Allergen-critical labeling, nut-free bakery vs shared-equipment vs may-contain?

The legal frame is FDA + FALCPA (Food Allergen Labeling and Consumer Protection Act), updated by the FASTER Act 2021 which added sesame as the 9th major allergen effective January 2023. The current Big-9: milk, eggs, fish, shellfish (crustacean), tree nuts, peanuts, wheat, soybeans, sesame.

Magento implementation: three flags per SKU per allergen:

• entire-bakery-free-of-X, the bakery has no X anywhere on premises (e.g. Erin McKenna’s, a 100% nut-free vegan bakery). The strongest claim. Mislabeling here is an FDA recall.
• shared-equipment, product made on equipment that also processes X. The middle claim, mandatory FDA disclosure where applicable.
• may-contain, trace amounts possible due to facility processing. The softest claim.

PDP renders allergen badges; category pages support filterable allergen facets (/nut-free, /gluten-free, /vegan, /dairy-free). Checkout warning fires if the customer has flagged an allergy in their account and the cart contains a shared-equipment or may-contain SKU. Every catalog edit triggers a compliance audit log entry, who changed which flag when. Auditable trail if an incident happens.

Compliance is not optional for bakeries shipping nationwide, one wrong “nut-free” flag on a cookie that goes to a peanut-allergic 8-year-old is a multi-million-dollar FDA + civil-suit problem. Build the flags correctly on day one.