How to declare compound ingredients on an Australian food label: the 5% rule, breaking down components, and why allergens and additives are never hidden.
A compound ingredient is an ingredient made up of two or more ingredients — a sauce, a marinade, chocolate chips or a spice blend. When a compound ingredient makes up 5% or more of the final food, its own components must be listed in brackets straight after it. Any allergen, and any additive performing a technological function, must be declared no matter how small the amount, so nothing hidden slips through. Key takeaways: A compound ingredient is one made from two or more ingredients — such as a sauce, marinade, seasoning blend or chocolate chips — and its make-up must be transparent on the label.. When a compound ingredient is 5% or more of the final food, list all of its components in brackets immediately after its name.. Below 5% you can usually skip the full breakdown, but every declared allergen must still be declared no matter how small the amount.. Any additive that performs a technological function in the finished food must also be declared, regardless of the 5% threshold.. You can only label accurately if your supplier gives you the full component breakdown of every compound ingredient you buy.. What counts as a compound ingredient A compound ingredient is any ingredient that is itself made from two or more ingredients. The moment you buy something pre-made and add it to your product, you are almost certainly working with a compound ingredient. A bottled tomato sauce, a mayonnaise, a stock powder, a curry paste, a seasoning blend, chocolate chips, a bread crumb coating or a marinade are all compound ingredients — each one hides a list of its own sub-ingredients inside a single familiar name. The risk is obvious once you see it. If your ingredient list simply says "marinade" or "seasoning", the person reading the label has no idea what is really in your food. That marinade might contain soy, wheat and added sulphites; the seasoning might contain milk solids or a colour. Left unbroken, a compound ingredient becomes a place where allergens and additives can disappear from view. Declaring compound ingredients is about lifting that lid. The Australia New Zealand Food Standards Code sets out how far you must break a compound ingredient down so a consumer can see what they are actually eating. The 5% rule: when you must break it down The core rule under the Food Standards Code (Standard 1.2.4, which governs ingredient listing) is a proportion test. When a compound ingredient makes up 5% or more of the final food, you must list all of its components in the statement of ingredients. Those components are shown in brackets straight after the compound ingredient's name. When a compound ingredient makes up less than 5% of the final food, you generally do not need to list its individual components. This keeps ingredient lists readable — a pinch of a complex spice blend does not need to spill a dozen sub-ingredients onto the label. It is a genuine concession, not a loophole. But the 5% concession has firm limits, and they are the whole point of getting this right. It never applies to declared allergens, and it never applies to additives that perform a technological function in the finished food. Those must be declared whether the compound ingredient is 50% of your product or a trace. Treat the 5% test as the rule for ordinary components only, with allergens and functional additives carved out and always declared. Allergens are never hidden by the 5% rule This is the single most important thing to understand about compound ingredients. Allergen declaration sits under a separate requirement — Plain English Allergen Labelling (PEAL) within Standard 1.2.3 — and it overrides the 5% threshold entirely. If a compound ingredient contains anything on the declared allergen list, that allergen must be declared even if the compound ingredient is a tiny fraction of your food. So a splash of a soy-and-wheat-based sauce, well under 5% of the finished dish, still forces you to declare soy and wheat. A dusting of a seasoning that contains milk solids still forces a milk declaration. The consumer who reacts to that allergen does not care that it arrived inside a compound ingredient — and neither does the law. Under PEAL, allergens must be declared using specified plain-English words, both in the ingredient list and in a separate summary allergen statement. An undeclared allergen hiding inside an unbroken compound ingredient is one of the most common triggers for a food recall, so this is where your attention should sit first. Additives must still be declared too The second carve-out from the 5% rule covers additives. If a compound ingredient contains an additive — a colour, a preservative, an antioxidant, an emulsifier and so on — and that additive still performs a technological function in your finished food, it must be declared regardless of how little of the compound ingredient you use. An additive is declared by its class name (its function, such as "preservative" or "colour") followed by either its specific name or its code number. For example, a preservative carried in from a sauce would appear as the preservative class name plus its identifier, not simply be swallowed into the word "sauce". The test is whether the additive does something in the final product. An additive that had a function in the compound ingredient but no longer performs any function once it is diluted into your food (a "carry-over" that is now inert) generally does not need to be declared. If you are unsure whether an additive is still active, treat it as declarable and confirm with your supplier rather than leaving it off. How to write the breakdown in the ingredient list Mechanically, declaring a compound ingredient is straightforward once you have the information. You name the compound ingredient in the statement of ingredients in its correct descending-weight position, then open a bracket and list its components inside, also in descending order by weight within that compound ingredient. For example, a product using a mayonnaise at more than 5% might read: "mayonnaise (vegetable oil, egg, water, vinegar, salt, mustard)". The egg is both a component and a declared allergen, so it appears in the bracket and is also captured in your summary allergen statement. Where a component is itself a compound ingredient, the same logic can nest again. A few practical rules keep the list clean and compliant: Place the compound ingredient in the main list by its total weight in the final food, not by the weight of its parts.. List the components inside the brackets in descending order of their weight within that compound ingredient.. Always surface allergens in plain-English terms and in the summary allergen statement, even for compound ingredients under 5%.. Declare functional additives by class name plus specific name or code number.. Keep wording consistent between the ingredient list and the allergen statement so they never contradict each other.. Get the full breakdown from your supplier You cannot label what you do not know. The whole system depends on your suppliers giving