FSANZ Allergen Labelling Requirements: Complete Guide for Australian Food Businesses
The 14 mandatory allergens under the Food Standards Code, who must comply, what “may contain” actually means legally, the 2024 bold-text declaration changes, and how to manage allergens across your kitchen and menu.
Quick answer
Food Standards Australia New Zealand (FSANZ) mandates declaration of 14 specific allergens in packaged food under Standard 1.2.3 of the Food Standards Code. From February 2024, allergen declarations must appear in bold text with sufficient contrast. Restaurants and caterers have no formal written labelling obligation under FSANZ, but carry a common-law duty of care to provide accurate allergen information on request.
What is FSANZ and what does it regulate?
Food Standards Australia New Zealand is the independent statutory authority responsible for developing and administering the Australia New Zealand Food Standards Code — the body of law that governs what food may be sold, how it must be labelled, and what additives and contaminants are permitted. The Code applies across all Australian states and territories and in New Zealand.
Allergen labelling is governed primarily by Standard 1.2.3 — Information Requirements. It sets out which allergens must be declared, how they must appear on a label, and what exemptions apply. State and territory food authorities enforce the standard, with penalties applying to businesses that fail to declare allergens correctly.
Allergen reactions range from mild discomfort to life-threatening anaphylaxis. An estimated 1–2% of Australian adults and up to 10% of children have a clinically diagnosed food allergy. Correct allergen labelling is not a bureaucratic exercise — it is a fundamental food safety obligation.
Standard 1.2.3 · FSANZ Food Standards Code
The 14 mandatory allergens in Australia
Every one of these allergens must be declared when present as an intentional ingredient in a packaged food. Restaurants and caterers must be able to confirm or deny their presence on request.
Milk
Includes all dairy derivatives — butter, cream, cheese, lactose, whey, casein.
Eggs
Whole eggs and egg products including albumen, lysozyme, and mayonnaise.
Fish
All fin fish species. Fish sauce, Worcestershire sauce, and Caesar dressing commonly contain fish.
Shellfish (crustacean)
Prawns, crab, lobster, crayfish, and related crustaceans. Note: molluscs are a separate category.
Tree nuts
Almonds, cashews, hazelnuts, macadamias, pecans, pistachios, walnuts, and others. Each species should be named.
Peanuts
Technically a legume, not a nut. Must be declared separately from tree nuts. Common in satay sauces and Asian cuisine.
Wheat (gluten)
Wheat, rye, barley, oats, spelt, and kamut. Gluten-containing cereals are declared together.
Soybeans
Tofu, miso, tempeh, edamame, and soy sauce all contain soy. Highly refined soy oil may be exempt — check with your supplier.
Sesame
Sesame seeds, tahini, sesame oil, and halva. Added to the mandatory list in Standard 1.2.3.
Lupin
A legume increasingly used in gluten-free flour blends. Cross-reacts with peanut allergy in some individuals.
Molluscs
Oysters, mussels, squid, octopus, abalone, and snails. Declared separately from crustacean shellfish.
Sulphites (>10 ppm)
Sulphur dioxide and sulphite preservatives (e.g. 220–228). Common in wine, dried fruit, sausages, and condiments.
Royal jelly
A bee-derived product used in some health supplements and specialty foods. Can trigger severe reactions in people with bee allergy.
Bee pollen
Found in some health food products, teas, and specialty honey. Declared separately from royal jelly.
Note on sesame:Sesame was added to the FSANZ mandatory allergen list in 2021 following a review of emerging allergy data. If you are updating older labelling or internal allergen matrices, ensure sesame is included as a distinct category — separate from “tree nuts” or other seed categories.
Scope of compliance
Who must comply with FSANZ allergen rules?
Allergen obligations differ significantly between packaged food producers and food service businesses. Understanding which framework applies to your operation is the first step.
Packaged food manufacturers
Full mandatory allergen declaration on label, in bold text with sufficient contrast. Must list every allergen present as an intentional ingredient. The declaration must appear in the ingredients list and may also appear in a 'Contains' summary statement.
Restaurants and cafés
No formal written labelling obligation under FSANZ, but a common-law duty of care applies. Staff must be able to accurately answer customer allergen questions. Voluntary allergen menus and printed allergen matrices are strongly recommended practice.
Caterers and food service
Same duty-of-care obligations as restaurants. For catering events, written allergen information becomes especially important — guests with allergies may not be able to identify dishes at a buffet, and verbal information may not reach every guest.
Takeaway and ready-to-eat food
Takeaway meals in packaging that is applied at the time of sale (e.g. a sealed container with a label) must comply with allergen labelling rules if the food is sold in a package. Unwrapped takeaway food sold loose is treated as food service.
Legal meaning
“Contains” vs “may contain” — what's the difference?
These two statements are often confused, but they have distinct legal meanings and very different implications for consumers.
“Contains” — mandatory
The allergen is intentionally present
When an allergen is a deliberate ingredient in a food, the law requires it to be declared. This includes obvious cases (milk in cheese) and less obvious ones (wheat in a soy sauce, fish in a Worcestershire sauce). There is no threshold — even trace amounts of an intentional ingredient must be declared.
