From the Food Allergy Research and Resource Center (FARRP website link below),
The Food Allergen Labeling and Consumer Protection Act in the U.S. requires the labeling of soy lecithin when used in any capacity, including use as a processing aid.
But in the past, it was not as clear with regard to soy lecithin. More from FARRP:
Additionally, on February 25, 2013, the FDA withdrew its May 2, 2006 guidance entitled "Guidance on the Labeling of Certain Uses for Lecithin Derived from Soy Under Section 403(w) of the Federal Food, Drug, and Cosmetic Act" which originally indicated a willingness by FDA to use "regulatory discretion" in dealing with the labeling of soy lecithin in circumstances where soy lecithin is used as a stick-release or pan-release agent, a common processing aid use in the food industry. The FDA now requires source labeling of soy lecithin when used as a release agent applied directly to the food contact surfaces or as a direct ingredient in the product formulation, with the exception of the specificAnother thing that FARRP points out is that the level of allergen present on the product when used as a processing aid may be well below the limit that will cause anyone to have a reaction. However, there may be that one case.
It is important that food operations review their use of processing aids. If allergens are present such as soy lecithin, it needs to be included on the label.
USDA News Release
Pennsylvania Firm Expands Recalls Pretzel Dog Products Due To Misbranding and Undeclared Allergens
Class I Recall 079-2014-EXP Health Risk: High Nov 18, 2014