Food allergies affect 1 in 10 Australian infants and 1 in 50 adults, making clear allergen information on food labels a critical safety issue. Until recently, confusing scientific terms like “whey,” “casein,” and “albumin” have hidden the presence of common allergens from people with allergies who depend on accurate allergen information to make safe food choices.
The Plain English Allergen Labelling (PEAL) system brings a big change in how food businesses declare allergens on their products. This comprehensive guide will walk you through everything Australian food businesses need to know about PEAL compliance, from core requirements to implementation strategies that protect both your customers and your business.
What you will learn:
The legal framework behind PEAL and its impact on food safety
Critical implementation deadlines and compliance dates
Specific labelling requirements for different allergen types
Practical guidance for various food business models
Transition strategies from old allergen labelling systems
Enforcement consequences and how to avoid penalties
Plain English Allergen Labelling (PEAL) is a mandatory food labelling system under the Australia New Zealand Food Standards Code that requires food businesses to use clear, everyday language when declaring allergens. Instead of hiding allergens behind technical terms, PEAL ensures that words like “milk,” “egg,” and “peanut” appear prominently on food labels where allergic consumers can easily identify them.
The legal framework for PEAL is established under Food Standards Australia New Zealand (FSANZ) through proposal P1044 of the Food Standards Code. This regulation affects all food businesses in Australia, from large food manufacturers to small cafes and restaurants that serve unpackaged food to customers.
Before PEAL implementation, food manufacturers could legally declare milk allergens using terms like:
Whey protein concentrate
Casein
Lactoglobulin
Milk solids
These scientific names meant that those with allergies allergic were unable to identify potentially dangerous ingredients. With severe allergic reaction cases continuing to rise, particularly cases of anaphylaxis Australia-wide, the food industry needed a systematic approach to manage allergens more effectively.
The most common food allergies affecting Australians include:
Milk (affecting both those with milk allergies and lactose intolerance)
Eggs
Peanuts
Tree nuts (including almonds, Brazil nut, pine nut, and others)
Wheat (distinct from gluten-containing grains)
Soy
Fish
Shellfish
Sesame
PEAL introduces several fundamental changes to allergen labelling requirements:
Plain English Names: All allergens must be declared separately using common names that ordinary consumers understand. Technical or scientific names are no longer sufficient for allergen declaration.
Bold Font Requirement: Allergens must appear in bold font within the ingredient list to make sure it is easy to see allowing consumers to scan labels quickly.
Allergen Summary Statement: A summary statement beginning with “contains” must appear near the ingredients list, providing a clear overview of all allergens present.
Specific Naming for Complex Allergens: Tree nuts, molluscs, and certain cereals containing gluten must be declared by their individual species rather than generic terms.
Understanding PEAL implementation deadlines is crucial for maintaining compliance and avoiding penalties. The transition to Plain English Allergen Labelling follows a carefully planned timeline that gives food businesses time to adapt while prioritising consumer safety.
|
Key Date |
Requirement |
Applies To |
|---|---|---|
|
February 25, 2021 |
PEAL legislation introduced |
All Australian food businesses |
|
February 25, 2024 |
Mandatory implementation for new products |
All newly manufactured/imported foods |
|
February 25, 2026 |
Full compliance deadline |
All foods packaged and sold in Australia |
Since February 25, 2024, all newly manufactured food products and imported foods entering Australia must comply with full PEAL requirements. This means:
Food manufacturers must ensure new product labels use plain english allergen labelling
Food suppliers bringing products to market must verify PEAL compliance
Food businesses selling packaged foods should prioritise sourcing PEAL-compliant products
The Australia New Zealand Food Standards Code provides a two-year transition period until February 25, 2026, for existing food products already in the supply chain. During this period:
Foods packaged before February 25, 2024, can continue to be sold using previous allergen labelling systems
Food businesses should develop plans to transition inventory to PEAL-compliant products
Consumer education initiatives should help customers understand both old and new label formats
The initial PEAL legislation in February 2021 gave a comprehensive three-year preparation period, allowing food businesses to:
Update label designs and printing processes
Train staff on new allergen information requirements
Develop supplier relationships with PEAL-compliant manufacturers
Implement allergen cross-contamination prevention procedures
After the February 25, 2026 deadline, food businesses face serious legal consequences for PEAL violations, including:
Financial penalties ranging from thousands to hundreds of thousands of dollars
Product recall requirements for mislabelled allergens
Criminal liability in cases involving serious allergen declaration failures
Potential business closure for repeated or severe violations
PEAL requires specific formatting and placement requirements that food businesses must follow when declaring allergens. These requirements apply to all packaged food products sold in Australia and form the foundation of compliant allergen labelling. Let's dive a bit deeper into what this looks like.
