Food allergies and food intolerance are growing health and safety concerns all over the world. According to the Australasian Society of Clinical Immunology and Allergy (ASCIA), an estimated 10% of infants, 4-8% of children, and about 2% of adults in Australia and New Zealand suffer from food allergies. This translates to millions of people who are at risk of severe allergic reactions due to food consumption.
To ensure the safety of consumers, the authorities in Australia and New Zealand have put forward specific rules about allergen labelling compliance that food manufacturers and packers must follow.
In this article, we’ll provide you with an overview of what food allergens are, the importance of allergen labelling compliance, and how to ensure your products are fully compliant with allergen labelling laws in both countries. We will also discuss the new Plain English Allergen Labelling (PEAL) rules and provide some key points for managing allergens.
So without further ado, let’s dive right in and learn all about allergen labelling compliance.
Food allergens are proteins that cause the body’s immune system to overreact. This reaction can range from mild rashes to life-threatening anaphylaxis.
Any edible substance, including herbal medicines, can cause an allergic reaction. The most common allergens are peanuts, tree nuts, cow’s milk, eggs, fish, shellfish, soy, sesame and wheat.
Food allergen declarations are important for several reasons.
First, it helps consumers identify potential allergens in the foods they purchase and make informed choices about the food they consume.
Second, it serves as a warning for people with severe food allergies. With proper allergen labelling on food products, individuals can easily identify the presence of allergens and take the necessary steps to avoid them.
Finally, it is a legal requirement that ensures food packaging complies with local laws and regulations. Food companies can avoid potential legal repercussions, product recalls, and other associated costs by complying with allergen labelling rules.
Food allergens must be declared if used as an ingredient, additive, or processing aid, even if the amount is minuscule. Compound ingredients, like sauces or dried fruit, must also specify any allergens contained within.
However, there are some exemptions regarding the amount of food allergens that need to be declared. For example, if a food product has added sulphites in concentrations of less than 10 mg/kg, then the allergen does not have to be declared.
In order to ensure food allergy labelling compliance, food manufacturers and packers must follow the basic rules and requirements set out by the authorities in Australia and New Zealand.
These rules and requirements mandate the presence of three main statements on a food label. The three main statements are.
The allergen declaration statement is a list of common allergens or ingredients sourced from it present in the food product or drink. The statement should use the standard names for each allergen identified by Food Standards Australia New Zealand (FSANZ).
The allergen declaration must appear in the ingredient list and include all allergens in a food product. This includes any components that are added during processing, like wheat flour or ingredients used to flavour a product.
The following allergens are mandatory to be listed in the ingredient list.
The rules for declaring allergens are discussed in the next section of the article.
The warning statement is a mandatory precautionary declaration that warns consumers about the potential risks of consuming food products containing allergens. The warning statement should be written in the exact wording as defined in Standard 1.2.3.
The warning statement also has a specific rule for type size to ensure that the statement is easily visible and legible for consumers.
If the package has a net weight of 500 g or less, the required warning statement must be in a minimum type size of 1.5 mm.
If the package has a net weight of more than 500 g, the required warning statement must be in a minimum type size of 3 mm.
The table below lists the foods and the written warning statement that must accompany them.
Food | Usage | Reference in Code | Wording of Mandatory Warning Statement |
|---|---|---|---|
Royal jelly
| When presented as a food, or as an ingredient
| Standard 1.2.3 – Mandatory Warning and Advisory Statements and Declarations, Clause 3
| ‘This product contains royal jelly which has been reported to cause severe allergic reactions and in rare cases, fatalities, especially in asthma and allergy sufferers.’
|
Kava | When presented as a food, or as an ingredient
| Standard 2.6.3 – Kava, Clause 3 | ‘Use in moderation.’
‘May cause drowsiness.’
|
Infant formula products
| For the label on a package of infant formula product in powdered form.
