We have one enrobing machine that we currently enrobe our bonbons and no other product. We'd like to use it to enrobe a number of our confection bars, several of which contain either tree nuts or peanuts. Based on a recent inspection by the FDA, in order to decrease the chance of cross contamination, they stated the order of production for the day should be no-nut product, then tree nut products, and then peanut based products at the end of the day. Typically if we worked with a small machine (5-10lbs), we save the chocolate at the end of the day and reuse it for the peanut based products only.
We label as per regulations of the FDA with "Contains:" and list the specific ingredients (i.e. pecans, coconut, etc.) in that particular product. We also have the "May contains: Traces of ..." on all of our labels.
I had hoped that we could use the enrober (25kg capacity) for both our bonbon and bars, but now am wondering how to do this as we're not going to be emptying our bowl of that much chocolate once we run bars containing nuts through it. If we don't then would we have to state that all of our products "Contains: traces of specific tree nuts, peanuts..." as the phrase "May contains:" is a bit more ambiguous?
What do other people do in this situation? Also, with enrobing our bars, occasionally small bits might fall into the chocolate which with our small machines, we'll strain the chocolate afterwards to remove them. What do you do if it falls into the bowl of the enrobing machine?
Given the legislation and severity of getting it wrong (from the standpoint of impact to potential consumers), i'd go with the most overt labeling route possible. I'd also suggest you have the discussion with your FDA inspector to ensure you're up to speed with the latest information.
FYI, there's a great deal of talk at the FDA around elimination of the 'may contain' type statements - the argument being that either a product does contain something, or it doesn't.