How to Write a Compliant Ingredient List

A compliant ingredient list names every ingredient in the food in descending order of ingoing weight, using names a consumer understands. Under the Australia New Zealand Food Standards Code, allergens from the declared allergen list must be shown in bold in both the ingredient list and a separate summary statement, following Plain English Allergen Labelling (PEAL) rules under Standard 1.2.3. Compound ingredients, food additives and added water all need careful handling. Key takeaways: List every ingredient in descending order of ingoing weight — the amount used when the food was made, not the amount left in the finished product.. Allergens from the declared allergen list must be shown in bold in the ingredient list and repeated in a separate summary statement under Plain English Allergen Labelling (PEAL), Standard 1.2.3.. Compound ingredients (an ingredient made of other ingredients) must be broken down so their own sub-ingredients — especially allergens and additives — are visible.. Food additives are named by their class (function) followed by the additive name or code number, for example Colour (160a).. Some foods are exempt from carrying an ingredient list, but allergen declarations can still be required — check the exemptions before leaving it off.. What a compliant ingredient list must include An ingredient list is a statement of every ingredient that went into the food, written so a consumer can see exactly what they are eating. Under the Australia New Zealand Food Standards Code, most packaged foods that need a label must carry one, headed clearly so it is easy to find — commonly with the word "Ingredients". The core rule is completeness in the right order. Every ingredient is listed, and they appear in descending order of ingoing weight, so the ingredient used in the largest amount comes first. "Ingoing" weight is the weight at the time the food is made, which is why water added during manufacture and any compound ingredients also have to be accounted for. Names matter as much as order. Each ingredient should be identified by a name a consumer will recognise, not an obscure trade term. Certain ingredients — food additives, and any allergen from the declared allergen list — carry extra naming and formatting rules covered in the sections below. Order ingredients by ingoing weight Ingredients are listed from most to least by the weight used when the food was manufactured. This is the single rule people most often get wrong, because they list ingredients in the order they add them, alphabetically, or by how prominent they seem on the plate. None of those is correct — it is strictly by ingoing weight. Added water counts. If water is added during manufacture, it is an ingredient and takes its place in the descending order by the amount added. There are limited conventions for how water is calculated and when very small amounts can be treated differently, so work from the actual formulation rather than guessing. Getting the order right depends on knowing your recipe by weight, not by volume or by "a splash" and "a handful". Convert every component to weight from the formulation you actually produce to, and re-check the order whenever you reformulate. Break down compound ingredients A compound ingredient is an ingredient that is itself made from two or more ingredients — a sauce, a seasoning mix, a pastry, a stock, a chocolate coating. Because consumers cannot see inside it, the Food Standards Code requires that compound ingredients be broken down so their own components appear in the list. In practice this means the compound ingredient is named and then its sub-ingredients are shown, usually in brackets after it, in descending order of their weight within that compound. There are limited allowances for very small compound ingredients, but two things can never be hidden inside a compound: any allergen from the declared allergen list, and any food additive that performs a technological function in the finished food. These must always be declared. The practical risk here is buying a pre-made component and copying only its trade name onto your label. You need the full breakdown from your supplier's specification so nothing — least of all an allergen — disappears inside a bracketed sub-recipe. Declare allergens in bold under PEAL Plain English Allergen Labelling (PEAL), set out in Standard 1.2.3, changed how allergens must be declared so they are impossible to miss. Allergens from the declared allergen list must be shown using specified, plain-English names, in bold type, in the ingredient list itself. The declared allergens include foods such as cereals containing gluten, crustacea, egg, fish, milk, peanuts, soy, tree nuts, sesame, lupin, and molluscs, along with added sulphites at or above the specified level. PEAL also requires a separate summary allergen statement — commonly a "Contains" statement placed close to the ingredient list — that repeats the allergens present, again in bold. So an allergen typically appears twice: once in the ingredient list and once in the summary statement. Use the required plain-English allergen name (for example "milk", "wheat", "soy"), not only a technical term the consumer may not link to the allergen.. Show each declared allergen in bold in the ingredient list.. Repeat the allergens present in a bold summary "Contains" statement near the ingredient list.. Declare allergens even when they sit inside a compound ingredient or a food additive.. Keep any voluntary precautionary "may be present" statement separate from the mandatory declarations.. Name food additives correctly Food additives are not listed by brand or by their chemical trade name. The Code requires them to be identified by their class name — the function they perform, such as Colour, Preservative, Antioxidant or Emulsifier — followed by either the specific additive name or its code number. So an additive appears as, for example, "Colour (160a)" or "Preservative (202)", or with the name spelled out in place of the number. The class name tells the consumer what the additive does; the name or number identifies exactly which one it is. Both parts are needed. Additives still take their correct place in the descending order of ingoing weight, and — as with any other ingredient — if an additive is or contains a declared allergen, that allergen must be declared in bold. Flavourings have their own naming conventions, so treat them carefully rather than assuming they follow the same class-name pattern. Know when an ingredient list is not required Not every food has to carry an ingredient list. The Code provides limited exemptions — for example, some foods sold unpackaged, made and packaged on the premises where they are sold, or in very small packages can be treated differently. These exemptions are specific, so confirm your product genuinely fits one before leaving the list off. The important catch is that an exemption from the full ingredient list does not switch off allergen obligations. Even where a food need not carry a complete ingredient list, information about declared allergens may still have to be provided to the consumer, whether on the label or by another required means. Allergen information is the last thing you should drop. Because the rules interact — exemptions, allergen declarations, and any state or territory requirements for the setting you sell in — check the current Standards and your obligations rather than relying on what a similar product down the street appears to do. Checklist: Every ingredient is listed, with none omitted.. Ingredients appear in descending order of ingoing weight, including any added water.. Compound ingredients are broken down into their sub-ingredients.. Food additives use class name plus additive name or code number.. Every declared allergen is shown in bold in the ingredient list, using its plain-English name.. A separate bold summary allergen ("Contains") statement sits near the ingredient list.. Allergens inside compound ingredients and additives are declared, not hidden.. Any exemption relied on has been confirmed, and allergen information is still provided.. The list has been re-verified after the latest reformulation or supplier change.. Common mistakes: Listing ingredients in the order they are added, alphabetically, or by prominence instead of by descending ingoing weight.. Forgetting that water added during manufacture is an ingredient that must take its place in the order.. Copying a compound ingredient's trade name without breaking down its sub-ingredients, hiding allergens or additives inside it.. Declaring an allergen only in the summary statement, or only in the ingredient list, instead of both, and not in bold.. Naming a food additive by brand or trade name rather than by class name plus the additive name or code number.. Assuming an exemption from the ingredient list also removes the obligation to provide allergen information.. Failing to re-check the list after reformulating or switching suppliers, so the order or allergens fall out of date..