• Almond flour must comply with stringent U.S. regulations, including gluten-free claims (<20 ppm gluten) and allergen labeling for tree nuts, with the FDA emphasizing enforcement starting in 2025.
• Brands should leverage defatted almond flour's high protein content (44-56%) for compliant nutrient claims, while ensuring all claims meet FDA definitions to avoid misleading consumers.
• Lifestyle claims like "Keto-friendly" and "Paleo" are prevalent but must be carefully vetted to avoid implications of nutrient content that do not align with product profiles.
• Maintaining rigorous documentation and allergen management practices is critical to mitigate recall risks and ensure compliance during FDA inspections, which are expected to intensify in 2025.

Labeling & Claims

Almond Flour Labeling & Claims: A 2025 Compliance and Market Claims Playbook

Product: Almond Flour
Section: Regulatory & Compliance

Executive summary

Almond flour is one of the most active “form factors” in the bakery and snack space, prized for being inherently gluten-free and nutrient dense. From a labeling perspective, almond flour sits at the intersection of three regulatory focal points in the United States: (1) gluten-free claims under 21 CFR 101.91, (2) major allergen labeling (tree nuts), and (3) guardrails on nutrient content, health, and descriptive claims under 21 CFR Part 101. In 2025, FDA sharpened its enforcement lens on gluten-free claims and modernized label compliance review, which raises the stakes for “truthful, not misleading, and compliant” label copy. My considered view is that almond flour brands are well-positioned to lead in clean, compliant “gluten-free” labeling with robust documentation, while selectively leveraging substantiated nutrition-forward positioning (especially for defatted almond flour) and avoiding overreach on health or undefined lifestyle claims. A disciplined approach to allergen management and claim substantiation is the single greatest risk reducer for this category in 2025. (21 CFR Part 101, 2025; Sanzo et al., 2025)

1) What almond flour is—and why the form matters

Commercial “almond flour” is milled almond kernel; “almond meal” is typically coarser; and “defatted almond flour/protein powder” is finely ground material derived after partial oil removal. These forms behave differently in formulas and support different claim strategies due to their nutrient profiles. Industry resources define the forms as follows: almond flour (finer, often blanched), almond meal (coarser, often natural with skins), and defatted almond flour/protein powder (extra-fine, lower fat, higher protein) (Almond Board of California, 2025; American Society of Baking, n.d.).

Peer-reviewed data show that partially defatted almond flour obtained from oil pressing can deliver very high protein levels, especially with screw-press extraction, with implications for potential protein-related nutrient content claims (subject to 21 CFR 101.54) (Influence of Pressure Extraction Systems…, 2021).

Table 1. Proximate composition of defatted almond flour from pressing cake (best-rated conditions)

These defatted flours are especially rich in protein (44–56%) and fiber, and they remain energy-dense ingredients. Notably, residual fat is substantially lower in screw-pressed flour, which reduces calories and can open different claim pathways versus hydraulic-pressed flour that retains more fat (Influence of Pressure Extraction Systems…, 2021).

Almond ingredients may also deliver polyphenols and prebiotic effects (notably via skins), which underpins the category’s use in “functional” concepts, though such effects should not be converted into unauthorized health claims without FDA authorization or qualified claim status (Almond By-Products: Valorization…, 2021).

2) The U.S. regulatory frame that governs almond flour labels

• Core framework. Food labeling in the U.S. is governed by 21 CFR Part 101, covering general principles for nutrient content claims (e.g., “good source,” “high,” “reduced”), health claims, descriptive claims, exemptions, and the structure and content of the Nutrition Facts Panel. Any explicit or implied nutrient content claim must meet the definitions and conditions in Part 101 and related sections; health claims must be specifically authorized and meet general and specific conditions of use (21 CFR Part 101, 2025).

• Gluten-free rule (21 CFR 101.91). A food may be labeled “gluten-free” if it inherently does not contain gluten and any unavoidable gluten is <20 ppm, among other criteria. FDA assesses compliance using scientifically valid analytical methods capable of detecting and quantifying 20 ppm gluten across matrices, including baked foods. Special labeling is required if “wheat” appears in the ingredients yet has been processed to remove gluten; the ingredients list or “Contains wheat” statement must immediately be followed by an asterisk leading to: “The wheat has been processed to allow this food to meet the Food and Drug Administration (FDA) requirements for gluten-free foods.” (21 CFR 101.91, 2025).

