Allergen Declarations Explained

Allergic reactions to food can be life-threatening. FSANZ Standard 1.2.3 makes allergen declarations mandatory on all packaged food sold in Australia and New Zealand. Incorrect or missing declarations are among the most common causes of food product recalls in Australia.

Getting this right is not optional — it protects your customers and your business from regulatory action, costly recalls, and reputational damage.

Under FSANZ Standard 1.2.3, the following allergens must be declared whenever they are present, regardless of the amount:

• Peanuts
• Tree nuts — almonds, Brazil nuts, cashews, hazelnuts, macadamias, pecans, pine nuts, pistachios, walnuts
• Milk
• Eggs
• Sesame seeds
• Fish
• Shellfish — crustacea (prawns, lobster, crab) and molluscs (oysters, squid, mussels)
• Wheat and other gluten-containing cereals — rye, barley, oats
• Soy
• Lupin

These must be declared in the ingredient list and in a separate allergen statement (e.g. "Contains: milk, wheat, soy.").

Contains means the allergen is an intentional ingredient — it must be declared.

May contain is a voluntary statement used to warn consumers about unintentional allergen presence due to shared equipment or shared production facilities (cross-contamination risk). Once you make a "may contain" statement, it is subject to the same accuracy requirements as a "contains" declaration — do not use it as a catch-all disclaimer.

In Batchbase, you flag both "contains" and "may contain" (cross-contamination) allergens on each raw material record. The spec sheet declaration is generated automatically from those flags across all ingredients in the recipe.

When you build a recipe, Batchbase scans the allergen flags on every linked raw material and combines them into a single declaration:

• All "contains" allergens across all materials are merged into the Contains statement.
• All "may contain" cross-contamination flags are merged into the May Contain statement.

You can review and edit the generated declaration on the spec sheet before publishing. If a raw material is missing allergen data, Batchbase flags it as incomplete so nothing is accidentally omitted.

CoOL is a separate regulatory requirement under FSANZ Standard 1.2.11. It identifies where your ingredients were grown, produced, or significantly transformed — distinct from allergen disclosure, but often reviewed together by buyers and auditors.

Batchbase populates CoOL data from the FSANZ ingredient database's origin fields. When you use USDA-sourced ingredients, CoOL origin data is not automatically available and must be entered manually on the raw material record.

Before publishing a spec sheet, confirm:

• Every raw material in the recipe has had its allergens reviewed — not left blank.
• Cross-contamination risks have been flagged where applicable.
• The generated allergen statement has been reviewed for accuracy, not just accepted automatically.
• If using USDA-sourced data, allergen flags have been set manually based on your supplier's specification.
• The completed spec has been reviewed by a qualified food technologist before commercial use.

Batchbase can automate the generation of the declaration, but the accuracy of the underlying raw material data is your responsibility.