How can food recalls and allergens affect my cottage foods?

Every month at least one food recall is caused by missing or undeclared food allergens in a product’s ingredient listing. An undeclared food allergen means that a food allergen is present in the product but is not included in the product’s ingredient listing. In 2021 and 2022, 42 percent of all food recalls, by both the USDA Food Safety and Inspection Service and FDA, were due to undeclared allergens.

Food products that contain undeclared food allergens can pose a severe risk to people with food allergies and intolerances. It is estimated that 1 in 10 adults and 1 in 13 children have food allergies. When a person with a food allergy eats a food that contains a specific ingredient or allergen, they can experience a range of symptoms. The symptoms can be life-threatening. 

Mild symptoms of an allergic reaction include a rash, hives, and abdominal pain. Severe symptoms include difficulty breathing, a drop in blood pressure, swelling of the tongue or lips, and gastrointestinal distress. This is why undeclared food allergens are a chemical hazard and food safety risk. 

What is a food recall?

A food recall is the process of alerting and removing food that does not meet the safe handling, processing or manufacturing, labeling and other regulations intended to promote the safety of food from the marketplace. Food recalls are issued when a confirmed or suspected hazard is present in the food. 

The hazard can be:

•  physical (e.g., a piece of plastic),
•  chemical (e.g., an undeclared food allergen or heavy metal like lead in cinnamon applesauce), or
• biological (e.g., illness-causing microorganisms such as Salmonella, E. coli or other bacteria). 

A food recall can be issued voluntarily by the food manufacturer or by the USDA or FDA.

In a study of FDA-regulated food recalls, the root cause of recalls related to major food allergens was product labeling errors made by the food manufacturer. 70% of all food allergen-related recalls from 2013 to 2019 were due to labeling errors. Actions that led to many of these labeling errors were: 

• product labels not being updated after an ingredient change or reformulation; 
• labels put on the wrong food products; 
• lack of understanding of food allergens; and 
  technology failures.

Cross-contact or the transfer of a food allergen to an allergy-free food was a contributing factor to the remaining 30% food allergen-related recalls. Cross-contact can occur when safe food handling and best practices are not followed.

What are the major food allergens?

While many foods can trigger an allergic reaction in a person with a specific allergy, nine major (or common) food allergens cause the majority of reactions. These are: milk, egg, peanut, soy, wheat, tree nut, shellfish, fish, and sesame. The nine major allergens are required to be listed in the product ingredient list or in a separate “Contains” statement on the package.

Many foods or ingredients that contain a major food allergen are referred to by uncommon names. For example, sesame can be called benniseed, and milk can be listed as casein or whey. The Food Allergy Research and Education (FARE) organization maintains lists of uncommon names of the nine major food allergens.*

How does this impact me as a cottage food producer?

As a cottage food producer, you can reduce the risk of undeclared food allergens in your products by:

• Adhering to the labeling and ingredient listing requirements for cottage foods
• Always reviewing the ingredient labels of foods you are using as ingredients in your products for changes, even if you purchase the same brand every time
• Food manufacturers can reformulate their recipes or changes in the processing space can introduce new allergens. 
• Updating your product labels as ingredients change
• Staying up-to-date on food recalls to ensure you do not use a recalled food as an ingredient in your products

While cottage foods would not be included in a food recall issued by a government agency, a cottage food that is suspected or confirmed to have caused illness or injury can be investigated by the Minnesota Department of Agriculture (MDA). Keep your customers safe by accurately labeling your cottage foods.