Understanding Plain English Allergen Labelling (PEAL) for Packaged Food

In February 2021, Food Standards Australia and New Zealand (FSANZ) announced new requirements for allergen labelling on packaged foods, to help make food allergen declarations clear and consistent for consumers and enable them to make safe food choices.

Prior to this, FSANZ required the 11 known foods and ingredients that can cause severe allergic reactions to be declared on labels when they are present in food. However, there was no requirement on how these declarations were to be made, leading to confusion and uncertainty in consumers which may have potential life-threatening consequences.

What has changed?

Under the new requirements in the Australia New Zealand Food Standards Code (the Code), businesses must state allergens using mandatory specified terms  (see Appendix 1) in bold font, with additional requirements to display them in the statement of ingredients, as well as in a separate allergen summary statement.

The Code amendments require businesses to separate the declaration of molluscs, individual tree nuts (such as Brazil nuts, cashews, and pecans among others) and wheat, barley, rye or oats and gluten if present.

Furthermore, allergen declarations must be made in the statement of ingredients (ingredients list), and must be:

• printed in bold font that provides a distinct contrast with any other text.
• printed in a size of type no less than that used for other text.
• provided as a separate word for each ingredient that is, or contains, an allergen.

Example above provided by FSANZ – Derek Castles

In addition, an allergen summary statement must be provided. This is the list of allergens that are or may be present in the product. This allergen summary statement must be:

• printed in a bold font that provides a distinct contrast with any other text in the statement of ingredients that is not a required name.
• printed in the same type face and size of type as the declarations in the statement of ingredients.
• commence with the word ‘Contains’ and only include the allergens required to be declared.

Example of allergen summary statement

When do these changes come into effect?

This variation to the Code came into effect in February 2021, with a three-year transition period followed by a two-year stock-in-trade period to implement PEAL. The transition period will allow any relevant food that has already been packaged to be sold, so long as the food complies with either the existing allergen declaration requirements in the Code or the new amendments.

What does this mean for your business?

All accredited businesses with Safe Food must be aware of their labelling requirements under the  Food Standards Code. Several sections in the Code provide information regarding labelling requirements.

Accredited businesses will need to comply with the PEAL changes by 2026. If you are purchasing new labels, it is recommended that you implement these new changes while doing so.

Accredited businesses that are not packaging products will still need to have correct PEAL allergen information readily available for consumers. For example, butchers that sell food containing allergens (e.g. eggs, wheat, gluten, nuts) within a display cabinet.

Grow your knowledge in food allergens

Did you know that undeclared allergens are the leading cause of food recalls in Australia? If you’re a food producer, it’s well worth the time and investment to better understand food allergens, how to manage them in your business, and what Australia’s labelling requirements are.

The Food Allergen Management Symposium (FAMS2023)  is coming to Brisbane from 30 May – 1 June 2023. This event is for anyone working in the food industry – from farming and primary production to food processing, food retail or food service providers – to hear from internationally recognised researchers, clinicians, and industry experts on allergen management best practice.

Check out the full program and register today: https://event.icebergevents.com.au/fams2023/program

Further resources

For information on food allergen  labelling:

Allergen labelling (foodstandards.gov.au)

Food allergies (foodstandards.gov.au)

Product exemptions from allergen labelling (foodstandards.gov.au)

Australia New Zealand Food Standards Code – Standard 1.2.3 – Information requirements – warning statements, advisory statements and declarations (legislation.gov.au)  (section 1.2.3-4 specifically)

Australia New Zealand Food Standards Code – Schedule 9 – Mandatory advisory statements (legislation.gov.au)

Allergen management info:

Allergen Bureau Food Allergy Management | Allergen Bureau

Allergen Risk Review – free interactive tool to conduct an allergen risk review at each stage of the food supply chain.

Food Industry Guide to Allergen Management

Appendix 1

Table 1: Required names for making mandatory declarations