Yes, and peanut oil and soy oil aren't considered part of the top-8 allergens, so they could be substituted in without warning. However, blatant addition of top-8 allergens must be identified on the label, even under these new rules.
What concerns me most are people with allergens outside the top-8 that don't have to be declared in the first place, and so calling companies is the only way to verify ingredients, but all that research is now lost and they have to call each and every company again to verify each and every time, with lot numbers. Many companies trusted by allergy families, like 88 Acres and Enjoy Life, are publicly declaring their labels will always be clear and always accurate, with no substitutions, despite FDA rules.
Then, how long will these substitutions be in place for, and how long will they sit in warehouses before they reach store shelves. Will this be revised again after the pandemic. Many, many questions. It's a good reason to sick to basic whole foods and make everything from scratch, which is typically healthier anyway.
It's definitely concerning.