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The sesame rule and your label

This week's allergen webinar is built around the sesame rule that took effect in January and is still tripping up small labels three months in.

Sesame has been a major food allergen under federal rules since the first of January, and three and a half months in, our helpline is still fielding the same question: does this actually touch cheese labels, or is it a bakery problem that cheesemakers can ignore? This week's allergen webinar exists mostly to answer that one question properly, along with the handful that follow it.

The short version is that sesame becomes relevant the moment it shows up anywhere near your product, not just in it. A few of our members coat rinds with sesame-adjacent seed blends, a few more share equipment or a packing line with a producer who does, and a couple sell alongside sesame-crusted crackers in a shared gift-box program. None of that automatically requires a "contains sesame" statement, but all of it requires you to have actually looked at your ingredient list and your shared-line risk before deciding your label doesn't need to change.

Where members are getting tripped up

The most common mistake we're seeing isn't a missing statement — it's an outdated one. A member updates their allergen contains-statement for sesame, then forgets that a "may contain" advisory statement follows different logic and different expectations from regulators, who have been public about not wanting advisory language used as a substitute for actual cross-contact controls. If your label says "may contain sesame" because it's easier than reworking a shared line's cleaning schedule, that's the kind of shortcut the current guidance is specifically aimed at.

The second mistake is timing. Products already on shelves before January 1 didn't need to be pulled or relabeled, which led a few members to assume they had more runway than they do. New print runs, new SKUs, and any relabeling you were already planning for this season all fall under the current rule, effective now, not phased in. A member who told us in March that they'd "get to it before summer" is, technically, already behind.

Beyond the label itself, the harder part for a lot of small producers is documenting how they decided what the label should say. If your creamery shares a packing table with a bakery tenant, or your supplier changed a spice blend without telling you, the paper trail showing you checked matters as much as the checking itself. Auditors and larger retail buyers have started asking for that documentation as a matter of course, not as an unusual request, and members who can produce it quickly tend to have shorter, less stressful audits.

What this week's session covers

The webinar walks through where sesame shows up in ingredient supply chains that don't look obviously sesame-related — some spice blends, some coating oils, some equipment shared with a bakery tenant in a shared commercial kitchen — and how to document a cross-contact assessment that would hold up if a buyer or an auditor asked to see it. It's aimed at the member doing their own labeling, not at anyone with a dedicated regulatory affairs team, so expect plain language over citation numbers.

If this week doesn't work for your schedule, the recording lands in the course library within a week, same as our other webinars this year. Members pursuing the Food Safety & HACCP Certificate should note that allergen control is part of that curriculum, so this session doubles as useful review even if labeling season doesn't feel urgent yet at your creamery.

Registration is open now through the member portal. Bring your ingredient list — the session works best as a working session, not a lecture, and members who've come prepared with a specific product in mind tend to get the most out of the Q&A.


The International Cheese Federation (ICF) and More Cheese are entirely fictional. This post is demonstration content created for MemberJunction. All people, organizations, events, courses, certifications, figures, and quotations in it are invented, and nothing here represents a real association, a real business, a real person, or real professional advice.

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