Allergen Declaration

What is an Allergen Declaration?

An allergen declaration is a mandatory statement on a food label that discloses the presence of any of the Schedule 9 allergens defined in FSANZ Standard 1.2.3 of the Australia New Zealand Food Standards Code. The declaration is required regardless of the quantity of the allergen present in the finished food — there is no threshold below which declaration becomes optional.

The 14 Declared Allergens in Australia and New Zealand

Standard 1.2.3 currently requires declaration of these allergen groups:

1. Peanuts
2. Tree nuts (almond, Brazil nut, cashew, hazelnut, macadamia, pecan, pine nut, pistachio, walnut, and others)
3. Milk
4. Eggs
5. Sesame seeds (added to Schedule 9 in 2021)
6. Fish
7. Crustacea (prawns, crab, lobster, etc.)
8. Molluscs (oysters, squid, clams, etc.)
9. Soy
10. Wheat and other gluten-containing cereals (rye, barley, oats, spelt, triticale)
11. Lupin
12. Royal jelly
13. Bee pollen (propolis)
14. Added sulphites at concentrations of 10 mg/kg or more

Allergen Declaration Requirements in Practice

Where the declaration must appear

Allergens must be declared in the ingredient list using the common name of the allergen in bold type or a contrasting colour, or in a separate "Contains:" statement immediately following the ingredient list. Both approaches are compliant; the bold-in-ingredient-list approach is more common for complex products.

May contain statements

"May contain traces of..." statements are voluntary and are used to warn consumers of potential allergen cross-contamination during manufacturing. They are not a substitute for mandatory declaration of intentionally added allergens. FSANZ guidance notes that precautionary statements should only be used where a genuine risk of cross-contact has been assessed — using them indiscriminately as a legal shield erodes consumer trust and may invite regulatory scrutiny.

Compound ingredients and allergens

If your product contains a compound ingredient (e.g., a sauce that itself contains wheat), the allergens in the sub-ingredients must still be declared in the finished product's ingredient list. See compound ingredient for declaration rules.

Common mistakes

Missing sub-ingredient allergens. A manufacturer includes a compound ingredient on their label but fails to declare the allergens within it. If your sauce contains soy sauce, and soy sauce contains wheat, then wheat must appear in the finished product's allergen declaration.

Assuming "traces" removes the obligation. If an allergen is an intentional ingredient — even in very small quantities as a flavouring or processing aid — it must be declared. The trace threshold applies to unintentional contamination only.

Outdated labels after supplier changes. If a supplier reformulates an ingredient you use, the allergen profile of your finished product may change without your knowledge. Supplier specification management is critical.

How Batchbase Handles Allergen Declarations

Batchbase automatically detects and tracks allergens across every ingredient in your recipe. When you add an ingredient from the FSANZ database or from a supplier specification, Batchbase identifies the allergen groups it belongs to and flags them at the recipe level.

If you update an ingredient — swapping a supplier, changing a formulation — the allergen summary for every affected recipe updates instantly. The allergen declaration is generated automatically in the correct "Contains:" format for your label, and cross-contamination (may contain) flags can be added at the product level.

Related Standards and References

• FSANZ Standard 1.2.3 — Warning statements, advisory statements and declarations
• Schedule 9, Standard 1.2.3 — The complete list of declared allergens
• FSANZ Standard 1.2.4 — Statement of ingredients (bold allergen in ingredient list)
• FSANZ allergen labelling guidance