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P1044 – Plain English Allergen Labelling

(January 2019)

We are working on a proposal to make allergen labelling requirements clearer, which will help food allergen-sensitive consumers and food businesses.

The Food Standards Code already contains a mandatory requirement to label 10 allergens; however it does not include requirements for the terminology that should be used.

The proposal aims to make allergen labelling clearer so that food allergen-sensitive consumers have the information they need to make informed and safe food choices. The first consultation paper for the proposal, (see link below) was released in March 2018.

What issues have been identified?

FSANZ identified a number of issues relating to the use of unclear terminology for:

  • fish, crustacea and molluscs
  • tree nuts
  • cereals containing gluten.

FSANZ has also identified issues with the terminology used in mandatory label elements (e.g. in ingredient lists) versus declarations made in other places on the label.

Other issues include the use of technical language, for example, sodium caseinate, which some consumers may not know is sourced from dairy.

What changes are being proposed?

The first consultation paper outlines approaches that could be used to make sure that allergen labelling is provided in clear, plain English.

The consultation paper also includes a number of possible labelling changes for consideration that relate to fish and molluscs as allergens, the types of tree nuts that must be declared as allergens, and the declaration of wheat and gluten.

We are seeking feedback on all of these potential changes, as well as feedback and evidence on consumer use and understanding of allergen labelling. 

Information received in response to the first consultation paper will help inform our approach to the second consultation paper, which will include draft amendments to the Food Standards Code.

Proposal P1044 Reports

Submissions (zip 23,924 kb) 

Call for submissions - 1 March 2018 (pdf 920 kb) | (word 150 kb) 

Previous work on plain English allergen labelling

Ministers asked FSANZ to undertake a review of the regulatory management of food allergens. FSANZ published the findings of this review in 2010. Read the review report.

In 2016, FSANZ completed a review into whether consumers experience difficulties identifying the presence of allergens from the terminology used to declare the allergen on food labels. FSANZ consulted targeted key stakeholders involved in food allergen management as part of the review.

Read the full report of the review (pdf 61kb) | (word 17kb).

Summary of issues raised in submissions (pdf 521kb) | (word 100kb).

Submissions (zip file 16.1MB)

The results of the review have formed the basis for starting work on Proposal P1044 – Plain English Allergen Labelling.

More information

Allergy and Anaphylaxis Australia

Allergy New Zealand



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