For the label on a package of concentrated infant formula product
| Standard 2.9.1 – Infant Formula Products, Subclause 14(1) | ‘Warning – follow instructions exactly. Prepare bottles and teats as directed. Do not change proportions of powder except on medical advice. Incorrect preparation can make your baby very ill.’
|
Infant formula products
| For the label on a package of ‘ready to drink’ infant formula product
| Standard 2.9.1 – Infant Formula Products, Subclause 14(1) | ‘Warning – follow instructions exactly. Prepare bottles and teats as directed. Do not dilute or add anything to this ‘ready to drink’ formula except on medical advice. Incorrect preparation can make your baby very ill.’ |
Infant formula products
| For the label on a package of all infant formula product except infant formula products for metabolic, immunological, renal, hepatic or malabsorptive conditions
| Standard 2.9.1 – Infant Formula Products, Subclause 14(3) | ‘Breast milk is best for babies. Before you decide to use this product, consult your doctor or health worker for advice.’
This statement must be under a heading that states ‘Important notice’ or any word or words having the same or similar effect.
|
Infant formula products
| For the label on a package of pre-term formula
| Standard 2.9.1 – Infant Formula Products, Subclause 26(1)
| ‘Suitable only for pre-term infants under specialist medical supervision.’
|
Infant foods
| For the label on a package of infant foods, where the food is recommended for infants between the ages of 4–6 months
| Standard 2.9.2 – Foods for Infants, Subparagraph 5(3)(c) | ‘Not recommended for infants under the age of 4 months.’ |
Infant foods
| For the label on a package of infant foods, where a food for infants contains more than 3 g/100 kJ protein
| Standard 2.9.2 – Foods for Infants, Subclause 6(2)
| ‘Not suitable for infants under the age of 6 months.’ |
Formulated supplementary sports foods
| For the label on a package of formulated supplementary sports food
| Standard 2.9.4 – Formulated Supplementary Sports Foods, Subclause 3(3)
| ‘Not suitable for children under 15 years of age or pregnant women: Should only be used under medical or dietetic supervision.’ |
Formulated supplementary sports foods
| If a formulated supplementary sports food contains added phenylalanine
| Standard 2.9.4 – Formulated Supplementary Sports Foods, Subclause 3(4)
| ‘Phenylketonurics: Contains Phenylalanine’.
|
The advisory statement is also a precautionary declaration providing additional information about allergens in a food product. It is a mandatory requirement for certain foods under clause 2 of Standard 1.2.3.
The advisory statement can be written in own words as long as they convey the intended effect clearly. There are no specific font style and size requirements for the advisory statement. However, Clause 2 of Standard 1.2.9 mandates that the advisory statement on the label should be written in English language and should be clear, prominent, and with adequate contrast to the background.
Food items that are exempted from bearing a label must also have advisory statements. These statements follow specific rules, such as.
The following table lists the foods and the advisory statements.
Food | Advisory Statement |
|---|---|
Bee pollen presented as a food, or a food containing bee pollen as an ingredient as defined in Standard 1.2.4
| Statement to the effect that the product contains bee pollen which can cause severe allergic reactions
|
Cereal-based beverages, where these foods contain no more than 2.5% m/m fat and less than 3% m/m protein, or less than 3% m/m protein only.
| Statement to the effect that the product is not suitable as a complete milk replacement for children under the age of five years.
|
Evaporated and dried products made from cereals, where these foods contain no more than 2.5% m/m fat and less than 3% m/m protein, or less than 3% m/m protein only, as reconstituted according to directions for direct consumption.
| Statement to the effect that the product is not suitable as a complete milk replacement for children under the age of five years.
|
Evaporated milks, dried milks and equivalent products made from soy or cereals, where these foods contain no more than 2.5% m/m fat as reconstituted according to directions for direct consumption.
| Statement to the effect that the product is not suitable as a complete milk food for children under the age of two years.
