> My understanding is that the recent law does not allow for compliance by simply labeling possible contaminants. If the recipe does not intentionally include seseme, the product must not list seseme as an ingredient
My mistake. Since 2004, Major food allergens have come with a requirement that manufacturers take steps to avoid cross contamination. The addition of sesame to the list requires it to be treated in the same way.
> and must not contain any seseme.
The manufacturer must follow "current good manufacturing practices (cGMPs)"[0] as described by the FDA. These should already be in place to prevent cross contamination of the existing major allergens.
> So, the insurmountable task is either maintaining completely seseme free manufacturing lines, or cleaning manufacturing lines between recipes to the point of guaranteeing no seseme cross-contamination.
The insurmountable task is to do the same thing they're already required to do to make sure enriched breads, containing milk and eggs, were not cross contaminating merely leavened products or to make sure that wheat flour doesn't contaminate non-wheat products.
> Does it really follow that executives should be jailed for adding seseme to their company recipes?
Yes. Any executive that added sesame to their product in response to this law should be in jail. I'm tired of executives facing no consequences when they intentionally cause harm in their pursuit of profit.
> I imagine many of the companies that made this change were previously voluntarily listing seseme as a possible contaminant, but had to stop because of the law.
Presumably part of the reason sesame was added as a major allergen was because companies weren't doing a great job disclosing it as an ingredient.
[0] https://www.fda.gov/media/80337/download
