Ingredients Statements, PEAL, and Allergen Declarations Explained (Australia and New Zealand)

Allergen mislabelling is one of the leading causes of food product recalls in Australia. FSANZ Standards 1.2.3 and 1.2.4 set out mandatory requirements for how allergens must be declared — both within the ingredients list and as a standalone allergen statement. Getting this right is not optional: it protects your customers from life-threatening reactions and protects your business from regulatory action, retailer delisting, and reputational damage.

Every packaged food sold in Australia and New Zealand must carry an Ingredients Statement — a full list of all ingredients in the product, declared in descending order of ingoing weight (i.e. the weight of each ingredient before cooking or processing).

Key rules under FSANZ Standard 1.2.4:

• Ingredients are listed from heaviest to lightest by their ingoing weight, not the final weight after cooking.
• Ingredients that make up less than 5% of the finished product may be listed in any order after the ≥5% ingredients.
• Water added during manufacture must be listed unless it is driven off during cooking (e.g. it evaporates entirely).
• Allergens must be emphasised — bolded, capitalised, or otherwise visually distinguished — wherever they appear in the ingredient list (see PEAL below).

In Batchbase, the ingredients statement is generated automatically from your recipe. Each ingredient is sorted by its calculated ingoing weight. You can review and manually edit the statement on the Declarations tab of your spec sheet before publishing.

A compound ingredient is an ingredient that is itself made from multiple ingredients — for example, a pre-made spice blend, a sauce, or a sub-recipe you manufacture yourself.

Under FSANZ Standard 1.2.4, compound ingredients must be handled as follows:

• If the compound ingredient is ≥5% of the finished product: list it by name, followed immediately by its own sub-ingredients in brackets in descending order of weight — e.g. Tomato Sauce (Tomatoes, Vinegar, Salt, Sugar).
• If the compound ingredient is <5% of the finished product: you only need to list the sub-ingredients that are allergens. If there are no allergens in the sub-ingredients, you can list the compound ingredient by name only.

In Batchbase, sub-recipes can be set to "Compound ingredient" or "Dissolve into finished good" mode:

• Compound ingredient — the sub-recipe appears in the ingredients statement by name, with its sub-ingredients in brackets when ≥5% of the finished good, or name-only (allergens only in brackets) when <5%.
• Dissolve — each ingredient from the sub-recipe is merged into the finished good's ingredient list and sorted by weight, as if it were added directly.

You can preview exactly how a sub-recipe will appear in the final statement from the Label Identity section of the sub-recipe editor.

PEAL stands for Plain English Allergen Labelling — the FSANZ initiative introduced under Proposal P1044 that standardised how allergens must be declared in Australia and New Zealand. Before P1044, allergens could be buried in technical ingredient names (e.g. "casein" instead of "milk"); PEAL requires them to be declared using common, recognisable names so consumers can identify risks at a glance.

PEAL covers two distinct types of allergen declaration:

• Intentional allergens (a "Contains" statement) — allergens that are deliberate ingredients. These are mandatory under FSANZ Standard 1.2.3.
• Precautionary allergens (a "May Contain" statement) — allergens that may be present due to cross-contamination from shared equipment or production environments. These are voluntary but, once made, are subject to the same accuracy requirements as a "Contains" declaration.

The term "PEAL" is widely used by food technologists, retailers, and auditors in Australia and New Zealand when reviewing spec sheets and product labelling. If a buyer asks for your "PEAL statement," they are asking for both your "Contains" and "May Contain" declarations in plain English.

Important: A "May Contain" declaration is not a regulatory loophole. You cannot add a "may contain everything" disclaimer to avoid the need for thorough allergen control. If you declare that a product "may contain peanuts," that statement must be backed by a genuine cross-contamination risk assessment.

Under FSANZ Standard 1.2.3, the following allergens must be declared whenever they are present as intentional ingredients, regardless of the quantity used:

• Peanuts — (Arachis hypogaea); a legume, not a tree nut, and listed separately.
• Tree nuts — the FSANZ closed list: almonds, Brazil nuts, cashews, hazelnuts, macadamia nuts, pecans, pine nuts, pistachios, and walnuts. No other nuts are covered by this category.
• Milk — from all mammalian species (cow, goat, sheep, buffalo). Lactose-free and A2 milk are not exempt.
• Eggs — from all poultry species.
• Sesame seeds
• Fish — finfish only. Crustaceans and molluscs are covered separately under shellfish below.
• Shellfish — two distinct sub-categories, both mandatory:
  • Crustacea — prawns, lobster, crab, crayfish, and related species.
  • Molluscs — oysters, mussels, scallops, squid, octopus, abalone, and related species.
• Cereals containing gluten — wheat (including spelt and kamut), rye, barley, oats, and their hybridised strains. The standard does not exempt low-gluten varieties.
• Soy — soybeans and all soy-derived ingredients (soy flour, soy protein isolate, soy lecithin, etc.).
• Lupin — Lupinus species seeds and flour; most commonly encountered in gluten-free and high-protein bakery products.