|
Food containing aspartame or aspartame-acesulphame salt
| Statement to the effect that the product contains phenylalanine
|
Food containing quinine
| Statement to the effect that the product contains quinine
|
Food containing guarana or extracts of guarana
| Statement to the effect that the product contains caffeine
|
Foods containing added phytosterols, phytostanols or their esters
| Statements to the effect that –
1. When consuming this product, it should be consumed as part of a healthy diet.
2. This product may not be suitable for children under the age of five years and pregnant or lactating women.
3. Plant sterols do not provide additional benefits when consumed in excess of three grams per day.
|
Foods containing polyols and poly dextrose
| Statement that excess consumption of the food may have a laxative effect
|
Formulated caffeinated beverages
| Statements to the effect that:
1. The food contains caffeine.
2. The food is not recommended for children, pregnant or lactating women and individuals sensitive to caffeine.
Statement on consumption level – consume no more than [amount of one-day quantity (as cans, bottles or mL)] per day
|
Kola beverages containing added caffeine, or food containing a kola beverage containing added caffeine as an ingredient as defined in Standard 1.2.4.
| Statement to the effect that the product contains caffeine
|
Milk, and beverages made from soy or cereals, where these foods contain no more than 2.5% m/m fat.
| Statement to the effect that the product is not suitable as a complete milk food for children under the age of two years
|
Propolis presented as a food, or food containing propolis as an ingredient as defined in Standard 1.2.4.
| Statement to the effect that the product contains propolis which can cause severe allergic reactions
|
Unpasteurised egg products
| Statement to the effect that the product is unpasteurised
|
Unpasteurised milk and unpasteurised liquid milk products
| Statement to the effect that the product has not been pasteurised
|
On 25 February 2021, Food Standards Australia New Zealand (FSANZ) introduced new rules about labelling and identifying allergens, called New Plain English Allergen Labelling (PEAL). These rules focus on simplifying the information presented on food labels to help consumers with allergies make informed and safe choices.
Under the new PEAL rules, manufacturers and packers are obligated to adhere to the following guidelines.
FSANZ has created a five-year implementation plan beginning on 25 February 2021 to ensure that businesses can adhere to these new requirements. During this transition period, businesses can choose to follow either the existing allergen labelling rules or the new PEAL rules.
However, by 25 February 2024, labels must be updated to meet new rules, and staff must be trained to ensure that the food label information meets the PEAL rules. Under the existing rules, any food packaged and labelled before this date can be sold for an additional two years.
25 February 2026 marks the end of the transition period. After this date, all food and drink products in Australia and New Zealand must comply with the PEAL rules.
Food Standards Australia New Zealand provides a list of the most common allergens that must be declared on food labels. The allergen must be declared on the label if it is an ingredient, part of a compound ingredient, a food additive, or is used as a processing aid.
These allergens are present in Schedule 9 of the Food Standards Code and are listed in the table below.
Food | Exception | Required Name for Declarations in a Statement of Ingredients | Required Name for Other Declarations |
|---|---|---|---|
Added sulphites in concentrations of 10 mg/kg or more
| Sulphites | Sulphites | |
Any of the following cereals (including hybridised strains thereof) if they contain gluten:
Barley,
Oats,
Rye,
Wheat (including its hybridised strain) irrespective of whether it contains gluten
|
The cereal or its hybridised strain that is present in beer or spirits
A. The wheat or its hybridised strain that is present in beer or spirits;
B. Glucose syrups made from wheat starch and that:
a. Have been subject to a refining process that has removed gluten protein content to the lowest level that is reasonably achievable; and
b. Have a gluten protein content that does not exceed 20 mg/kg;