you an accurate, complete breakdown of every compound ingredient you buy — right down to allergens and additives carried inside their own sub-ingredients. A generic name on a delivery docket is not enough to build a compliant label. Ask each supplier for a current product specification sheet for every compound ingredient. It should state the full component list, all allergens present (including anything from their own compound sub-ingredients), and every additive with its function and code. Keep these specifications on file and treat them as living documents — reformulations happen, and a supplier changing a sauce recipe can silently introduce a new allergen into your product. Build a habit of re-confirming specifications periodically and whenever a supplier signals a change. Tying each finished-product label back to the supplier specifications it was built from also makes traceability and any future recall far faster, because you can see exactly which compound ingredient introduced a given allergen or additive. Where compound ingredients quietly hide The failures almost never come from the obvious big-ticket ingredients. They come from the small, easy-to-overlook ones: the coating on a crumbed product, the glaze on a pastry, the stock in a soup base, the flavouring in a snack, the chocolate chips in a muffin. Each is a compound ingredient carrying its own allergens and additives. Because many of these sit well under 5% of the final food, it is tempting to treat them as a single simple word on the label. That is exactly the trap. The 5% concession lets you skip ordinary components, but the allergens and functional additives inside those small compound ingredients still have to be declared. Work through your recipe line by line and ask of every item: is this itself made of other ingredients? If yes, you are holding a compound ingredient, and you need its full specification before you finalise the label. A methodical pass like this is the most reliable way to make sure nothing is hidden. Checklist: Every recipe item has been checked to see whether it is itself a compound ingredient. A current supplier specification sheet is on file for each compound ingredient. Compound ingredients at 5% or more have all components listed in brackets. Every allergen in every compound ingredient is declared, even under 5%. Functional additives are declared by class name plus specific name or code number. The ingredient list and the summary allergen statement agree with each other. Specifications are re-confirmed after any supplier reformulation. Common mistakes: Listing a compound ingredient by name only — "marinade", "seasoning", "sauce" — with no breakdown of what is inside it.. Assuming the 5% concession lets you skip allergens; declared allergens must be declared no matter how small the compound ingredient.. Forgetting that additives performing a technological function in the finished food must be declared regardless of proportion.. Overlooking small compound ingredients — coatings, glazes, stocks, chocolate chips — that carry allergens or additives.. Building a label from a product name or delivery docket instead of a full supplier specification sheet.. Not re-checking specifications after a supplier reformulates, letting a new allergen slip silently into your product..
How to declare a compound ingredient step by step
Go through your recipe and flag anything that is itself made from two or more ingredients — sauces, pastes, blends, coatings, chocolate chips, stocks. Each flagged item is a compound ingredient that needs closer attention.
Obtain a current product specification sheet from the supplier listing all components, every allergen present, and all additives with their function and code. Do not build a label from a product name alone.
Work out each compound ingredient's proportion of the final food. If it is 5% or more, list all its components in brackets. If it is under 5%, you can usually skip the ordinary components — but not the carve-outs below.
Check every compound ingredient against the declared allergen list. Declare any allergen present in plain-English terms, both in the ingredient list and in the summary allergen statement, even when the compound ingredient is under 5%.
For any additive that still performs a technological function in the finished food, declare it by class name plus its specific name or code number, whatever the compound ingredient's proportion.
Place the compound ingredient by its total weight, order the bracketed components by their weight within it, and confirm the ingredient list and allergen statement agree. Keep the supplier specifications on file for traceability.
Frequently asked questions
What is a compound ingredient?
A compound ingredient is an ingredient that is itself made from two or more ingredients. Common examples are sauces, mayonnaise, stock powders, curry pastes, seasoning blends, chocolate chips and crumbed coatings. On a label it appears under one familiar name, but it hides its own list of sub-ingredients — which is why the Food Standards Code sets rules for breaking it down.
When do I have to list a compound ingredient's components?
When the compound ingredient makes up 5% or more of the final food, you must list all its components in brackets after its name. Below 5% you can generally omit the ordinary components. However, any declared allergen and any additive with a technological function must always be declared, regardless of the 5% threshold.
Do I still declare allergens if the compound ingredient is under 5%?
Yes, always. Allergen declaration sits under Plain English Allergen Labelling (PEAL) in Standard 1.2.3 and overrides the 5% rule entirely. If a compound ingredient contains anything on the declared allergen list, you must declare that allergen even if the compound ingredient is a tiny fraction of your food. Undeclared allergens are a leading recall trigger.
How do I show a compound ingredient in the ingredient list?
Place the compound ingredient in the main list by its total weight in the final food, then list its components inside brackets in descending order of their weight within that compound ingredient. For example: "mayonnaise (vegetable oil, egg, water, vinegar, salt, mustard)". Allergens like egg are also captured in the summary allergen statement.
Do additives inside a compound ingredient need to be declared?
If the additive still performs a technological function in your finished food, yes — declare it regardless of the 5% threshold, using its class name plus specific name or code number. An additive that no longer has any function once diluted into your food (an inert carry-over) generally does not need declaring. If unsure, treat it as declarable and confirm with your supplier.
How do I get the information I need to declare a compound ingredient?
Ask your supplier for a current product specification sheet for each compound ingredient. It should list every component, all allergens present (including any from their own sub-ingredients), and every additive with its function and code. Keep these on file, and re-confirm them whenever a supplier changes a recipe, as reformulations can introduce new allergens.