FDA has historically taken the position that highly refined peanut oil — produced through full refining, bleaching, and deodorization — has peanut protein removed to levels not detectable by standard immunoassay methods and is therefore exempt from major food allergen labeling under FALCPA. However, cold-pressed, expeller-pressed, or extruded peanut oils retain protein and are not exempt. Importers and food manufacturers should obtain supplier documentation confirming the refining process and consult FDA guidance or legal counsel before making allergen-labeling decisions.

Fractionation of refined peanut oil yields a liquid olein fraction with a low cloud point suitable for salad dressings and cold applications, and a solid stearin fraction used in confectionery fats and shortenings. Both fractions remain classified in the same heading as the refined oil provided no chemical modification has occurred. Buyers should specify the fraction type, iodine value, and slip melting point in purchase contracts to ensure the product meets their formulation requirements.