Allergen Labelling for Packaged Food (PEAL)

Packaged food sold in Australia must declare allergens using Plain English Allergen Labelling (PEAL) under Standard 1.2.3 of the Food Standards Code. In practice each declared allergen must appear in bold in the ingredients list every time it occurs, plus a separate bold summary statement that begins with the word "Contains" in the same field of view. Specified plain-English names are mandatory. Always confirm your obligations with FSANZ and your state or territory food regulator. Key takeaways: PEAL was introduced into the Food Standards Code on 25 February 2021. A three-year transition period ended on 25 February 2024, and food packaged and labelled before that date could be sold through until 25 February 2026 - so packaged food on sale now generally must comply.. Declared allergens must appear in bold in the ingredients list every time they occur, and again in a separate bold summary statement that begins with the word 'Contains'.. You must use the specified plain-English names - for example 'milk', 'wheat', 'cashew', 'fish' - not vague terms like 'seafood', 'tree nuts' or a supplier code.. The 'Contains' summary statement must sit in the same field of view as, and directly next to, the ingredients list.. How the rules are enforced can vary by jurisdiction, so confirm your exact obligations with FSANZ and your state or territory food regulator.. Grouped terms and their required plain-English names: Don't use, Use instead. 'Tree nuts' — The individual nut named (almond, Brazil nut, cashew, hazelnut, macadamia, pecan, pine nut, pistachio or walnut). 'Seafood' — Fish, crustacea and molluscs each named where present. Generic 'gluten' or 'cereals' only — The specific grain (wheat, rye, barley, oats), plus 'gluten' in the summary statement where present. 'Casein' or 'whey' alone — 'Milk'. What PEAL is and why it changed Plain English Allergen Labelling (PEAL) is the set of allergen declaration rules introduced into the Australia New Zealand Food Standards Code through FSANZ Proposal P1044. It amended Standard 1.2.3 (Information requirements - warning statements, advisory statements and declarations) and the related Schedule 9, which lists the mandatory declarations and the specific names that must be used. The change was driven by a simple safety problem: under the old rules, allergens could be buried in an ingredients list, written in technical or inconsistent language, or grouped under broad terms like 'seafood' or 'tree nuts'. That made labels hard to read quickly for people managing life-threatening allergies. PEAL standardises the language and the placement so a consumer can scan a label and find the information reliably. The PEAL amendments were made to the Code on 25 February 2021. Businesses were given a three-year transition period, which ended on 25 February 2024 - the date from which packaged food generally has to meet the PEAL format. In addition, a stock-in-trade allowance let food that was packaged and labelled before 25 February 2024 (and that complied with the previous rules) continue to be sold until 25 February 2026. Because enforcement is carried out by state and territory regulators, confirm how the rules apply to your specific products with FSANZ and your local food authority. Which allergens must be declared Standard 1.2.3, read with Schedule 9, requires certain foods and substances to be declared whenever they are present as an ingredient, a component of an ingredient, a food additive, or a processing aid. The declared allergens generally are: Added sulphites in a concentration of 10 mg/kg or more; cereals containing gluten (declared by their specific grain name - wheat, rye, barley, oats and their hybridised strains); crustacea; egg; fish; milk; molluscs; peanut; sesame; soy; lupin; and tree nuts. A central PEAL change is specificity. Tree nuts must be named individually - almond, Brazil nut, cashew, hazelnut, macadamia, pecan, pine nut, pistachio or walnut - rather than grouped as 'tree nuts'. Similarly, fish, crustacea and molluscs must each be named where present, rather than lumped together as 'seafood'. This individual naming lets consumers distinguish, for example, a cashew allergy from a hazelnut allergy. For gluten sources, the specific cereal (such as wheat) is declared in the ingredients list, and where the food contains gluten the word 'gluten' is also included in the summary statement. Use the specific grain (wheat, rye, barley, oats) rather than only a generic 'gluten' or 'cereals' reference, and include 'gluten' in the summary statement where gluten is present. Name each tree nut individually - 'almond', 'cashew', 'walnut' - not 'tree nuts'. Name fish, crustacea and molluscs separately - never 'seafood' alone. Declare added sulphites when present at 10 mg/kg or more. Declaration applies to ingredients, components of ingredients, additives and processing aids. The two-part format: bold ingredients plus a summary statement PEAL requires each declared allergen to appear in two places on the label, and to stand out in the ingredients list. First, in the statement of ingredients: the allergen's specified name must be shown in bold font, every time it appears, at a font size no smaller than that used for the other ingredients. Where an allergen is inside a compound ingredient, it is typically shown in bold in brackets - for example, 'maltodextrin (wheat)' or 'vegetable oil (soy)'. Where milk powder is listed, the required name 'milk' must appear in bold. Second, a separate allergen summary statement. This is a distinct statement that begins with the word 'Contains' in bold, followed by each declared allergen in bold, for example: 'Contains milk, wheat, almond.' The summary is not a substitute for the ingredients-list declarations - both are required. The summary gives an at-a-glance