• Enforcement posture (2025). FDA updated its General Food Labeling Requirements compliance program in June 2025, explicitly adding verification of gluten-free labeling regulations to inspection priorities and emphasizing immediate enforceability (no general grace period). Manufacturers should be prepared to substantiate “gluten-free” claims and demonstrate label compliance at import and domestically (Sanzo et al., 2025).

• “Healthy” claim modernization. FDA’s final “healthy” rule tightened alignment with Dietary Guidelines and declined to allow “healthy” eligibility solely based on “nutrients to encourage” (e.g., fiber, protein) or based on a food group equivalent being the first ingredient. It also made targeted flexibilities (e.g., small RACC foods) but overall narrows pathways for “healthy” claims on many formulations absent broader nutrient profile alignment, which may constrain “healthy” usage on almond-flour products unless criteria are met (Hogan Lovells, n.d.).

• Allergens. Under U.S. law, major allergens (including tree nuts) must be declared either in the ingredients list using the common or usual name or in a “Contains” statement. The 2023 addition of sesame as the ninth major allergen—and FDA’s 2025 inspection emphasis—reinforces the scrutiny on proper allergen declaration formatting and placement. Almond flour products must clearly declare almond as a tree nut allergen (Sanzo et al., 2025).

3) Gluten-free claims for almond flour and almond-flour foods

Single-ingredient almond flour is inherently gluten-free and generally eligible for a “gluten-free” claim provided cross-contact is controlled and any unavoidable gluten remains below 20 ppm. For multi-ingredient products, none of the ingredients may be a gluten-containing grain or derivative not processed to remove gluten, and the finished product must meet the <20 ppm threshold. For wheat starch-like ingredients processed to remove gluten, the mandatory “wheat has been processed…” asterisked statement applies if “wheat” is in the ingredients or a Contains statement appears (21 CFR 101.91, 2025).

FDA’s 2025 compliance program signals active verification of these criteria. While the rule does not mandate manufacturers to conduct particular testing, firms must ensure claims are truthful and not misleading; keeping method validation data, supplier attestations, and production records that control cross-contact is therefore prudent. Third-party gluten-free certifications (e.g., those that certify to 10 ppm) are optional but can strengthen consumer trust and demonstrate programmatic rigor, even though FDA’s legal threshold remains 20 ppm. Note that products produced in facilities handling gluten can still be labeled gluten-free if they meet the rule’s criteria—precautionary allergen statements (“made in a facility with…”) are voluntary and do not substitute for compliance with the <20 ppm threshold (21 CFR 101.91, 2025; gfJules, n.d.).

Table 2. Gluten-free labeling essentials (21 CFR 101.91)

Sources: 21 CFR 101.91; FDA compliance program update 2025 (21 CFR 101.91, 2025; Sanzo et al., 2025).

For consumer-facing education and internal alignment, FDA-aligned educational materials from reputable celiac organizations can help teams interpret the rule consistently (e.g., “inherently gluten-free” foods may bear the claim; oats can be labeled gluten-free when they meet criteria) (Celiac Disease Foundation, n.d.).

4) Other on-pack claims commonly seen on almond flour

• Lifestyle descriptors. “Keto-friendly,” “Paleo,” “Vegan,” and “Dairy-free” are prevalent on almond flour packs. These claims are not defined by FDA in the same way as nutrient content claims; however, they can be considered implied nutrient content or otherwise misleading if they suggest nutrient profiles that the product does not meet. Manufacturers should review these with legal/regulatory counsel; the Almond Board’s technical materials likewise advise vetting all claims with counsel (Almond Board of California, 2025; 21 CFR Part 101, 2025).

• Nutrient content claims. Phrases like “good source of protein” or “high in fiber” must meet 21 CFR definitions and be substantiated with Nutrition Facts data and applicable DVs; claims must follow 21 CFR 101.13 general principles and 21 CFR 101.54 specifics. Use of defatted almond flour (44–56% protein) can facilitate compliant protein claims, subject to all calculation and declaration rules (21 CFR Part 101, 2025; Influence of Pressure Extraction Systems…, 2021).

