Allergen management has always been a cornerstone of food safety programs but, for food processors, the challenge has never been greater. In 2025 alone, there have already been 142 recalls of food products due to undeclared allergens. This startling number underscores how allergen control has emerged as one of the most pressing and complex issues facing the industry.

One of the primary reasons allergen control has become so difficult is supplier variability. Ingredient suppliers often reformulate spice blends, marinades, coatings, and other functional ingredients. These may contain allergens such as milk, soy, wheat, or sesame. But, even seemingly minor adjustments, like introducing a new allergen into a facility, or onboarding a new ingredient supplier, can introduce additional risk that an undeclared allergen could be unknowingly introduced into a food processing system. Because these changes are sometimes made with little advance notice, processors relying on established ingredient specifications may not always catch the subtle changes in time to make necessary changes to food product ingredient statements or labels. The result can be costly recalls, brand damage, and intense regulatory scrutiny.

What makes allergens especially challenging is that they behave differently than pathogens. While pathogens can sometimes be controlled through cooking, freezing, or other interventions, allergens cannot be “killed” or neutralized during processing. For most consumers, undeclared allergens pose no issue, but for those with sensitivities, even trace amounts can cause serious, sometimes life-threatening reactions. For meat companies, the risk is magnified by the sheer number of product variations, the use of shared equipment, and the reliance on multiple upstream suppliers.

To control their risk to the greatest extent possible, processors can work to strengthen their programs in several practical ways. Supplier management must be a top priority. This can be achieved with strong supplier approval programs, and clear requirements that suppliers notify customers of any formulation or label changes, no matter how small. Label verification can and should be treated as a multi-layered process, where barcode scanning, the cleaning and clearing of lines, and human verification can all be utilized to identify and eliminate potential errors before products are released. Where possible, risk can be reduced by using dedicated equipment. When shared lines are used, however, validated cleaning procedures with allergen-specific test kits can confirm that the potential for cross-contact has been eliminated. On a broader scale, fostering a company-wide culture of both food safety and allergen awareness can have a significant impact on reducing risk as well.

The stakes for industry could not be higher. In most cases, regulators at both USDA’s FSIS and FDA consider undeclared allergens to be Class I hazards because of their potential to cause severe health consequences. Companies that fall short on allergen control face not only regulatory enforcement, but also civil liability, reputational harm, and the loss of consumer trust. Indeed, even potential class action exposure is now a risk that processors must assess. With allergen-related recalls now among the most common in the food industry, and an increasingly aggressive FSIS focus on undeclared allergens, allergen control is no longer just a compliance issue — it is a central pillar of risk management, brand protection, and consumer safety.

So, continue to work within your organization to make allergen control a top priority.  Declaring the need for action now may decrease the risk for an undeclared issue tomorrow.