Undeclared Allergens: The Hidden Danger Behind Most Food Recalls

Every year, hundreds of food products are pulled from shelves not because of bacteria or foreign objects, but because of something invisible: undeclared allergens. For the estimated 33 million Americans living with food allergies, an unlabeled ingredient is not just an inconvenience. It can be a life-threatening emergency.

In this guide, we break down why undeclared allergens are the number one reason for food recalls, which allergens pose the greatest risk, and what you can do to keep your family safe.

Why Undeclared Allergens Are the #1 Reason for Food Recalls

According to FDA enforcement data, undeclared allergens consistently account for more food recalls than any other single cause, including contamination from Salmonella or Listeria. In 2025, allergen-related recalls made up roughly 17% of all food recalls reported to the FDA, and many of those were classified as Class I, the most serious category.

The reason is straightforward: even trace amounts of an allergen can trigger anaphylaxis in sensitized individuals. Unlike bacterial contamination, which can sometimes be mitigated by cooking, there is no way to neutralize an allergen once it is present in food. The only defense is accurate labeling and consumer awareness.

The Big 9: Allergens You Need to Know

Under the Food Allergen Labeling and Consumer Protection Act (FALCPA) and the FASTER Act of 2021, food manufacturers in the United States are required to clearly declare the presence of nine major allergens on product labels:

1. Milk - The most common allergen in recalls, often present as whey, casein, or lactose in unexpected products.
2. Eggs - Found in baked goods, pasta, sauces, and many processed foods.
3. Fish - Includes all species of finfish, sometimes hidden in Worcestershire sauce or Caesar dressing.
4. Shellfish - Covers crustacean species such as shrimp, crab, and lobster.
5. Tree nuts - Includes almonds, walnuts, cashews, pecans, pistachios, and many others.
6. Peanuts - One of the most dangerous allergens, capable of causing severe reactions from minimal exposure.
7. Wheat - Present in a vast number of processed foods, sauces, and seasonings.
8. Soybeans - Widely used as soy lecithin, soybean oil, and soy protein in packaged foods.
9. Sesame - Added to the major allergen list in 2023, found in breads, hummus, sauces, and spice blends.

Milk, wheat, and soy are the allergens most frequently involved in recalls, largely because they appear as hidden sub-ingredients in countless processed foods.

How Allergens End Up Undeclared

Undeclared allergen recalls rarely happen because a manufacturer deliberately hides an ingredient. The causes are usually systemic and often preventable.

Shared Equipment and Production Lines

Many food manufacturing facilities produce multiple products on the same equipment. A production line that runs peanut butter cookies in the morning might be used for sugar cookies in the afternoon. If cleaning between runs is inadequate, cross-contact occurs and the allergen ends up in a product where it does not belong.

Ingredient Supplier Changes

A manufacturer may switch to a new supplier or the supplier may reformulate an ingredient without adequate notification. A seasoning blend that was previously soy-free might suddenly contain soy protein, and if the manufacturer does not update their label, the product ships with an undeclared allergen.

Label Errors and Packaging Mix-Ups

Sometimes the food itself is fine, but the wrong label is applied. A product containing milk might be placed in packaging intended for a dairy-free variant. These packaging errors are among the most common triggers for allergen recalls.

Reformulation Without Label Updates

When a recipe changes, the label must change with it. Delays in updating labels after adding a new ingredient that contains an allergen can result in products reaching consumers with outdated information.

Real Examples of Allergen Recalls and Their Impact

Allergen recalls are not abstract regulatory events. They affect real people and real families.

In 2025, several major allergen recalls illustrate the scope of the problem. Ready-to-eat meals, baked goods, snack bars, and even spice mixes were recalled because they contained undeclared milk, wheat, or soy. Some of these recalls involved products distributed across dozens of states, affecting thousands of units on store shelves and in consumer pantries.

The consequences of undeclared allergens can be severe. The CDC estimates that food allergies send roughly 200,000 people to emergency rooms each year in the United States. While not all of these reactions stem from recalled products, mislabeled food is a significant contributing factor.

How to Check for Allergen Recalls on RecallPedia

Staying informed is one of the most effective things you can do to protect an allergen-sensitive household.

