FSANZ Allergen Labelling Requirements

Overview of FSANZ Standard 1.2.3 Food Standards Australia New Zealand (FSANZ) Standard 1.2.3 sets out the requirements for declaring the presence of certain substances in food that are known to cause allergic reactions in sensitive individuals. This standard applies to all food businesses in Australia and New Zealand, including restaurants, cafes, takeaway outlets, caterers, food manufacturers, and retailers. The standard was developed by FSANZ in recognition of the growing prevalence of food allergies and the potentially life-threatening nature of allergic reactions. It aims to ensure that consumers have access to the allergen information they need to make safe food choices. For hospitality businesses, understanding and complying with this standard is not just a legal obligation — it is a fundamental aspect of customer care. Standard 1.2.3 operates within the broader context of the Australia New Zealand Food Standards Code , which is enforced by state and territory food authorities such as the NSW Food Authority and Safe Food Queensland . Non-compliance can result in penalties including fines, improvement notices, and in serious cases, prosecution. Which Allergens Must Be Declared? FSANZ identifies a specific list of substances that must be declared because they are the most common causes of food allergy and intolerance in the Australian and New Zealand population. These substances are: Peanuts: One of the most common causes of severe allergic reactions (anaphylaxis) in Australia. Tree nuts: Almonds, Brazil nuts, cashews, hazelnuts (filberts), macadamias, pecans, pine nuts, pistachios, and walnuts. If any tree nut is present, the specific type must be declared. Milk: Includes all forms — whole, skim, powdered, condensed, butter, cream, cheese, yoghurt, and milk proteins such as casein and whey. Lactose intolerance is a separate issue from milk allergy but is also covered. Eggs: From any bird species, including chicken, duck, and quail eggs. Includes whole eggs, egg whites, egg yolks, and products derived from eggs. Cereals containing gluten: Wheat, rye, barley, and oats, and their hybridised strains. This includes products derived from these grains, such as flour, breadcrumbs, and malt. Soybeans: Includes all soy products — soy sauce, tofu, tempeh, soy lecithin, and soy protein isolates. Fish: All species of fish. If fish is present, the specific species should be declared where possible. Crustacea: Prawns, shrimp, crab, lobster, crayfish, and similar species. The specific type should be declared. Sesame seeds: Including sesame oil and tahini. Lupin: A legume used in some flour blends, bread products, and pasta. It is cross-reactive with peanut allergy in some individuals. Molluscs: Oysters, mussels, clams, scallops, squid (calamari), octopus, and snails. Sulphites: Where present in concentrations of 10 mg/kg or more. Sulphites are used as preservatives in many products, including dried fruits, wine, and some processed foods. Celery: Including celeriac (celery root) and celery salt. Mustard: Including mustard seeds, mustard powder, and prepared mustard. Packaged Food Requirements For packaged food, allergen declaration must appear on the label. The Food Standards Code specifies that allergens must be declared in the ingredient list or in a separate summary statement (commonly formatted as "Contains: [allergen]" below the ingredient list). Since March 2024, FSANZ requires that allergen information be presented in a standardised format using bold text to ensure it is easily identifiable by consumers. Key labelling requirements for packaged food: Allergens must be declared using their common name (e.g., "milk" rather than "casein" alone, though both can be used). All sources of allergens must be declared, including sub-ingredients (e.g., if a sauce contains soy, and the sauce is an ingredient in the dish, soy must be declared). Precautionary allergen statements (e.g., "May contain traces of nuts") are voluntary and should only be used when there is a genuine risk of cross-contamination that cannot be controlled through standard procedures. Unpackaged Food Requirements For unpackaged food — which includes most meals served in restaurants, cafes, and takeaway outlets — the requirements are less prescriptive but equally important. Food businesses must be able to provide allergen information to customers upon request. This can be done through: Verbal communication: Staff must be able to accurately answer customer questions about allergens in any menu item. This requires staff to be trained and have access to up-to-date allergen information. Written information: Menus, allergen information sheets, table cards, or wall-mounted signage that lists allergen information for each dish. Digital platforms: Online menus, QR-code-accessible allergen information, or apps that allow customers to filter menu items by allergen. Best practice is to use a combination of methods. Display signage inviting customers to ask about allergens, provide written allergen information (either on the menu or as a separate document), and ensure all staff are trained to provide accurate verbal information. Precautionary Allergen Labelling (PAL) Precautionary allergen statements — commonly known as "may contain" statements — are voluntary in Australia. They are intended for situations where there is a genuine, uncontrollable risk of cross-contamination during manufacturing or preparation. They should not be used as a blanket disclaimer to avoid responsibility. FSANZ guidelines recommend that precautionary statements should only be used when a thorough risk assessment has identified a genuine cross-contamination risk that cannot be adequately controlled through standard food safety measures. Overuse of precautionary statements reduces their value, limits food choices for allergic consumers, and can undermine trust in your allergen management system. Record-Keeping and Documentation Maintaining accurate, up-to-date allergen rec