Warning and Advisory Statements on Food Labels

Warning statements are mandatory safety alerts the Food Standards Code requires on certain foods, such as royal jelly, unpasteurised products and some sports foods. Advisory statements provide other required information, like the presence of aspartame, caffeine, added phytosterols or unpasteurised milk. Both differ from allergen declarations. This guide explains which statements apply, where they belong on the label and how to word them, so your packaging meets Australian labelling requirements. Key takeaways: Warning statements are compulsory safety alerts for specific foods; they must appear on the label and cannot be left off.. Advisory statements tell consumers something they may need to know (for example the presence of aspartame or caffeine) and are also mandatory when the trigger applies.. Warning and advisory statements are separate from allergen declarations, though the same product may need all three.. Royal jelly carries a specific mandatory warning about severe allergic reactions and, in rare cases, death.. Where wording is prescribed in the Code, use it exactly; where a state or council overlay may apply, confirm with your regulator.. Common triggers at a glance: Food / ingredient, Type, What the label must convey. Royal jelly (and foods containing it) — Warning — Associated with severe allergic reactions and, rarely, fatalities. Aspartame / added phenylalanine — Advisory — Contains phenylalanine. Added caffeine / guarana — Advisory — Presence of caffeine, where the Code requires. Added phytosterols / phytostanols — Advisory — Intended use and suitability information. Unpasteurised milk products (where permitted) — Advisory — Product is made from unpasteurised milk. Formulated supplementary sports foods — Warning — Not suitable for children / use under supervision, per Code. Warning vs advisory statements: what's the difference? The Australia New Zealand Food Standards Code treats warning statements and advisory statements as two different things, and it helps to keep them separate in your mind. A warning statement is a mandatory safety alert that must appear on the label of a specific food, in prescribed or near-prescribed wording, because that food carries a genuine risk to some people. An advisory statement is information that must be declared so consumers can make an informed choice, but it is not framed as a safety warning. Both are required by the Code when the relevant trigger applies, so neither is optional. Allergen declarations (for example wheat, milk, egg, peanut, tree nuts, soy, fish, crustacea, sesame and lupin) are a third, separate category handled under the Code's allergen requirements. A single product can carry all three at once, so treat each requirement on its own merits rather than assuming one covers another. Warning statement: mandatory safety alert (e.g. royal jelly).. Advisory statement: mandatory disclosure so consumers can choose (e.g. aspartame, caffeine).. Allergen declaration: separate mandatory requirement for the listed allergens.. One product may need warning, advisory and allergen information together.. Foods that require a warning statement Warning statements apply to a defined list of foods in the Code, not to food generally. The best known is royal jelly, which must carry a warning that it has been associated with severe allergic reactions and, in rare cases, fatalities, especially in asthma and allergy sufferers. This warning applies to royal jelly sold as a food and to foods containing royal jelly. Certain formulated caffeinated beverages and formulated supplementary sports foods also carry mandatory statements, for example that the product is not suitable for children, pregnant or lactating women, or that it should be used only under medical or dietetic supervision. Because the exact list and wording are set out in the Code and can be updated, always check the current Code text for the food you are labelling and confirm any additional requirements with your state or territory regulator. Royal jelly and foods containing it: severe allergic reaction / fatality warning.. Formulated supplementary sports foods: 'not suitable for children under 15 years of age or pregnant women' type wording.. Formulated caffeinated beverages: not recommended for children, pregnant or lactating women, and caffeine-sensitive people.. Always verify the current prescribed wording in the Food Standards Code.. Foods and ingredients that require an advisory statement Advisory statements cover ingredients and foods where consumers benefit from a clear heads-up, even though the food is safe for most people. Common triggers include aspartame or other phenylalanine sources (a statement that the product contains phenylalanine, important for people with phenylketonuria), guarana or added caffeine, added phytosterols, and foods containing unpasteurised milk or products made from unpasteurised milk. Other examples include statements about certain quinine content, or that a product contains a particular ingredient the Code singles out. The advisory statement must be worded