When food labels declare the presence of allergens in an accurate, clear and consistent manner, people with food allergy can quickly and easily identify which foods they can eat.

Allergen declaration requirements differ amongst many countries and regions. Care should be taken to ensure that labels and specifications for foods and ingredients imported into Australia and New Zealand fully comply with local regulatory requirements. Also, foods sold into other countries may be required to meet different requirements. Differences may include whether mandatory declaration is required, what the specific allergens are, and any allergen labelling exemptions. FARRP (Food Allergy Research and Resource Program) provide a Food Allergens – International Regulatory Chart which is a useful tool for understanding some of the differences between the allergen regulations.

Australia New Zealand allergen labelling requirements

All foods sold in Australia and New Zealand, including imported foods, must comply with the food labelling regulations set out in the Australia New Zealand Food Standards Code (Code). The Code is developed and administered by Food Standards Australia New Zealand (FSANZ) and enforced by several food enforcement agencies.

The Code sets out the mandatory declaration requirements for foods that are allergens in Division 3 Mandatory Declarations of Standard 1.2.3 Information requirements – warning statements, advisory statements and declarations. If a food for sale contains an allergen (or a derivative of that allergen) listed in Column 1 of the table to section S9-3 in Schedule 9 Mandatory advisory statements and declarations, the label must declare the allergen as per the requirements set out in Standard 1.2.3. This is accessible via the Food Standards Australia New Zealand website. Always refer directly to the Table to S9-3 when preparing a label, as it can change from time to time.

If the specified foods or substances (allergens) are present in a food for sale, the allergen must always be declared. The Code requires the declaration of the allergen when they are present as an ingredient, food additive or processing aid, or components of these, and includes products of these.

Example: Jack has reviewed a cake recipe and has interpreted the table to S9-3 as shown in this table.

Wheat FlourIngredientWheatWheat is a cereal containing gluten
Egg Yolk PowderIngredientEggEgg yolk is a product of egg
Butter (Butter, Salt)IngredientMilkButter is a compound ingredient.
Milk is an ingredient of a compound ingredient (butter).
FlavourFood AdditiveSesameSesame oil is an ingredient of the food additive (flavour).
Raising AgentsFood Additive
Soybean Oil for spraying the baking tinsProcessing AidSoyIf the soybean oil has been degummed, neutralised, bleached and deodorised, it is not mandatory to declare the soy (it is exempt from allergen labelling)

When considering which allergens are present in a food for sale, look at the recipe and the entire process. When reviewing the process, if a processing aid which contains an allergen is used, it must be declared on the label.

The Code sets out the requirements for when a food for sale must bear a label. Standard 1.2.1 Requirements to have labels or otherwise provide information describes when a food for sale must bear a label and when the allergen information must be attached to the package. The Standard lists certain conditions where a food for sale does not have to bear a label. An example of one condition is if the food is delivered packaged and ready for consumption at the express order of purchaser (such as take away food). Another example is food displayed in an assisted service display cabinet (such as cold meats and cheeses in a refrigerated deli cabinet). If these foods don’t bear a label, the allergen information must be provided either upon request or accompany the food or be displayed in connection with the food. Refer directly to the Standard a full understanding of the requirements.

Standard 1.2.1 also sets out requirements for the sale of ingredients, where compositional, labelling or declaration requirements of the Code (which includes the allergen status) are to be provided to the purchaser upon request. For ingredients, this information can be communicated in a raw material specification (or PIF) by stating presence of allergens that are intentionally included as part of a recipe, and the concentration and form of any allergens that may be present due to unintentional cross contact.

Standard 1.2.3 of the Food Standards Code contains mandatory requirements for the format, terminology and location of the statement of ingredients and summary statement and their declaration of allergens. Refer to Australian Food and Grocery Council & Allergen Bureau Food Industry Guide to Allergen Management and Labelling.

The VITAL Program & precautionary allergen labelling (PAL)

The Code does not set requirements for declaring allergens that may be present due to unintentional cross contact. One way the food industry informs consumers of cross contact allergens is through a precautionary allergen statement. The precautionary allergen statement is voluntary and can be used to communicate a real and documented risk of allergen cross contact.

The VITAL Program provides a consistent methodology for the food industry to assess the impact of allergen cross contact from raw materials and the processing environment. It determines appropriate precautionary labelling based on risk by using Action Levels that are underpinned by scientific evidence. The VITAL Program can be used to assist food producers in presenting allergen labelling accurately and consistently for people with food allergy.

Create label specification

The label specification is a document owned by individual businesses that includes all information that is to be printed on a finished product label, including any allergen declarations. A person with food technology understanding and a good grasp of food regulations is best suited to creating these specifications. When creating the label specification, ensure that all information is traceable including the raw material data used, the recipe, processing information, any decisions or assumptions made, and the label version. Ensure the specification is based on the formulation that will be used for the finished product.

The specification should include the finished product allergen declaration (for example this can be in the form of an ingredient list, an allergen summary statement and a precautionary allergen statement), and it should be accurate and in a clear, consistent format. The information used to generate the ingredient list should be from the raw material specifications that have been reviewed thoroughly by a technical person for allergen status. Cross contact allergen status should also be determined from the information provided by the raw material specifications and any cross contact identified due to processing. A useful tool that enables a business to capture the allergen status of raw materials and from processing is VITAL Online. Transcribing the allergen information into clear consistent ingredient list format is described in VITAL Best Practice Labelling Guide for Australia and New Zealand.

Maintain a library of label specifications that includes version control.

Review label artwork

When label artwork is designed for the first time, ensure that the allergen information is transcribed correctly onto the label. Use the label specification and ensure the information matches. If it does not match, determine why and, if needed, review the label specification to ensure it remains the most accurate source of truth.

Each time label artwork is redesigned, or altered in any form, or undergoes any changes (for example it is relocated from one printer to another), review the label artwork against the specification to ensure the information matches. If there are long periods between re-prints, check that the formulation or allergen status has not changed. If it has, update the specification and the artwork.

Label artwork is best reviewed using formal label review process.  There have been several recalls of food products, initiated due to incorrect or missing information on a food label, highlighting the requirement for the label review process to be thorough. The review should be by more than one person within the business to ensure all key parts of the label are correct, but from an allergen perspective, a technical person with food allergen and regulatory knowledge should review the allergen declarations and any allergen claims. Sometimes a label may require reviewing more than once before it is approved for printing. Subsequent rounds of review are encouraged if the initial version contains allergen errors. Only approve artwork ready for printing when the allergen information is correct.

Review the printed label

Once the label artwork has been printed, do a final check to ensure the information is correct. A formal sign-off of the printed label artwork against the label specification should form part of the label review process.

An effective AMP will include procedures in place for the management of product labels and to ensure compliance to regulation.
Labelling – Procedures to control the changeover of labels are in place. Internal audits are conducted to verify that the formulation matches the ingredients specified on the label.
Procedures for ensuring allergens are labelled as per the Code’s requirements are in place.
Regulation – Procedures and monitoring practices are in place to ensure compliance with Australian and New Zealand regulatory requirements.