Allergen guidance

How to establish a written allergen control program

What is an allergy?

An allergy is an immune response to a foreign substance. Allergies can be triggered by exposure through consumption, skin contact, or respiratory exposure.

A food allergy is an immune response to a food triggered by the body’s immune system. Food allergies occur when the body’s immune system reacts to certain proteins in food. Food allergies can cause mild symptoms (e.g., hives, itching, gastrointestinal issues), but in rare cases can trigger a severe and life-threatening reaction known as anaphylaxis.

Properly identifying and labeling allergens in cannabis products and preventing allergen cross-contact are important factors in ensuring the safety of consumers who suffer from food allergies.

What are the major food allergens?

The Department of Cannabis Control (DCC) follows federal law that recognizes nine major food allergens: Milk, Eggs, Tree Nuts, Wheat, Peanuts, Soybeans, Sesame, Fish, and Shellfish.

Additional information: California Code of Regulations (CCR) Title 4, section 15000 (c)

What is allergen cross-contact?

DCC regulations define allergen cross-contact as the unintentional incorporation of a food allergen into a cannabis product. For example, allergen cross-contact can occur when multiple products with different allergen profiles are produced using the same equipment and the equipment is ineffectively cleaned between production runs or through the generation of dust containing an allergen.

Additional information: CCR section 17207 (a)

DCC regulations and allergens

To protect those with food allergies and sensitivities, DCC regulations require that licensees who handle allergens establish and implement a written allergen control program as part of the Product Quality Plan to prevent both labeling mistakes and allergen cross-contact between product types. Licensees must implement an allergen control program that is appropriate for their specific manufacturing activities.

Key elements of an allergen control program include:

• Accurately listing all major allergens present in the cannabis product on the ingredient list of the product labeling.
• Providing accurate allergen warnings on the cannabis product label in the form of a contains statement – the word “contains” followed by a list of the allergens contained in the cannabis product.
• Implementing good manufacturing practices (GMPs) and other allergen controls during manufacturing to prevent allergen cross-contact between product types and labeling mistakes.

Additional information: CCR section 17214 (d)(3)

DCC regulatory requirements and example practices for an allergen control program

Regulatory requirement

Licensees are required to implement a Quality Control Program to ensure cannabis products are not adulterated or misbranded. This includes preventing allergen cross-contact during manufacturing because products with undeclared allergens may be considered adulterated or misbranded.

Additional information: CCR section 17208 (a)

Example practices

Schedule production with allergens to minimize potential for cross contamination

• Consider scheduling production of allergen-containing products on their own day, or at the end of a shift. This minimizes the chances of allergen cross-contact between products.

Implement thorough cleaning protocols

• After production of allergen-containing products, follow an established written protocol to clean and sanitize equipment before producing the next batch of cannabis products.
• Document when cleaning and sanitizing is performed.

Designate and label equipment and utensils for use with allergens or allergen-containing ingredients

• If possible, use dedicated equipment, processing lines, and utensils for allergens and allergen-containing products
• Identify equipment and utensils for use with allergens (e.g., color coding).

Regulatory requirement

Licensees are required to train employees in the licensee’s manufacturing specific quality control procedures, product quality plans, and cleaning and maintenance requirements, and document these trainings.

Additional information

• CCR section 17211.1 (a)(2)(B)
• CCR section 17211.1 (a)(2)(C)
• CCR section 17211.1 (a)(2)(F)

Example practices

Staff training

• Train staff on the importance of allergen controls.
• Manufacturing staff should know:
  • The nine major food allergens.
  • All allergens present in your facility.
  • The allergens present in each cannabis product.
• Manufacturing staff should understand the hazards of allergen cross-contact and the allergen controls they are responsible for implementing.
• Ensure training is documented and refreshed annually.

Regulatory requirement

Licensees are required to store raw materials and components under conditions that prevent against allergen cross-contact, including using containers to protect against allergen cross-contact, and identifying components and raw materials that are or contain food allergens.

Additional information

• CCR section 17212 (b)(2)
• CCR section 17212 (b)(6)
• CCR section 17212 (b)(8)

Example practices

Properly store allergens and allergen-containing ingredients

• Have a designated, labeled storage area for each allergen and allergen-containing ingredient.
• Label each allergen and allergen-containing ingredient clearly with the name(s) of the allergen(s).
• Use containers with lids to prevent spills during storage and transport.
• Store allergens and allergen-containing ingredients below other ingredients to prevent spills onto non-allergen ingredients or components.

Regulatory requirement

Licensees are required to accurately label cannabis products with the ingredients, sub-ingredients, and allergens they contain, including an allergen warning in the form of a “contains” statement, followed by a list of the allergens.

