Undeclared Almond in Hershey's Kisses: What an SFCR Allergen Control Plan Must Do

On 1 August 2026 the Canadian Food Inspection Agency posted a Class 1 recall for Hershey's brand Kisses Creamy Milk Chocolate, 104 g and 200 g bags, because the product may contain almonds that are not declared on the label. It was a national recall triggered by the company after one reported reaction. Reporting on the recall put the distribution window at roughly early May to late July 2026, which means the product was on the market for about twelve weeks before the problem was caught.

For anyone running a food plant, the interesting number is not the recall itself but that twelve-week gap. A near three-month delay between first distribution and recall is a detection issue as much as a prevention issue. In a facility that runs both a plain product and an almond-containing version on shared equipment, the Safe Food for Canadians Regulations expect an allergen control plan that manages cross-contact at changeover and a finished-product verification programme capable of catching a failure long before a consumer does. This article sets out what that plan has to do.

Executive summary

CFIA treats food allergens, gluten and added sulphites as chemical hazards that must be addressed in your hazard analysis and controlled through the preventive control plan. Undeclared allergens are a leading cause of food recalls in Canada, and the agency is clear that the presence of an allergen cannot be eliminated by a thermal treatment or a post-processing step. Its guidance on preventive controls for food allergens, gluten and added sulphites sets the expectations this article follows.

A workable SFCR allergen control plan does five things well:

• Identifies every allergen in every ingredient and in the establishment, not just in the recipe.
• Maps cross-contact points along the line, in storage and through the air.
• Controls changeover through scheduling, sequencing, validated cleaning and label management.
• Verifies that the controls actually work using surface and finished-product testing.
• Keeps records so a problem is caught in days, not in twelve weeks.

What an SFCR allergen control plan is

What it is: the allergen control plan is the documented set of measures within your preventive control plan that prevents allergens, gluten and added sulphites from ending up in a food where they are not an intended ingredient, and ensures they are properly declared where they are. Why it matters: an allergic reaction to an undeclared allergen can be serious or life-threatening, which is why undeclared allergens drive so many Class 1 recalls. What to do: build the plan from a full allergen inventory and a line map, then attach a control to each risk and a verification step to each control.

CFIA suggests establishing an allergen prevention team so that identification and control are not left to one function. In a small plant one competent person can lead it. In a larger plant the team usually pulls together the people responsible for the hazard analysis and preventive control plan, quality assurance, purchasing, manufacturing, engineering and product development, because cross-contact risk is created in all of those areas.

Why allergen recalls take months to detect

What it is: detection latency is the time between a control failure and the moment anyone notices. Why it matters: the longer the latency, the wider the distribution and the bigger the recall, as the Kisses case shows with about twelve weeks on the market before action. What to do: design verification that samples the finished product and the environment often enough to close the gap, rather than relying on a downstream complaint.

A plan that prevents cross-contact but never checks that it worked will only find a failure when a consumer reacts. That is the pattern behind long distribution windows. The correct response after this class of event is almost never operator retraining alone. If the root cause sits in the changeover sequence, the cleaning validation or the label control system, then retraining will not survive an inspector's challenge and will not stop it happening again. Effective corrective and preventive action fixes the system, and verification proves the fix holds.

The priority allergens you must control

What it is: Canada recognises a defined set of priority food allergens plus gluten and added sulphites. Why it matters: your inventory has to cover all of them wherever they appear, including as derivatives and through cross-contact. What to do: list every ingredient against this set and record the control applied.

Watch for cross-reactive proteins as well. Any protein-containing ingredient can trigger a reaction, and Health Canada's allergen labelling guidance covers known examples such as canola protein and mustard allergy, and pea protein and peanut allergy. If it is a protein, it belongs on the list until proven otherwise.

