Allergen Management & PEAL Compliance

Why Allergens Are the Highest-Stakes Hazard in Hospitality A microbiological hazard might make a customer ill for a week. An allergen hazard can kill them in fifteen minutes. That asymmetry is why allergen management has moved from a side-of-desk task to a board-level compliance priority across Australian hospitality. According to the National Allergy Council, around one in ten Australian infants and about two in every hundred adults live with diagnosed food allergy, and the rate of presentations to emergency departments for food-related anaphylaxis has more than tripled in two decades. Australian regulators have responded by significantly raising the bar. The Plain English Allergen Labelling (PEAL) reforms under FSANZ Standard 1.2.3 — phased in from 25 February 2024, with a full transition deadline of 25 February 2026 — are the most significant change to Australian food labelling in a generation. They affect every packaged food sold in Australia, and they reframe the entire conversation about how hospitality venues describe and protect against allergens. This guide is the operator-level pillar reference for allergen management in Australia. It complements our PEAL allergen management feature and our category page on food safety topics . The 24 Declarable Allergens in Australia The PEAL reforms were issued by FSANZ following stakeholder consultation and align with allergen-management practices recommended by the Australian Department of Health and Aged Care and consumer-facing guidance from the NSW Food Authority . Operators should treat the PEAL list as the minimum legal baseline, not a ceiling — best-practice menus also flag culturally significant allergens (e.g. coconut for some communities) where relevant. Standard 1.2.3 lists the substances that must be declared whenever they are present as ingredients, processing aids, or are present through cross-contact above a defined threshold. As of the PEAL reforms the list comprises: Cereals containing gluten: wheat, rye, barley, oats, spelt, and their hybridised strains, declared individually by name (PEAL no longer permits the combined "gluten" declaration alone). Crustaceans: declared as "crustacean." Eggs. Fish. Milk. Peanuts. Soybeans. Tree nuts: almond, Brazil nut, cashew, hazelnut, macadamia, pecan, pine nut, pistachio, walnut — declared individually under PEAL. Sesame seeds. Lupin. Molluscs. Sulphites in concentrations of 10 mg/kg or more. Added sulphur dioxide in concentrations of 10 mg/kg or more. The expansion to require individual tree nuts and individual gluten-containing cereals — rather than collective categories — is the change that has caught most hospitality operators by surprise. A label that simply says "contains nuts" no longer satisfies PEAL when applied to a packaged product, and a customer-facing menu that says "may contain gluten" is no longer aligned with how packaged food is described in the same supply chain. Standard 1.2.3 and the PEAL Transition Plain English Allergen Labelling came into force on 25 February 2024. From that date, all newly manufactured packaged food in Australia and New Zealand had to comply. Existing stock manufactured before the date was given a two-year transition window, ending 25 February 2026. From that point, every packaged food on the shelf must comply. What PEAL requires Mandatory bold declaration in the ingredients statement. Each allergen must be bolded where it first appears, using a defined font and contrast. A separate "Contains" statement immediately after the ingredient list, summarising allergens present. Specific names rather than collective categories. "Wheat," "rye," "almond," "cashew" — not "gluten" or "tree nuts" alone. Cross-reference between processing aids and allergens. Allergens used as processing aids are declared in the same way as ingredients. Consistent terminology across the label. No variation between ingredients list, contains statement, and front-of-pack callouts. What PEAL implies for hospitality PEAL is technically a packaged-food rule, but its impact ripples through hospitality in three ways: Your supply chain is changing. Suppliers are reformulating, relabelling, and updating product specifications. Allergen statements on a sheet of paper from 2022 may no longer match the product in the box. Verifying allergen information at receipt has become a frontline control, not a back-office formality. Customer expectations are changing. Customers used to plain-English packaged labels expect the same clarity from menus, ordering apps, and verbal descriptions. Regulators are scrutinising consistency. If your supplier declares "wheat, rye, oats" on the can, and your menu says "gluten," and your verbal description to a customer says "no nuts" without reference to gluten — you are creating an inconsistency a regulator can use against you. Cross-Contact vs Cross-Contamination Two terms get used interchangeably in industry but mean very different things in allergen management. Cross-contamination generally refers to the transfer of microbiological pathogens — for example, raw chicken juices contaminating ready-to-eat salad. Cross-contact refers to the transfer of allergenic protein from one food to another. Even microscopic quantities — invisible to the eye, undetectable by smell — can trigger life-threatening anaphylaxis in a sensitised person. Cross-contact occurs through shared utensils, shared cutting boards, shared fryer oil, shared chargrills, airborne flour, splashed batter, and gloved hands that touched a previous allergen. The control measures for cross-contact are stricter than for cross-contamination because the dose required to cause harm is so much smaller. Allergen Matrices and Recipe Management An allergen matrix is the single most important document in your allergen management system. It is a master table of every menu item against every declarable allergen, indicating presence (Y), absence (N), and risk of cross-contact (M for "may be present"). How to bui