C. Alcohol distilled from wheat.
|
Barley,
Oats,
Rye,
Wheat
|
Gluten
A. Wheat.
B. If gluten is present – gluten.
|
Almond | Almond | Almond | |
Brazil nut
|
Brazil nut
|
Brazil nut
| |
Cashew | Cashew | Cashew | |
Hazelnut | Hazelnut | Hazelnut | |
Macadamia | Macadamia | Macadamia | |
Pecan | Pecan | Pecan | |
Pine nut
|
Pine nut
|
Pine nut
| |
Pistachio | Pistachio | Pistachio | |
Walnut | Walnut | Walnut | |
Crustacea | Crustacea | Crustacea | |
Egg | Egg | Egg | |
Fish |
Isinglass derived from fish swim bladders and used as a clarifying agent in beer or wine
| Fish | Fish |
Lupin | Lupin | Lupin | |
Milk |
Alcohol distilled from whey
| Milk | Milk |
Mollusc | Mollusc | Mollusc | |
Peanut | Peanut | Peanut | |
Sesame seed
|
Sesame seed
|
Sesame seed
| |
Soybean |
A. Soybean oil that has been degummed, neutralised, bleached and deodorised.
B. Soybean derivatives that are tocopherol or phytosterol.
|
Soy, Soya or Soybean
| Soy |
Some food items are exempt from allergen labelling. For these items, the declaration of allergen presence is still required but with a particular format found as present in the table below.
Labelling Exemption | Required Allergen Information |
|---|---|
Food for retail sale not required to bear a label, such as:
Whole fruit and vegetables,
Takeaway food,
Food made and packaged on the premises from which is sold,
Food packaged in the presence of the purchaser
| Allergen information must be displayed in connection with the display of the food or provided to the purchaser on request.
|
Exempt from displaying a statement of ingredients on small packages, packaged water and alcoholic beverages
| Summary statement must list allergens
|
Individual portion packs not designed for individual sale
| Allergen information must be included on labels of individual portion packs
|
Food sold to caterers
| 1. Labelling containing allergen information must be provided to the caterer with the food.
2. Allergen information can be provided on inner packaging if the ingredients list is on the outer packaging or in documentation that accompanies the food.
3. Allergen information must be provided with any food not in a package, or packaged fruit and vegetables in clear packaging.
|
Here is a list of allergen names as required by Food Standards Australia New Zealand on food labels.
FSANZ has laid down several rules and guidelines to ensure that food and beverage businesses adhere to allergen labelling standards. These directives guarantee that consumers receive exact, comprehensive, and concise information regarding the presence of allergens in food products.
FSANZ general regulations regarding the inclusion of allergen information on food labels vary according to the type of label component. Depending on the label component, every allergen must be.
The allergen deceleration on packaging labels depends on the type of label required for the product. The type of labels are categorised into three categories.
For Products With a Label But Without Ingredients Lists | |
|---|---|
On the label (using the required allergen name)
| Yes |
In bold font
| Optional |
In the same font and size as in the ingredients list
| Not required
|
In a specific place
| Not required
|
Certain products are required to have labels but don’t require an ingredient list. These products include.
The products mentioned above don’t require an ingredient list but must display the allergen name on the label. There are no strict regulatory guidelines on displaying, positioning or formatting the allergen name on the label.
Label designers are free to create labels suitable to their product as long as the customer can easily read and discern the allergen information on the product label.
For Products With a Label and an Ingredients Lists | |
|---|---|
On the label (using the required allergen name)
| Yes |
Repeated for each ingredient that contains that allergen
| Yes |
In bold font
| Yes |
In the same font and size as in the ingredients list
| Yes |
In a specific place
| Yes |
Product labels that require an ingredients list must have allergens declared within the ingredients list.
The ingredients list, as the name suggests, is an area on the label where the food items’ ingredients are declared. On the ingredient list, users are required to.
Products with a label and an ingredient list can declare allergens in two ways.
Please note that certain ingredients may have allergens in their name (e.g. Oatmeal and Buttermilk), but it’s wrong to bold just a portion of the word. Correct formatting is to write them as follows: Buttermilk (milk); Oatmeal (oats).
For Products That Do Not Require a Label | |
|---|---|
On the label (using the required allergen name)
| Yes |
In bold font
| Not required
|
In the same font and size as in the ingredients list
| Not required
|
In a specific place
| Not required
|
Some products like food sold in cafes for immediate consumption delivered pizza, and pick-and-mix lollies in a shop do not require a label; however, the allergen declaration is still required.
