Guide · Allergens
Allergen labelling in Australia — the Plain English rules, now fully in force
Plain English Allergen Labelling has been law since 2021, but two transition windows meant older labels stayed legal. The last of them closed on 26 February 2026. Every label on the shelf must now use the required names, in the required places. Here is what that means, taken from Standard 1.2.3 and Schedule 9.
The dates, from the Code itself
The transitional provisions attached to Standard 1.2.3 come from the Food Standards (Proposal P1044 – Plain English Allergen Labelling) Variation, registered 24 February 2021. They say:
“The transition period is the period of time that commences on 25 February 2021 and ends on 25 February 2024. The post-transition period is the period of time that commences 26 February 2024 and ends on 26 February 2026.”
Three years to change over, then two more during which stock already made could still be sold. Both have now passed. If you are reading an article that says “from 2026” in the future tense, it was written before that date.
When a declaration is required
Section 1.2.3—4 sets the trigger. A declaration is required if the food is present in any of these ways:
- as an ingredient, or as an ingredient of a compound ingredient;
- as a substance used as a food additive, or an ingredient or component of such a substance;
- as a substance used as a processing aid, or an ingredient or component of one.
The processing-aid limb is the one that catches people out. A release agent, a clarifying agent or an enzyme preparation is not an ingredient in the everyday sense and is squarely inside the rule.
The required names
This is the heart of Plain English Allergen Labelling: you no longer choose the wording. Section S9—3 sets a required name for the ingredient list and, separately, a required name for the summary statement. Usually they are the same word. For the gluten cereals they are not:
| Food | Exemption | Name in the ingredient list | Name in the ‘Contains’ statement |
|---|---|---|---|
| Added sulphites at 10 mg/kg or more | — | sulphites | sulphites |
| Barley (if it contains gluten) | in beer or spirits | barley | barley gluten |
| Oats (if they contain gluten) | in beer or spirits | oats | oats gluten |
| Rye (if it contains gluten) | in beer or spirits | rye | rye gluten |
| Wheat, gluten or not | in beer or spirits; certain refined wheat glucose syrups; alcohol distilled from wheat | wheat | wheat, and gluten if gluten is present |
| Tree nuts — almond, Brazil nut, cashew, hazelnut, macadamia, pecan, pine nut, pistachio, walnut | — | the nut’s own name | the nut’s own name |
| Crustacea | — | crustacean | crustacean |
| Egg | — | egg | egg |
| Fish | isinglass from fish swim bladders used to clarify beer or wine | fish | fish |
| Lupin | — | lupin | lupin |
| Milk | alcohol distilled from whey | milk | milk |
| Mollusc (marine) | — | mollusc | mollusc |
| Peanut | — | peanut | peanut |
| Sesame seed | — | sesame | sesame |
| Soybean | fully refined soybean oil; soybean tocopherols and phytosterols | soy, soya or soybean | soy |
Read the last two columns for barley, oats and rye again. In the ingredient list the
name is barley; in the summary statement it is
barley gluten. Writing “Contains: barley” is not compliant,
and it is the mistake we see most often on relabelled products.
Note also what the Code does not do: there is no collective term for tree nuts. Each of the ten is named in its own right, and “contains tree nuts” does not discharge the obligation for almonds.
Fish, crustacea and molluscs are three separate things
Section S9—3(2) defines the boundary expressly for this table: the general definition of fish does not apply, fish excludes crustacea and molluscs, and mollusc means a marine mollusc. Three declarations, three names. A seafood mix with prawns, mussels and cod carries all three.
‘May contain’ is not a substitute
Precautionary statements about unintended cross-contact are not part of the mandatory declarations in Standard 1.2.3. They neither satisfy the requirement nor excuse it. If an allergen is present as an ingredient, an additive or a processing aid, it is declared by its required name — and a precautionary statement about something else is a separate decision.
How this differs from the EU
If you also sell into Europe, the lists are close but not identical, and the mechanics differ:
- The EU has fourteen groups in Annex II of Regulation (EU) No 1169/2011; Australia names its foods individually in Schedule 9.
- The EU requires emphasis within the ingredient list (Article 21) — bold, italics or a different colour. Australia requires the required names plus a summary declaration.
- Celery and mustard are EU allergens and are not on the Australian list. Lupin is on both.
One ingredient list, two labels. That is a data problem, not a writing problem, and it is worth solving once.
Frequently asked questions
Is Plain English Allergen Labelling mandatory now?
Yes, entirely. The transition period ran from 25 February 2021 to 25 February 2024, and the post-transition period for existing stock ended on 26 February 2026. There is no longer any grandfathering.
Which foods must be declared in Australia?
The table to section S9—3: added sulphites at 10 mg/kg or more, gluten-containing cereals, wheat, the named tree nuts, crustacea, egg, fish, lupin, milk, mollusc, peanut, sesame seed and soybean — and derivatives of each.
Can I write ‘may contain traces of nuts’?
Not instead of a declaration. Precautionary statements are not part of the mandatory declarations and cannot substitute for them.
This article is general information and does not replace legal advice. Quoted from the Australia New Zealand Food Standards Code, Standard 1.2.3 (F2015L00397, Compilation 6) and Schedule 9 (F2015L00479, Compilation 2), on the Federal Register of Legislation. The transitional dates are from the Food Standards (Proposal P1044 – Plain English Allergen Labelling) Variation, F2021L00145.