There is no de minimis threshold — any intentional presence triggers mandatory declaration regardless of amount.

These allergens must be declared in two places: emphasised (bold, capitals, or another clearly distinguishing format) within the ingredients list, and in a separate standalone allergen statement — e.g. "Contains: Milk, Wheat, Soy."

Contains — the allergen is an intentional ingredient. Declaration is mandatory under FSANZ Standard 1.2.3.

May Contain — the allergen may be present due to shared equipment or production facilities (cross-contamination risk). Declaration is voluntary but, once made, must be accurate and backed by a genuine risk assessment. Under PEAL, both statements must use the same plain English allergen names — you cannot use "casein" in place of "milk" or "lactose" in place of "milk" in either declaration.

Do not use "May Contain" as a blanket disclaimer for allergens you haven't assessed. If you declare it, you are accountable for it.

In Batchbase, you set both "Contains" and "May Contain" allergen flags on each raw material record. The Declarations tab of your spec sheet then merges all flags across the recipe into a single, formatted allergen statement automatically.

When you build a recipe in Batchbase, the allergen declaration is assembled automatically:

1. Every raw material in the recipe carries its own allergen flags ("Contains" and "May Contain").
2. Batchbase scans all flags across all ingredients — including ingredients inside compound sub-recipes — and merges them into a single declaration.
3. The Contains statement lists all intentional allergens present across any ingredient.
4. The May Contain statement lists all cross-contamination allergens flagged on any raw material.
5. Allergens are automatically bolded in the ingredients statement wherever they appear, satisfying the PEAL plain English emphasis requirement.

You can review and edit both the ingredients statement and the allergen declaration on the Declarations tab before publishing. If any raw material is missing allergen data, Batchbase flags it as incomplete — so nothing is accidentally omitted.

CoOL (Country of Origin Labelling) is a separate mandatory requirement under the Country of Origin Food Labelling Information Standard 2016, administered by the ACCC and DAFF — not FSANZ. (The former FSANZ Standard 1.2.11 was repealed in 2016 when CoOL was moved to Commonwealth consumer law.) CoOL identifies where your ingredients were grown, produced, or significantly transformed — distinct from allergen disclosure, but typically reviewed at the same time by buyers and auditors.

For products sold in Australia, the standard requires a statement such as "Product of Australia" or "Made in Australia from local and imported ingredients", along with a bar chart showing the percentage of Australian content.

Batchbase calculates CoOL automatically from the origin data on your raw material records:

• If raw materials were imported from the FSANZ database, origin data is often pre-populated.
• If you use USDA-sourced ingredients or manually created raw materials, you will need to enter origin data on each raw material record.
• The spec sheet CoOL section shows the calculated Australian content percentage, the countries of origin for each ingredient, and the appropriate label statement.

CoOL does not affect your allergen declarations, but both are required for a complete, compliant spec sheet.

Primary regulatory sources:

• FSANZ Allergen Labelling for Food Businesses — the authoritative FSANZ guidance on which allergens must be declared and how, covering both Standard 1.2.3 requirements and PEAL.
• FSANZ Standard 1.2.4 — Labelling of Ingredients — the full legislative text governing the ingredients statement, compound ingredients, and allergen emphasis.
• FSANZ Proposal P1044 — Plain English Allergen Labelling Approval Report — the full regulatory history and rationale behind the PEAL initiative.
• ACCC Country of Origin Food Labelling — authoritative guidance on CoOL requirements for food sold in Australia.

Before publishing a spec sheet:

• Every raw material has had its allergens reviewed — "Contains" and "May Contain" flags are not left blank.
• Cross-contamination risks have been assessed and flagged where genuine risk exists.
• Compound ingredients are configured correctly (≥5% vs <5% behaviour previewed and confirmed).
• The generated ingredients statement has been reviewed — ingredient order, compound ingredient brackets, and allergen emphasis are all correct.
• The allergen declaration ("Contains" and "May Contain" / PEAL statements) has been reviewed for accuracy, not just accepted automatically.
• If using USDA-sourced data, allergen flags have been set manually from your supplier's specification.
• CoOL origin data is complete for all raw materials.
• The completed spec has been reviewed by a qualified food technologist before commercial use.

Batchbase automates the generation — but the accuracy of the underlying raw material data is your responsibility.