For such products, customers must be informed about allergens present in the product via verbal communication (upon asking) or through an allergen display board at the point of sale.
“Contains” Statement | |
|---|---|
On the label (using the required allergen name)
| Yes |
In bold font
| Yes |
In the same font and size as in the ingredients list
| Yes |
In a specific place
| Yes |
Using no other words (e.g. ‘and’, ‘processing aid’)
| Yes |
The “Contains” statement is a new requirement on food labels. The “Contains” statement lists all allergens present in the food product in one place, making it easier for consumers to identify allergens they are allergic to.
FSANZ provides strict guidelines on how to format the “Contains” statement. These guidelines are.
The “free-from” statement is an optional labelling declaration. These statements help consumers know that a product is free of certain allergens or ingredients.
FSANZ permits using alternative words and similar expressions like “contains no nuts” instead of “free from.” However, it is important to ensure that these statements are true and not misleading. Proof to back the allergen-free claim must also be available.
Some food labels use ‘may contain’ or ‘may be present’ statements about specific allergens. These statements are used to inform customers if the product may potentially contain an allergen or ingredient due to shared manufacturing facilities, transportation, storage and handling.
‘May contain’ statements are not regulated by allergen rules and are voluntarily used by food businesses. Nevertheless, if a business does use them, it must ensure that the statements are easy to identify, read, and comprehend on the label.
‘May contain’ statements are also known as precautionary allergen labelling (PAL).
FSANZ has rules for mentioning compound ingredients on the label.
When listed on the ingredients list, the allergen in the name of the compound ingredient does not need to be bolded. Instead, only the individual ingredients containing allergens must be bolded—for example, Egg Fettuccine (Durum Wheat Semolina, Egg).
Processing aids are ingredients (e.g., clarifying agent, antistick agent) used during food preparation to perform a technical function like baking or freezing but are not present in the final food product.
Processing aids are not required to be listed on the ingredients list until and unless they contain an allergen.
In case processing aids contain an allergen, they must be listed on the ingredient list with their allergen name and in bold. However, the specific name of the processing aid does not need to be mentioned on the label.
To ensure compliance with the allergen labelling rules and regulations, food businesses need to understand and follow them. Here are a few key points to keep in mind while managing allergens.
Foodservice retailers, such as cafés, restaurants and pubs, must provide information on allergens in their food when asked by customers. This applies to both packaged food and unpackaged food made and sold on the premises.
Depending on the type of food, there are specific rules about how the allergen information can be displayed.
If the food product requires a label, the allergen declaration must be made on that label.
If the food product does not require a label, the allergen must be displayed next to the food or given to a customer upon request.
Food manufacturers must disclose allergen information for their products. This applies to all packaged foods and unpackaged foods.
If the food requires a label, the allergen information must appear on the label. If not, the information must be available upon request from the customer.
Declaring food allergen information is a legal requirement, and failure to comply can result in serious consequences.
Food importers are in charge of making sure that the imported food they handle is labelled accurately and includes clear and precise information about allergens.
To accomplish this, they must employ a system that provides clear and accurate information about allergens. Moreover, food importers are also responsible for ensuring that the labels of imported products comply with local rules and regulations.
In the food industry, allergen labelling rules and regulations are of utmost importance to ensure the safety of consumers. Non-compliance with allergen labelling rules and regulations can have severe consequences, both for consumers and businesses.
For consumers, it can lead to potential health risks, from mild symptoms like hives and vomiting to severe reactions that can be life-threatening.
For businesses, not adhering to labelling requirements can lead to legal penalties, negative publicity, product recalls, damage to their reputation, lawsuits and loss of consumer trust.
Therefore, it is vital that food manufacturers and processors take this matter seriously and prioritise the proper labelling of all allergens in their products. It is not just a matter of following rules but also a matter of ensuring the safety, trust, and well-being of all stakeholders involved.
