Labelling Food Made and Packaged On-Site

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 needs a full label: Situation, Full retail label required?. Made and packaged on the premises, sold direct to the consumer — Generally no. Packaged in the presence of the customer — Generally no. Sold to another business or premises for resale — Generally yes. A nutrition content or health claim is made — Yes, plus a Nutrition Information Panel. 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 the counter, or a printed sticker on the pack. What you cannot do is guess, omit an allergen, or rely on staff memory. Cross-contamination risk in a shared kitchen also matters: many businesses add a clear statement about the possibility of trace allergens, though precautionary statements do not replace the mandatory declaration of allergens that are deliberately present. Use the required plain-English allergen names, not technical synonyms, and name the specific tree nut.. Display allergen information in connection with the food, or provide it on request.. Cover the full recognised allergen list, including added sulphites at 10 mg/kg or more.. Keep an accurate, up-to-date allergen matrix for every product and update it when a recipe or supplier changes.. Date marking and shelf life Date marking is dealt with under Standard 1.2.5. For packaged food generally, a 'use-by' date is required where the food must be consumed by a certain date for health or safety reasons, and a 'best before' date applies to most other packaged foods with a shelf life of less than two years. For food made and packaged on the premises where it is sold, the food is generally exempt from bearing a full label, so a printed date mark is not always mandatory on the pack itself in the same way it would be for shelf-stable retail products. However, date marking is closely tied to food safety and to your lot identification and traceability duties. For high-risk, ready-to-eat and perishable items, applying a use-by date is strong best practice and is often expected by councils and auditors, even where the strict letter of the labelling exemption might not compel it. Because the interaction between the labelling exemption, date marking and your food safety program can be nuanced, and because Standard 3.2.2A now places additional food safety management obligations on many businesses handling unpackaged, ready-to-eat, potentially hazardous food, confirm your specific date-marking expectations with your local council or state or territory food regulator. When in doubt, date-mark perishable on-site food; it protects customers and evidences your due diligence. Use-by dates apply where food must be eaten by a date for safety; never sell past a use-by date.. Best-before dates apply to most other packaged foods with a shelf life under two years.. On-site made-and-packaged food may be exempt from a printed date mark, but date-marking perishable items is strong best practice.. Align date marking with your food safety program and Standard 3.2.2A obligations.. Lot identification, supplier details and traceability Lot identification is one of the most overlooked obligations for on-site packaged food. A lot mark identifies the batch a food comes from and the premises where it was packed or prepared, so that if a problem emerges the affected products can be found and recalled quickly. Even when a full label is not required, the ability to identify a lot must be maintained. In many small operations a date mark plus your business name and address effectively satisfies lot identification, because together they help pinpoint what was made, where and when. The name and business address of the responsible supplier must be available so customers and regulators can identify who stands behind the food. A PO box alone is generally not sufficient as a business address for these purposes. Good traceability is not just a labelling formality; it is the backbone of an effective recall. Keep records that link each batch to its ingredients and suppliers, so that if an ingredient is recalled upstream you can identify every affected product you made. This is increasingly important under strengthened food safety requirements and is exactly the kind of evidence an environmental health officer looks for. Maintain a lot identification system for every batch you make and pack.. A date mark combined with business name and address can satisfy lot identification in many small businesses.. Provide a genuine business address, not a PO box alone.. Keep batch-to-ingredient records to support a fast, accurate recall.. When the exemption falls away The made-and-packaged-on-site exemption is narrower than many businesses assume, and several common scenarios pull food back into full labelling. If you make a nutrition content claim or a health claim (for example 'high in protein', 'low fat', 'good source of fibre'), you generally trigger the requirement for a Nutrition Information Panel and must meet the associated conditions in Standard 1.2.7 and Standard 1.2.8, even for on-site food. If you sell the same food to another business for resale, supply it to a distributor, or send it to a different premises, the exemption typically no longer applies and a full label is generally required. Wholesale supply is treated very differently from selling directly to the final consumer over your own counter. Selling through a third-party platform or a market stall that is not 'the premises from which it is sold' can also change your obligations. Country of origin labelling is a separate regime under Australian Consumer Law (the Country of Origin Food Labelling Information Standard, administered with the ACCC), not the Food Standards Code, and it has its own rules and exemptions, including for some food made and packaged where it is sold. Because these boundaries are fact-specific, and because getting them wrong can mean non-compliant product on shelves, check with your state or territory food regulator and, for country of origin, the ACCC guidance before you assume an exemption applies. Making a nutrition content or health claim generally triggers a Nutrition Information Panel.. Selling to another business or premises for resale generally requires a full label.. Wholesale and third-party channels can change your obligations.. Country of origin labelling is a separate legal regime with its own rules.. Worked examples: Sandwiches made and wrapped in your own cafe: A cafe assembles and wraps sandwiches behind the counter and sells them directly to customers. These generally do not need a full retail label, but the cafe must still declare allergens in connection with the food or on request, and can trace each batch through a date code plus its business name and address. Wholesaling baked goods to another cafe: A bakery that supplies its slices to a separate cafe for resale can no longer rely on the on-site exemption for that product. Because it is sold to another business, a full retail label is generally required, so the bakery adds the mandatory label elements before supplying. Checklist: Every product is genuinely made and packaged on the premises where it is sold direct to the consumer.. An allergen matrix exists for every item, based on verified supplier specifications, using required plain-English names (including the specific tree nut).. Allergen information is displayed in connection with the food and can be accurately provided on request.. Lot identification is in place for every batch (for example, date code plus business name and address).. The responsible business name and a genuine business address are available to customers and regulators.. Perishable and ready-to-eat items carry appropriate use-by dates.. No nutrition content or health claim is made without meeting its conditions and providing a Nutrition Information Panel.. Any food sold to another business or premises carries a full retail label.. Staff are trained on allergen handling, cross-contamination and how to answer information requests.. Obligations have been confirmed with the local council and state or territory food regulator.. Common mistakes: Assuming 'no label required' means 'no rules apply' and failing to declare allergens.. Using technical or synonym ingredient names, or only 'tree nuts', instead of the required plain-English allergen names.. Relying on staff memory for allergen answers instead of a documented, up-to-date allergen matrix.. Forgetting lot identification, leaving the business unable to trace or recall a batch.. Making a casual nutrition content or health claim on a ticket or menu without providing a Nutrition Information Panel.. Wholesaling on-site food or sending it to another premises without adding a full retail label.. Not date-marking perishable ready-to-eat items and treating the labelling exemption as a food safety exemption.. Listing only a PO box instead of a genuine business address for the responsible supplier..