Requiring the extra labeling even when it seems redundant increases clarity for consumers and simplifies the rules. It's fine. At least, I doubt that you can w

Requiring the extra labeling even when it seems redundant increases clarity for consumers and simplifies the rules. It's fine. At least, I doubt that you can write a set of rules for declaring allergens that is shorter if you do include exceptions to the labeling requirements. And I think there's a pretty strong argument that treating the ingredients and allergens as separate sections makes the allergens easier to interpret than sometimes requiring reading both.