May Contain Statements NZ: What to Review Before Changing One

Before adding, removing or narrowing a may contain statement, organise the evidence behind the proposed change. Start with the exact packaged food, relevant allergen, suppliers and manufacturing arrangements—not the space available on the artwork.

This guide helps New Zealand packaged-food manufacturers prepare a product-specific cross-contact review brief. For mandatory declaration names and presentation, use our allergen labelling rules guide. The task here is different: identifying what a reviewer needs to assess possible unintended presence before precautionary wording changes.

May contain statements NZ: keep the two assessments separate

Official guidance: FSANZ’s allergen labelling guidance identifies may contain and may be present statements as voluntary precautionary allergen labelling (PAL), not statements regulated by the Food Standards Code.

Mandatory declarations are different. Under Standard 1.2.3, particularly section 1.2.3—4, covered foods and derivatives require declarations when present through ingredients, compound ingredients, additives or processing aids and their relevant components, subject to the specified exemptions. A precautionary statement does not replace a declaration that is required.

FSANZ’s guidance for manufacturers, retailers and importers identifies responsibility for managing unintended allergen presence and providing clear, current and accurate product allergen information. Its industry messages include effective allergen management plans and staff training.

Voluntary PAL is not a general exemption from truthful labelling. FSANZ’s explanation of truth in labelling states that New Zealand food and fair trading laws prohibit false, misleading or deceptive label representations.

Define the exact product and proposed change

Our recommended starting point is a short brief recording:

• The product name, code, variant and current formulation version.
• The manufacturing site, relevant line and any contract-manufacturing arrangements.
• The allergen being assessed, current precautionary wording and proposed replacement or removal.
• The reason for the review and the evidence behind the previous decision, where available.
• What has changed in ingredients, suppliers, equipment, production arrangements or cleaning—and what is believed to be unchanged.

Identify each affected variant. Ask the reviewer whether shared evidence covers them all rather than assuming that one conclusion applies across the range.

Build a product-specific cross-contact evidence worksheet

The following is a recommended briefing format, not a regulator-prescribed record or validated technical assessment protocol. Select relevant rows alongside the controls and records in your applicable food safety plan or programme. These questions organise a review; they do not provide acceptance criteria or permission to change PAL.

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

Make unanswered questions visible

Give each open question an owner, requested response date and status. Identify the affected product, allergen, missing information and decision that remains open. Ask the reviewer to record the assessment’s basis, coverage and limitations.

Illustration only: A supplier removes a soy precautionary statement from a revised specification without explaining why. Keep both versions and ask what changed, whether the revision covers the ingredient code and manufacturing site supplied, and what evidence supports it. Do not automatically carry that deletion onto the finished-product label.

Control a supported label change

After the product-specific review, use this recommended change checklist:

1. Record the conclusion: identify each product and allergen assessed, the evidence, rationale and any conditions or outstanding actions.
2. Keep declarations separate: check that the proposed PAL change does not remove or contradict required ingredient-related declarations.
3. Control the artwork: identify the exact reviewed version and the business decision-maker authorising its use.
4. Define the changeover: record the effective production point and distinguish packaging and product versions.
5. Align other information: review affected customer specifications, online product descriptions and staff information.
6. Set review triggers: identify supplier, formulation, equipment, process or cleaning changes that should reopen the assessment.

If evidence is insufficient, pause the proposed label change and resolve the question. Do not treat changing precautionary wording as a correction for a known failure in allergen controls.

Common mistakes to avoid

• Copying a supplier’s wording without review: retain it as evidence, then assess its relevance to the finished product.
• Using a blank to mean no risk: distinguish information not received from a supported assessment conclusion.
• Collecting cleaning records without examining their meaning: ask what the evidence demonstrates for this allergen and operation.
• Commissioning another test before defining the question: first identify the evidence gap and suitable way to address it.
• Extending one conclusion to every variant: make the coverage and differences explicit.

How AFVA can help with the review brief

AFVA’s consulting service includes allergen control procedures and documentation and record review. Ask for support identifying gaps between your written controls, supporting evidence and actual practice.

AFVA’s food labelling review service covers allergen declarations and provides compliance-gap comments and practical recommendations. It is not official label approval; final responsibility for label compliance remains with the food business.

The support described here is consulting and label review only, not an offer of a combined consulting, evaluation or verification engagement.

Frequently asked questions

Is this exact worksheet compulsory?

No. It is a recommended briefing format, not a prescribed regulatory form. It does not replace the applicable requirements or controls in your food safety plan or programme.

Should every review start with new laboratory testing?

Our recommendation is to start with the question and existing evidence. Ask the reviewer whether that evidence is sufficient and, if not, what further work is appropriate. This guide does not set a universal testing requirement.

What if the supplier will not explain its precautionary statement?

Record the precise gap and ask whether relevant information can be shared through an agreed confidential route. Keep the affected conclusion open rather than inventing a reason for the statement or its removal.

Does removing may contain wording support an allergen-free claim?

Not by itself. Treat a proposed free-from claim as a separate evidence and requirements review. The absence of precautionary wording is not its supporting evidence, and label representations must not mislead.

Can several products share one review?

Identify every product and ask the reviewer to explain which evidence is shared and which differences need separate consideration. Do not presume that a shared factory or similar recipe makes the conclusion transferable.

What should be retained after the review?

We recommend keeping the brief, evidence versions, resolved questions, technical conclusion, business authorisation and released artwork together. Record what future changes should trigger another review.

Start with one product and one clear question

Choose the product and statement under review, assemble the evidence already available and identify the questions that remain. For the broader handover to a label reviewer and printer, use our food label review information-pack guide.

General information only: Requirements depend on the complete food activities, ingredients, products, processes, locations and sales model. Confirm the requirements applying to the specific business and product. This recommended evidence-preparation workflow is not a threshold calculator, a complete allergen risk assessment, official approval or permission to remove a precautionary statement.