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Allergy Today Advice Article: Making Food Labels Safer

Reading labels on food should be a lot easier when Australia and New Zealand’s Food Standards Code is amended later this year. Labels on manufactured food have been required to list the main allergens (milk, eggs, peanuts, tree-nuts, soy, wheat, fish and shellfish) since 2004. However, reviews and case reports since then have found a lot of confusion and inconsistencies which have made it difficult for consumers and industry alike. young-caucasian-woman-is-watching-into-product-composition-picture-id646120786-57

Consumers rely on labels to provide information about allergen content so they can make safe and informed food choices. A potentially fatal allergic reaction could be the result of a consumer not being able to identify the presence of an allergen in a food. On the other hand, they could be unnecessarily excluding foods due to the uncertainty about the presence of an allergen. Consumers with food allergy are likely to have to make a much greater effort in reading labels to find allergen information than other people. Surveys have also indicated consumers don’t have much confidence in allergen labelling.

The lack of clarity also impacts on the industry, with uncertainty in how to comply with requirements, and for regulators in enforcing the Code.

To address these issues, Food Standards Australia developed and consulted on a proposal called ‘Plain English Allergen Labelling’ in 2018. Feedback on this has led to further development, with recommendations and a second round of consultation currently underway. They identified three regulatory options, with recommendations for Option 3.

Option 1: Maintain the status quo (i.e. no change to allergen declaration requirements).

Option 2: Declare allergens using mandatory specified terms in bold font.

Option 3: Declare allergens using mandatory specified terms in bold font, with additional requirements to declare in the statement of ingredients as well as in a separate allergen summary statement.

Assuming submissions support the proposal, it should become law later this year.

The main proposals are:

· Allergens to be declared in plain english (using specified terms) in bold font in the ingredients list. (Currently, technical terms can be used such as ‘sodium caseinate’ instead of milk; and the font is not defined).

· A separate allergen summary statement (e.g. ‘Contains….’) will be required, with the terms specified. (Currently, although many manufacturers use ‘contains’ statements, these are voluntary and not regulated. This could mean that, where a product does not have a ‘contains’ statement, a consumer might assume, incorrectly, it does not contain any allergens).

· Molluscs will be added to the list. This covers seafood such as calamari, mussels, oysters and scallops. (Currently only fish and crustacea are required to be declared).

· Individual tree nuts are to be listed: almond, Brazil nut, cashew, hazelnut, macadamia, pecan, pine nut, pistachio and walnut. (Currently only the term ‘Tree Nuts’ is required)

· Wheat, barley, rye, oats or spelt or their hybrids to be declared. (Currently the requirement is for cereals containing gluten to be declared; this regulation will require specific cereals as well as gluten to be declared)

Allergy New Zealand strongly supports Option 3, which requires the ‘Allergen Summary Statements’ in addition to the other changes. This option will make reading labels a lot easier for consumers.

If you would like to know more, and/or make a submission, go to:

The deadline for submissions is 6pm (Canberra time), 27 February 2020

Note: Separate work is ongoing at an international level (at CODEX Alimentarius under the World Health Organisation) towards regulation of PAL (precautionary allergen labelling) aka ‘may contain’ statements. Once international agreement has been reached on a Code of Practice for Food Allergen Management, including the use of reference doses for determining whether a ‘PAL’ is required or not, it will be possible for regulations to be introduced through Australia and New Zealand’s Food Standards.


Penny Jorgensen, Allergy Advisor, Allergy New Zealand