Undeclared sulfites in FDA food recalls

261 FDA food recall records since 2012 name undeclared sulfites, out of 7,778 undeclared allergen recalls in total. 123 are Class I. Data last updated 2 September 2026.

Records of 29,386

261

Share of all recalls

0.9%

Class I of 261

123

Reported between

2012 to 2026

Sulfites and the nine

Sulfites are not a major food allergen. They are declared under a separate rule when present at 10 parts per million or more, and they appear in recall records often enough to be worth tracking alongside the nine.

These records are a subset of the 7,778 undeclared allergen recalls. A single recall frequently names more than one allergen, so the counts across this family overlap. An undeclared allergen recall means a food contained one of the major allergens and the label did not say so, either because the wrong label was applied or because an ingredient carried an allergen nobody traced.

What is different about these records

A recall involving undeclared sulfites stays open a median of 255 days between the report and termination, against 215 days for the corpus as a whole. Termination follows the firm accounting for every unit of the affected lot.

These recalls stay local: 8.8% state nationwide distribution, against 20.7% across the corpus.

The volume is falling: 35 records in the three years to 2025, against 99 in the four before them. 2026 is excluded because the agency reports an enforcement action months after a firm begins a recall, so the most recent year is always incomplete.

What the FDA says

What the law says about sulfites

Sulfites are not in 21 U.S.C. 321(qq) and are not a major food allergen. Their declaration comes from a different place. 21 CFR 101.100(a)(3) exempts an incidental additive from the ingredient list when it is present in an insignificant amount with no technical effect, and paragraph (a)(4) says that a sulfiting agent, sulfur dioxide and the five named sulfite salts, is present in an insignificant amount only if no detectable amount is in the finished food, and that a detectable amount is 10 parts per million or more. So a sulfite carried in on a dried fruit or a wine has to appear in the ingredient list at that level even though it was never added on purpose, and below it there is no requirement. A sulfite record on this page is a 101.100 failure and not a section 343(w) one, and a plan that files sulfites with the nine will apply a threshold the nine do not have.

The clause this maps to

A preventive controls plan covers an undeclared sulfites allergen under the clauses below. This is where the control belongs, not a finding against any firm named on this page: a recall record states a reason, and most of these recalls were initiated by the firm itself.

21 CFR 117.135(c)(2)

Food allergen controls: the written preventive controls that keep an allergen out of a food it does not belong in, and that get the allergens present onto the label.

21 CFR 101.4

Ingredient declaration: every ingredient listed by its common name, in descending order of predominance, on the label of a packaged food.

21 CFR 117 subpart G

Supply-chain programme: the approval and verification a receiving facility runs on a supplier when the hazard is controlled before the ingredient arrives.

By year

Counts are by the date the FDA reported the enforcement action. That date runs behind the date a firm started a recall, so the most recent year is always partial.

Firms with the most records

A firm appears here because it reported recalls, which is what a working recall procedure produces. A high count frequently reflects a single event split across many product codes rather than many separate failures.

• Liberty Fruit Co Inc DBA Carol's Cuts21
• Joy Gourmet Foods LLC.13
• Barlean's Llc12
• Silver Moon LP dba Loard's Ice Cream4
• Global Commodities Inc4
• S & M International Inc4
• Rong Shing Trading NY Inc3
• A & C Best Food Trading3
• Aspire Food Group USA Inc.3
• Kelejete LLC3
• Geneva Foods, LLC3
• AA USA Trading Inc.3

Where the recalling firms are

The state is the location of the recalling firm, not where the product was sold. Distribution is recorded separately on each record.

• New York80
• New Jersey37
• Kansas21
• Washington20
• California16
• Florida14
• Texas9
• Puerto Rico9
• Massachusetts8
• Michigan7
• North Carolina6
• Arizona4

Most recently reported

Questions

How many FDA recalls involve undeclared sulfites?

261 FDA food recall records since 2012 name undeclared sulfites, out of 7,778 undeclared allergen recalls in total. That makes it the seventh most frequently undeclared of the allergens tracked here.

Is sulfites a major food allergen?

Sulfites are not a major food allergen. They are declared under a separate rule when present at 10 parts per million or more, and they appear in recall records often enough to be worth tracking alongside the nine.

Which clause covers undeclared sulfites?

Allergen labelling failures are covered under 21 CFR 117.135(c)(2), the food allergen preventive controls, together with 21 CFR 101.4 for the ingredient declaration itself. Where the allergen arrived inside a purchased ingredient, the supply-chain programme in 21 CFR 117 subpart G is the control that should have caught it.

All FDA food recall data