Allergen Labelling Rules NZ: Plain English Requirements for Food Businesses

Allergen labelling rules in New Zealand require more than a familiar “Contains” line. The applicable declaration depends on the ingredient, its form, any specific exemption and whether the food needs a label and an ingredients list.

This guide explains Plain English Allergen Labelling (PEAL) for ordinary retail food, with practical checks for manufacturers, importers and food brands. It focuses on allergen declarations; use our complete food labelling requirements guide for the wider label review. Special-purpose foods can have different declaration provisions.

Allergen labelling rules NZ businesses need to use now

PEAL is part of the Australia New Zealand Food Standards Code. FSANZ’s current allergen labelling guidance identifies 25 February 2024 as the date the new requirements took effect. It says food packaged and labelled before that date, in compliance with the previous requirements, could continue to be sold until 25 February 2026. That sell-through concession has ended.

Treat these as current requirements, rather than a future deadline. This does not make every food carry an ingredients list or a packaged-food summary: the relevant labelling and exemption provisions still determine how information is provided.

The principal references are Standard 1.2.3: mandatory declarations and their presentation, Schedule 9: covered foods, exemptions and required names, and Standard 1.2.1: labels and information for food without a label. Read them together rather than using a shortened allergen list as the entire rule.

Check the ingredient and the applicable declaration duty

Standard 1.2.3 covers the listed foods and their derivatives, subject to its exemptions. A relevant food can be present as an ingredient, within a compound ingredient, or through a food additive or processing aid, including their ingredients or components. Checking only the main ingredients named on the front of the pack is therefore insufficient.

As a practical review, start with the complete current formulation and information matching the ingredients actually used. Include bought-in sauces, coatings, seasonings, flavours and premixes. Ask the supplier to explain an unclear specification rather than treating the product’s marketing name as evidence of composition.

Keep the declaration assessment separate from unintended allergen presence. The ingredients and their required declarations answer one question; the possibility of cross-contact during manufacture answers another. Neither should disappear merely because an artwork template has limited space.

Use the required names in the right part of the label

Schedule 9 has different columns for declarations in a statement of ingredients and for other declarations, including a summary statement. The following reading aid highlights important differences. It is subject to the food-specific exemptions in Schedule 9 and does not replace the complete label assessment.

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

Wheat and gluten need separate attention

Do not use “gluten” as a substitute for “wheat”. Subject to the specific exemptions, wheat is declared even if it does not contain gluten. When gluten is present, the other declaration includes both wheat and gluten. For barley, oats and rye, the declaration duty depends on gluten being present: the ingredient declaration names the cereal, while the other declaration uses gluten.

Name the listed tree nuts; do not invent shellfish naming rules

The listed tree-nut names are almond, Brazil nut, cashew, hazelnut, macadamia, pecan, pine nut, pistachio and walnut. Use the applicable individual names rather than only “tree nuts”.

For the mandatory allergen declaration, the required seafood names are fish, crustacean and mollusc. Schedule 9 defines mollusc here as a marine mollusc. It does not require each prawn, crab, oyster or mussel species to be listed as a separate mandatory allergen name. The product’s ordinary ingredient description is a separate matter.

Retain the condition for sulphites

The Schedule 9 entry is for added sulphites in concentrations of 10 mg/kg or more. Keep both the “added” qualification and the concentration when assessing whether this declaration applies; a list that simply says “all sulphites” loses the condition.

Check bold ingredients and the Contains statement together

For ordinary retail labels to which the standard ingredients-and-summary provisions apply, required names in the ingredients list must be bold, with distinct contrast, and in a type size no smaller than the other ingredient text. Declare the required name separately for each relevant ingredient. If the ingredient name does not already contain it as a separate word, place the required name separately next to that ingredient.

For an allergenic processing aid, or its relevant ingredient or component, the declaration also includes the words “processing aid” with the required name. The statement of ingredients and summary therefore need to be checked against the actual formulation and process, not only copied from the previous label.

The required summary begins with “Contains”, lists the applicable required names and contains no other words. It is bold, in the same typeface and size as the required names in the ingredients list. It must be directly next to that list, in the same field of view, and distinctly separated from it. A summary elsewhere on the pack does not meet that placement rule.

Foods not required to display an ingredients list can still need allergen declarations elsewhere on the label using the applicable required names. Do not impose the ordinary ingredients-and-summary layout on every exempt format, and do not mistake an ingredients-list exemption for an allergen-information exemption.

Check specific exemptions and keep precautionary statements separate

Some derivatives and forms have specified declaration exemptions. FSANZ’s product-exemption guidance explains examples including qualifying wheat-starch glucose syrups, fully refined soybean oil, specified soy derivatives, and distilled alcohol from wheat or whey. Schedule 9 contains the controlling descriptions and conditions.