Allergens must be declared using everyday language instead of confusing scientific terminology.
Acceptable PEAL-compliant terms:
“Milk” (not whey, casein, or lactose)
“Egg” (not albumin or ovalbumin)
“Peanut” (not arachis oil or groundnut)
“Soy” (not lecithin when derived from soy)
Previously acceptable terms now prohibited:
Technical names like sodium caseinate for milk
Scientific terms like ovomucin for egg
Chemical derivatives that obscure allergen sources
All allergen names within the ingredients list are to be in bold font to ensure maximum visibility. This helps consumers quickly scan ingredient lists for potentially dangerous substances.
The bold font requirement applies to:
The allergen name itself (e.g., milk, egg, peanut)
Allergen-containing ingredients (e.g., milk powder, wheat flour)
Multiple allergens within compound ingredients
PEAL requires an allergen summary statement that begins with “contains” and appears near the ingredients list. This statement must list all allergens present in the food product using plain english allergen labelling.
Proper allergen summary statement format:
Contains: milk, wheat, egg, soyStatement placement requirements:
Must appear immediately after or near the ingredients list
Should use the same font size as the ingredients list
Must be clearly separated from other label information
Cannot be hidden within other text blocks
Certain allergen categories require individual species identification rather than generic terms, giving precise allergen information.
PEAL gets rid of generic terms like “tree nuts” or “nuts” and replaces it with specific tree nut identification:
Almond
Brazil nut
Cashew
Hazelnut
Macadamia
Pecan
Pine nut
Pistachio
Walnut
Similar requirements apply to mollusc allergens:
Abalone
Oyster
Mussel
Scallop
Clam
Octopus
Squid
When cereals containing gluten are present, each grain must be declared separately:
Wheat (including spelt and kamut)
Barley
Rye
Oats (when containing gluten)
PEAL introduces important distinctions between wheat allergy and coeliac disease management, requiring separate declaration approaches for wheat and gluten-containing ingredients. Understanding these requirements is essential for food businesses serving customers with different types of grain sensitivities.
Food businesses need to understand that wheat allergy and coeliac disease are different conditions needing different allergen information approaches:
Wheat Allergy Considerations:
Affects individuals allergic to wheat proteins specifically
Requires wheat declaration regardless of gluten protein content
May allow consumption of other gluten-containing grains like barley or rye
Triggers typical allergic reactions including potential anaphylaxis
Coeliac Disease Considerations:
Involves intolerance to gluten protein found in multiple grains
Requires avoidance of all gluten-containing cereals
Affects individuals who cannot process gluten protein content safely
Causes digestive and autoimmune responses rather than allergic reactions
For more information on consumer attitudes to food safety in Australia and New Zealand, see the latest survey findings.
