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Allergen Requirements for Packaged, Unpackaged, and Bulk Labeling Frequently Asked Questions
What is the definition of a Major Food Allergen?
Major Food Allergen Includes:
- Milk
- Eggs
- Fish (such as bass, flounder, cod)
- Crustacean shellfish (such as crab, lobster, or shrimp)
- Tree nuts (such as almonds, pecans, or walnuts)
- Wheat
- Peanuts
- Soybeans
- Sesame
Major Food Allergen does NOT Include:
Any highly refined oil derived from a food specified above.
What is the requirement for food allergens for PACKAGED foods?
Food packaged in an establishment must list the name of the Major Food Allergen as an ingredient under 3-601.11, along with other labeling requirements.
Packaged is defined as bottled, canned, cartoned, bagged, or wrapped whether packaged in a food establishment or a food processing plant.
Packaged food does NOT include wrapped or placed in a carry-out container to protect the food during service or delivery to the consumer by a food employee upon consumer request.
What is the requirement for food allergens for UNPACKAGED foods?
The permit holder shall notify consumers by written notification of the presence of major food allergens as sold as ingredients in unpackaged food items that are served or sold to the consumer under 3-602.12.
Written notification includes physical or electronic means, including, but not limited to, brochures, deli case or menu notifications, label statements, table tents, placards, or other effective means.
The intent is to notify the consumer to the presence of major food allergens.
What is the requirement for food allergens for BULK foods?
Bulk food that is available for consumer self-dispensing shall be labeled with the following information in plain view of the consumer:
- The manufacturer’s or processor’s label that was provided with the food.
OR
- A card, sign, or other method of notification that includes the information specified:
- The name of the food source of each major food allergen contained in the food unless the food source is already part of the common or usual name of the respective ingredient.
Can a “blanket” statement be provided at a buffet or bakery case?
Each food item should have a written notification for major food allergens. Depending on the written notification method, food items with major food allergens could be collectively listed.
Do items at a buffet need to be labeled with specific allergens?
Yes. Food items that use one (or more) of the nine major food allergens MUST be listed in written notification.
Are QR codes allowed as written notification?
Yes. A QR code would be considered a written notification for a food establishment.
However, the establishment should consider if the QR code would be appropriate and provide physical copies for guests upon request.
Do items at a deli case and bakery case need to be labeled with specific allergens?
Yes. Food items that use one (or more) of the nine major food allergens must be listed on a written notice. Deli cases may use brochures or deli case notifications.
Do menu items need to be labeled with specific allergen information?
Yes. If menu items include one (or more) of the major food allergens, allergen information must be included using one of the methods of written notification, including menu notification.
Do “specials” need to be labeled with allergen information?
Yes. Specials should use the same written notifications as typical menu items.
What if the bakery item is pre-packaged?
If any item prepared on-site is pre-packaged on-site, they MUST conform to all labeling requirements of 3-601.11, including major food allergen labeling.
What if the pre-packaged item that comes from a wholesale operation does not contain any labeling information?
Wholesale products are required to include allergen information on labels.
If a food establishment is receiving products without labeling or product sheets, an incident report should be completed and submitted to: dph.mfgfood@illinois.gov.
