Guide · Buffet labels
The FDA Food Code and allergen notices on a buffet
Written by a hotel banquet operations manager ·
The FDA Food Code is a model code, not a federal law: it applies to a buffet only where your state or local government has adopted it, and its 2022 edition (section 3-602.12) addresses written notice of the major food allergens in unpackaged food. This page explains the terms; your health department tells you what applies to you. It is not legal advice.
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What the Food Code is
The FDA publishes the Food Code as a model code. It is offered for adoption by local, state and federal governmental jurisdictions, and each decides which edition, and which changes, to enforce. The same buffet can therefore be held to different editions in different places. See the FDA's own page: Food Code 2022. FDA has since issued a 2026 edition, which its Food Code page lists as the most recent (as of September 17, 2026); the 2022 facts below are the ones that introduced sesame and the allergen-notice section.
What section 3-602.12 is about
The 2022 edition's section 3-602.12 deals with written notice of major food allergens when food is not in a package. A banquet buffet is unpackaged food, so this is the section hotel kitchens hear about. The FDA's page on the 2022 change describes it, and lists written notice through means such as menu notifications, label statements, table tents or placards; read it and the code text itself rather than a summary on a third-party page: FDA: sesame added to the 2022 Food Code.
| Question | Short answer |
|---|---|
| Is the Food Code a law? | No. It is a model code. It binds a kitchen only where a government has adopted it. |
| Which edition applies to me? | Your health department decides. Ask which edition it enforces. |
| What does 3-602.12 cover? | Written notice of major food allergens in unpackaged food (2022 edition). |
| Does this page say what I must print? | No. It cannot, because that depends on where you operate. |
The nine major allergens
The FDA lists nine: milk, eggs, fish, crustacean shellfish, tree nuts, peanuts, wheat, soybeans and sesame (sesame was added effective January 1, 2023). See the FDA's food allergies page. Hotelwright's labels name the same nine, in English and Spanish, from a fixed dictionary (soybeans print as "soy"). See the nine in both languages on the allergen label legend.
What to ask your health department
- Which Food Code edition do you enforce for banquet and buffet service?
- Does written allergen notice apply to our unpackaged buffet food, and in what form do you accept it (a label, a sign, a menu line)?
- Does the notice need to name allergens dish by dish, or may it point to a person?
- Do we need to keep anything on file, such as a printed label set or a record of who checked it?
Write the answers on your pre-shift sheet so every captain says the same thing.
How Hotelwright labels fit
Hotelwright prints a Contains line for the nine allergens only after a manager confirms the event's allergens, and it records who confirmed and when. Until then the label says "Allergens not confirmed". Hotelwright does not detect allergens or check recipes: the hotel is responsible for the list it confirms, and for any notice its local rules require. Printing labels does not by itself meet a rule; ask your health department. See buffet labels with allergens and buffet label requirements.
Sources
FAQ
What banquet managers ask.
Is the FDA Food Code federal law?
No. It is a model code. It applies where a state or local government has adopted it, so ask your health department which edition it enforces.
What does section 3-602.12 say?
In the 2022 edition it addresses written notice of the major food allergens in unpackaged food. Read the FDA's page on the 2022 change and the code text for the exact wording; this page only points to them.
Does a buffet need allergen labels?
That depends on where you operate. Check with your health department. This page is not legal advice.
Which allergens are "major" under the FDA list?
Milk, eggs, fish, crustacean shellfish, tree nuts, peanuts, wheat, soy and sesame.
Does Hotelwright make my labels meet the Food Code?
No. Hotelwright prints what a manager confirms for each event. Whether that satisfies your local rule is for your health department to say.