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Allergy Today: Undeclared Allergens in Food – a Case Study from MPI

For many New Zealanders, undeclared allergens in food are a life and death matter. Food labels can protect the consumer but sometimes products with undisclosed allergens still get onto our shelves.MPI Logo - black & green

New Zealand law requires that all pre-packaged food for sale in New Zealand is labelled. Food labels must include a declaration of the presence of specified allergens, so those who are at risk from consuming allergens have access to the information they need.

These rules are in place to protect people. Undeclared allergens are one of the most common forms of non-compliance that New Zealand Food Safety, part of the Ministry for Primary Industries, respond to. When we have evidence, we swing into action.

One example of this is New Zealand Food Safety’s Food Compliance Officer Hasitha Bandara’s recent investigation into rice milk imported from Korea into New Zealand.

“The product was supposed to be milk-free, but someone in Canada got sick because of the presence of milk casein. The rice milk was imported into New Zealand by an importer in Christchurch and sold throughout 18 stores in New Zealand.

“This case was important to me because it could have been fatal to someone in New Zealand if we hadn’t acted on this. Milk products can cause a serious allergic reaction in some people.”

In most cases, food and beverage recalls are voluntarily initiated by a food business when it becomes aware of a potential food safety or suitability issue with the product. In this case, the Food Compliance Services team were alerted to a problem via the International Food Safety Authorities Network (INFOSAN).

“The product had been on shelves for two weeks. Luckily, no one got sick during that time. We had to quickly undertake a consumer level recall of this product. It was important to get it off the shelves as soon as possible.”

The presence of milk should have been stated on the product labelling.

“I asked the importer for information, including the product information form and allergen declaration, so we could review these to see if any allergens were present.

“After the food recall was under way, the food importer employed the specialist services of a food labelling consultant and a food technologist, to figure out what allergens should have been declared on the label.

“I worked with these experts to see if there were any other concerns about sub-ingredients and labelling.

“I reviewed the lab analysis to ensure that there were no other undeclared allergens in the rice milk. On top of the presence of casein, I discovered that it also contained soy lecithin as a sub-ingredient. These proteins can cause allergic reactions, so it’s mandatory that these two allergens are declared.”

Once the food labels had been corrected, they were sent to Hasitha for review.

“I was pleased to find that they are now compliant with the Australia New Zealand Food Standards Code and that this risk to public health had been addressed.”

Anyone selling food in New Zealand must meet labelling and composition requirements under the Food Act 2014 and the Australia New Zealand Food Standards Code. Verification checks are one way of confirming that food businesses are adhering to their food control plans to ensure their products meet food safety requirements.

No food business wants to harm their customers. At New Zealand Food Safety, we’re making it easy to comply. You can find out about putting together a plan to manage this kind of risk on our website, here.

To report an allergic reaction you or your family have had to undeclared allergens in food, call 0800 00 83 33 or email

You can also receive email alerts on food recalls due to undeclared allergens, by going to Subscribe to MPI | MPI | NZ Government, enter your email address and name, then go down to “Email Update Topics” and tick on “Food recalls – allergies”.

Allergy Today, 25 February 2021