Request a demo

The FDA Big 9 allergens.A plain guide for restaurants.

The nine foods US law names as major food allergens, where each one turns up in restaurant cooking, what the law asks of packaged food and of restaurants, and a short checklist for your kitchen. Checked against its sources on October 30, 2026.

The nine major food allergens.And where each one hides.

Federal law names nine foods as major food allergens, often called the Big 9: milk, eggs, fish, crustacean shellfish, tree nuts, peanuts, wheat, soybeans and sesame.⁠1

More than 160 foods are known to cause food allergies. When the first eight were named in 2004, they accounted for 90 percent of food allergies and serious allergic reactions in the U.S., according to the FDA.⁠1

  1. Milk

    What counts. Milk from cows, goats, sheep and other ruminants, and any ingredient with protein from it.⁠34

    In your kitchen. Butter is made from milk or cream, so a pan sauce finished with butter counts.⁠10 So do cream, cheese, yogurt and whey, and ghee often still carries milk protein.⁠4 Labels write it like “whey (milk).”⁠2

  2. Eggs

    What counts. Eggs from chickens, ducks, geese, quail and other fowl.⁠34

    In your kitchen. The federal standard for mayonnaise calls for egg yolk or whole egg.⁠9 Many aiolis start from mayonnaise or from yolks, and so do classic Caesar dressing and hollandaise. Egg wash on bread and pastry counts too.

  3. Fish

    What counts. Fish such as bass, cod, flounder, salmon, trout and tilapia. A package label has to name the species.⁠45

    In your kitchen. Worcestershire sauce is usually made with anchovies, so Caesar dressing and many marinades carry fish. Fish sauce and anchovy paste do too.

  4. Crustacean shellfish

    What counts. Crab, lobster and shrimp, for example. Mollusks such as oysters, clams, mussels and scallops are not major food allergens under federal law.⁠4

    In your kitchen. Shrimp paste and dried shrimp turn up in some curry pastes and sauces, and shells go into stocks and bisques. When a guest says “shellfish,” ask whether they mean oysters and clams too.

  5. Tree nuts

    What counts. The FDA lists twelve: almond, black walnut, Brazil nut, California walnut, cashew, hazelnut (filbert), heartnut, macadamia, pecan, pine nut, pistachio and walnut. Since the FDA’s January 2025 guidance, coconut is not on the list.⁠34

    In your kitchen. Pine nuts in pesto, almonds in marzipan and in many romesco sauces, nut flours, praline and nut crusts. For nut oils, see the note on oils below.

  6. Peanuts

    What counts. Peanuts, and any ingredient with protein from them. They are listed on their own, apart from tree nuts.⁠14

    In your kitchen. Satay and other peanut sauces, peanut butter in dressings and desserts, and crushed peanuts as a garnish.

  7. Wheat

    What counts. Every kind of wheat, including durum, semolina, spelt, einkorn, emmer, Khorasan and triticale. The list names wheat, not gluten, so barley and rye are not on it.⁠14

    In your kitchen. Flour in a roux, so many gravies, gumbos and cream sauces. Breading, batter, breadcrumbs, pasta and croutons. Many soy sauces are made with wheat as well as soybeans. Labels write it like “flour (wheat).”⁠2

  8. Soybeans

    What counts. Soybeans, and any ingredient with protein from them.⁠14

    In your kitchen. Soy sauce, tamari, miso, tofu and edamame, and the many marinades and glazes built on them. On labels, look for lines like “lecithin (soy).”⁠2

  9. Sesame

    What counts. Sesame, and any ingredient with protein from it. The ninth major food allergen since January 1, 2023.⁠146

    In your kitchen. Tahini is made from sesame, so hummus and baba ghanoush usually carry it. Toasted sesame oil, seeded buns, bagels, some breads and crackers, and some spice blends.⁠678

A note on oils. Highly refined oils made from a major food allergen, and ingredients made from those oils, are not counted as major food allergens under federal law. Other oils can be. Check the label, and ask your supplier how an oil is made.⁠5

About the kitchen examples. They are common recipes and typical labels, not an FDA list. Recipes and products differ, so read the label on everything you buy.

What the law covers.Packaged food carries a label. A plate doesn’t.

Two different sets of rules touch allergens. One is federal law for packaged food. The other is the FDA Food Code, a model that states and cities can adopt for restaurants and other food businesses.

Packaged food

A 2004 federal law, the Food Allergen Labeling and Consumer Protection Act (FALCPA), requires most packaged food to name any major food allergen it contains. The FASTER Act, signed on April 23, 2021, added sesame from January 1, 2023.⁠14

For fish, crustacean shellfish and tree nuts, the label names the kind, like cod, shrimp or pecans.⁠5

In the ingredient listflour (wheat), whey (milk), lecithin (soy)

Or in a Contains lineContains Wheat, Milk, and Soy.

