Food Additive Labelling NZ: Choose the Class, Name or Number

A supplier specification may give a trade name, a chemical name and an additive number for the same preparation. The label reviewer still needs to identify the substance actually used, its role in the finished food and the declaration rule that applies.

This guide helps New Zealand manufacturers, importers and food brands check additive wording where an ingredients statement is required. Confirm that information route first; exceptions do not remove every other mandatory declaration. It is not permission to use an additive, a dosage guide or a complete assessment of every food category.

Separate use permission from label declaration

Standard 1.3.1 on food additives addresses when additives may be used and the relevant restrictions. A substance appearing in a names-and-numbers list is not, by itself, permission to add it to every food or at any level. Check the applicable food category, permission and conditions before treating the formulation as settled.

The declaration question is different: given the actual substance and its assessed use, what must the ingredients statement say? A correctly written name does not cure an unpermitted use. Equally, an acceptable formulation still needs the right consumer information.

Keep these conclusions in separate fields in the product file. This makes it clear whether an open question concerns permission, function, quantity, identity or label wording. Do not ask a designer to resolve a technical formulation question by choosing a shorter name.

Identify the substance and its role in this food

Begin with the current specification for the exact supplier product code. A bought-in preparation may contain several substances, carriers or other ingredients. Obtain enough information to identify what enters the finished food, rather than copying the preparation’s sales name into the label.

FSANZ’s food additive labelling guidance explains that a class name indicates the additive’s purpose. A substance that can serve several functions therefore needs assessment in the actual application. Section 1.2.4—7 requires the most appropriate class name where more than one class is possible.

Record the role being relied on and who can explain it. A specification describing the supplier’s intended uses may help, but does not necessarily establish the function in your particular food. Ask the supplier or a suitable technical reviewer to resolve an unclear identity or role before the artwork is released.

Carry-over and compound ingredients need their own checks. Standard 1.3.1 contains a conditional carry-over permission; that does not automatically settle ingredients-statement treatment. The named under-5% compound-ingredient route retains additives that perform a technological purpose in the final food, alongside applicable mandatory declarations. Our compound-ingredient listing guide develops that separate decision.

Choose the applicable declaration route

Standard 1.2.4, section 1.2.4—7 sets the declaration routes. Use Schedule 7 for class names and Schedule 8 for the substance names and code numbers together; they answer different parts of the question.

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Declaration illustration only: FSANZ gives colour (Caramel I) and colour (150a) as name and number alternatives. Schedule 8 links Caramel I to 150a. This illustrates wording; it does not establish that a particular product may use that colour or that every other label requirement has been met.

Preserve letters and other distinctions in the actual code. Caramel I and Caramel IV have different entries. A shortened number selected from memory can identify the wrong substance. The Code’s definition of code number also permits the Schedule 8 number preceded by E; an E prefix does not remove the need to match the correct entry.

Check the specific enzyme and flavouring provisions

Do not turn the usual class-plus-name-or-number format into an unconditional rule. Section 1.2.4—7 permits an enzyme to be listed as enzyme without its specific name. It separately describes the wording for a flavouring substance. Those routes still depend on the actual substance and other applicable requirements.

The flavouring provisions identify substances that must be specifically declared through the additive route when added as flavouring or within a flavouring. The list includes specified glutamates and related flavour-enhancing substances. Check the complete list in subsection (5) instead of assuming every substance inside a flavour preparation can disappear under flavouring.

Subsection (6) also requires added caffeine to be listed as caffeine, whether it is added as a flavouring substance or otherwise. This article does not determine caffeine permissions or any additional beverage declarations; those are separate product-specific checks.

An additive number does not settle allergen information. Check relevant mandatory declarations and their exceptions for ingredients, additives and processing aids. The New Zealand allergen labelling guide covers the separate presentation question. Do not substitute a class name or a voluntary precautionary statement for an applicable required declaration.

Build a short additive declaration worksheet

The following fields are AFVA’s recommended review aid, not an official form. Use them for the actual product and link them to existing formulation controls rather than creating a competing recipe.

• Finished product: food name, formulation version and intended sales market.
• Supplied material: supplier, product code, current specification and substance identity.
• Use assessment: reference to the applicable permission and conditions; identify any unresolved question.
• Function and route: actual purpose, relevant class and the provision supporting any exception or omission.
• Name or number: exact Schedule 8 entry and the proposed bracketed wording where required.
• Other declarations: applicable allergen or other information needing a separate assessment.
• Artwork connection: current ingredients statement, review comment, responsible person and final file reference.

For example, if the supplier document identifies a blend but not its constituent additives, record that gap. A reviewer cannot reliably choose the final entries from the brand name alone. Obtain the missing information or suitable confidential supplier clarification before treating the declaration as complete.

Check the complete ingredients statement before printing

Compare the final proof with the reviewed worksheet and formulation. Check the full class wording, brackets, substance spelling or code, and relevant retained declarations. Confirm that an artwork edit has not removed a code letter or changed the substance while shortening the text.

Then check the ingredients statement as a whole. The general ingoing-weight rules, compound-ingredient route and other label duties still apply. An additive wording check is not a substitute for the complete food labelling assessment.

Common errors are copying a supplier trade name, choosing the first possible class without checking function, treating Schedule 8 as a universal permission list, applying flavouring wording to a specified exception, and reusing an old declaration after a supplier or formulation change.

Frequently asked questions

Can we use a number instead of the substance name?

The usual classified-additive route allows the Schedule 8 name or code number after the class name. Use the exact applicable entry and check whether a specific provision changes the route.

Must we show both the name and number?

The usual provision gives name or code as alternatives; it does not require both simply because both appear on the supplier specification. Other applicable declarations still need their own assessment.

Can every additive in a flavour blend be called flavouring?

No blanket conclusion follows. The Code specifies particular substances that need their own declaration, and added caffeine must be listed as caffeine. Obtain enough composition information to check those provisions.

Does this review prove the recipe uses a permitted amount?

No. Permission and use conditions are a separate assessment. Keep that conclusion identifiable rather than relying on the correctness of the printed name.

Practical food label-review support

AFVA’s food labelling review service includes ingredients and allergen declarations and compliance-gap comments. Send the product formulation, matching specifications, use/function questions and complete artwork so the declaration review can be scoped accurately.

The service provides consulting comments and practical recommendations, not official label approval. The food business remains responsible for the product and final label. Identify specialist questions or separate assessments in the agreed scope rather than treating a wording review as approval of the formulation.

Official sources and review date

Current official material checked on 1 November 2026. Apply the relevant provisions to the actual food, substance and sales arrangement.

• Standard 1.2.4: ingredients and additive declaration routes
• Schedule 7: additive class names
• Schedule 8: additive names and code numbers
• Standard 1.3.1: use permissions, restrictions and carry-over
• Standard 1.1.2: definitions, including code number
• FSANZ: food additive labelling guidance

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.