Ensuring compliance with allergen labelling rules and regulations is crucial in protecting the health and well-being of consumers. Here are some steps to take to ensure meeting regulatory requirements.
By carefully following these steps, businesses can help ensure that their products are safe for all consumers and avoid potential regulatory fines or legal action.
In the food industry, allergen labelling compliance is crucial for safety reasons and a legal obligation. When designing allergen labels, it is important to follow some basic rules to ensure that the labels are easy to read and understand.
Our article on best practices for designing perfect labels and barcodes provides helpful guidelines for designing labels that comply with regulatory requirements.
If you’re looking for a reliable tool to help streamline your allergen labelling process, we highly recommend BarTender software. With its intuitive design features and powerful data management capabilities, this software simplifies the process of designing accurate and compliant labels, helping you to increase productivity and ensure customer safety.
Triton is proud to be a trusted provider of Seagull Scientific’s BarTender Software. We understand that every organisation is unique and requires individual attention, which is why we offer all four BarTender editions, namely, Starter Edition, Professional Edition, Automation Edition and Enterprise Edition.
The Starter Edition is perfect for small teams, while the Professional Edition offers an enhanced experience for those with more complex labelling requirements. Those who prefer a more automated process can opt for the Automation Edition, and the Enterprise Edition is perfect for large organisations.
We also offer BarTender Cloud, which is the latest and easiest way to manage label printing and design operations on the go.
At Triton, we remain dedicated to providing the best software options for our customers and are confident that BarTender Software will exceed your expectations.
So why wait? Contact us now via the live chat widget, or fill out a form here and get started on experiencing the best software solutions for your business.
Once you have designed the allergen labels, it’s time to print them. This is a crucial step in ensuring that your product labels comply with regulatory requirements.
Label printers come in a variety of sizes and printing technologies, so it’s important to choose the right printer for the job at hand. The wrong choice can lead to inaccurate labels and illegible barcodes, both of which can cause problems down the line.
Thermal printing is a great option for printing allergen labels, as it offers many advantages over other methods. First and foremost, thermal printing produces sharp and precise labels that are both cost-effective and easier to read than standard inkjet or laser printing. The labels also offer superior durability compared to other print methods, which makes them ideal for food labelling.
Our guides on thermal printer vs laser printer and thermal printer vs inkjet printer will help you compare and decide which printing technology is right for your business.
At Triton, we understand the importance of reliable and efficient thermal printing. That’s why we’re proud to offer an unbeatable selection of top-of-the-line printers from major brands like Zebra, Honeywell, TSC, and OKI.
Our printers are carefully chosen to deliver the utmost accuracy, efficiency, and durability, ensuring that every printing job is tackled with ease. Our vast inventory stocks different printer models, including desktop label printers, industrial label printers, direct thermal printers, thermal transfer printers and barcode label printers
At our store, we take pride in not only offering an exceptional range of thermal printer models but also providing premium print consumables that deliver optimal performance. Our extensive collection includes thermal transfer ribbons, thermal labels, thermal carton labels, thermal carcase tags, and food-compliant thermal inserts.
What sets our products apart is their unbeatable adhesion and long-lasting prints that are designed to withstand any environment. Our high-quality range of print consumables complements our thermal printer models, allowing our customers to create prints that speak to their brand’s quality and professionalism.
Choose Triton, and give yourself the gift of superior quality and exceptional value. Get in touch with us today via the live chat widget below, and let us help you find the perfect thermal printer and consumable combination for your business.
Providing accurate and transparent allergen information is a legal requirement and is also critical for the health and safety of individuals with food allergies.
Adhering to allergen labelling regulations requires a comprehensive understanding of the rules and art of designing and printing compliant labels. We hope that this article has provided you with an overview of allergen labelling compliance in Australia and New Zealand, helping you to navigate the complex world of regulatory requirements.
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