Sesame

Sesame is the newest of the nine major food allergens in the United States, and the story of how it got there is the clearest example this site has of a labelling rule producing the opposite of its purpose.

What the law says

The FASTER Act was signed in April 2021 and took effect for foods entering interstate commerce from 1 January 2023. It added sesame to the list in 21 U.S.C. 321(qq), which now reads: “Milk, egg, fish (e.g., bass, flounder, or cod), Crustacean shellfish (e.g., crab, lobster, or shrimp), tree nuts (e.g., almonds, pecans, or walnuts), wheat, peanuts, soybeans, and sesame.”

Being on that list means a packaged food containing sesame has to say so in plain language, either in the ingredient list or in a “contains” statement. Before 2023 sesame could appear as “spices” or “natural flavour” and often did.

What happened next

Rather than change production to keep sesame out of products that never had it, some bakers and restaurant chains added a small quantity of sesame flour and declared it. That is lawful. A product containing sesame and saying so is compliant.

The legislators who wrote the law said so publicly. In a May 2023 letter to the American Bakers Association, Matsui, McHenry and Wyden wrote that “the dangerous practice of adding sesame to baked goods that have not previously contained the ingredient, often without notice, undermines the trust that people with food allergies place in the food industry”, and that manufacturers “are adding trace amounts of sesame to their baking products since the passage of the FASTER Act. It appears that this is being done to avoid the costs associated with the processes and systems controls necessary to ensure safe baking practices.”

They put the consequence plainly: these actions “undercut the purpose and intent of the FASTER Act”.

The practical result for a reader is that a bread which was fine in 2022 may not be now, and the change is invisible unless you re-read a label you had already learned.

Why sesame flour is harder than sesame seeds

Seeds on a bun are visible. Sesame flour blended into dough is not, and that is the form used when it is added for compliance reasons.

So the visual check that works for many allergens does not work here, and the ingredient list is the only route. For anyone managing this allergy, re-reading familiar products is the specific habit worth building rather than a general one.

The names it hides behind

Tahini is sesame paste. Benne, gingelly and til are regional names. Halva, hummus and many spice blends contain it as a matter of course.

Since 2023 US packaged food has had to name it, so those synonyms matter most on imported products and outside the US. In markets that treat sesame as a declarable allergen the position is similar; where it is not on the list, “spices” remains a lawful place for it to sit.

The exemption worth knowing

The same law exempts “any highly refined oil derived from” a major allergen. Highly refined sesame oil is therefore outside the declaration requirement, on the same reasoning that exempts highly refined peanut oil: the refining removes the protein that provokes the reaction.

Cold-pressed and unrefined sesame oil is a different matter and does carry protein. The label will not always distinguish them, which is one of the few places this otherwise strong rule leaves a reader guessing. The wider picture is on the page for reading labels with a food allergy.