Yes, the food allergen labeling requirements apply to bulk containers such as reusable totes or containers for bulk food shipped for further processing, labeling or repacking between manufacturers, repackers or distributors. While a food shipment may be exempt from most of the mandatory food labeling requirements through the use of a labeling agreement, these regulations do not provide an exemption from allergen labeling requirements.
More information regarding food allergen labeling requirements are available at the following links to the Draft Guidance and Final Guidance to Industry
- Guidance for Industry: Questions and Answers Regarding Food Allergen Labeling (Edition 5) November 2022
- Draft Guidance for Industry: Questions and Answers Regarding Food Allergen Labeling (Edition 5) November 2022