Under PEAL, wheat and gluten require separate declaration when both are present in food products:
Wheat Declaration:
Must appear as “wheat” in plain english
Required regardless of gluten protein content
Applies to wheat hybrids like triticale
Includes wheat-derived ingredients like wheat starch
Gluten Declaration:
Must specify gluten-containing grains: “contains gluten from wheat, barley, rye”
Required when gluten protein content exceeds regulatory thresholds
Applies to barley oats when gluten is present
Includes malted products from gluten-containing grains
Wheat hybrids like triticale (wheat-rye hybrid) require careful allergen declaration:
Must be declared as wheat for wheat allergy management
Must also be declared for gluten content when applicable
Should specify the hybrid nature if space permits: “wheat (triticale)”
Example 1: Bread containing wheat flour
Ingredients: Wheat flour, water, yeast, salt
PEAL-compliant: Contains wheat (contains gluten)
Example 2: Cereal containing multiple grains
Ingredients: Wheat flakes, barley malt, oat flour, sugar
PEAL-compliant: Contains wheat, barley, oats (contains gluten from wheat, barley, oats)
Example 3: Gluten-free wheat starch product
Ingredients: Wheat starch (gluten removed), rice flour, corn starch
PEAL-compliant: Contains wheat (gluten-free)
For more information about food safety, see these little-known food safety facts.
PEAL’s approach to tree nut labelling is one of the most significant changes from previous allergen declaration systems. Food businesses must now provide specific tree nut identification rather than using generic terms, giving consumers exact information needed for safe food choices.
The elimination of generic terms like “tree nut” or “nut” ensures that individuals with specific tree nut allergies can identify problematic ingredients accurately. Some people may be allergic to certain tree nuts and not others, making specific identification super important for allergen information.
PEAL-compliant tree nut declarations:
|
Tree Nut Type |
PEAL Declaration |
Previous Generic Terms (Now Prohibited) |
|---|---|---|
|
Almond |
“almond” |
“tree nut,” “nut” |
|
Brazil nut |
“Brazil nut” |
“tree nut,” “nut” |
|
Cashew |
“cashew” |
“tree nut,” “nut” |
|
Hazelnut |
“hazelnut” |
“tree nut,” “nut,” “filbert” |
|
Macadamia |
“macadamia” |
“tree nut,” “nut” |
|
Pecan |
“pecan” |
“tree nut,” “nut” |
|
Pine nut |
“pine nut” |
“tree nut,” “nut,” “pinoli” |
|
Pistachio |
“pistachio” |
“tree nut,” “nut” |
|
Walnut |
“walnut” |
“tree nut,” “nut” |
When food products contain multiple tree nuts, each must be declared separately in the ingredients list and allergen summary statement:
Example: Mixed nut product
Ingredients: Almonds, cashews, Brazil nuts, sea salt
Contains: almond, cashew, Brazil nut
PEAL requirements include tree nut oils and derivative products, which must clearly identify their tree nut source:
Acceptable declarations:
“almond oil”
“hazelnut paste”
“macadamia butter”
Previously acceptable terms now prohibited:
“nut oil”
“tree nut extract”
“natural nut flavouring” (without specific identification)
Similar specificity requirements apply to mollusc allergens, particularly important for food businesses in the seafood industry or those using mollusc-derived ingredients:
Required mollusc-specific declarations:
Abalone
Oyster
Mussel
Scallop
Clam
Octopus
Squid
Shellfish vs. Mollusc Distinction:
Crustacean shellfish (prawns, crabs, lobsters) remain grouped under “crustacea”
Molluscs require individual species identification
Some consumers may be allergic to molluscs but not crustaceans, or vice versa
When cereals containing gluten are present, PEAL requires individual grain identification rather than generic “gluten” declarations:
Individual cereal requirements:
Wheat (including ancient wheat varieties)
Barley (including malted barley)
Rye
Oats (when containing gluten due to cross-contamination)
This helps those with grain-specific sensitivities while giving clarity for those avoiding gluten entirely.
PEAL requirements vary significantly depending on your food business model, from large-scale food manufacturers to small cafes serving unpackaged food. Understanding how PEAL applies to your specific operation will make sure you are compliant while maintaining practical business operations.
Food manufacturers face the most comprehensive PEAL compliance requirements, as they control label design, printing, and allergen declaration processes directly.
