The use of disclaimers on packaging is voluntary. Even with a disclaimer, the consumer oftentimes is unsure about the safety of the product. This is a valid concern. Recall events due to undeclared allergens have multiplied since FALCPA went into effect, validating this concern. A recent report by Stericycle found “undeclared allergens or other allergen concerns remained the primary cause of recalls during the fourth quarter, accounting for more than one third of food recalls initiated in the quarter.”[9]