• Health claims. “Healthy” is tightly regulated under the new rule; other health claims (e.g., CHD, fiber-related) must conform to authorized claim language and conditions. Absent specific authorization, health claims are prohibited (21 CFR Part 101, 2025; Hogan Lovells, n.d.).

• Third-party certifications. Non-GMO Project Verified and various gluten-free certifications appear on almond flour products. These are voluntary and independent of FDA requirements; they may include lower gluten thresholds (e.g., 10 ppm) and encompass audits, testing, and cross-contact controls. Such certifications can support consumer trust and internal diligence, though they are not a substitute for FDA compliance (gfJules, n.d.).

Table 3. Common almond flour claims and their regulatory status

Sources: 21 CFR Part 101; 21 CFR 101.91; Hogan Lovells (healthy); Almond Board technical takeaways; gfJules (certification programs) (21 CFR Part 101, 2025; 21 CFR 101.91, 2025; Hogan Lovells, n.d.; Almond Board of California, 2025; gfJules, n.d.).

5) Nutrition positioning: how almond flour compares

Relative to common gluten-free flours and starches, almond flour is nutrient-dense—especially on protein, fiber, iron, and calcium per cup—supporting responsible nutrition-forward positioning (again, within the bounds of 21 CFR). Industry data below (Almond Board) illustrate how blanched and natural almond flour compare with other typical gluten-free ingredients. These data support strategy—not direct label copy—and should be reconciled with final product Nutrition Facts when making any claims.

Table 4. Nutrient comparison per cup (industry data)

Source: Almond Board of California “Almond Flour Power” (chart excerpt attribution noted in the document) (Almond Board of California, n.d.).

Defatted almond flour can materially increase protein per serving and reduce fat, potentially enabling compliant protein claims in finished foods when DVs are met and the label is constructed per regulation. However, protein claims also implicate protein quality and calculation rules; coordinate claims with regulatory specialists and verify Nutrition Facts panel accuracy (Influence of Pressure Extraction Systems…, 2021; 21 CFR Part 101, 2025).

6) Safety and allergen management: impacts on labeling

• Allergen controls. Almonds are a major food allergen. Facilities must implement allergen management and sanitation to prevent cross-contact and label accurately; mislabeling allergens is a leading cause of recalls. Almond flour labels must declare almond (tree nut) appropriately, either within the ingredients or via a “Contains” statement (American Society of Baking, n.d.; Sanzo et al., 2025).

• Aflatoxin vigilance. Almonds can be vulnerable to aflatoxin contamination from Aspergillus species. The U.S. limit for aflatoxin in foods is 20 ppb, while EU limits for ready-to-eat almonds are stricter (10 ppb total, 8 ppb B1). Ingredient specifications and supplier controls should reflect these thresholds; although not a label claim per se, safety compliance underpins truthful labeling and market access (American Society of Baking, n.d.).

7) Market snapshot: a label example

Blue Diamond’s Finely Sifted Almond Flour (SmartLabel) illustrates typical contemporary claims: “Gluten Free,” “Keto Friendly,” “Non-GMO Project Verified,” “Vegan,” “Peanuts Free,” and “Made with 100% California Almonds.” These claims combine regulated (gluten-free), third-party certification (Non-GMO), and lifestyle designations. This mix underscores the need to segregate strictly regulated claims from marketing descriptors, ensuring each is substantiated and not misleading on the total label impression (Blue Diamond Growers, 2019).

8) Practical recommendations (opinion)

Given the 2025 enforcement climate and the category’s strengths, I recommend almond flour brands and private-label buyers adopt the following program:

1. Anchor on impeccable gluten-free compliance, even when not strictly required to test.

   • Implement a written program that includes supplier attestations, validated analytical testing for high-risk SKUs or matrix/formulations, and robust cross-contact controls.
   • Retain documentation to support claims during FDA inspections or at the border.
   • Consider third-party gluten-free certification (<10 ppm) for consumer trust and trade compliance signaling, especially for export, while recognizing FDA’s regulatory threshold remains <20 ppm (21 CFR 101.91, 2025; Sanzo et al., 2025; gfJules, n.d.).

