Compound Ingredients NZ: What the Under-5% Labelling Exception Allows

A sauce, seasoning or premix can introduce several ingredients into your recipe. A compound ingredient is an ingredient containing two or more ingredients. FSANZ’s ingredient-list guidance explains the under-5% exception and why relevant allergens cannot simply disappear with the smaller components.

This article focuses on ordinary packaged foods that require an ingredients list. For the wider label assessment, use AFVA’s New Zealand food labelling checklist.

Compound ingredient labelling in NZ: choose an approach

Standard 1.2.4, section 1.2.4—5 provides two routes, subject to descending ingoing-weight order:

• Named route: name the compound ingredient and bracket its components. At 5% or more, list all components; below 5%, retain those specified in subsection (6)(b).
• Individual route: list each component as an ingredient of the food for sale. The reduced bracket-list permission belongs to the named route.

Check declarations that remain

Allergens and other covered declarations

Standard 1.2.3, sections 1.2.3—4 to —7 covers relevant declarations from compound ingredients, additives and processing aids, subject to its exemptions. For ordinary ingredients-and-summary labels, a “Contains” statement alone does not replace the required ingredient declarations.

For example, milk powder introduces a milk declaration. FSANZ’s allergen guidance explains required names, bold ingredient declarations and the separate bold summary. Specific exemptions and conditions still matter. For the fuller presentation rules, see AFVA’s plain-English allergen labelling guide.

Additives functioning in the finished food

The question is whether the additive serves a technological purpose in your finished food—not merely in the supplier’s ingredient. FSANZ’s food additive labelling guidance explains this retained duty. Most declared additives use a class name followed by their name or number.

Applicable GM declarations

The retained provisions also reference section 1.5.2—4. FSANZ’s GM food labelling guidance explains the conditional requirements involving novel DNA, novel protein or altered characteristics and applicable exemptions. Do not decide this from supplier origin alone.

Worked example: turn a specification into review questions

Hypothetical illustration: assume 4 kg of seasoning is present in 100 kg of finished food, without processing losses or gains: 4%. The manufacturer chooses the named route. The rows below illustrate possible specification findings; they are not a complete recipe or approved label.

On a small screen, swipe sideways to view all columns. Keyboard users can focus the table region to scroll.

For a real product, use the full specification rather than these illustrative rows. If the additive’s role or a declaration condition is unclear, mark the label decision as open until it is resolved.

Prepare a product-specific review brief

The following is a recommended briefing checklist, not a prescribed testing programme or statutory record format:

1. Identify the exact ingredient. Gather its supplier, product code, specification version, constituent list and relevant declaration information. Request clarification of unexplained carriers or sub-components.
2. Show the quantity basis. Provide the recipe, finished yield and calculation supporting the percentage. For drying, concentration or reconstitution, ask for a product-specific assessment rather than assuming the mixing-sheet percentage answers the finished-food question.
3. State the listing route. Show whether the draft uses a compound name with brackets or lists constituents individually.
4. Explain every proposed omission. Include the component identity, applicable declarations and any finished-food additive role. Existing supplier and product/process evidence may help; this checklist does not automatically require new laboratory testing.
5. Bring the complete artwork. Include the ingredients list, allergen summary, product name and other statements—not only the shortened bracket text.
6. Keep the decision connected to the specification. Record the reviewed versions, outstanding questions and who will implement the changes. Revisit the assessment after a relevant supplier or recipe change.

Common mistakes to avoid

• Removing the compound ingredient itself. A shorter component list is not permission to erase the named ingredient.
• Checking only the supplier’s allergen summary. Ask for enough composition information to assess the components and additive roles.
• Treating an additive’s name as proof of its role. Bring an explanation of what it does in this product.
• Using “may contain” for an intentional milk ingredient. Precautionary wording is not a substitute for the required ingredient declaration.
• Extending the exception to the whole label. Check other applicable duties separately, including warnings and advisory statements.

How AFVA can help with the label decision

AFVA’s food labelling review service includes ingredient lists and allergen declarations, with compliance-gap comments and practical recommendations. It is not food-label approval; final responsibility remains with the food business.

For this enquiry, request label-review consulting only and provide your specification, calculation and artwork. This article does not offer a combined verification, evaluation or certification engagement.

Frequently asked questions

Does the exception apply at exactly 5%?

No. Exactly 5% falls into the 5%-or-more branch, not the below-5% branch.

Can I keep the full component list instead?

Yes. The exception permits reduced listing; it does not require shortening. Review any full list for accurate ingredient order, names and applicable declarations.

Can an allergen be shown only in “Contains”?

Not where the ordinary ingredients-and-summary requirements apply. Check the required ingredient declaration as well as the summary.

Does every supplier additive need to remain?

Not solely because it appears in the supplier specification. Below 5%, assess its purpose in the final food and any separate mandatory declaration.

Is an incomplete specification enough to use the exception?

As a practical release decision, do not treat missing information as evidence for omission. Ask the supplier or reviewer to resolve the relevant questions first.

Resolve the component decisions before printing

Start with the actual compound ingredient, its percentage and your chosen listing route. Keep each proposed omission linked to a clear explanation.

General information only: Requirements depend on the complete food activities, products, processes, locations and sales model. Use current official guidance and confirm the requirements applying to the specific business before relying on a classification, timeframe or record list.