Additional information

• CCR section 17406 (a)(5)
• CCR section 17406 (a)(6)

Example practices

Correctly label cannabis products containing allergens

• Ensure ingredients and sub-ingredients (ingredients within another ingredient), especially allergens, are accurately declared in the ingredient list on your cannabis product’s labeling.
• Review the ingredient lists on each of your ingredients. List those ingredients (especially allergens), and any sub-ingredients they contain on the label of your cannabis product.
• E.g. If milk chocolate is one of your product ingredients, you must list all of its ingredients and declare its allergens “(cocoa butter, milk powder, sugar, cocoa powder);” “contains milk.”
• When receiving packaging and labeling for cannabis products that contain allergens, review a sample label to ensure the allergens are accurately listed and declared on the label.
• Implement additional cannabis product label reviews during packaging and labeling of allergen-containing products to ensure the correct labels are applied to the correct cannabis product.
• Consider documenting these checks in the Batch Production Record.

Note: An ingredient manufacturer and/or supplier may change their product formulation at any time – including adding an allergen, for example, switching a sub-ingredient to peanut oil. Periodically review the ingredient lists and allergen warnings on your ingredients and update your cannabis product labels’ ingredient lists when necessary to prevent manufacturing a cannabis product with an undeclared allergen.

Regulatory requirement

Licensees are required to establish and implement a written product quality plan which includes evaluating the risk for allergen cross-contact and implementing an allergen control program.

Additional information

• CCR section 17214 (a)
• CCR section 17214 (c)(2)
• CCR section 17214 (d)(3)

Example practices

Written procedures

• Put your allergen controls in writing. Create written procedures describing the steps and actions you take to prevent allergen labeling errors and allergen cross-contact (see Allergen Control Program Checklist).

Major food allergens

The following are the nine major food allergens recognized by DCC and federal law. The list includes alternate
names for these allergens, some common foods and ingredients that contain these allergens, and some
examples of cannabis products that may contain these allergens.

These examples are not an all-inclusive list.

Allergen	Alternate names (also known as)	Indirect and third-party commercial sources (examples)	Cannabis products where this allergen may be found (examples)
Wheat	Semolina Flour Rye Barley Spelt Malt	Cookie pieces Cereals	Baked goods (cookies, brownies, crisped rice treats) Confections (licorice) Non-alcoholic beers Pretzels
Peanuts	Groundnut Goober	Peanut butter Peanut oil	Baked goods (cookies, brownies, granola bars) Chocolates (peanut butter cups, candy bars) Infused peanut butter
Tree nuts	Walnuts Almonds Pecans Cashews Pistachios Hazelnut (Filbert and Cobnut) Brazil Macadamia Pine Nut	Nut oils Nut-based vegan “butter” alternatives Nut milks/beverages Nut butters & creams/spreads	Baked goods (cookies, brownies, granola bars) Chocolates (candy bars, nut-flavored chocolates) Confections (nougat, nut clusters) Nut butters Infused vegan “butter” derived from tree nuts Tinctures Topicals Infused oils
Sesame	Tahini Sesamol or sesamolina Benne, benne seed, or benniseed Gingelly and gingelly oil Sim sim	Sesame seeds Sesame oil Cereals, such as muesli and granola Margarine Sauces, dips, and dressings	Baked goods (cookies, brownies, granola bars, bagels, bread) Sesame oil-based tinctures Chocolates Savory snacks
Milk	Butter Ghee Casein Whey	Butter Cheese Cheese powder Cookies Milk chocolate Fudge Caramel Toffee	Baked goods (cookies, brownies) Chocolates Confections (caramels) Savory “cheesy flavored” snacks Infused Butter/Ghee
Eggs	Egg whites Meringue Albumin Egg lecithin	Cookies Marshmallow	Baked goods (cookies, brownies, crisped rice treats) Confections (nougat)
Soy	Soy lecithin Soybeans Soybean oil Soy-based vegan “butter” Soybean protein powder Edamame	Chocolates, baked goods and confections containing soy lecithin or soy oil Tofu Soy Sauce Vegan “butter” alternatives	Baked goods (cookies, brownies) Chocolates Confections Soy oil-based tinctures Infused Vegan “butter” cooking alternatives derived from soy
Crustacean shellfish	Crab Lobster Shrimp Clams Scallops	Omega-3 Fatty Acids (derived from shellfish) A sub-ingredient in savory seasonings, dried powder flavorings, Clamato & Bloody Mary mixes/beverages	Infused Clamato/Bloody Mary Mix Savory snacks
Fish	Fish oil	Omega-3 Fatty Acids (derived from fish) A sub-ingredient in savory seasonings, dried powder flavoring	Fish oil-based supplements and tinctures

Last revised: June 2, 2025

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