Q: Kelly – After toying with the idea of going dairy-free for a while, I've finally just started. But there is one question where I find I am at a loss. When a product states "made on equipment shared with milk" or "manufactured on shared equipment with milk" should that product be taken off your list of foods you can eat even though there are not any dairy ingredients actually in the food?
A: Alisa – The food labeling laws within the U.S. (similar standards or laws are in place in Canada and Europe, but they vary a bit) require that food manufacturers clearly label if products contain milk in the ingredients. This may be done by indicating “milk” next to the ingredient, by putting “contains milk” at the end of the ingredients, or if the ingredients only contain milk ingredients that are obviously milk-based (ie milk, cheese, etc.). Consumers, including children, must be able to clearly see that there is milk in the ingredients.
The labels that say “may contain traces of milk,” “made on shared equipment with milk,” “made in a factory that also processes milk,” etc. are completely optional. This means that many products out there are made on shared equipment, but they don’t state it on the label, only some do …
The amount of milk that gets into a product made on shared equipment or in a shared facility will vary, but usually won’t be high. In many cases, due to cleaning processes between production runs, it will only be trace amounts (we’re talking parts per million). This is not a problem for most people who avoid milk, but can be a problem for those who have severe or life-threatening food allergies or who generally find themselves extremely sensitive to dairy products. It could also be a major issue in the rare situations where cleaning processes are not practiced between production runs (for example a crossover from producing milk chocolate to dark chocolate). In these cases, more than trace amounts may be found in the end product.
In your situation, it sounds as if dairy is not an immediate danger to you. If this is the case, then products that may contain some cross-contamination of milk would probably not be a major health concern. Thus, it would be entirely up to you if you choose to consume those products.
Anyone who has a severe or life-threatening allergy or sensitivity to milk should not rely on the labels alone, particularly since companies do not need to disclose how the products are manufactured (yet). When milk or any other food allergen is a potential danger, always contact the company directly before consumption of any packaged food to ensure that it will be safe.
For more information on reading food labels, identifying ingredients, spotting hidden dairy in foods, and understanding kosher labels, see Go Dairy Free: The Guide and Cookbook.
The following are some examples of what you may see in terms of food allergen labeling …
Note that even though most people would recognize Parmesan and Butter as dairy ingredients, the company still opted to put a milk notation next to those ingredients. Not all food manufacturers do this.
This is a product that is consumed safely by many people I know with moderate food allergies, but the company still uses caution actually noting that it is made in a shared facility. This is currently optional for food labeling as noted above.
Here is one that is made on shared equipment, relating to Kelly's question directly. But notice how the wording used is often a bit different from label to label.
Red Flag Concerns
This product isn't from a company that is known for strict food allergen processes, so the fact that it contains chocolate chips yet it doesn't say that it may contain traces of milk raises a red flag to me. They indicate that the bars are made in a facility that processes tree nuts and peanuts – but this does not mean that the ingredients such as the chocolate chips were not produced in another facility that also processes milk-containing products. This would not usually be a concern for most who avoid milk, but those who are dealing with severe food allergies and intolerances should watch for red flags like these and contact the company to find out if the product may contain traces of the offending allergen or if they do in fact source "safe" ingredients, such as truly dairy-free chocolate.
This is what I would call a blatent labeling "error" (though it may still pass the FDA labeling requirements), and these do happen all too often. Take a look at the "Allergy Information." It says "Contains Peanuts," but nothing else. Now look a little closer …
Whey Protein Concentrate, hidden under the flap, is one of the first ingredients (translation: there is a decent dose of whey in this product). Whey is a type of dairy protein. Not everyone will have a problem with whey, but it is a milk byproduct nonetheless and I would not describe this as clearly labeled. For one, the product doesn't state milk in the Allergy Information, and for two, I know of many adults, let alone children, who would not quickly recognize whey as a milk ingredient on a food label.
Alisa Fleming is the founder of GoDairyFree.org and author of Go Dairy Free: The Guide and Cookbook for Milk Allergies, Lactose Intolerance, and Casein-Free Living. In addition to her own dairy-free lifestyle, Alisa has experience in catering to the needs of various special diets, including gluten-free, soy-free, egg-free, vegan, and multiple food allergies.