Plain English Allergen Labelling

Plain English Allergen Labelling (PEAL)
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Watch our short interview for an overview of the changes.

Late February 2021 the FSANZ Code was amended to introduce new requirements for the labelling of allergens in food, sold in Australia. FSANZ approved Proposal P1044 Plain English Allergen Labelling (PEAL).
Businesses have 3 years (till 25 February 2024) to adjust their product information and labels to meet the new requirements. There is a further 2 years stock in trade period.

These requirements change how allergen information is to be declared.
Products for sale in Australia will have specific allergen information, in a specific format, specific wording and terms, in bold font, in a specific location on food labels.
PEAL changes include

• Allergen identification in the Ingredients List, for each ingredient
• Required specific names for making allergen declarations
• Declaration of allergens in processing aids used
• Bolded format of specific allergen words
• In a size of type no less than that used for other text
• Molluscs as a new allergen category
• Specific nut type must be named rather than "nuts" or "tree nuts", eg cashew, hazelnut. almond
• Specific cereal type must be named rather than "cereals", eg wheat, barley, oats in the ingredient list
• ‘Wheat’ must still be declared when it is present in food, irrespective of whether gluten is present
• Specific declaration of gluten in the separate allergen statement
• A separate allergen statement in addition to the Allergens declared in the Ingredients list
• Allergen information clearly legible, and same size font so as to contrast distinctly with the background of the label

Note: This is not an exhaustive list of all the changes.
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FSANZ’s applies the required names to allergen declarations made for food:

• Not required to bear a label, such as food on display.
  Must provide allergen declarations, either by displaying in connection with the display of the food, or providing to the purchaser/ customer on request 
• Exempt from displaying a statement of ingredients (including alcohol, small packages).
  Must have a Allergen Declaration Statement.
• Individual portion packs
  Must have a Allergen Declaration Statement.
• Sold to caterers.
  The allergen declarations must be provided to the caterer with the food, if not on the label 

Allergen declaration information applies to Food Service. This is included in the requirement for allergen declarations for food not required to bear a label. The requirement is a allergen declaration is to be are to be displayed in connection with a food on display/ offer or provided to the purchaser/ customer on request.

Allergen Specific Terms.

FSANZ has specified the mandatory terms that must be used in both the Ingredient List and the Allergen Declaration Statement. In some cases - where gluten is present in the specific cereal, gluten must be named in the Allergen Declaration Statement.
From FSANZ Table 2: Approval report – Proposal P1044. 15 Dec 2020

​Ingredient List

• Every ingredient that has an allergen must declare it. So if milk is three different ingredients, it must say so every time.
  So now its “Ingredients……..Cream (Milk), Butter (Milk), Whey Powder (Milk)………”
  Alternatively it may be declared as part of the name of the ingredient eg Milk Powder
• The table above gives the word that must be used. These terms are mandatory.
  • “Milk” not dairy. Use of a common name like cream, butter is out to declare as a allergen. Correct example is now Cream (Milk)
  • Terms like seafood and shellfish are also not to be used
  • Soy, soya and soybean are the only exception where there is more than one allowable word.
• Each allergen word must be bolded
• The bolded allergen word must be the same size or bigger font than the font size used in the ingredients list
• Wheat must be declared on its own and cannot be hidden in “cereals”
• Spelt must be declared on its own as “Spelt (Wheat)” and cannot be hidden in “cereals”
• Triticale must be declared on its own as “Triticale (Wheat, Rye)” and cannot be hidden in “cereals”
• Molluscs are a new category of allergen
  • Calamari / squid, octopus, cuttlefish, abalone, scallops, pipis, snails, etc.
• Each tree nut present must be declared, such as Hazelnut, Almond, Cashew and cannot be hidden in “nuts’ or “tree nuts”
• Allergenic processing aids have to be mentioned in the ingredient list. 

Allergen Declaration Statement

• There must be an allergen statement in addition to the Ingredients List
• The allergen statement must be co-located or distinctly separate
• Commence with the word "Contains" and include the allergens required to be declared
• The allergen statement must be in colour contrast to be the background
• It must be the same type face and at least the same size of font size as the ingredients list.
• The one word rules apply, but there are some differences [see table above]
  • For wheat, spelt and triticale, both wheat and gluten must be declared.
  • For barley, rye and oats, gluten is declared in the allergen statement.
  • ‘soy’ will be the required name for declarations of soy in the summary statement

An example: 
Ingredients: Calamari (Mollusc), Lettuce, Egg, Bacon, Flour (Wheat), Bread Crumbs (Wheat,Oats), Dressing (Wheat, Fish, Soy, Milk ), Oil (Peanut), Cheese (Milk), Bread (Wheat, Oats), Anchovies Fillets (Fish), Seasoning, Salt, Pepper.
 
Contains: Wheat, Gluten, Egg, Milk, Fish, Mollusc, Soy, Peanut
May Contain: Sesame, Pine Nut

This is not an exhaustive list of all the changes.
Further information can be found at FSANZ in Standard 1.2.3 ( link to Standard 1.2.3), and Schedule 9 Mandatory Advisory Statements (link to Schedule 9) and in the proposal  approval report.
The AFGC and The Allergen Bureau have released a Industry Guide incorporating these changes.
The guide can be found on the The Allergen Bureau Industry Guidance webpage, or in our CFS resources page
 

Correct Food Systems can conduct a label review to check your draft label, to ensure new labels meet the requirements.
Please contact us to conduct a label review of PEAL requirements. Standard hourly rate fee charges will apply.