Allergen labelling (PEAL) rules explained

Plain English Allergen Labelling, usually called PEAL, is the allergen format in the Australia New Zealand Food Standards Code, centred on Standard 1.2.3. The transition period has ended. Packaged food labelled for sale in Australia should already use the required names and the required format. This note explains the pattern a small brand can check on a draft. It is not a legal opinion and it does not replace the current Code.

Before PEAL, a label could declare an allergen with a scientific or ingredient name and leave the reader to translate it. PEAL asks for a set of required plain-English names so a person with an allergy can see the same words every time. The declaration is made in the statement of ingredients and again in a separate summary statement.

If your artwork still says “casein”, “whey”, or “albumen” without the required name beside it, or if the summary statement is missing, treat that as a fix before print. Imported stickers are where this shows up most often, because the original label was written for another country’s list.

The required names cover the allergens the Code lists. In practice a checker looks for wheat, and gluten where the cereal rules require that word; crustacean; egg; fish; milk; peanut; soy, using the required spelling rather than a marketing variant; sesame; lupin; mollusc; the individual tree nuts the Code names, such as almond, cashew, and walnut rather than only the phrase “tree nuts”; and sulphites at or above the level that triggers a declaration.

The exact spelling and the “contains” wording should follow the Code, not a house style guide. “Dairy” is not a substitute for milk. “Nuts” is not a substitute for the specific tree nut. A precautionary “may contain” line is a separate decision about cross-contact. It does not replace a required declaration when the allergen is an ingredient.

Sulphites are a frequent miss on dried fruit, wine-derived ingredients, and some processed sauces. If sulphur dioxide or a sulphite is in the formula, check whether the concentration meets the declaration threshold and whether the required name appears in both places.

In the statement of ingredients, the required name is printed in bold each time it appears, including inside a compound ingredient. Bold is not decoration. If the allergen is only bold in one place and ordinary text in another, the format is inconsistent and a reader can miss it.

The summary statement sits separately, typically beginning with “Contains”, and lists the required names that apply to that food. It is not a second ingredient list and it should not introduce allergens that are not in the food. It also should not omit one that is. The two locations have to agree.

A compound ingredient such as a marinade, a chocolate chip, or a stock powder is where declarations get lost. Break the compound down far enough that each required name is visible. If a supplier specification says “flavour” and the flavour contains milk, the finished label still has to say milk.

An English sticker on an imported pack has to carry the Australian allergen format even when the original label already mentions allergens in another language or another naming system. Covering the original allergen panel with a sticker that uses the wrong names is worse than leaving a gap, because it looks complete.

PEAL does not tell you whether your factory’s cleaning is good enough to justify, or to drop, a “may contain” statement. That is a cross-contact assessment. PEAL also does not prove that a “gluten free” claim meets the separate conditions for that claim. Allergen declaration and a free-from claim are different sentences with different tests.

When you review a draft, print the ingredient list and the summary statement side by side and tick each required name. Then compare both to the supplier specifications, not only to the recipe nickname used in the kitchen. If you want that comparison done against a real file, the food label mini review includes allergens as one of the checks.