Label Design Requirements:
Implement bold formatting for all allergen names in ingredients lists
Create allergen summary statements using proper “Contains:” format
Ensure plain english allergen labelling throughout product lines
Design labels with sufficient space for specific allergen naming (especially tree nuts and molluscs)
Manufacturing Process Considerations:
Update product specifications to reflect PEAL-compliant ingredient declarations
Review supplier contracts to ensure incoming ingredients meet labelling requirements
Implement allergen cross-contamination prevention procedures
Train quality control staff on PEAL verification processes
Documentation and Record-Keeping:
Maintain records proving PEAL compliance for regulatory inspections
Document allergen management procedures and staff training
Keep supplier certifications confirming ingredient allergen declarations
Create audit trails for label approval and printing processes
Food businesses serving unpackaged food must provide accurate allergen information verbally or through written materials when requested by customers.
Staff Training Requirements:
Train all customer-facing staff to recognise and communicate allergen information
Develop standardised responses for common allergen inquiries
Create quick-reference guides for identifying allergens in menu items
Implement procedures for handling special allergen-related customer requests
For kitchen staff, understanding proper allergen summary statement format is an important part of food safety training.
Menu and Communication Strategies:
Consider voluntary allergen information display on menus
Develop clear protocols for when a customer asks about allergen content
Train kitchen staff to prevent allergen cross-contamination during food preparation
Create backup procedures for identifying allergens in complex dishes
Ingredient Management:
Source ingredients with clear PEAL-compliant labelling when possible
Maintain ingredient lists and allergen information for all menu items
Regularly update allergen information when suppliers or recipes change
Implement systems for tracking allergens present in daily specials
Businesses selling unlabelled food items must provide allergen information upon customer request while managing complex ingredient combinations and cross-contamination risks.
Point-of-Sale Information Systems:
Develop clear allergen information cards for display items
Train staff to identify allergens in baked goods and prepared foods
Create systems for tracking ingredient changes in daily production
Implement clear procedures for handling customer allergen inquiries
Cross-Contamination Management:
Establish allergen-free preparation areas where possible
Develop cleaning protocols between allergen and non-allergen food preparation
Train staff to recognise and communicate cross-contamination risks
Consider separate storage and handling procedures for high-risk allergens
Large-scale food service operations, including catering companies and institutional kitchens, must manage allergens across complex supply chains and diverse meal programs.
Supply Chain Management:
Work with food suppliers to ensure PEAL-compliant ingredient labelling
Develop supplier approval processes that verify allergen information accuracy
Implement receiving procedures that confirm allergen declarations on incoming products
Create backup procedures for managing allergens when primary suppliers change
Service Delivery Considerations:
Develop clear communication channels for allergen information between kitchen and service staff
Create procedures for handling special dietary requirements and allergen-free meal requests
Implement systems for preventing allergen cross-contamination during large-scale food preparation
Train staff to manage allergens in buffet and self-service environments
Food businesses importing products into Australia must ensure all imported foods meet PEAL requirements before distribution to local markets.
Pre-Import Verification:
Verify that overseas suppliers understand and comply with Australian PEAL requirements
Review product labels and allergen declarations before importing
Develop relationships with suppliers who demonstrate consistent PEAL compliance
Create approval processes for new imported products
Documentation Requirements:
Maintain complete allergen declaration records for all imported products
Keep supplier certifications and compliance documentation
Document any label modifications needed for Australian PEAL compliance
Create audit trails linking imported products to their allergen declarations
While PEAL mandates clear declaration of allergens actually present in food products, precautionary allergen labelling remains a voluntary tool for food businesses to communicate potential cross-contamination risks. Understanding how PAL works under the PEAL framework helps businesses balance consumer safety with practical manufacturing realities.
Unlike mandatory allergen declarations, precautionary statements like “may contain” or “may be present” remain voluntary under PEAL. Food businesses can choose whether to use these statements based on their risk assessments and manufacturing practices.
Common PAL Statement Formats:
“May contain milk, nuts, and soy”
“May be present: wheat, egg”
“Manufactured in a facility that also processes peanuts”
“Cannot guarantee nut-free”
Important PAL Considerations:
PAL statements do not replace mandatory allergen declarations
They supplement required allergen information for known ingredients
Overuse of PAL statements can reduce their effectiveness for allergic consumers
PAL should reflect genuine cross-contamination risks, not serve as legal protection only
The Australian food industry has developed standardised PAL language to help consumers understand different levels of cross-contamination risk.
