The new allergen labeling law for sesame doesn’t take effect for another year-and-a- half, but bakers should begin preparing now for the changes.
That was the take from speakers in the latest American Bakers Association Bake to the Future podcast.
“Even though it seems like a lot of lead time, bakers need to start working on it now to be ready for the January 1, 2023 compliance date,” said Meaghan Meyer, Senior Vice President of Food Safety and Quality, CraftMark Bakery. Meyer is also the Co-Chair of ABA's Food Technical Regulatory Affairs Professionals Group.
The law, signed in April by President Biden, establishes sesame as the first new U.S. allergen designated in many years. The podcast delves into the labeling requirements and points to the risks of failing to comply.
Meyer was interviewed by Rasma Zvaners, American Bakers Association’s Vice President, Regulatory and Technical Services. The podcast’s hosts are Katie Juhl, ABA’s Director, Marketing and Communications, and Hailey Blumenreich, Marketing and Communications Manager.
Understanding the New Law
The new law is known as the FASTER Act — an acronym denoting Food Allergy Safety, Treatment, Education and Research. Sesame becomes the ninth food allergen for which package labeling is mandated by the FDA. The others are milk, wheat, eggs, peanuts, tree nuts, soybeans, fish and shellfish.
The U.S. follows Canada and the European Union in identifying sesame as an allergen. Nearly 1.6 million Americans are allergic to sesame, according to FARE, the Food Allergy Research and Education community.
Logistics of Complying
The new law will require that bakers provide plain language on package labels indicating the presence of sesame. Bakers should also consider how the use of sesame impacts their manufacturing logistics.
“Sesame is a very small seed and it can be hard to see and clean,” Meyer said. “It will push bakers to do deeper dives into their equipment design and their sanitation practices.”
Importance of Planning Early
Planning early for costly packaging changes will ease challenges for bakers. Many bakers purchase packaging in large quantities and hope to use it all before the need for changeovers, Meyer said.
While the FDA sometimes extends deadlines, bakers can’t assume that will be the case, “so the work needs to start now,” said Meyer.
Observed Zvaners: “We’re down to a year and a half. That’s a blink of an eye in regulatory terms.”
Strategies for Bakers to Pursue
Bakers would do well to try to synchronize packaging changes for sesame with any other near-term packaging adjustments planned, the speakers said.
Some bakers may consider more extensive changes.
“Some organizations may decide to make formula changes,” Meyer said. “New equipment may be needed for segregation of products.”
Risks in Not Complying
Allergens can trigger a potential recall situation if they aren’t listed clearly on packages.
“Historically, the baking sector ranks fairly high on being subject to allergen recalls,” either forced or voluntary, said Zvaners.
Other Considerations for Bakers
Bakers will need to decide whether to include a “may contain” sesame statement in cases when a product is produced at a facility that uses an allergen like sesame.
While these statements are voluntary, the information is often useful for highly allergic consumers, Meyer said.
“Consumers increasingly want more information rather than less,” she added.
What’s Ahead in the Near Future
The FDA will be holding public sessions to discuss details about compliance with the new law, and ABA will be further educating members.
The new law will establish a new scientific process and framework for adding new allergens in the future.
“ABA will be monitoring all these developments for our members,” Zvaners said.