Where cross-contact happens

What it is: cross-contact is the unintentional transfer of an allergenic residue into a food that is not meant to contain it. Why it matters: it is the mechanism behind most undeclared-allergen recalls, and it is often invisible. What to do: map every route in your plant and attach a control to each. Common routes CFIA identifies include:

• Shared equipment and cross-contact points along the processing line.
• Carry-over from an ingredient, or re-using an ingredient such as frying oil.
• Dust or aerosols carried through the processing area.
• A change, substitution or addition of an ingredient or supplier without a label review.
• Using the wrong ingredient, an unknown ingredient, or ineffective cleaning, especially where a heated or denatured protein clings to a surface.

Process controls: scheduling, sequencing and rework

What it is: the process controls separate allergen-containing production from allergen-free production, by dedication where possible and by time and sequence where not. Why it matters: this is exactly the area a shared plain-and-almond line depends on. What to do: put the following controls in writing and audit them.

• Create a flow diagram for each line, ingredient and conveyance, and mark every point where cross-contact is possible and every piece of multi-use equipment.
• Use dedicated lines where you can. Where you cannot, schedule allergen-containing product so equipment can be thoroughly cleaned before an allergen-free product runs.
• Add allergenic ingredients as late in the process as possible to limit the equipment they touch.
• Control rework tightly: a food or ingredient that contains an allergen should only be reworked into the same product, and the rules for what can be reused and where must be written down.
• Store allergen-containing materials in a dedicated area, on shelves below other ingredients, sealed, away from packaging and labels, and clearly identified with signs or colour codes.

Sanitation and cleaning validation

What it is: effective cleaning is one of the most important controls for preventing allergen cross-contact, and CFIA expects the cleaning method to be validated. Why it matters: rinsing with water alone is not enough, and proteins are hard to remove once heated or denatured. What to do: match the method to the residue and prove it works.

Wet cleaning is recommended for doughy or sticky residues that can contain allergens. It should use detergents and sanitizers rather than water alone, and chlorinated alkaline detergents are the most effective for removing proteins, with alkaline or caustic cleaners combined with hydrogen peroxide and enzymes also effective. Some equipment must be disassembled and hand cleaned, and clean-in-place systems should be checked for pitting or rough welds that trap residue. Dry cleaning suits low-moisture areas and uses methods such as controlled compressed air, vacuum, brushing or a push-through with the next ingredient, but it is not appropriate where residues are wet or sticky. Cleaning validation ties the chosen method to evidence that the surface is clean to the required level.

Label control at changeover

What it is: the label is the control that tells a sensitive consumer whether a food is safe for them, and it fails when the wrong label meets the right food or a formulation change is not reflected. Why it matters: an undeclared allergen from a label error is as dangerous as one from cross-contact. What to do: build changeover controls into the packaging line and treat label changes as controlled changes, as covered in our guide to preventing label errors.

• Build a production break when the type of food changes, and use marked containers so products are not intermixed before labelling.
• Verify labels before application, and confirm the inner and outer packaging are for the same food.
• Trigger a label review whenever an ingredient is substituted or a formula changes, especially where the change introduces an allergen not already declared, and dispose of obsolete labels.

Verifying that the controls work

What it is: verification tests whether allergen residues remain in the environment or reach a food that should not contain them. Why it matters: verification is what closes the detection gap that let the Kisses recall run for weeks. What to do: choose methods fit for the target and sample the right places.

The analytical method should be able to detect the target in the low milligram-per-kilogram range. Non-specific checks such as ATP tell you a surface is generally clean, but only a specific protein or DNA method tells you the allergen itself is gone. Records supporting these controls should be retained, and under the Safe Food for Canadians Regulations most preventive control records are kept for two years.

SFCR allergen control plan checklist

• Maintain a full allergen inventory covering every ingredient, derivative and cross-reactive protein, plus everything present in the establishment.
• Obtain written supplier specifications and verify incoming ingredients and their labels against them at receipt.
• Keep a written, current formula for each product and define how formulation changes are made and how obsolete formulas are removed.
• Map cross-contact on a flow diagram and identify all multi-use equipment.
• Use dedicated lines or scheduled sequencing with validated cleaning between allergen and allergen-free runs.
• Control rework, storage segregation, and personnel and traffic flow.
• Apply changeover label controls: production break, label verification, and a mandatory label review on any ingredient or formula change.
• Verify effectiveness with protein or DNA testing on surfaces and finished product, and retain the records.

