Clear, accurate, and complete food allergen information is critical for protecting the health of highly vulnerable consumers. Nevertheless, these consumers continue to find current labeling practices confusing and uninformative, especially the use of advisory labels. At the same time, manufacturers are equally confused about when and how to use advisory labels. Government organizations such as FAO and FDA are trying to address this issue but are limited to providing general advice tied to the legislative authorities they have been given. Often overlooked in the discussion is the expectation that effective allergen controls must be in place before considering the need for advisory labels. In other words, food manufacturers are responsible for ensuring that their facility's allergen-related GMPs and cross-contact controls are as effective as possible. The facility PCQI must “provide a written justification, in your food safety plan, for why allergen cross-contact controls cannot ensure protection of food from allergen cross-contact.” This presentation will describe the data needed to support such a written justification and practical strategies to generate these data. The role of testing, the need to validate testing, and the advantage of having external support for the justification will be discussed.