IFN 08-17 – Mandatory allergen labelling
Issued: 18 May 2017
The purpose of this notice is to alert importers of their responsibility to ensure imported food is safe and allergens are correctly declared and labelled. This notice provides further information and guidance on complying with the mandatory allergen labelling requirements in the Australia New Zealand Food Standards Code.
Mandatory allergen labelling requirements
Allergen labelling saves lives and can mean the difference between life and death for people with food allergies.
Importers must ensure that they meet the mandatory allergen labelling requirements in the Australia New Zealand Food Standards Code.
The Australia New Zealand Food Standards Code specifies the allergens that must be on food labels. These allergens are: peanuts, tree nuts, milk, eggs, sesame seeds, fish and shellfish, soy and wheat and lupins. These ingredients must be declared on the food label whenever they are present as ingredients or as components of food additives or processing aids.
If the food is not in a package or is not required to have a label (for example, bulk containers), allergen information must accompany the consignment so the business purchasing the food has access to the allergen information.
If you import food you are responsible for understanding and meeting mandatory allergen labelling requirements.
Many food recalls occur because food businesses have not labelled allergens correctly. Meeting mandatory allergen labelling requirements can save lives. But meeting the requirements can also mean you avoid having to conduct a food recall, saving your business time and money.
What importers need to do?
Importers should review products they import and ensure the labelling meets the mandatory allergen labelling requirements. This may mean contacting overseas suppliers and requesting them to provide information and assurances as to whether any allergens are present. Importers should educate supply partners on the allergens to avoid health incidents and non-compliance. Importers can also consider analysing the product to verify any assurances provided by overseas suppliers.
In considering whether allergens must be declared importers should ensure that suppliers are aware of the difference between mandatory allergen labelling and any biosecurity requirements for the presence of particular foods. For example, a declaration that a food contains less than 5% egg does not necessarily mean that the food does not contain egg.
Further assistance in managing allergens in food is set out below.
Importation of food which poses a risk to human health is an offence
Importers must be aware that the presence of undeclared allergens poses a risk to human health for people with food allergies.
Under section 8 of the Imported Food Control Act 1992 (Act), it is an offence to import food into Australia if the importer knows, or ought reasonably to have known, that it poses a risk to human health. The offence carries a penalty of imprisonment for 10 years.
Assistance in managing allergens in food
As the responsible food business in Australia, the importer must know what ingredients are in the food and whether these ingredients are allergens. Upon arrival, the importer must also ensure allergens are correctly declared on the label.
There are tools to assist the food industry (including importers) manage allergens and labelling. The Australian Food and Grocery Council publish the Food Industry Guide to Allergen Management and Labelling.
As well as publishing standards, Food Standards Australia New Zealand have an Allergen labelling page, summarising allergen labelling requirements. State and territory health authorities also publish requirements and assistance on identification and declaration of food allergens, such as: