EthicalHub

Regulations

PEAL allergen labelling: a checklist for manufacturers

The required names, the bold declarations, the summary statement, and the checks to run before a label goes to print.

The short answer

PEAL (plain English allergen labelling, Standard 1.2.3) has applied since 25 February 2024, and the window for selling stock labelled under the old rules closed on 25 February 2026. Every label now needs allergens declared by their required names, shown in bold in the ingredients list, and a separate bold summary statement starting with “Contains” next to the ingredients list. Check each label against the Code before it goes to print.

Names

The required names

AllergenDeclare as
Cerealswheat (always); barley, oats, rye only if they contain gluten; plus “gluten” in the summary where it applies
Crustaceacrustacean
Molluscsmollusc, declared separately
Eggegg
Fishfish
Milkmilk
Lupinlupin
Peanutpeanut
Soysoy
Sesamesesame
Tree nutseach by name: almond, Brazil nut, cashew, hazelnut, macadamia, pecan, pine nut, pistachio, walnut
Sulphitessulphites, when added at 10 mg/kg or more

From FSANZ guidance on Standard 1.2.3. Check the Code itself for the full wording before you print.

Before print

The label checklist

Ingredients list

  • Each allergen declared by its required name
  • In bold, at a font size no smaller than other ingredients
  • Inside compound ingredients and additives too, such as maltodextrin (wheat)

Summary statement

  • Separate from the ingredients list
  • Bold, in the same field of view and next to it
  • Starts with “Contains”, e.g. Contains milk

Everything else

  • Every allergen in the summary also appears in the list
  • No ingredients list? Declarations still go on the label
  • “May contain” statements are voluntary, not PEAL
Common gaps

Where labels usually go wrong

  • A supplier changes a recipe. The new ingredient brings an allergen, but the label is reprinted from the old artwork.
  • Generic names. “Nuts” or “shellfish” instead of the required names.
  • Missing the summary line, or putting it somewhere other than next to the ingredients list.
  • Old stock. Anything still labelled under the pre-2024 rules can no longer be sold.

Labels go wrong mostly at handover points between suppliers, recipes and artwork. A label check signed off at each change is the simplest control.

Context

A correct label depends on knowing what’s in every raw material. Undeclared allergens are a leading cause of food recalls in Australia, and most start upstream: a supplier specification that changed, or cross-contact on a shared line. Your allergen management plan controls those risks; the label tells the customer the result. If something goes wrong, see food recall obligations.

Where EthicalHub fits

Supplier allergen declarations, kept current

In EthicalHub, supplier management keeps allergen declarations and specifications with each approved supplier, with expiry alerts, and goods-in logs record what arrived. When a supplier changes something, you see it before the label is wrong.

See supplier management in action

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Questions

PEAL labelling: common questions

What is PEAL?
Plain English allergen labelling: the allergen declaration rules in Standard 1.2.3 of the Food Standards Code. They set the names allergens must be declared by, require them in bold in the ingredients list, and require a separate summary statement starting with “Contains”.
When did PEAL become mandatory?
The requirements came into force on 25 February 2024. Food packaged and labelled before then under the old rules could be sold until 25 February 2026, so all food on sale now must carry PEAL-compliant labels.
Do I have to name each tree nut separately?
Yes. Tree nuts must be declared individually by their required names: almond, Brazil nut, cashew, hazelnut, macadamia, pecan, pine nut, pistachio and walnut. Molluscs and individual cereals are also declared separately.
Are “may contain” statements covered by PEAL?
No. Precautionary statements such as “may contain” are voluntary and not regulated by the Food Standards Code. If you use them, base them on a real risk assessment of cross-contact, not as a blanket disclaimer.

Right label, every run.

Supplier allergen declarations and specifications, kept current.

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