“May contain” — voluntary
A precautionary cross-contact warning
Used when an allergen is not an intentional ingredient but there is a genuine, documented risk of cross-contact during manufacture or preparation. FSANZ does not prescribe the wording or regulate it in the same way as a mandatory declaration. Businesses should only use “may contain” when the risk is real and documented — using it as a blanket disclaimer for all products is poor practice and potentially misleading.
Important:Under Australian Consumer Law, providing false or misleading allergen information — including omitting a “contains” declaration — can result in significant penalties and civil liability. If a guest suffers an allergic reaction because your staff stated a dish was allergen-free when it was not, your business may be liable. Accurate allergen information is not optional.
Two different frameworks
Labelling rules: packaged food vs food service
The Food Standards Code draws a clear distinction between food sold in a package and food sold in a food service context (restaurants, cafés, caterers, market stalls). The obligations are materially different.
Packaged food
A food is considered “packaged” under the Code when it is sealed or enclosed in packaging before it reaches the point of sale, and the label is applied before the consumer selects it. For packaged food, Standard 1.2.3 requires:
- ✓Full ingredients list with each allergen named, bolded, and distinguishable from surrounding text.
- ✓Allergen text must appear in a colour or shade that provides sufficient contrast against the label background.
- ✓A summary 'Contains' statement is permitted (e.g. 'Contains: milk, wheat, soy') and is considered best practice alongside the ingredients list.
- ✓The declaration must apply to every form of an allergen — for example, both 'almond oil' and 'almond flour' must be declared if present, even though both derive from tree nuts.
Restaurants, cafés, and food service
Food sold loose at a restaurant, café, school canteen, or catering event is excluded from the Standard 1.2.3 packaged food labelling requirements. You are not legally required to print allergen declarations on your menu, though doing so is strongly encouraged.
What does apply is a general duty of care under common law and Australian Consumer Law. If a guest asks whether a dish contains peanuts and your staff says “no” — and the dish does — you have provided false and misleading information with potentially life-threatening consequences. Food safety authorities in each state also have powers to prosecute for unsafe food practices.
Best practice for food service is to maintain an up-to-date allergen matrix for every dish on your menu, brief all front-of-house staff on how to use it, and have a clear escalation path when a guest has a complex or severe allergy. Many venues now provide a printed allergen menu or a digital allergen lookup as standard.
Regulatory update
The 2024 mandatory allergen declaration changes
From 25 February 2024, allergen labelling for all packaged food sold in Australia and New Zealand must comply with updated presentation requirements under Standard 1.2.3. The headline change:
Bold text + sufficient contrast — now mandatory
Every allergen declared in the ingredients list must be typeset in bold and must appear in a colour or shade that is clearly distinguishable from surrounding non-allergen text. Previously, allergens embedded in long ingredient lists could be easily missed. The new rule ensures they are visually salient.
The update was driven by evidence from consumer testing and incidents where allergens were declared in the ingredients list but went unnoticed by affected consumers. FSANZ reviewed international approaches — particularly the EU and UK mandatory allergen highlighting rules — and adopted similar requirements.
There was a transitional period: products labelled before February 2024 under the old format could remain on shelves until stock was exhausted, provided the underlying allergen information was accurate. New product runs and revised labels produced from that date must comply with the bold and contrast requirements.
For food manufacturers:if you are revisiting your label design, ensure your designer has updated every allergen entry in the ingredient list — not just the summary “Contains” box, which some manufacturers previously used in lieu of in-list highlighting.
Operational guidance
How to manage allergens in a restaurant kitchen
Good allergen management is a system, not a one-time task. Here are the five steps that underpin a professional allergen programme in a commercial kitchen.
Tag allergens at the ingredient level
Every ingredient in your pantry or prep list should be tagged with the allergens it contains. This is the foundation: if you get it right at this level, it propagates correctly through every recipe. Read supplier specifications carefully — sauces, stocks, and seasoning blends frequently contain hidden allergens such as wheat, soy, or sulphites.
Build a dish-level allergen matrix
Once every ingredient is tagged, compile a matrix: dishes as rows, the 14 allergens as columns. Mark each cell as 'Contains', 'May contain' (cross-contact risk), or 'Free'. Review the matrix every time a recipe changes or you swap a supplier ingredient.
Control cross-contact in the kitchen
Cross-contact (sometimes called cross-contamination) occurs when an allergen transfers from one food to another — through shared equipment, surfaces, oil, or hands. Key controls include colour-coded boards and utensils for allergen-free prep, designated fryer oil for allergen-free frying, and a dedicated section of the kitchen for allergen-free cooking when needed.
Train all staff on allergen protocols
Front-of-house staff must know which dishes are safe for which allergens, how to communicate accurately with guests, and when to escalate to the kitchen. Kitchen staff must understand the allergen matrix, follow cross-contact protocols, and know what to do when a modification is requested — including checking that every component of a dish (sauces, garnishes, bread) is accounted for.
