What the FASTER Act Added to Food Allergen Labels

If you read ingredient lists carefully, you may have noticed "sesame" starting to show up more often in "Contains" statements over the past couple of years. That is not a coincidence or a marketing trend. It is a federal law change, and the FDA's own guidance explains both what changed and, just as importantly, what did not.

The nine major food allergens, and the one that is new

The Food Allergen Labeling and Consumer Protection Act of 2004 (FALCPA) originally named eight foods as major food allergens: milk, eggs, fish, crustacean shellfish, tree nuts, peanuts, wheat, and soybeans. According to the FDA, these eight accounted for 90 percent of food allergies and serious allergic reactions in the United States at the time the law passed.

In April 2021, the Food Allergy Safety, Treatment, Education, and Research (FASTER) Act added a ninth: sesame. The FDA states the requirement took effect on January 1, 2023, meaning that as of that date, "sesame must be labeled as an allergen on packaged foods and dietary supplements." The current list of nine major food allergens is: milk, eggs, fish, crustacean shellfish, tree nuts, peanuts, wheat, soybeans, and sesame.

What "labeled as an allergen" actually requires

Before the FASTER Act, sesame already had to appear in the ingredient list if it was directly added, the same rule that applies to any added ingredient. What changed is that sesame now gets the same elevated treatment as the other eight major allergens: manufacturers must specifically call out sesame by name, even when it is part of a less obvious ingredient like "natural flavor" or "spice mix."

The FDA describes three ways this can appear on a label:

• In the ingredient list itself, using sesame's common name. Example from FDA's guidance: "Ingredients: Brown rice flour, sesame seeds, potato starch, flax seeds, olive oil, amaranth, quinoa, salt."
• In a "Contains" statement right after or next to the ingredient list. Example: "Ingredients: Potatoes, canola oil, spices (sesame, wheat), salt, garlic powder, sugar, natural flavoring. CONTAINS: Wheat, Sesame."
• In parentheses following an ingredient name that is made from sesame. Example: "Tahini paste (sesame, canola oil), water, garlic, lemon juice, parsley, salt."

All three formats satisfy the law. If you are scanning labels quickly, it helps to know you might find the word "sesame" in any of these three places, not just in a dedicated allergen line.

The transition period you should actually watch for

Here is the part of the FASTER Act that catches people off guard: the FDA explicitly states that products already on store shelves, or already on their way there, before January 1, 2023, did not have to be pulled or relabeled. Because many packaged foods have a long shelf life, the FDA's own consumer update warns that "it's hard to say when pre-2023 stock will be replaced with food products carrying the required labels."

In practice, this means a product you have bought safely for years could, in theory, still be running through old packaging without a sesame disclosure, even though the law has been in effect for several years now. The FDA's own guidance recommends that anyone managing a sesame allergy continue to read the full ingredient list closely rather than relying only on the presence or absence of a "Contains sesame" line, and to contact the manufacturer directly if a product's sesame content is unclear.

A related change worth knowing: recipes can shift

The FDA's consumer update also flags something less obvious: some manufacturers changed their recipes after the FASTER Act took effect, meaning products that never contained sesame before may now include it in small amounts as part of the reformulation. This is a general reminder that applies beyond sesame too, a product you have safely eaten for years is not guaranteed to have the same ingredients today, which is exactly why the FDA recommends rereading the label every time you buy a product, not just the first time.

A quick label-reading checklist for allergen awareness

• Check the ingredient list first; a major allergen must appear there by its common name if it is a direct ingredient.
• Look for a separate "Contains" statement, often placed directly below or beside the ingredient list.
• Watch for allergens hiding inside compound ingredients, which by law now must be called out in parentheses, for example "tahini paste (sesame, canola oil)."
• Do not assume a long-trusted product is unchanged; recipes and ingredient sourcing can shift between purchases.
• If a label is unclear or missing allergen information you expect, the FDA recommends contacting the manufacturer or distributor directly rather than guessing.

Key takeaways

• The FASTER Act made sesame the ninth major food allergen in the US, effective January 1, 2023, joining milk, eggs, fish, crustacean shellfish, tree nuts, peanuts, wheat, and soybeans.
• A major allergen must be identified by its common name, either directly in the ingredient list, in a "Contains" statement, or in parentheses after a compound ingredient.
• Products already in the supply chain before 2023 were not required to be relabeled, so some pre-2023 stock may still lack a sesame disclosure.
• Manufacturers can and do change recipes, so a familiar product's ingredient list is worth rereading rather than assumed to be unchanged.
• When label information is unclear, the FDA's own guidance recommends contacting the manufacturer directly rather than guessing based on past experience with the product.