“May Contain” Statements:
Indicates potential cross-contamination during manufacturing
Suggests shared equipment or facility allergen exposure
Typically used when cleaning procedures reduce but don’t eliminate allergen traces
Implies moderate cross-contamination risk that allergic consumers should consider
“Manufactured in a Facility” Statements:
Indicates shared manufacturing facilities with allergen-containing products
Often suggests physical separation between allergen and non-allergen production lines
May indicate lower cross-contamination risk than “may contain” statements
Used when facility-level allergen management reduces direct exposure risk
“Cannot Guarantee” Statements:
Indicates uncertainty about complete allergen absence
Often used by food businesses with complex supply chains
May suggest higher cross-contamination risk requiring extra caution
Commonly used when multiple suppliers make allergen tracking challenging
Food businesses using PAL statements should understand how allergic consumers interpret and respond to different precautionary language.
Consumer Response Patterns:
Most allergic consumers avoid products with PAL statements for their specific allergens
“May contain” statements typically prompt complete product avoidance
“Manufactured in facility” statements may be acceptable to some consumers depending on allergy severity
Clear, specific PAL language helps consumers make informed risk decisions
Communication Best Practices:
Use specific allergen names rather than generic terms in PAL statements
Avoid unnecessary PAL statements that don’t reflect genuine risks
Consider providing additional allergen information through customer service channels
Regularly review and update PAL statements based on manufacturing changes
Making the switch from traditional allergen labelling to PEAL takes some thoughtful planning and teamwork across your entire food business. When done right, this transition not only keeps your customers safe but also helps your business run smoothly and stay on the right side of the regulations.
Understanding which allergen terms are no longer acceptable under PEAL helps food businesses identify products requiring label updates or supplier changes.
Milk Allergen - Terms Being Phased Out:
Whey protein concentrate
Casein
Caseinate (sodium, calcium)
Lactalbumin
Lactoglobulin
Milk solids (when not clearly identifying milk)
Egg Allergen - Terms Being Phased Out:
Albumin
Ovalbumin
Ovomucin
Lecithin (when egg-derived)
Lysozyme (when egg-derived)
Wheat/Gluten - Terms Being Phased Out:
Gluten (without specifying source grain)
Modified wheat starch (without wheat identification)
Wheat protein isolate (without clear wheat naming)
Cereal protein (without specific grain identification)
Soy Allergen - Terms Being Phased Out:
Lecithin (without soy identification when soy-derived)
Hydrolyzed vegetable protein (when soy-derived without specification)
Vegetable gum (when soy-derived)
Textured vegetable protein (without soy specification)
Comprehensive staff training ensures consistent PEAL implementation across all business operations and customer interactions.
Customer-Facing Staff Training:
Train staff to read and interpret both old and new allergen labelling formats
Develop standardised responses for allergen inquiries during transition period
Create quick-reference guides comparing old vs. PEAL-compliant allergen terms
Practice scenarios for handling customer confusion about labelling changes
Kitchen and Production Staff Training:
Educate staff about importance of accurate allergen information
Train personnel to recognise allergen ingredients using plain english names
Implement procedures for preventing cross-contamination during food preparation
Develop systems for maintaining allergen awareness in daily operations
Consider moving from a paper food control plan to a digital system to streamline allergen management and compliance
Management and Quality Control Training:
Train managers to verify PEAL compliance in incoming products
Develop procedures for auditing supplier compliance with PEAL requirements
Create systems for documenting allergen management and staff training
Implement regular review processes for maintaining compliance standards
PEAL enforcement involves multiple regulatory authorities working together to ensure food businesses comply with allergen labelling requirements. Understanding enforcement mechanisms and penalty structures helps businesses prioritise compliance and avoid serious consequences.
Food Standards Australia New Zealand (FSANZ) establishes PEAL requirements, while state and territory authorities enforce compliance through regular inspection programs.
