Information You Must Provide for Unpackaged Food

Even when the Food Standards Code does not require a printed label, food sold loose or unpackaged must still carry key information. You must be able to give the food's name or description, declare any of the regulated allergens it contains, and display any mandatory warning or advisory statements. Allergen details in particular must be shown with the food or supplied to the customer on request, in writing if they ask. Key takeaways: Unpackaged food is exempt from a full printed label, but not from providing key information such as the food's name, allergens and any mandatory warning or advisory statements.. Allergen information is the critical requirement: it must be displayed with the food or given to the customer on request, and in writing if the customer asks.. The declared allergens cover gluten-containing cereals, crustacea, molluscs, egg, fish, milk, peanuts, tree nuts, sesame, soy, lupin and added sulphites at 10 mg/kg or more.. Staff must know what is in each dish so they can answer allergen questions accurately; a guess is never acceptable.. Keep supplier and recipe records so your information stays correct and you can respond quickly during a recall.. When a printed label is not required The Food Standards Code sets out when food must carry a label and when it does not. Food that is not in a package, food packaged in front of the customer, food sold from a bulk container that the customer serves themselves, and food made and packaged on the premises where it is sold are common examples that are exempt from a full printed label. Restaurant meals, bakery items sold loose, deli products, self-serve salad bars and market stalls typically fall into this group. Food sold unpackaged, such as a meal served on a plate or bread sold loose.. Food packaged in the presence of the purchaser, such as a sandwich made to order.. Food dispensed from a bulk bin or self-service display.. Food made and packaged on the premises from which it is sold.. Being exempt from a label is not being exempt from information An exemption from the label does not switch off every obligation. The Code still requires certain information to reach the customer, either displayed in connection with the food or provided when the customer asks. What changes is the format, not the fact that the information must exist and be available. In practice this means you can drop the elements that only make sense on a package, such as the nutrition information panel, percentage ingredient labelling and a directions-for-use statement. What you cannot drop is anything that protects the customer's health, above all allergen information and any mandatory warning or advisory statement. Allergen information is the non-negotiable requirement Allergen declarations apply to unpackaged food just as they do to packaged food. Under the Plain English Allergen Labelling (PEAL) requirements in Standard 1.2.3, the presence of a declared allergen must be made known to the customer. For unpackaged food this information must be either displayed in connection with the food or provided to the purchaser on request. If a customer asks for the allergen information in writing, it must be able to be provided in writing. This is why a verbal 'I think it's fine' is never enough. The declared allergens that must be identified are: cereals containing gluten (wheat, rye, barley, oats and their hybrids), crustacea, molluscs, egg, fish, milk, peanuts, tree nuts, sesame, soy, lupin, and added sulphites in concentrations of 10 mg/kg or more. Display allergen information beside the food, or state clearly that it is available on request.. Be able to provide it in writing if the customer asks.. Use the specific, plain-English allergen names, not vague terms.. Make sure the source of the information, such as a recipe card or supplier specification, is kept up to date.. The food's name and mandatory statements The customer needs enough information to know what the food is. For unpackaged food this usually means the name or a description of the food is displayed or given on request, so the food is not misleading. A pie labelled simply as 'pie' at a self-service cabinet, for instance, should still let the customer establish what kind of pie it is and what it contains. Some foods also carry mandatory warning or advisory statements that must reach the customer regardless of packaging. Examples include advisory statements for foods such as unpasteurised products, and warning statements where the Code requires them. These do not disappear because the food is sold loose; the information must still be displayed with the food or provided on request. Self-service and displayed food Where customers serve themselves, from a salad bar, bulk bin or open display, you carry extra responsibility because there is no server to answer questions at the point of choice. The Code requires that self-service food is protected from contamination and that the customer can still access the information they need to choose safely. Practical steps include placing allergen and product information on or immediately beside each container, keeping ingredients physically separated so allergens are not transferred between them by shared utensils, and providing separate serving tools for each item. Signage stating that full allergen information is available from staff is a simple, effective backstop, provided staff can actually deliver it. Country of origin and other consumer-law information Separate from the Food Standards Code, many foods must carry country-of-origin information under Australian Consumer Law, and some of those rules reach unpackaged food such as loose fruit, vegetables and seafood in certain settings. These requirements are administered by consumer-law regulators, not FSANZ, and the detail depends on the food and how it is sold. Because these obligations sit outside the Food Standards Code and can vary by food type and jurisdiction, confirm what applies to your products with the relevant regulator. Requirements that touch on registration, notification or local trading are administered by state and territory regulators and local councils and vary by location, so check with your local council or state regulator before you rely on any general rule. Keeping the information accurate and traceable The information you provide is only as reliable as the records behind it. To declare allergens correctly you need to know exactly what goes into each dish, including sub-ingredients in sauces, marinades, dressings and pre-made components bought from suppliers. Keep supplier specifications and up-to-date recipe or ingredient records, and re-check them whenever a supplier, product or recipe changes. Good records also matter for recalls. If a supplied ingredient is recalled, or you discover an allergen was not declared, you need to trace which products were affected and act quickly. Train every staff member who handles or sells food to find and communicate allergen information, and to escalate any uncertainty rather than guess. Checklist: Every unpackaged food line has a current, accurate ingredient record. Declared allergens are identified for each food using plain-English names. Allergen information is displayed with the food or clearly offered on request. The information can be provided in writing if a customer asks. The food's name or description is available so the food is not misleading. Any mandatory warning or advisory statements are shown or provided on request. Self-service items are separated with dedicated utensils to prevent allergen transfer. Staff are trained to find and communicate allergen information and to escalate uncertainty. Supplier specifications and recipe records are kept up to date for traceability and recalls. Common mistakes: Assuming that no label means no information obligations, and providing nothing at all.. Answering allergen questions verbally with a guess instead of checking a reliable record.. Overlooking allergens hidden in sauces, dressings, marinades and bought-in components.. Using shared utensils across self-service containers, transferring allergens between foods.. Failing to update ingredient records when a supplier, product or recipe changes.. Being unable to provide allergen information in writing when a customer requests it..