2. Treat allergen management as non-negotiable.

   • Always declare “almond” as a major allergen using compliant formatting.
   • If multi-nut facilities are involved, ensure shared-equipment claims are accurate and not used as substitutes for controls. This is the single largest recall risk in the category and the most visible compliance obligation on pack (Sanzo et al., 2025; American Society of Baking, n.d.).

3. Use defatted almond flour strategically to enable compliant nutrient content claims.

   • Where brand strategy calls for “good source of protein” or “high in protein/fiber” claims, defatted flour’s 44–56% protein enables efficient claim substantiation—so long as final Nutrition Facts meets thresholds and all calculation rules are followed (including protein quality rules where applicable).
   • Avoid implying a “healthy” halo unless the full criteria are met (Influence of Pressure Extraction Systems…, 2021; 21 CFR Part 101, 2025; Hogan Lovells, n.d.).

4. Be conservative with lifestyle claims; verify they are not implied nutrient content claims.

   • “Keto-friendly,” “Paleo,” “Clean label,” and similar statements should be subjected to internal standards, documented substantiation, and legal review.
   • Avoid conflating voluntary third-party seals with regulatory compliance; ensure seal-use guidelines are followed and current (Almond Board of California, 2025; 21 CFR Part 101, 2025).

5. Maintain Nutrition Facts accuracy and claim consistency across all panels.

   • If using ingredient forms (blanched vs natural vs defatted), monitor variability (e.g., residual oil affecting calories).
   • Align product development, QA, and regulatory teams so that serving sizes, DVs, and claims remain synchronized after any reformulation (21 CFR Part 101, 2025).

6. Build for audits.

   • FDA’s 2025 program update means labels are more likely to be sampled and claims scrutinized—including at import.
   • Keep a “labeling technical file” per SKU with legal labels, proofs of claims, certificates, test data, and change logs. In my view, this documentation discipline is the lowest-cost, highest-impact insurance policy for almond flour brands in 2025 (Sanzo et al., 2025).

Conclusion

Almond flour’s natural alignment with “gluten-free,” protein and fiber-forward nutrition, and clean ingredient decks gives it a durable advantage—if labels are built on regulatory bedrock. In 2025, the winning posture is cautious confidence: assert the gluten-free identity with documented controls; declare allergens flawlessly; unlock nutrient content claims where the data and DVs truly support them (especially using defatted flour); and treat lifestyle descriptors as carefully substantiated marketing, not regulatory shields. This is the surest route to compliant growth in the U.S. market for almond flour and the many products it enables.

References

• 21 CFR Part 101 - Food Labeling. (2025). U.S. Food & Drug Administration. https://www.ecfr.gov/current/title-21/chapter-I/subchapter-B/part-101

• 21 CFR 101.91 - Gluten-free labeling of food. (2025). U.S. Food & Drug Administration. https://www.ecfr.gov/current/title-21/chapter-I/subchapter-B/part-101/subpart-F/section-101.91

• Almond Board of California. (2023, April). Almond Forms Fueling Product Innovation. https://www.almonds.org/sites/default/files/2023-04/Almond_Forms_Fueling_Product_Innovation.pdf

• Almond Board of California. (2025, February). Almond Flour Technical Takeaways. https://www.almonds.com/sites/default/files/2025-02/Almond_Flour_Technical_Takeaways.pdf

• Almond Board of California. (n.d.). Almond Flour Power. https://www.almonds.org/sites/default/files/almond_flour_power%5B1%5D.pdf

• American Society of Baking. (n.d.). Almond Flour | American Society of Baking. https://asbe.org/article/almond-flour/

• Blue Diamond Growers. (2019, August 29). SmartLabel - Finely Sifted Almond Flour - 041570142967. https://smartlabel.labelinsight.com/product/5879082/other/claims

• Celiac Disease Foundation. (n.d.). Label Reading & the FDA. https://celiac.org/gluten-free-living/gluten-free-foods/label-reading-the-fda/

• gfJules. (n.d.). Shopping for Safe Gluten Free Products – How to Read Food Labels. https://gfjules.com/shopping-for-safe-gluten-free-products/

