While it's likely the FDA will temper FALCPA by defining a threshold level, Phelan says the law raises the bar on knowing the composition of suppliers' ingredients and managing the information in a more efficient way. FALCPA also requires disclosure of low-level preservatives and colorants and restricts the use of catchall phrases such as "may contain" certain ingredients.
An FDA spot check of 118 food items in 2001 found unlabeled peanuts, tree nuts, milk, eggs, soy, wheat, fish and shellfish in 23 samples. Placing the wrong label on the package often produced the error, but processing errors were blamed in many cases, including a failure to account for the composition of the ingredients.