Is it necessary to declare ingredients in “trace”, i.e., incidental amounts? Can sulfites be considered incidental additives?
Answer: FDA does not define “trace amounts”; however, there are some exemptions for declaring ingredients present in “incidental” amounts in a finished food. If an ingredient is present at an incidental level and has no functional or technical effect in the finished product, then it need not be declared on the label. An incidental additive is usually present because it is an ingredient of another ingredient. Note that major food allergens (as discussed under Food Allergen Labeling), regardless of whether they are present in the food in trace amounts, must be declared.
might be a better answer! XP