Search by Allergen

Use RecallPedia's search to look up specific allergens like "undeclared milk" or "undeclared peanut." This surfaces all active and recent recalls related to that allergen.

Search by Product or Brand

If you have a specific product in your pantry, search by brand name or product name to see if any recalls have been issued.

Check Regularly

Allergen recalls are issued throughout the year, often multiple times per week. Make it a habit to check RecallPedia before your weekly grocery trip or whenever you purchase a new product.

Tips for Allergen-Sensitive Families

Living with food allergies requires constant vigilance, but a few practical habits can significantly reduce risk.

Read Every Label, Every Time

Never assume a product is safe because it was safe last time you bought it. Manufacturers change ingredients and suppliers regularly. Read the full ingredient list and allergen statement on every purchase.

Look Beyond the Front of the Package

Marketing claims like "dairy-free" or "nut-free" on the front of a package are not regulated with the same rigor as the ingredient list on the back. Always verify by reading the actual ingredients and allergen declarations.

Contact Manufacturers Directly

If you are unsure whether a product is safe, call or email the manufacturer. Ask specifically about shared equipment, ingredient sourcing, and allergen testing protocols. Reputable companies will answer these questions.

Keep Epinephrine Accessible

If anyone in your household has a prescribed epinephrine auto-injector, make sure it is not expired and is always within reach. Seconds matter during anaphylaxis.

Educate Your Circle

Make sure schools, daycare providers, babysitters, and family members understand the severity of the allergy and know how to respond in an emergency.

What to Do If You Have an Allergic Reaction to a Recalled Product

If you or someone in your family experiences an allergic reaction that you suspect is linked to a food product, take these steps:

1. Seek Medical Attention Immediately

For severe symptoms such as difficulty breathing, swelling of the throat, rapid pulse, or dizziness, use an epinephrine auto-injector if available and call 911. Do not wait to see if symptoms improve on their own.

2. Preserve the Product

Keep the food product and its packaging. Note the lot number, UPC code, and "best by" date. This information is critical for reporting and for verifying whether the product is part of a recall.

3. Report to the FDA

File a report through the FDA's MedWatch Safety Reporting Portal at safetyreporting.hhs.gov. Your report helps the FDA identify problems and may trigger a recall that protects others.

4. Contact the Manufacturer

Notify the food manufacturer directly. Many companies have consumer hotlines and will investigate the issue, especially if the product is not yet subject to a recall.

5. Document Everything

Keep records of the product, the reaction, medical treatment received, and all communications with the manufacturer and FDA. This documentation may be important if you pursue further action.

Precautionary Allergen Labeling vs. Actual Recalls

You have probably seen statements like "may contain traces of peanuts" or "manufactured in a facility that also processes tree nuts" on food labels. These are known as precautionary allergen labels (PAL), and they are entirely voluntary.

What PAL Means

Precautionary labels indicate that the manufacturer is aware of a potential for cross-contact but has not been able to eliminate it entirely. The product is not required to be recalled simply because of a "may contain" statement.

What Triggers a Recall

A recall is triggered when an allergen is actually present in a product and is not declared anywhere on the label, including in the ingredient list and the "Contains" statement. In other words, the consumer had no way to know the allergen was there.

How to Approach PAL Statements

The decision to avoid products with precautionary labels depends on the individual's sensitivity and their doctor's advice. Some allergists recommend avoiding all "may contain" products, while others take a more case-by-case approach. There is currently no regulation requiring standardized language or testing thresholds for precautionary labels, which makes them inherently inconsistent across manufacturers.

Staying Safe in an Imperfect System

The food labeling system in the United States is robust but not flawless. Allergen recalls will continue to happen as long as complex supply chains, shared production facilities, and human error remain part of the food manufacturing process.

The best defense is a combination of careful label reading, regular recall monitoring, open communication with manufacturers, and preparedness for emergencies. Bookmark RecallPedia and make it part of your routine. When it comes to food allergies, the information you have can make all the difference.

For real-time allergen recall information, search RecallPedia or visit FDA.gov. If you are experiencing a severe allergic reaction, call 911 immediately.