FSANZ Role:
Develops and updates Food Standards Code requirements for allergen labelling
Provides guidance documents and implementation resources
Monitors compliance trends and industry feedback
Coordinates with enforcement authorities on complex cases
State and Territory Enforcement:
Local health departments conduct routine food business inspections
Specialised food safety units investigate allergen-related incidents
Import inspection services verify PEAL compliance for imported foods
Consumer affairs departments handle mislabelling complaints
Inspection Focus Areas:
Product label compliance with PEAL formatting requirements
Staff knowledge of allergen content in foods served
Documentation of allergen management procedures
Supplier compliance verification processes
Consumer complaint response procedures
PEAL violations carry significant financial penalties that escalate based on violation severity and business response to enforcement actions.
Individual Food Business Penalties:
Minor labelling violations: $1,000 - $10,000 initial penalties
Serious allergen mislabelling: $10,000 - $50,000 penalties
Repeated violations: $50,000+ penalties plus potential license suspension
Corporate violations: $100,000+ penalties for large food manufacturers
Additional Financial Consequences:
Product recall costs including retrieval, disposal, and notification expenses
Legal fees for defending against serious allergen violation charges
Increased insurance premiums following allergen-related incidents
Lost sales and customer confidence during compliance resolution
Business Operation Impacts:
Temporary closure orders for serious allergen management failures
License suspension or revocation for repeated violations
Mandatory staff retraining requirements at business expense
Enhanced inspection schedules increasing compliance monitoring costs
Food businesses discovering allergen labelling errors must implement immediate recall procedures to protect allergic consumers from serious harm.
Mandatory Recall Triggers:
Undeclared allergens discovered in distributed products
Incorrect allergen information on product labels
Cross-contamination incidents affecting multiple product batches
Supplier notifications of allergen contamination in distributed ingredients
Recall Implementation Requirements:
Immediate notification to relevant food safety authorities
Public recall notices through media and industry networks
Direct notification to retailers and distributors for product removal
Consumer notification through websites, social media, and press releases
Documentation of all recall actions and effectiveness monitoring
Recall Effectiveness Standards:
Product retrieval rates meeting regulatory authority expectations
Timely consumer notification preventing further exposure
Complete documentation of recalled product distribution
Verification that recalled products are properly disposed of or corrected
Implementation of corrective actions preventing future similar incidents
For advice on managing issues related to ingredients like these, such as potential product recalls, see how to minimise damage to your food business during food recalls.
Successfully implementing PEAL is much easier when you have the right resources, training, and expert guidance at your fingertips. Food businesses can tap into a range of support options to stay compliant, keep operations running smoothly, and most importantly, make sure customers are safe and confident.
Food Standards Australia New Zealand provides comprehensive resources specifically designed to support food businesses through PEAL transition and ongoing compliance.
Professional food safety training programs have been updated to include comprehensive PEAL education, ensuring food safety supervisors understand current allergen management requirements.
Technology solutions with allergen tracking features such as Chomp can assist with PEAL compliance.
Plain English Allergen Labelling marks a big step forward for Australian food businesses in keeping customers safe with clear and easy-to-understand allergen info. With the full compliance deadline coming up fast, businesses that fully grasp PEAL requirements won’t just stay compliant, they’ll show they truly care about their customers’ wellbeing.
The numbers don’t lie: food allergies affect 1 in 10 Aussie babies and 1 in 50 adults, so having accurate allergen info isn’t just important, it can be life-saving. PEAL’s use of plain English, bold text, and clear allergen naming cuts through the confusion that’s put allergic consumers at risk for far too long.
Whether you operate a large food manufacturing facility, a local restaurant, or anything in between, PEAL compliance is not just a regulatory requirement, it’s an opportunity to show your commitment to customer safety and build trust with the growing number of consumers who depend on accurate allergen information to make safe food choices.
For the most current PEAL guidance, implementation tools, and compliance resources, visit the FSANZ website and ensure your business stays informed about this critical food safety initiative that’s transforming allergen communication across the Australian food industry.