In the United States, the annual total of federal recalls of meat and poultry products recalled due to the mislabeling of allergens increased from 8% in 2008 to 35% in 2012.  Moreover, the total number of recall events involving meat and poultry products due to undeclared allergens increased 103% between the calendar years 2012 and 2015. Undeclared allergens have now become the leading reason for recalls of meat and poultry products from the U.S. marketplace.
If a company distributes a food product with an undeclared allergen into commerce, the USDA Food Safety Inspection Service (FSIS) considers the recall to be a failure of the company’s food safety system. To address a ‘sustained increase’ in the number of recalls of meat and poultry products due to undeclared allergens, the agency conducted a public meeting in Washington DC on March 16 that discussed strategic approaches to reducing recalls prompted by undeclared allergens.

Currently, FSIS requires all ingredients to be declared by their common or usual name in descending order. The agency supports the voluntary use of allergen statements (e.g. contains) and evaluates “may contain” type statements on a case-by-case basis.

Labeling errors such as undeclared allergens can be a costly error for food companies, but a FSIS Federal Register notice (14 Feb 2017) indicated the problem is “often preventable”.   Within the notice, the agency suggested the majority of recalls due to undeclared allergens could be attributed to “incorrect labeling or packaging of products, due to unexpected product and ingredient changes, cross-contamination of product during processing, and other types of procedural and human error.”
Due to a sustained increase in recalls due to undeclared allergens, the agency has responded in recent years with analysis, policy documents and verification activities to clarify the industry requirements and responsibilities. In November 2015, the agency issued compliance guidelines.

Source: USDA FSIS