame seeds
• Soybeans
• Sulphur dioxide and sulphites
• Tree nuts

Key differences:

• The UK list includes allergens like celery, lupin, mustard, and sulphites, which are not required under FALCPA.
• FALCPA treats coconut as a tree nut, while the UK does not.
• The UK requires allergens to be emphasized (e.g., bold type) within the ingredients list, especially under Natasha’s Law for PPDS foods, whereas FALCPA allows a separate “Contains” statement.
• Natasha’s Law means that even small food businesses and independent shops must be vigilant about ingredients and allergen labelling, not just large manufacturers.

Why UK Exporters to the US Must Understand FALCPA

If you’re exporting food products from the UK to the US, your packaging must comply with FALCPA. Failure to declare allergens in accordance with US law can result in products being refused entry at the border, costly recalls, or even legal penalties. US consumers and retailers rely heavily on clear allergen labelling, so even minor errors can have significant business consequences.

It’s also worth noting that while Natasha’s Law and PPDS rules are unique to the UK, the US is also seeing increased scrutiny of allergen safety and labelling. UK businesses already accustomed to the high standards of Natasha’s Law may find it easier to adapt to FALCPA. 

Still, it’s critical to remember that the lists and labelling formats differ. For example, a sandwich prepacked for sale in a London café (a PPDS food) must have a full ingredient and allergen label under Natasha’s Law. Still, if you export a similar product to the US, you’ll need to ensure it also meets FALCPA’s requirements for the eight US allergens.

For a broader understanding of UK food labelling rules, visit: Understanding UK Food Labelling Regulations.

FALCPA Allergen List vs. UK’s 14 Allergens

Here’s a quick comparison:

Allergen	Required in the US (FALCPA)	Required in the UK
Milk	✅	✅
Eggs	✅	✅
Fish	✅	✅
Crustacean shellfish	✅	✅
Tree nuts	✅	✅
Peanuts	✅	✅
Wheat / Gluten	✅ (wheat)	✅ (all gluten)
Soybeans	✅	✅
Celery		✅
Lupin		✅
Molluscs		✅
Mustard		✅
Sesame seeds		✅
Sulphur dioxide/sulphites		✅

Practical Steps for UK Food Businesses

1. Audit Your Ingredients

Regularly review your ingredient lists for both UK and US-regulated allergens. This is especially important if you change suppliers or update recipes.

2. Dual-Compliance Packaging

If you sell in both the UK and the US, consider packaging that meets the requirements of both FALCPA and UK regulations. This can reduce errors and streamline production, but be sure to check for any market-specific nuances.

3. Staff Training

Ensure your team understands the differences in allergen labelling laws across markets. Regular training can prevent costly mistakes and protect your customers.

4. Use Software Tools

MenuSano can help streamline allergen declaration and nutrition labelling for UK, US, and Canadian standards. With MenuSano, you can generate compliant labels, track ingredient changes, and update packaging quickly and easily.

5. Document Control and Record Keeping

Maintain up-to-date records of your recipes, ingredient lists, and labelling for both markets. This helps with audits and demonstrates due diligence if any issues arise.

International Allergen Labelling: Beyond FALCPA and the UK

Allergen labelling laws are evolving globally. For example, Canada has its own set of priority allergens, and the EU retains similar rules to the UK post-Brexit. If you’re exporting to multiple markets, always check the latest regulations or consult a specialist. 

MenuSano’s easy-to-use software is regularly updated to reflect the latest legal requirements, so you can ensure compliance and have peace of mind as you expand internationally.

Frequently Asked Questions

How MenuSano Simplifies International Allergen Labelling

Staying compliant with both UK and US allergen labelling requirements can be challenging, especially for growing food businesses. 

MenuSano’s nutrition analysis and labelling software is designed to help you meet all regulatory requirements effortlessly, whether you’re selling locally or exporting abroad. With MenuSano, you can:

• Generate fully compliant nutrition and allergen labels for the UK, US, and Canadian markets, including Natasha’s Law requirements for PPDS foods.
• Instantly update your labels when regulations or recipes change.
• Save time and reduce the risk of costly errors with automated checks and calculations.
• Access up-to-date regulatory information for multiple regions.

MenuSano is trusted by food manufacturers, restaurants, and exporters across North America and the UK for its accuracy, ease of use, and ongoing support. Whether you’re just starting to export or already serving international markets, MenuSano helps you stay ahead of changing regulations and protects your brand reputation.

Ready to make international food labelling compliant and straightforward? Discover MenuSano’s labelling solutions here.