For example, the soybean-oil exemption identifies oil that has been degummed, neutralised, bleached and deodorised. The words “soybean oil” on a specification alone do not demonstrate those processing steps. Our recommendation is to retain evidence explaining why a claimed exemption applies to the exact ingredient supplied.

An allergen declaration exemption does not remove the separate requirements for a “gluten free” claim. FSANZ’s exemption guidance expressly distinguishes these questions. Assess a suitability or marketing claim separately instead of deriving it from the absence of a mandatory allergen declaration.

Statements such as “may contain” address possible unintended presence and are voluntary precautionary allergen labelling (PAL), not statements regulated by the Food Standards Code. They do not replace a required ingredient declaration. As a practical check, keep the supplier’s actual wording and the cross-contact assessment separate from the ingredients and the required summary.

This guide concerns mandatory allergen declarations. Other warning and advisory statements can also apply, including provisions for bee products. A completed PEAL check is only one part of a complete label review.

Food without a label still has information requirements

Section 1.2.1—6 sets out when retail food is not required to bear a label, including unpackaged food and specified situations for packaged food. For ordinary food-service food exempt under that section, allergen declarations must be displayed in connection with the food or provided to the purchaser on request under section 1.2.1—9(6)–(7). A café name alone does not classify every product it sells.

Do not extend that option to every situation. For example, section 1.2.1—9(3)(d) separately requires the relevant declarations for unlabelled vending-machine food in labelling accompanying or displayed with the food. Packaged foods that do require labels and foods supplied to caterers also have their own provisions.

FSANZ’s food-service allergen guidance recommends trained staff and clear, accurate, up-to-date information about allergens that may be present directly or indirectly. For the separate operational problem of a substituted ingredient in a café or catering menu, use our menu allergen records and ingredient-change checklist. That article focuses on keeping recipes, records and staff answers aligned.

A practical allergen-label artwork checklist

The following is AFVA’s recommended review sequence, rather than a regulator-prescribed form. Use it before artwork approval and repeat the relevant checks when the product, supplier information or label changes.

1. Confirm the sales format. Identify whether the food requires a label and ingredients list, and which information provisions apply. Do not choose the format solely from a previous product.
2. Assemble current evidence. Match the recipe, compound ingredients, additives and processing aids to the actual product and current supplier information. Give unresolved discrepancies an owner.
3. Assess declarations and exemptions. Check the exact food and form against Schedule 9. Record the basis for any exemption rather than assuming that a refined or processed ingredient is exempt.
4. Map names to their position. Compare required names in the ingredients list with those in the summary or other declaration, particularly soy and gluten-containing cereals.
5. Inspect actual presentation. Check bold type, relative size, repeated ingredient declarations, summary wording, adjacency, field of view and separation on the final artwork.
6. Review PAL and claims separately. Keep unintended presence separate from deliberate ingredients. Do not treat a declaration exemption or an empty allergen field as permission for a suitability claim.
7. Control the approved version. Link the reviewed artwork to its formulation and evidence. Inspect a print proof or actual pack to see whether the intended text, contrast and placement survived production.

For an imported label, check the applicable Code requirements on the actual artwork rather than accepting its origin country or language as proof. The allergen provisions discussed here belong to the Australia New Zealand Food Standards Code; they should not be described as inherently different “Australian-format” allergen rules.

Common allergen labelling mistakes to avoid

• Using a general category where a required individual name applies: replace only “tree nuts” with the applicable listed nut names.
• Confusing ingredient and summary terminology: “soya” or “soybean” can appear as the required ingredient name, while the summary uses “soy”.
• Replacing wheat with gluten: apply the wheat duty and, where present, the additional gluten declaration.
• Missing a component or processing aid: review source evidence beyond the front-of-pack ingredient description.
• Checking words but overlooking presentation: confirm the relative type size and summary position, not only that a Contains line exists.
• Applying packaged-food formatting to every food: first establish the label and information provisions that apply.
• Treating an exemption or PAL statement as a shortcut: assess the exact exemption and keep cross-contact and claim questions distinct.

How AFVA can help with an allergen label review

Access Food Verification & Auditing Limited’s label-review service covers ingredient lists, allergen declarations, warning and advisory statements, claims and imported labels. We can identify possible compliance gaps and provide practical recommendations before printing, importing, selling or updating your product.

This is label-review support, not regulatory approval. AFVA’s service page states that final responsibility for label compliance remains with the food business. Bring the current artwork, formulation and relevant supplier evidence so the review concerns the product actually being supplied.

Review the product and the finished label together

For the next label review, work from the formulation and supplier evidence through to the actual ingredients list and summary. Resolve exemptions and names before approving layout, then check that the final pack preserves the reviewed wording and presentation.

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 food and declaration. This guide concerns ordinary retail allergen information and does not replace a complete product-specific label assessment.