Common mistakes

The most common mistake is treating the allergen control plan as a labelling exercise, when labelling is only the final declaration. The second is relying on ATP or visual checks alone, which confirm general cleanliness but not the absence of a specific allergen. The third is closing a cross-contact event with operator retraining as the only corrective action, when the real root cause sits in scheduling, cleaning validation or label control. The fourth is failing to trigger a label review when a supplier or ingredient changes, which is how a new allergen slips onto a line undeclared. The fifth is verifying prevention but not sampling finished product, which is what allows a failure to run for weeks before anyone notices.

Frequently asked questions

What does an SFCR allergen control plan require?

It requires you to identify all allergens, gluten and added sulphites in your ingredients and establishment, map where cross-contact can occur, and apply controls across receiving, formulation, scheduling, changeover, storage, sanitation and labelling. It also requires you to verify that those controls work and to keep records. The plan sits inside your broader preventive control plan.

Why do allergen recalls take so long to detect?

Because many plans prevent cross-contact but do not verify the result. When there is no routine testing of surfaces and finished product, a failure only becomes visible when a consumer reacts, which can be weeks after the product ships. Closing that gap needs a verification programme that samples often enough to catch a problem early.

Is ATP swabbing enough to confirm an allergen is gone?

No. ATP and total protein tests are non-specific hygiene checks, and the residue they measure may not come from an allergen. To confirm a specific allergen has been removed you need a protein-based test such as an ELISA or a DNA-based PCR method, capable of detecting the target in the low milligram-per-kilogram range.

Can cooking remove an allergen from a food?

No. CFIA is explicit that a thermal treatment or post-processing step cannot eliminate an allergen. That is why allergen controls are preventive, focused on keeping the allergen out of a food where it does not belong, rather than trying to destroy it later.

Do precautionary may contain statements replace an allergen control plan?

No. A precautionary statement does not substitute for controlling cross-contact. Health Canada expects precautionary labelling to be used only after reasonable controls are in place and a real, unavoidable risk remains. Using it to cover a weak control programme is not acceptable and does not protect consumers.

How long must allergen control records be kept?

Under the Safe Food for Canadians Regulations, most preventive control records, including those supporting your allergen controls, are kept for two years. Retention should be confirmed against the specific record type and the regulations, since different record classes can carry different periods.

How MFLRC can help

MFLRC helps food and beverage manufacturers build and defend allergen control plans under the SFCR. We run allergen control plan builds and preventive control plan gap assessments, design changeover and sanitation validation protocols, write label-control and rework SOPs, and set up finished-product verification programmes and mock recalls. Our audit services include inspection-readiness assessments and CAPA review so a cross-contact event is closed at the root cause, not with retraining that will not hold.

Running plain and allergen-containing products on shared equipment? MFLRC will assess your allergen control plan against the SFCR and show you where cross-contact and detection gaps put you at risk of a recall.

Conclusion

The Kisses recall is a reminder that an allergen control plan is judged by two things: whether it keeps the allergen out, and whether it catches the failure fast when something slips. Prevention across receiving, scheduling, changeover and sanitation is the first half. Verification of surfaces and finished product is the second, and it is the half most plans underbuild. Strengthen both and test them with a mock recall, and make sure your preventive control plan covers the risks it is easiest to overlook, including chemical residues in imported ingredients.

Sources and references

• CFIA, Preventive controls for food allergens, gluten and added sulphites
• CFIA recall, Hershey's brand Kisses Creamy Milk Chocolate recalled due to undeclared almond (RA-82433, 1 August 2026)
• Health Canada, Food allergen labelling
• Safe Food for Canadians Regulations (SOR/2018-108), Justice Laws Website