Product Reformulation & Relabelling

Any change to a product's ingredients, suppliers or process that affects the label requires relabelling before that product reaches customers — and getting this wrong, especially for allergens, is one of the leading causes of food recalls in Australia. Reformulation is a normal part of running a food business: costs change, suppliers change, and recipes get improved. The risk is not the change itself but the gap between changing the product and updating the label. This guide sets out when reformulation triggers relabelling, the allergen review steps to follow, how to transition stock safely, and how to communicate with customers when a change matters to them. When Does Reformulation Trigger Relabelling? You must relabel whenever a change affects information that appears on, or should appear on, the label. Common triggers include: Adding, removing or substituting an ingredient Changing a supplier where the new ingredient has a different allergen or origin profile A change that alters the allergen declaration in any way A change to nutrition values that affects the Nutrition Information Panel or a nutrition claim A change to shelf life, storage conditions or country of origin Allergen changes are the highest-risk category. Undeclared allergens are consistently among the most common reasons for food recalls coordinated through FSANZ . Allergen Review Steps Run a structured allergen review for every reformulation: Capture the new recipe and supplier specifications in full, including any "may contain" statements from suppliers. Compare the new allergen profile against the current label line by line. If a new allergen is introduced, update the label before any reformulated product is released. This is non-negotiable and time-critical. If an allergen is removed, update the label only after the change is verified across production — removing an allergen declaration prematurely is dangerous if any old-formulation stock remains. Plain English Allergen Labelling under Standard 1.2.3 means allergen declarations must use specified terms, so re-check both the ingredient list emphasis and the "Contains" statement. Managing the Stock Transition The cut-over between old and new formulation is where mislabelling happens. Plan it deliberately: Identify all existing stock carrying the old label — raw materials, work in progress and finished goods. Decide the fate of each: relabel, sell through under controlled conditions, return, or destroy. Never mix old-formulation product into new-label packaging, or vice versa. Maintain batch traceability throughout so any issue can be isolated quickly. Set and communicate a clear changeover date. Communicating the Change to Customers and Trade Tell your wholesalers and retailers about the change so they manage their own shelves correctly. Where the change affects allergen status, communicate proactively to consumers through your website and social channels — a customer who relies on a product being free of a given allergen needs to know the moment that changes. How Do You Prove You Managed the Change Properly? Keep records at every step: the old and new recipe, the supplier specifications, the allergen comparison, the decision on existing stock, the changeover date, and who approved each stage. If a problem later emerges, this documentation is your evidence of due diligence and the foundation of any recall. Beyond Allergens: Other Label Elements to Recheck Allergens are the highest-risk element, but a reformulation can quietly break other parts of the label too. Recheck each of the following whenever you change a recipe or supplier: Nutrition Information Panel — new ingredients or ratios change energy and nutrient values. Nutrition and health claims — a "low fat" or "high fibre" claim must still meet its qualifying criteria after the change. Ingredient list order — a change in proportions can reorder ingredients by weight. Country of origin — a new supplier may shift the origin statement. Shelf life and storage — a formulation change can alter the safe use-by date. Treat the label as a system: touching one part often ripples into others. Silent Supplier Changes: The Hidden Risk Not every reformulation is one you plan. A supplier can change the recipe of an ingredient you buy — adding an allergen, changing the origin, or altering the nutrition profile — without prominent notice. If you do not read updated supplier specifications, your finished product can drift out of line with its label without anyone deciding to change anything. Protect against this by: Reviewing supplier specification sheets on a regular cycle, not just at onboarding. Requiring suppliers to notify you of allergen and formulation changes in your supply agreement. Checking incoming ingredient labels against your held specifications at receival. A silent supplier change that introduces an undeclared allergen is exactly the kind of failure that leads to a national recall. When a Reformulation Becomes a Recall If reformulated product with an incorrect label has already reached customers — especially with an undeclared allergen — you may need to initiate a recall. Speed and traceability are everything. Good batch records and version control let you identify precisely which product is affected and where it went, so the recall can be targeted rather than sweeping. Coordinate consumer-level recalls through the processes overseen by FSANZ and notify your state or territory regulator promptly. A Reformulation Change-Control Checklist Bring the whole process together into a repeatable change-control routine so nothing is missed under time pressure: Document the change — capture the old and new recipe and the reason for the change. Gather specifications — obtain current supplier specification sheets for every affected ingredient. Run the allergen review — compare old and new allergen profiles line by line. Recheck the whole label — allergens, ingredient order, nutrition panel, claims, origin and shelf life. Plan