Georgia Food Allergen Labeling Requirements

This guide unpacks Georgia food allergen labeling requirements for packaged products, grab-and-go items, and restaurant menus. You’ll learn how state rules build on FDA regulations, what the 2025 sesame update means for you, and how to build a compliant label in minutes. For broader kitchen controls, see our food-allergen-management page.

Federal vs. Georgia-Specific Rules

FDA Foundation

The Food Allergen Labeling and Consumer Protection Act (FALCPA) of 2004 and the FASTER Act of 2021 set nationwide rules that all packaged foods disclose the eight major allergens—now nine with sesame. Labels must list allergens in plain English either in-line (e.g., “whey (milk)”) or in a separate “Contains” statement.

These federal laws cover interstate commerce. Products manufactured and sold solely within Georgia are still subject because Georgia adopts the 2022 FDA Model Food Code by reference.

Georgia Nuances

Georgia Department of Public Health Rule 511-6-1 requires:

  • Written allergen procedures for unpackaged self-service foods.
  • Date marks on any TCS food packaged on-site for >24 hours.
  • Menu disclosures if recipe changes add a major allergen.

Inspectors can issue a priority violation for missing or inaccurate allergen info even when federal penalties don’t apply.

The 2025 Sesame Update—What Changes on Jan 1, 2025?

Starting January 1, 2025, sesame becomes the ninth major allergen under both federal and Georgia law. Any product manufactured on or after that date must declare sesame in the ingredient list or a “Contains” statement. Georgia local inspectors will immediately begin enforcing disclosure during routine visits.

A six-month grace period exists only for inventory produced before 2025. House-made items—like hummus, buns topped with sesame seeds, or sesame oil vinaigrettes—have no grace period.

Quick Tip: Order pre-printed “Contains Sesame” stickers in bulk now—costs run as low as 0.2 ¢ per label and prevent hand-written errors later.

Packaged Foods vs. Menu Boards & Grab-and-Go

Pre-Packed Retail Items

Deli / Grocery Re-Pack

Restaurant Menus & Online Ordering

Dive deeper into overlapping requirements in our Georgia food safety regulations guide.

Building a Compliant GA Allergen Label – Step-by-Step

  1. Statement of Identity – product name in bold type.
  2. Net Weight – U.S. and metric, e.g., “12 oz (340 g)”.
  3. Ingredient List – common names in descending weight.
  4. Contains Statement – list major allergens in ALL CAPS.
  5. Manufacturer Info – name, city, state, and ZIP.
  6. Date Mark / Lot Code – required under GA Rule 511-6-1-.04.
Federal Text Georgia Nuance
Ingredient list may omit sub-ingredients <2 % Still disclose allergen sub-ingredients (e.g., Worcestershire (fish))
Date mark optional on shelf-stable items Date mark required if TCS after opening or repack
Penalty Alert: GDPH can impose stop-sale orders and civil fines of $100–$500 per mislabeled unit. Repeat violations may trigger permit suspension.

Allergen Label Quick-Preview Tool

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Sample Code Block

<label>
    SESAME HUMMUS
    Net Wt: 8 oz (227 g)
    Ingredients: Chickpeas, Water, Tahini (Sesame), Olive Oil, Salt
    Contains: SESAME
    Made by: Peach State Foods, Atlanta, GA 30303
</label>

Enforcement & Penalty Matrix

Violation Type Packaged Food Processor Restaurant / Food Truck Retail Grocery / Deli
First Observed Warning + 10 days corrective $100 civil fine Inspector stop-sale on product lot
Repeat Within 12 Months $500 per unit (Ga. Code §26-2-86) $250 fine + re-inspection fee $250 fine + public score drop
Knowingly Misbranding $1000 + recall order Permit suspension hearing $500 fine + recall

Practical Compliance Checklist

Recordkeeping & Supplier Verification

The most iron-clad label in the world collapses if you cannot prove where each ingredient came from or when a recipe changed. Georgia regulators approach allergen investigations like accountants: show the paper trail or accept the citation. Maintaining organised, legible, and date-stamped records shields you from costly recalls and demonstrates a culture of due diligence during inspections.

