Food producers should be aware of recent updates to the Australia New Zealand Food Standards Code around allergen declarations, warnings and advisory statements – an area of expertise for Lane Neave’s Corporate team.
In New Zealand, all food packaging must record the presence of common allergens. Specific disclosure requirements are found in the Code, which applies to all food sold in Australia and New Zealand.
What are the changes?
We’ve listed the changes below, all of which are designed to make allergen information clearer and easier for consumers to locate.
- The following ingredients must be written in bold in the ingredient list: wheat, fish, crustacean, mollusc, egg, milk, lupin, peanut, soy, sesame, almonds, Brazil nuts, cashews, hazelnuts, macadamias, pecans, pine nuts, pistachios, and walnuts.
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- Barley, oats and rye must also be declared if they contain gluten.
- Sulphites must be declared when added in amounts equal to or more than 10 milligrams per kilogram of food.
- There must be a separate statement identifying allergens. This must be next to the ingredients list and start with the word “contains”. For example, “Contains eggs and peanuts”.
- The specific allergen name must be given. For example, an ingredient list must specify that the product has “almonds” rather than just stating “nuts”.
- Products containing bee pollen, propolis or royal jelly must have a warning statement. For example, “This product contains bee pollen which has been reported to cause severe allergic reactions and, in rare cases, fatalities, especially in asthma and allergy sufferers”.
Are there exemptions?
The new changes do not affect the old product exemptions from allergen labelling. This means that the following ingredients do not have to be listed in bold or placed in the allergen statement:
- Glucose syrups made from wheat with less than 20milligrams per kilogram of detectable gluten;
- Fully refined soybean oil;
- Tocopherols and phytosterols;
- Distilled alcohol from wheat or whey;
- Beer or spirits made from barley, rye, oats or wheat; and
- Isinglass (derived from swim bladders) does not require a declaration of “fish”.
However, even though glucose syrups do not need to declare wheat as a food allergen, products containing the glucose syrup cannot be labelled as “gluten-free”.
What does this mean for your business?
Any food packaged and labelled before 25 February 2024 fall under the old rules and can be sold for a further two years. However, food packaged after this date needs labels that comply with the new allergen labelling requirements.
How can we help?
If you would like help labelling your products or have any queries about your legal obligations regarding allergen labelling, please do not hesitate to get in touch with Lane Neave’s experienced Corporate team.