list; the ingredients list shows exactly where each allergen sits. Placement, font and the 'same field of view' rule Placement matters as much as wording. The 'Contains' summary statement must appear in the same field of view as the statement of ingredients - meaning both are visible together without turning the package - and directly next to (typically immediately below or beside) the ingredients list. Separating the summary from the ingredients, or putting it on another panel, does not meet the requirement. The summary statement is a separate statement to the ingredients list, and both the bolded allergen names in the ingredients list and the summary statement must be in bold font. For general legibility, the bolded allergen names in the ingredients list must be no smaller than the other ingredient text, and the whole label must comply with the general legibility requirements of Standard 1.2.1 (including minimum type sizes and adequate contrast). If your product is very small, check the specific concessions in the Code for small packages, and confirm their application with your regulator. Cross-contamination ('may contain') statements PEAL governs how you declare allergens that are deliberately present in the food. It does not, on its own, mandate precautionary allergen labelling (PAL) - the voluntary 'may contain traces of...' statements used to warn about unintended cross-contact from shared equipment or facilities. Precautionary statements should only be used after a genuine risk assessment of your process; they are not a substitute for good allergen management and must not be used to mask poor controls. Overuse or 'defensive' labelling reduces the number of safe choices for allergic consumers and can undermine trust in the warning. Industry guidance such as the VITAL (Voluntary Incidental Trace Allergen Labelling) program from the Allergen Bureau provides a structured method for deciding when a precautionary statement is warranted. Keep precautionary wording separate and clearly distinguishable from the mandatory 'Contains' summary. Getting your labels right in practice Start by mapping every ingredient, sub-ingredient, additive and processing aid in each product against the Schedule 9 list, then translate each hit into its required plain-English name. Build the ingredients list so every allergen is bolded at each occurrence, and add the 'Contains' summary directly beneath it in the same field of view. Version control is critical: a supplier reformulation, a new flavour, or a change of oil can introduce a new allergen without anyone updating the artwork. Tie your label sign-off to your food safety and supplier approval processes, and re-check labels whenever a specification changes. Keep dated records of label approvals so you can demonstrate due diligence if a regulator or an auditor asks. For any borderline call - small-package concessions, unusual ingredients, imported stock - seek written confirmation from your state or territory food regulator rather than relying on assumptions. Worked examples: Declaring an allergen inside a compound ingredient: A product uses maltodextrin derived from wheat. In the ingredients list the allergen is bolded, typically in brackets, as 'maltodextrin (wheat)', at a font size no smaller than the other ingredients. A separate bold 'Contains' summary directly beneath the ingredients list, in the same field of view, lists wheat and any other declared allergens. A supplier reformulation adds a new allergen: A supplier changes the oil in an ingredient to one containing soy, introducing a new allergen without the artwork changing. Because label sign-off is tied to supplier approval and change control, the label is re-checked, soy is bolded at each occurrence and added to the 'Contains' statement. A dated record of the approval is kept to show due diligence. Checklist: Every declared allergen (Schedule 9) is identified across ingredients, components, additives and processing aids. Specified plain-English names are used - individual tree nuts named; fish/crustacea/molluscs named separately; specific gluten grains named. Each allergen is in bold in the ingredients list at every occurrence, no smaller than other ingredient text. A separate 'Contains' summary statement is present, starting with the bold word 'Contains', with the allergens in bold. The 'Contains' statement is in the same field of view as, and directly next to, the ingredients list. Where gluten is present, 'gluten' is included in the summary statement. Added sulphites are declared when present at 10 mg/kg or more. Any precautionary 'may contain' statement is risk-assessed and kept separate from the mandatory declarations. Label meets general legibility requirements (Standard 1.2.1) and any small-package rules have been checked. Label approval is dated, recorded, and linked to change control for reformulations and supplier changes. Common mistakes: Using grouped terms like 'seafood' or 'tree nuts' instead of the specific required names. Bolding an allergen only once, or only in the summary, when it must be bold at every occurrence in the ingredients list. Omitting the separate 'Contains' summary statement, or treating the bolded ingredients list as sufficient on its own. Placing the 'Contains' statement on a different panel or out of the same field of view as the ingredients list. Forgetting allergens that enter through additives, processing aids or components of compound ingredients. Failing to update the label after a supplier reformulation introduces a new allergen. Using a 'may contain' precautionary statement to cover poor controls instead of managing cross-contact, or blending it into the mandatory 'Contains' line. Assuming imported or pre-25-February-2024 stock can still be sold indefinitely - the stock-in-trade sell-through ended on 25 February 2026.