Start with a master ingredient list that cross-references every SKU on your receiving log to the menu item or packaged product it feeds. When suppliers substitute raw materials, log the change immediately—even if the formulation looks identical. A quiet swap from soy oil to blended soy–canola, for example, triggers an undeclared allergen if your label still omits soy. Attach e-mailed specification sheets or case labels as photographic evidence using a tablet or smartphone; digital images satisfy inspectors provided they are time-stamped and retrievable on-site.

Georgia’s Rule 511-6-1 requires priority items like allergen logs to be immediately accessible during an inspection. That means they can be electronic, but the person-in-charge must retrieve them without internet if cellular service drops. Many operators keep a redundant USB drive in the variance binder for offline access.

Georgia Rule Reminder: Retain supplier change logs for two years and keep batch production records for at least 12 months past the product’s shelf-life.

Periodically audit your records against labels on finished goods. A 30-minute monthly review catches small inconsistencies before they snowball into formal violations.

Staff Training & Onboarding

Labels are only as accurate as the people printing, applying, and verifying them. A line cook who swaps shredded cheese brands or an expediter who re-packs muffins into unlabeled clamshells can undermine months of precise compliance work. Building a training loop into new-hire onboarding and annual refreshers keeps every team member aligned on allergen protocol.

During orientation, walk employees through a real product label and identify each required element—statement of identity, net weight, ingredient list, and Contains line. Follow with a short hands-on exercise printing a mock label using your preferred software or thermal printer. This tactile approach cements the steps far better than a slide deck alone.

Georgia inspectors frequently ask hourly staff to describe the allergen control plan during routine visits. Empower your team with three talking points:

Consider a quick five-question quiz after training, stored in the personnel file, to document competency. For high-turnover positions, dip into micro-learning: one-minute video reminders played during pre-shift meetings Reviewing a single topic—like sesame disclosure—each week keeps knowledge fresh without overwhelming staff.

Finally, schedule an annual mock recall drill. Assign roles, trace a fictitious allergen error through production, and practice pulling affected inventory. Drills both satisfy Georgia’s inspection expectations and build muscle memory for real-world incidents.

Frequently Asked Questions

Yes. Georgia's Cottage Food Regulation requires clear labeling when a product contains any of the nine major allergens. The label must list the allergen in plain language plus carry the standard “This product is made in a cottage food operation” disclaimer. Local inspectors can issue stop-sale orders at farmers markets for non-compliant labels.

List the composite ingredient followed by its constituent allergens in parentheses—e.g., “Worcestershire Sauce (anchovies, soy, wheat)”. Georgia follows FDA rules but reminds operators that undeclared fish allergens trigger priority violations under Rule 511-6-1.

Advisory statements like “may contain” are voluntary and do not replace proper cleaning or changeover. Georgia inspectors will still expect written procedures to prevent cross-contact and may cite you if the advisory is used in place of feasible control measures.

Yes. Packaged snacks sold via vending fall under FALCPA and must display allergen info on the primary label. Georgia inspectors periodically sample vending routes for compliance, especially in schools and hospitals.

Georgia operators are responsible for the final product label. Implement supplier verification programs and compare invoices to formulation specs weekly. If a new allergen appears, stop distribution until labels are updated.

Verbal disclosure alone does not satisfy labeling for packaged foods. For restaurant menus, a verbal statement can supplement but not replace written menu disclosures mandated by Ga. Food Code §511-6-1. Written evidence ensures consistent communication during inspections and reduces liability.

Related Resources

Allergen Management

Comprehensive controls for kitchen cross-contact.

Safety Regulations

Understand Georgia-wide rules for every food business.

Food Code Summary

Key points of Georgia’s adoption of the FDA Model Code.

Managing Allergies

Planned deep-dive into real-world allergy scenarios.

Ensuring accurate allergen labeling is a cornerstone of food safety and brand trust. Review your entire allergen program today to stay ahead of inspections and protect guests.