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(January 2018) Neither the Food Allergen Labeling and Consumer Protection Act of 2004 nor FDA’s Food Labeling Guide address the use of bold face type for allergen labeling within the ingredient statement.
Our guidance is to use the same type size and style for every word in the ingredient statement and call out the allergens in a separate “Contains” statement following the ingredient statement.
FDA allows ingredients in small amounts to be listed in any order following a "contains 2% or less of:" statement.
If a finished product for example uses varying levels of citric acid to adjust p H, then it could be helpful to use a "2% or less" clause so that the citric acid and other minor ingredients can be listed in any order.
If the calculated cancer risk level is below a certain threshold indicating that there is no observable effect, then there is assumed no significant risk and a warning statement is not required.
If however, the calculated level is above the threshold, products that contain a Prop 65 listed chemical require a warning statement to alert consumers to its risk.
Again, there is no FDA guidance for bolding the allergen (Milk) in this case, though we do not recommend it.FDA is aware of this error and their staff is "working with the publishers to get the information corrected." When that occurs, FDA will post an announcement on their website.Where can I find a reference for bolding allergens in the Ingredient Statement?Butter is an ingredient with a statutory standard that requires compliance with a very specific definition as found in 21 U. In these cases, use of butter in the name is acceptable and not misleading, as consumers understand the context for how the term butter is used.I'm being told by a client in Canada there is an exemption when a formula uses 5% or less flour, even when unenriched flour is prohibited. (October 2017) Canada's Food & Drug Regulations (FDR) require that white wheat flour be enriched to specific levels.