and placed so a consumer can find and read it. As with warnings, the Code sets out which ingredient triggers a statement and, in many cases, the words to use, so cross-check each ingredient in your recipe against the current Code requirements. Aspartame / added phenylalanine: 'contains phenylalanine' advisory.. Added caffeine or guarana: advisory about caffeine content where required.. Added phytosterols / phytostanols: advisory about intended use and suitability.. Unpasteurised milk and products made from it: advisory that the product is unpasteurised.. Quinine and certain other ingredients: advisory where the Code specifies.. Unpasteurised products: a special case Unpasteurised (raw) milk and some products made from unpasteurised milk sit in a tightly controlled part of the Code because raw milk can carry harmful pathogens. Where the Code permits such a product to be sold, it typically requires clear labelling that the product is made from unpasteurised milk so consumers can make an informed decision. Selling raw drinking milk for human consumption is heavily restricted in Australia, and the rules around what may be sold and how it must be labelled vary by product type and jurisdiction. If your product involves unpasteurised milk in any form, do not rely on a generic template. Confirm exactly what is permitted, and the required wording, with your state or territory regulator and, where relevant, your local council before you print anything. Raw drinking milk for human consumption is heavily restricted in Australia.. Where permitted, unpasteurised products generally must be labelled as such.. Requirements differ by product and jurisdiction — do not assume.. Confirm what is legal to sell and how to label it with your regulator.. Where and how the statement must appear A warning or advisory statement only does its job if a consumer can actually find and read it, so the Code sets legibility expectations. Warning statements generally must appear on the label in a type size no smaller than a set minimum (commonly 3 mm, or 1.5 mm on small packages), in English, and in a way that stands out against the background. Advisory statements must also be legible and prominent, though some may be provided in connection with the food rather than on the package where the Code allows (for example for unpackaged or certain foods). Do not bury a warning in the ingredient list or reduce it to unreadable fine print. Keep it in clear, contrasting type, in plain English, and use the prescribed wording where the Code sets it out rather than paraphrasing. English, legible, and prominent against the background.. Minimum type size applies to warning statements (commonly 3 mm; 1.5 mm on small packages).. Use the Code's prescribed wording where it exists — don't paraphrase.. For some foods (e.g. unpackaged), the statement may be displayed with the food rather than on a package.. How this interacts with allergen and other labelling rules Warning and advisory statements sit alongside the rest of your label, not instead of it. You still need your mandatory allergen declarations, ingredient list, nutrition information panel, name and description of the food, lot identification, business details, date marking and country of origin as applicable. A royal jelly product, for instance, needs its warning statement and its ordinary allergen and ingredient labelling. Avoid the trap of thinking a caffeine advisory removes the need to declare caffeine in the ingredient list, or that an 'unpasteurised' advisory replaces allergen labelling for milk. Each requirement stands on its own. Build a labelling checklist for every product so nothing drops out when you reformulate, change suppliers or update packaging. Statements are additional to allergen, ingredient and nutrition labelling.. A caffeine advisory does not replace declaring caffeine in the ingredient list.. An 'unpasteurised' advisory does not replace milk allergen labelling.. Re-check every requirement whenever you reformulate or rebrand.. Checklist: I have identified my food category and listed every ingredient.. I have checked each trigger against the current Food Standards Code.. Warning statements use the exact prescribed wording.. Advisory statements convey the required information clearly.. The statement is legible, in English, and meets the minimum type size.. The statement is separate from, not buried in, the ingredient list.. Allergen, ingredient, nutrition and date-marking labelling is still complete.. I have confirmed any state, territory or council overlays for restricted products.. Common mistakes: Assuming an allergen declaration covers a required warning or advisory statement.. Paraphrasing or softening a prescribed warning instead of using the Code's exact words.. Burying the statement in the ingredient list or in unreadable fine print.. Treating a caffeine or unpasteurised advisory as a substitute for ingredient or allergen labelling.. Using a generic template for unpasteurised milk products without checking what is legal to sell.. Forgetting to re-check statements after reformulating or changing suppliers..