Portland Allergen Labeling Compliance Checklist for Food Operators

FDA Big 8 Allergen Labeling Requirements

The FDA requires all packaged foods to clearly declare the "Big 8" allergens: milk, eggs, fish, crustacean shellfish, tree nuts, peanuts, wheat, and soybeans. Labels must use plain language (e.g., "Contains: Milk" or "Contains: Peanuts") in a location separate from other ingredients, or use parenthetical statements within the ingredient list (e.g., "whey (milk)"). Portland inspectors verify that all pre-packaged menu items sold—including house-made sauces, dressings, and prepared foods—carry accurate allergen declarations. Facilities must maintain supplier documentation proving allergen content and update labels if recipes or suppliers change.

Oregon & Portland-Specific Allergen Disclosure Rules

Oregon Health Authority (OHA) and Portland's Health & Human Services require food service establishments to inform customers about potential allergen cross-contact and have documented allergen information available upon request. Staff must be trained to identify allergen risks and communicate them clearly—both verbally and on menus. Oregon requires that if a menu item contains an allergen, establishments either label it on the menu or provide a summary sheet at point-of-service. Establishments must also maintain ingredient specifications and supplier statements for all raw materials, including spices and additives that may contain undeclared allergens.

Common Violations & Inspection Checklist Items

Portland inspectors frequently cite incomplete allergen labeling on prepared foods, missing ingredient information for house-made products, and failure to disclose cross-contact risks in writing. Key inspection items include: verifying all pre-packaged items list the Big 8, confirming staff can answer allergen questions accurately, checking that allergen information is visible and legible, and reviewing supplier documentation for completeness. Additional violations involve mislabeled items (e.g., a sauce labeled "peanut-free" that contains sesame), inadequate staff training records, and absence of written allergen procedures. Keep updated records of all recipes, suppliers, and any reformulations for at least one year to demonstrate compliance.

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