What Australian food businesses must do when packaging food made on-site: allergen declaration, date marking, lot ID and when a full label is required.…
Food you make and package on the same premises where you sell it generally does not need to carry a full retail label under the Food Standards Code. But "no label required" is not "no rules". You must still declare allergens, provide certain information on request, and honour any claims you make. This guide explains what generally applies, what is exempt, and how to stay compliant. Key takeaways: Food made and packaged on the premises from which it is sold is generally exempt from bearing a full retail label under Standard 1.2.1 of the Food Standards Code.. The exemption does not remove allergen obligations. Allergens must still be declared using the required plain-English names, either in connection with the food or provided to the purchaser on request.. Certain information (name of the food, lot identification, supplier name and address, warning and advisory statements, storage and use directions) must still be provided, usually on request, even when a full label is not required.. The exemption can fall away. If you make a nutrition content or health claim, sell to another business for resale, or sell by another method, full labelling requirements can be triggered.. Requirements vary by state and territory and by product. Confirm your specific obligations with your state or territory food regulator and local council.. When on-site food is (and isn't) required to bear a full label Standard 1.2.1 of the Australia New Zealand Food Standards Code sets out when food for sale must carry a label and when it does not. One of the key exemptions is food that is 'made and packaged on the premises from which it is sold'. In plain terms, if you produce the item and pack it in the same shop, cafe, bakery, deli or commercial kitchen from which the customer buys it, that item generally does not need a full retail label with every mandatory element. This is why the sandwich you assemble and wrap behind the counter, the salad you portion into a container at your deli, or the loaf you bake and bag in-store usually does not need the same label as a product on a supermarket shelf. Other related exemptions in Standard 1.2.1 include food packaged in the presence of the purchaser, and food delivered packaged and ready for consumption at the customer's express order. Crucially, 'exempt from a label' is not the same as 'exempt from all information rules'. The Code still requires certain information to be available, and allergen obligations apply regardless. The exemption is about the format and the physical label, not about your duty to inform customers so they can eat safely. Because the precise application of these exemptions can depend on how and where you sell, confirm your situation with your state or territory food regulator. Made and packaged on the same premises where sold: generally no full label required.. Packaged in front of the customer: generally no full label required.. The same food sent to another premises or another business for resale: a full label is generally required.. What you must still provide even without a full label When food is not required to bear a label because it is made and packaged on-site, Standard 1.2.1 still requires that specified information either be displayed in connection with the food or be provided to the purchaser on request. Treat this as a live obligation, not a technicality: an environmental health officer can ask, and so can a customer. The information that most commonly must still be available includes the name or a description of the food, the name and business address of the supplier (the business responsible for the food), lot identification, any mandatory warning statements and advisory statements, directions for use or storage where these are necessary for health or safety, and information about certain substances such as added sulphites or specific ingredients where required. Allergen information sits above all of this. It is never optional and cannot be withheld in a way that puts a customer at risk. In practice, most well-run businesses display allergen information openly and keep the remaining details (such as full ingredient breakdowns and supplier address) documented and ready to hand over on request. Building this into your standard operating procedures protects both the customer and the business. Name or description of the food.. Name and business address of the supplier responsible for the food.. Lot identification (so a batch can be traced and recalled).. Mandatory warning and advisory statements where they apply.. Allergen declarations (always required).. Storage and use directions where needed for safety.. Allergen declaration: PEAL applies to on-site food too Allergen labelling is governed by Standard 1.2.3 and the Plain English Allergen Labelling (PEAL) requirements, which became mandatory on 25 February 2024 (the transition period, and the further stock-in-trade period, have since ended). PEAL applies to food that must bear a label and, in a modified way, to food that is exempt from bearing a label, including food made and packaged on-site. For food that does not require a label, allergen information must be displayed in connection with the food or provided to the purchaser on request, and it must use the required plain-English names. For example, you must declare 'wheat' rather than a technical synonym, and you must name the specific tree nut (such as 'almond' or 'cashew') rather than only 'tree nuts'. For cereals containing gluten, the required approach is to declare 'gluten' where it is present, so barley, rye and oats are shown as 'gluten', while wheat is declared as 'wheat' (and 'gluten' as well where gluten from wheat is present). The declarable allergens cover the recognised list: cereals containing gluten, crustacea, molluscs, egg, fish, milk, tree nuts, peanut, sesame, soy, lupin and added sulphites (at 10 mg/kg or more). Practically, this means a legible allergen statement on a menu board, a ticket beside the product, a folder at t
How to set up compliant labelling for on-site food
Check that each product is genuinely made and packaged on the premises where it is sold directly to the consumer. If any item is wholesaled, sent elsewhere, or sold through another business, treat it as requiring a full label and confirm with your state or territory regulator.
List every menu and packaged item against the recognised allergen list, using the required plain-English names (including the specific tree nut). Base it on verified ingredient specifications from your suppliers, not assumptions, and record where cross-contamination is possible in your kitchen.
Choose a reliable method to display allergens in connection with the food, such as ticketing at the point of sale, a menu-board statement, or printed stickers. Ensure staff know that allergen information must also be provided accurately on request.
Implement a simple lot system (often a date code plus business name and address) so every batch is traceable. Keep the responsible business name and a genuine business address available to customers and regulators.
Even where a printed date mark is not strictly mandatory for exempt food, apply use-by dates to high-risk, ready-to-eat and perishable products as best practice, and integrate this with your food safety program.
If any label, ticket or menu makes a nutrition content or health claim, confirm the product meets the conditions and provide the required Nutrition Information Panel and supporting information.
Confirm your specific obligations with your local council and state or territory food regulator, then review your allergen matrix and labelling whenever a recipe, ingredient or supplier changes.
Frequently asked questions
Do I need to put a label on sandwiches I make and wrap in my own cafe?
Generally no full retail label is required if the sandwich is made and packaged on the premises where it is sold. However, you must still declare allergens using the required plain-English names, either displayed with the food or provided on request, and be able to give other required information such as the business name and address. Confirm specifics with your local council.
Does allergen labelling (PEAL) apply to food that doesn't need a label?
Yes. Under Standard 1.2.3, allergens must still be declared for food that is exempt from bearing a label. The information must be displayed in connection with the food or provided to the purchaser on request, using the required plain-English names. The obligation to inform customers about allergens never disappears, even when a full label is not required.
Do I have to put a use-by date on food I package on-site?
Food made and packaged where it is sold is generally exempt from bearing a full label, so a printed date mark is not always strictly mandatory on the pack. However, applying use-by dates to perishable, ready-to-eat items is strong best practice, supports traceability, and is often expected by councils. When in doubt, date-mark perishable food and confirm expectations with your regulator.
What is lot identification and do I still need it?
Lot identification links a product to the batch and premises where it was made, so it can be traced and recalled if there is a problem. It is required even for food exempt from a full label. In many small businesses a date code combined with the business name and address is enough to satisfy it. Keep batch-to-ingredient records to support recalls.
If I sell my baked goods to another cafe, do the rules change?
Yes. The made-and-packaged-on-site exemption generally applies only when you sell directly to the final consumer at your own premises. Supplying another business for resale is typically wholesale and usually requires a full retail label with the mandatory elements. Confirm your obligations with your state or territory food regulator before supplying other businesses.
Can I say my on-site product is 'high in protein' without a label?
Making a nutrition content claim like 'high in protein' or a health claim generally triggers the requirement for a Nutrition Information Panel and the conditions attached to that claim, even for on-site food. If you are not prepared to provide compliant nutrition information and meet the claim conditions, it is safer not to make the claim.