Sesame became the ninth major food allergen in U.S. law for food sold from January 1, 2023, joining milk, egg, fish, shellfish, tree nuts, wheat, peanuts and soybeans. A packaged food that contains sesame has to say so in one of two ways: a "Contains" line naming sesame, right after or beside the ingredient list in type at least as large, or "(sesame)" in parentheses after the ingredient that carries it. If the ingredient's own name already says sesame, "sesame seeds" or "sesame oil", that counts, and nothing more is needed. The places sesame hides are the ones to check: a seed blend or seasoning listed only by its name, a spice blend, since spices can otherwise go on the list as plain "spice", a flavoring, and tahini. The law covers flavorings, colorings and incidental additives too. The one exemption is a highly refined oil, so ask the oil supplier, and if you can't confirm it, declare it. A "may contain sesame" line for shared equipment is voluntary and has to be true; it doesn't replace the required declaration. In the example below, a New Jersey bagel shop checks the labels on the bagels it sells to cafés.
The short version
- Sesame has been a major food allergen since January 1, 2023.
- Declare it with "Contains: sesame" by the ingredient list, or "(sesame)" after the ingredient.
- If the ingredient's name already says sesame, that's enough.
- Check seed blends, seasonings, spice blends, flavorings and tahini.
- Highly refined oils are exempt; confirm with the supplier or declare it.
- "May contain sesame" is voluntary and has to be true.
- TaroStack records which supplier's za'atar went into each batch. More below.
Where sesame hides
| Ingredient | On the label | Enough? |
|---|---|---|
| Sesame seeds | "sesame seeds" | Yes: the name says sesame |
| Tahini | "tahini (sesame)" or Contains: sesame | Only with sesame named |
| Everything topping, za'atar, a seed blend | Its parts listed, or "(sesame)", or Contains: sesame | Not by the blend's name alone |
| A spice blend with sesame | "spice (sesame)" or Contains: sesame | Not as "spice" alone |
| Sesame oil | "sesame oil" | Yes; a highly refined oil is exempt |
All nine allergens and how to label them are in food allergen labeling requirements, and keeping them apart in the kitchen in allergen control plan template.
The rules
| Rule | Where |
|---|---|
| Sesame is a major allergen | Milk, egg, fish, Crustacean shellfish, tree nuts, wheat, peanuts, soybeans and sesame; highly refined oils excepted; sesame for food sold from January 1, 2023 (21 U.S.C. 321(qq)) |
| How to declare it | Contains and the source by the ingredient list, no smaller than it, or the source in parentheses after the ingredient, unless the name already says it; flavorings, colorings and incidental additives included (21 U.S.C. 343(w)) |
| Spices | Otherwise may be listed collectively as "spice" (21 CFR 101.22(h)(1)) |
This is general information, not legal advice.
An example: five bagels for the cafés
Passaic Street Bagels, the made-up bagel shop in Clifton, New Jersey, I use in these examples, sells bagged half dozens to cafés. One café asked whether the everything bagels listed sesame. The owner checked every label:
| Bagel | Sesame from | Label before | Label now |
|---|---|---|---|
| Sesame | Sesame seeds | "...sesame seeds..." | No change; Contains: wheat, sesame added |
| Everything | Topping blend | "...everything topping" | "everything topping (sesame seeds, poppy seeds, dried onion, dried garlic, salt)"; Contains: wheat, sesame |
| Za'atar, new | Supplier's za'atar | "za'atar (thyme, sumac, sesame seeds, salt)"; Contains: wheat, sesame | |
| Plain | Shared boards and oven | "May contain sesame" | |
| Cinnamon raisin | None; baked on a separate day | Contains: wheat |
The everything bagels had been labeled with the topping's name alone since the shop opened, which doesn't name sesame. The za'atar came from a spice supplier, so the owner asked for its spec sheet before writing the label. Plain bagels go on the same boards and in the same oven as the seeded ones, and seeds do turn up on them, so the "may contain" line is true. The cinnamon raisin bagels are baked on Mondays, before any seeds come out, and carry no sesame line. What the bagels cost is in how to price bagels.
Get the checker
Download the sesame label checker. One sheet: each product, its sesame ingredient, whether sesame is already in that ingredient's name, whether it's a highly refined oil, and whether it shares equipment; what the law requires and whether to weigh a "may contain" line fill in. It's an ordinary Excel file with no macros, and it works in Google Sheets, LibreOffice and Numbers.
Where this stops working
The label is right for today's za'atar. When the spice supplier changes the blend, or the shop buys from a different supplier for a week, the label can stop matching the jar on the shelf, and nobody looks at the label again.
How TaroStack does it
TaroStack records which supplier's za'atar went into each batch.
Receiving by supplier and lot. Each delivery of za'atar is received from its supplier with its lot, so a new supplier is on record.
Batches by lot. Each batch records which ingredient lots it used, so a question about one bag of bagels leads to the za'atar behind it.
Recalls. If a lot turns out to carry sesame the label didn't name, one report shows every café that got it.
| The job | Notebook | In TaroStack |
|---|---|---|
| A new spice supplier | Noticed later | Each delivery by supplier |
| Which za'atar went into a batch | Not recorded | Batches by lot |
| Who got a mislabeled batch | Invoices | One recall report |
Receiving, batches and recalls are on every plan, from $49 a month. The first 30 days are free, with no credit card. If you'd like a hand setting up, ask, and we'll do it with you.