Allergen labelling: what must be bold and the Contains statement
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Allergens on Australian food labels follow Plain English Allergen Labelling, usually called PEAL. The rules are in Standard 1.2.3, Division 3, and Schedule 9 (S9—3) of the Food Standards Code. They say which names must appear, where they go and how they look. This guide goes through them, with the section for each rule in brackets.
Labelwise applies these rules to the allergens you confirm for each ingredient. This guide, like Labelwise, isn't advice: you are responsible for the label you print, and for knowing what is in each ingredient you buy.
The required names
Schedule 9 (S9—3) sets the name to use for each allergen, called its required name. They are:
- peanut;
- the tree nuts: almond, Brazil nut, cashew, hazelnut, macadamia, pecan, pine nut, pistachio and walnut;
- milk, egg, fish, crustacean, mollusc, sesame, soy and lupin;
- wheat, and barley, oats and rye when they contain gluten;
- sulphites.
Some have rules worth knowing:
- Tree nuts are named one by one: almond, Brazil nut, cashew, hazelnut, macadamia, pecan, pine nut, pistachio and walnut.
- Wheat is "wheat" in the ingredient list. The summary statement says both "wheat" and "gluten".
- Barley, oats and rye, when they contain gluten, are named as the cereal in the ingredient list, and the summary says "gluten".
- Soy may be "soy", "soya" or "soybean" in the ingredient list, and is "soy" in the summary.
- Sulphites are declared only when added at 10 mg/kg or more.
Either the singular or the plural form is fine, such as "almond" or "almonds" (1.2.3—8).
Some ingredients made from an allergen are exempt, listed in S9—3: glucose syrups from wheat, alcohol distilled from wheat or whey, isinglass, refined soy oil, soy tocopherols and phytosterols. Whether an exemption applies to an ingredient you buy is for you to confirm with your supplier.
Bold in the ingredient list
Each required name is shown in bold in the ingredient list, in the same size as the rest of the ingredient text (1.2.3—7(1)).
If an ingredient's name already contains the required name, that word is made bold: "Wheat flour". If it doesn't, the required name is added next to the ingredient's name, in brackets, and that is bold: "Butter (milk)" (1.2.3—7(2)(c)).
So a simple dough might read:
Ingredients: Wheat flour, Water, Butter (milk), Salt.
The "Contains:" statement
A summary statement goes with the ingredient list. The rules (1.2.3—7(3)–(5)):
- It starts with the word "Contains".
- It lists only required names, nothing else.
- It is in bold.
- It sits directly next to the ingredient list.
For the dough above:
Contains: milk, wheat, gluten
Note "gluten" as well as "wheat", from the rule for wheat above.
"May contain" is voluntary, and doesn't replace anything
Statements such as "may contain traces of nuts" or "may be present: sesame" are voluntary. The Food Standards Code doesn't regulate them. They don't take the place of the bold names or the "Contains:" statement: an allergen that is in an ingredient is declared under the rules above, whatever else the label says.
Labelwise prints a "may contain" statement if you enter one. It doesn't work one out for you, and it doesn't assess cross-contact, such as shared equipment or a shared kitchen. Whether your food needs a precautionary statement is your judgement.
Check every ingredient's specification
A name doesn't tell you everything in an ingredient. A bought sauce, a spice blend or a stock can carry allergens you wouldn't guess. So:
- Labelwise only suggests allergens from each ingredient's name. You confirm each ingredient's allergens from the supplier's specification.
- Every ingredient must be marked "allergens checked" before anything can be printed. The server enforces this: downloads are refused while any ingredient is unchecked.
- Changing an ingredient's name or components clears its check, so you look again.
- Made products from the ingredient database (bread, sauces, sausages and other commercial foods) are marked "allergens unknown: check the spec", because their names can't show what is in them.
- Labelwise never says "no allergens" for an ingredient that hasn't been checked.
When a supplier changes a product, check its specification again and update the recipe.
Make this label
Enter your recipe, confirm each ingredient's allergens from its specification, and Labelwise writes the ingredient list with the required names in bold and the "Contains:" statement beside it.