Review on every menu change
The allergen matrix is only as useful as it is current. Set a policy that any menu change — a new dish, a recipe tweak, or a supplier substitution — triggers an allergen review before the dish goes live. Undeclared allergen incidents in hospitality are almost always the result of a process failure, not a knowledge failure.
Allergen matrix: what it looks like
An allergen matrix is the single most useful tool in food service allergen management. Rows are dishes; columns are the 14 allergens. Each cell contains one of three values:
Contains
Allergen is an intentional ingredient in this dish.
May contain
Cross-contact risk in kitchen — not an ingredient.
Free
No risk identified for this allergen in this dish.
Auto-generate your allergen declaration cards.
Tag allergens once per ingredient. Chef Pauly handles the rest — for every dish, every menu, every catering job.
How Chef Pauly helps
Allergen management built into your kitchen workflow
Chef Pauly is kitchen management software built specifically for Australian hospitality businesses — restaurants, cafés, and caterers. Allergen management is built into the ingredient and recipe layer, not bolted on as a separate module.
Allergen tagging per ingredient
When you add an ingredient to your Chef Pauly pantry, you tag it with the allergens it contains. The tagging follows the 14 FSANZ mandatory allergens. When that ingredient is used in a recipe, the allergen data carries through automatically. Change the ingredient and every affected dish updates.
Auto-generated allergen declaration cards
For each dish, Chef Pauly generates a printable allergen declaration card showing which of the 14 allergens are present. These are designed for kitchen reference, customer-facing allergen menus, and catering proposal documents. You can print them for your physical menu folder or export them digitally.
FSANZ-aligned nutrition labels
Alongside allergen cards, Chef Pauly generates FSANZ-format nutrition information panels for each dish — useful for packaged products, canteen menus, hospital foodservice, and any context where nutrition data must be displayed. The allergen and nutrition data share the same ingredient database, so updating one ingredient updates both outputs.
Catering job allergen overview
For catering businesses, each job's menu has an allergen summary that flags which dishes on the event menu contain which allergens. When you receive a guest dietary briefing, you can quickly cross-reference it against the menu without manually checking each dish.
A note on compliance: Chef Pauly is a kitchen management tool that supports your allergen programme — it is not a substitute for professional food safety advice or legal review. For packaged product labelling intended for retail sale, seek guidance from your state food authority or a registered food safety consultant to confirm your specific labelling requirements.
FAQ
Common questions about FSANZ allergen requirements
Which 14 allergens are mandatory in Australia?
Under Standard 1.2.3 of the FSANZ Food Standards Code, the 14 mandatory allergens are: milk, eggs, fish, shellfish (crustacean), tree nuts, peanuts, wheat and other gluten-containing cereals, soybeans, sesame, lupin, molluscs, sulphites at concentrations above 10 mg/kg, royal jelly, and bee pollen. All must be declared when present as intentional ingredients in packaged food.
Does FSANZ require allergen labelling in restaurants?
Restaurants and food service businesses are not subject to the same written labelling obligations as packaged food manufacturers under Standard 1.2.3. However, a common-law duty of care applies: businesses must be able to accurately answer allergen questions from customers. Providing false or misleading allergen information — whether verbally or in writing — exposes the business to significant legal and financial risk.
What changed in the 2024 allergen declaration rules?
From 25 February 2024, allergen declarations in the ingredients list of packaged food must appear in bold text and in a colour or shade that provides sufficient contrast against the label background. The change was introduced to reduce incidents where allergens were technically declared but visually overlooked by consumers. All new product labels and reprinted labels from that date must comply.
What is the difference between 'contains' and 'may contain'?
'Contains' is a mandatory declaration required when an allergen is an intentional ingredient in a food — e.g. 'Contains: milk, wheat, soy'. 'May contain' is a voluntary precautionary statement used when there is a genuine documented risk of cross-contact during manufacture or food preparation. 'May contain' is not regulated in the same way, but it must be accurate and should not be used as a blanket disclaimer for all products when no real risk exists.
How do I create an allergen matrix for my menu?
Start by tagging allergens at the ingredient level — every item in your pantry gets flagged for the allergens it contains. Then build a table with your dishes as rows and the 14 allergens as columns, marking each cell as 'Contains', 'May contain', or 'Free'. Review it every time a recipe or supplier ingredient changes. Software like Chef Pauly does this automatically from your ingredient tags.
Can I use Chef Pauly to generate FSANZ allergen labels?
Yes. Chef Pauly allows you to tag all 14 mandatory allergens against individual ingredients. Those tags automatically propagate through your recipes, and Chef Pauly generates allergen declaration cards for each dish. These are suitable for kitchen reference, customer-facing allergen menus, and catering proposals. The allergen data also connects to the FSANZ nutrition label generator. A 14-day free trial is available at chefpauly.com/signup.
Allergen management made simple
Stop managing allergens in a spreadsheet.
Tag allergens once against your ingredients. Chef Pauly generates declaration cards for every dish, keeps them up to date when recipes change, and exports them ready for your menu and catering proposals.
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