• Hogan Lovells. (n.d.). FDA Issues Final “Healthy” Rule. https://www.hoganlovells.com/en/publications/fda-issues-final-%E2%80%9Chealthy%E2%80%9D-rule

• Influence of Pressure Extraction Systems on the Performance, Quality and Composition of Virgin Almond Oil and Defatted Flours. (2021). Foods (Basel), via PubMed Central. https://pmc.ncbi.nlm.nih.gov/articles/PMC8151718/

• Almond By-Products: Valorization for Sustainability and Competitiveness of the Industry. (2021). Foods (Basel), via PubMed Central. https://pmc.ncbi.nlm.nih.gov/articles/PMC8394390/

• Sanzo, K. M., Corrado, F. A., & Silva, A. (2025, July 7). FDA Updates Food Labeling Compliance Program: What It Means for Food Manufacturers. Morgan, Lewis & Bockius LLP. https://www.morganlewis.com/blogs/welldone/2025/07/fda-updates-food-labeling-compliance-program-what-it-means-for-food-manufacturers

URLs (for quick access)

• https://www.ecfr.gov/current/title-21/chapter-I/subchapter-B/part-101
• https://www.ecfr.gov/current/title-21/chapter-I/subchapter-B/part-101/subpart-F/section-101.91
• https://www.almonds.org/sites/default/files/2023-04/Almond_Forms_Fueling_Product_Innovation.pdf
• https://www.almonds.com/sites/default/files/2025-02/Almond_Flour_Technical_Takeaways.pdf
• https://www.almonds.org/sites/default/files/almond_flour_power%5B1%5D.pdf
• https://asbe.org/article/almond-flour/
• https://smartlabel.labelinsight.com/product/5879082/other/claims
• https://celiac.org/gluten-free-living/gluten-free-foods/label-reading-the-fda/
• https://gfjules.com/shopping-for-safe-gluten-free-products/
• https://www.hoganlovells.com/en/publications/fda-issues-final-%E2%80%9Chealthy%E2%80%9D-rule
• https://pmc.ncbi.nlm.nih.gov/articles/PMC8151718/
• https://pmc.ncbi.nlm.nih.gov/articles/PMC8394390/
• https://www.morganlewis.com/blogs/welldone/2025/07/fda-updates-food-labeling-compliance-program-what-it-means-for-food-manufacturers

Frequently Asked Questions

What are the key regulatory requirements for labeling almond flour?

Almond flour labeling must comply with 21 CFR Part 101, which includes guidelines for nutrient content claims, health claims, and allergen declarations. Specifically, almond flour can be labeled "gluten-free" if it contains less than 20 ppm of gluten and must declare almond as a major allergen.

How does the FDA's 2025 compliance program affect almond flour labeling?

The FDA's 2025 compliance program emphasizes strict verification of gluten-free labeling and allergen management. Manufacturers must be prepared to substantiate their claims with documentation and may face inspections focused on compliance, as there is no grace period for violations.

What are the implications of gluten-free claims for almond flour products?

Single-ingredient almond flour is inherently gluten-free and can bear the claim if cross-contact is controlled. Multi-ingredient products must ensure that none of the ingredients contain gluten and that the final product meets the <20 ppm gluten threshold.

How should allergen labeling be handled for almond flour?

Almond flour labels must clearly declare almond as a tree nut allergen either in the ingredient list or via a "Contains" statement. This is crucial for compliance, as mislabeling allergens is a leading cause of product recalls.

Can almond flour make health claims on its packaging?

Health claims on almond flour must be authorized by the FDA and meet specific criteria. The new "healthy" rule restricts claims unless the product aligns with broader nutrient profile guidelines, making it essential to ensure compliance before making such claims.

What lifestyle claims can be made on almond flour products?

Lifestyle claims like "Keto-friendly" or "Paleo" are not defined by the FDA and can be misleading if they imply nutrient profiles that the product does not meet. Manufacturers should vet these claims with legal counsel to ensure they do not mislead consumers.

How can manufacturers substantiate nutrient content claims for almond flour?

Nutrient content claims such as "good source of protein" must comply with 21 CFR definitions and be substantiated with accurate Nutrition Facts data. Using defatted almond flour, which contains 44-56% protein, can facilitate compliant claims, provided all regulatory requirements are met.