Two ways a package can name its allergens. Examples from the FDA.⁠2

These rules also cover food a restaurant packages and labels for sale. They do not cover food wrapped or boxed after a guest orders it, or most food a restaurant serves that is not packaged with a label.⁠14

Food you serve

The FDA Food Code is a model code. It is not federal law. States, cities, counties, tribes and territories decide whether to adopt it, so the rules where you are depend on what your area has adopted.⁠41113

The current edition came out on September 17, 2026. Where it is adopted, a restaurant must tell guests in writing which major food allergens are ingredients in food that is not packaged. A note on the menu, a table tent, a placard, a brochure or an electronic notice can all do it.⁠1112

It also says staff should be trained in food allergy awareness: which foods are major food allergens, and the symptoms they can cause.⁠12

Some states go further. In California, SB 68 requires restaurant chains with 20 or more locations, at least one of them in California, to disclose the nine major food allergens for every standard menu item, from July 1, 2026.⁠14

A kitchen checklist.Six habits that keep the answer straight.

When a guest asks about an allergen, the answer is only as good as what the kitchen wrote down. These habits keep it right.

  1. Write down every ingredient.

    For every dish, down to the garnish, the oil in the pan and the butter at the end.

  2. Know what is in each sauce.

    Many kitchens make sauces, dressings, stocks and doughs ahead and use them in several dishes. Some call these batches. Give each one its own ingredient list, and carry its allergens into every dish that uses it.

  3. Keep the labels of what you buy.

    Bought-in sauces, spice blends, breads and bases carry allergens too. Keep the ingredient list and the Contains line for each product.

  4. Update the record when something changes.

    A new supplier, a different brand or a small recipe change can change a dish. The FDA notes that since sesame was added, some makers changed their recipes, and some products now contain small amounts of sesame they did not have before.⁠6

  5. Give servers one answer.

    Keep one written record the whole team reads from, the same on every shift, so nobody has to stop the chef mid-service or guess.

  6. Train the team, and plan for shared equipment.

    Everyone should know the nine and the symptoms an allergy can cause.⁠12 The FDA notes that a mild reaction does not always mean the allergy is mild.⁠2 A recipe record does not cover shared fryers, cutting boards and utensils. Your kitchen procedures do.

Where Tullia fits.One record for the whole kitchen.

Tullia is a recipe and allergen tool for US restaurants. You talk or type a recipe to its AI sous chef, and the recipe builds on screen.

Every ingredient is recorded as Contains or Free from for each of the nine. A batch, like a sauce or dressing made ahead, is its own recipe, and a dish’s allergens are worked out from its ingredients and every batch inside it. Change a batch, and every published dish that uses it is worked out again.

Front of house reads the same answer on a read-only screen, an allergen grid or a printout. Tullia doesn’t test food, and its AI can get an allergen wrong, so you check each dish before you save it.

How Tullia tracks allergens

House Caesar

  • Milk
  • Eggs
  • Fish
  • Shellfish
  • Tree Nuts
  • Peanuts
  • Wheat
  • Soybeans
  • Sesame
  • Milkfrom the Parmigiano-Reggiano, in the Caesar Dressing
  • Eggsfrom the egg yolks, in the Caesar Dressing
  • Fishfrom the Worcestershire sauce, in the Caesar Dressing
  • Wheatfrom the sourdough, in the Garlic Croutons
  • Contains
  • Free from
A dish from a real Tullia session. The dish has two batches, a dressing and croutons, and each allergen is carried up from the ingredient inside them. Two answers only: Contains or Free from.

Sources.Read on October 30, 2026.

  1. Food AllergiesU.S. Food and Drug Administration (FDA), content current as of March 11, 2026
  2. Food Allergies: What You Need to KnowFDA, content current as of August 16, 2024
  3. Frequently Asked Questions: Food Allergen Labeling Guidance for IndustryFDA, content current as of October 29, 2026
  4. Questions and Answers Regarding Food Allergens, Including the Food Allergen Labeling Requirements of the Federal Food, Drug, and Cosmetic Act (Edition 5): Guidance for Industry (PDF)FDA, January 2025. Questions A.1, B.7, B.9, B.10, C.1, C.3, C.7 (Table 1), C.9 and D.16 to D.18
  5. Food Allergen Labeling and Consumer Protection Act of 2004 (FALCPA)FDA, the text of the law, content current as of November 29, 2022
  6. The FASTER Act: Sesame Is the Ninth Major Food AllergenFDA, content current as of April 12, 2024
  7. Allergic to Sesame? Food Labels Now Must List Sesame as an AllergenFDA Consumer Update, content current as of January 10, 2023
  8. Voluntary Disclosure of Sesame as an Allergen: Guidance for Industry, draft (PDF)FDA, November 2020. The foods named in reports of reactions to sesame
  9. 21 CFR 169.140, MayonnaiseThe federal standard of identity, as published by the Legal Information Institute
  10. 21 U.S.C. 321a, ButterThe federal definition of butter, as published by the Legal Information Institute
  11. FDA Releases 2026 Food CodeFDA, September 17, 2026
  12. FDA Food Code 2026 (PDF)FDA. Sections 2‑103.11(O) and 3‑602.12(C), and Annex 3 on 3‑602.12
  13. Addition to the 2022 Food Code: Sesame Added as a Major Food AllergenFDA, content current as of December 10, 2024
  14. Allergen Disclosures (SB 68)California Restaurant Association

Keep the answer in one place.

Tell us about your kitchen and we’ll show you how Tullia records the Big 9 for every dish.

Request a demoSee allergen tracking