1) The Allergen Claim
The FDA requires labeling all foods that contain a major food allergen as an ingredient, or have potentially come in contact with the product. A major food allergen, the so-called “Big 8”, is defined as one of the following: milk, eggs, fish, Crustacean shellfish, tree nuts, peanuts, wheat, and soybeans.
2) The "May Contain" Statement
Have you ever noticed on packs: “may contain milk”? The ‘may contain’ labeling is used for products that do not have milk as an ingredient but are, for example, made on lines that also share milk-containing ingredients. It results in unavoidable and involuntary presence of milk allergens due to cross-contact.
Despite measures taken, this hazard cannot be prevented, especially not with chocolate where typical wet cleaning regimes are not possible. Barry Callebaut therefore, where needed, labels a precautionary allergen declaration like ‘may contain milk’. Products with a "may contain" labeling should not be consumed by allergic persons.