Allergen labels hit your grab-and-go on November 12

If you package anything before a customer orders it — sandwiches in a case, muffins in a bag, a salad with a lid on it — you have until November 12, 2026.

New York State is the first in the country to require written allergen information on food that is prepared, packaged and sold on the same premises. It sits in Agriculture & Markets Law section 199-G, and it lands in the middle of your busiest quarter.

What is actually in scope

The test is simple, and it is about when the package closes.

• In scope: food you prepare, wrap and put out for someone to pick up. The case sandwich. The bakery item in a clamshell. The prepared salads. Soup you fill and lid in the morning.
• Not in scope: food packaged after a customer orders it. A pizza in a box. A sandwich you make to order and wrap at the counter. A burrito you roll when someone asks for it.

That distinction catches people out, because the same kitchen produces both. The made-to-order sandwich at 1pm is exempt. The identical sandwich you wrapped at 9am and put in the case is not.

What has to be on the label

Not a full ingredient list. That is the part most operators get wrong when they first read about this, and it is a relief.

You need to identify whether the item contains any of the nine major allergens the FDA recognises: milk, eggs, fish, crustacean shellfish, tree nuts, peanuts, wheat, soybeans and sesame.

A sticker is enough. It can be on the packaging or on a label attached to it.

Why this is harder than it looks

The labelling is trivial. The knowing is not.

To put a truthful sticker on a chicken salad sandwich, somebody has to know what is in the mayonnaise you buy, whether the bread has sesame on it, and whether the roasted vegetables went into a pan that had almonds in it an hour earlier. Most kitchens have that knowledge in one person's head.

Three things worth doing before November:

1. Pull the spec sheets for everything you buy in. Your distributor has them. Sesame in particular has been showing up in products since it became the ninth major allergen, because reformulating was harder than adding it to the label.
2. Write down what goes in each packaged item. Not for the regulator — for whoever makes it when your prep cook is out.
3. Decide who owns the list when a recipe changes. A label that was true in October and wrong in January is worse than no label, because now somebody relied on it.

The bit nobody says out loud

This is a food safety rule with real consequences attached, and the reason it exists is that people have died from a wrapped sandwich.

An inspection finding is the smaller risk here. Get the labels right because someone with a peanut allergy is going to read one and trust it.

What to do this month

Inventory what you package before it is ordered. That list is your scope. Everything else you sell is unaffected.

Then check whether your packaging supplier already offers allergen sticker stock — several do, and it is cheaper than printing your own.

Keep the spec sheets somewhere they can be found in thirty seconds. When a customer asks whether the focaccia has sesame, "let me check" should take a moment, not a phone call to a supplier.