How does food allergen labelling differ in Australia, the UK and the USA?

Dave Hoogakker
January 31, 2024
5 min read
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How does food allergen labelling differ in Australia, the UK and the USA?

Any kind of non-compliance can impact the reputation of your food and beverage brand, but incorrect allergen labelling can be especially damaging. 

Omitting vital information from your product packaging can compromise the safety of your consumers – and put your business in the regulator’s spotlight. 

Allergen labelling mistakes happen more often than you think, especially among brands selling in multiple markets. Mandatory and precautionary allergen information varies from country to country, affecting what you must include on product packaging AND how that data is formatted. 

Australia, the UK and the USA are good examples of the global differences in food allergen labelling requirements.

As all three countries speak English and consumers follow similar diets, you’d think one allergen label would work across these territories. However, there are significant differences in how each country approaches allergen labelling. 

Let’s compare their regulations: 

Australia food allergen labelling 

In 2021, Food Standards Australia and New Zealand (FSANZ) introduced new Plain English Allergen Labelling (PEAL) requirements to make information more accessible for consumers. 

Under the guidelines, major allergens must be highlighted in bold within the ingredient list on food and beverage labels, with individual cereals, molluscs and tree nuts declared separately. 

Australia’s current major food allergen list includes: 

  • Almond
  • Barley (if it contains gluten)
  • Brazil nut 
  • Cashew
  • Crustacean 
  • Egg
  • Fish
  • Hazelnut
  • Lupin
  • Macadamia 
  • Milk
  • Mollusc
  • Oats (if it contains gluten)
  • Peanuts
  • Pecan 
  • Pistachio
  • Pine nut 
  • Rye (if it contains gluten)
  • Sesame
  • Soy, soya, soybean 
  • Sulphites (when added in amounts equal to/more than 10mg per kilogram of food)
  • Walnut
  • Wheat

Product packaging must also include a dedicated statement (written in bold) that lists major allergens – for example, ‘contains milk, egg, sesame’. 

FSANZ gave food and beverage brands three years to meet PEAL requirements, which means all labels must comply with these criteria by February 2024. 

There are some exemptions to Australian allergen labelling rules that are worth noting, as the ingredients have been processed in a way that makes them suitable for people with allergies. 

For example, glucose syrups made from wheat starch are exempt from declaring wheat, fully refined soybean oil is exempt from declaring soy, and distilled alcohol from wheat or whey is exempt from declaring wheat or milk. 

In addition to PEAL requirements, Australian food authorities urge brands to include Precautionary Allergen Labels (PALs) on product packaging. 

PALs help to identify the unintended presence of major allergens in food and beverage products – for example, if an item has been manufactured in the same facility as products containing allergens. 

However, the Australian PAL system is currently voluntary and unregulated, meaning there is no single approach to including and formatting precautionary statements. 

A study of 1335 food products sold in the country found that 65% of packaging contained a PAL statement for one or more allergens. Tree nuts were the most commonly listed allergen, with the phrases ‘may contain traces of’ and ‘may be present’ the most popular warnings.  

UK food allergen labelling 

Like in Australia, food and beverage brands selling products in the UK must include mandatory allergen information on product labels. However, the list of major allergens differs slightly:  

  • Celery
  • Cereals containing gluten (e.g. wheat, barley and oats)
  • Crustaceans (e.g. prawns, crabs and lobsters)
  • Eggs
  • Fish
  • Lupin
  • Milk
  • Molluscs (e.g. mussels and oysters)
  • Mustard
  • Peanuts
  • Sesame
  • Soybeans
  • Sulphur dioxide and sulphites (if they are at a concentration of more than ten parts per million)
  • Tree nuts (e.g. almonds, brazil nuts, cashews, hazelnuts, macadamia nuts, pecans, pistachios and walnuts)

UK mandatory allergen labelling rules apply to additives, processing aids and any other substances present in the final product. Each allergen must be highlighted on the label using a different font, style or background colour, in the ingredients.

Where UK allergen labelling differs from Australia's is precautionary statements. 

The UK Food Standards Agency (FSA) updated its best practices for PALs in September 2023 to provide more clarity for consumer brands. New guidelines state that:  

  • Precautionary allergen labels only apply if there is an unavoidable risk of cross-contamination, which can’t be controlled through segregation and cleaning

  • Food and beverage brands should specify which major allergens could feature in a product on precautionary labels – for example, stating ‘may contain peanuts’ instead of ‘may contain nuts’

  • PALs should still be included on products labelled ‘vegan’ if there is a risk of cross-contamination, as the two statements are aimed at different consumer groups

These latest guidelines put the UK ahead of many other regions, including Australia and the USA, for regulating precautionary allergen statements. The last point carries particular significance for UK food brands, as in 2017, a British woman with a severe cow’s milk allergy died after eating a pre-packaged wrap labelled as suitable for vegans. 

USA food allergen labelling 

Food and beverage brands selling products in the USA are governed by the Food and Drug Administration’s (FDA) Food Allergen Labelling and Consumer Protection Act (FALCPA).

Released in 2004, FALCPA requires all major food allergens to be declared on product packaging in one of two ways: 

  • On the ingredient list in parentheses following the ingredient name – for example ‘flour (wheat)’; or
  • In a dedicated statement immediately after the ingredient list that begins with the word contains – for example, ‘contains milk’ 

These requirements are the same as Australian food law, with the exception that Australian food brands must list major allergens in both formats, whereas U.S. brands have the option to choose one or the other. 

The USA also has a smaller list of major allergens compared to Australia and the UK, which currently encompasses nine food groups: 

  • Crustacean shellfish
  • Egg
  • Fish
  • Milk
  • Peanuts
  • Sesame
  • Soybeans
  • Tree nuts
  • Wheat

The USA mirrors Australia in its approach to precautionary allergen labels, encouraging companies to include advisory statements for products where cross-contamination is unavoidable – for example, facilities using shared equipment or production lines. 

These statements are not required by law, but they can make consumers with allergies aware that a product may contain a certain allergen, or that it has been produced in a facility that also uses major allergens.  

Managing food allergen information on your product packaging 

Selling internationally compliant food and beverage products relies on your brand understanding: 

  • Which allergens must be listed in each region 
  • How information should be formatted on your product label or packaging 
  • Whether precautionary allergen statements are required by law (and how they should be worded)

You may also need to translate allergen information into multiple languages while adapting your product packaging without impacting brand consistency. Food allergen labelling can quickly become a complex issue!  

It’s possible to manage this process in-house, but it can take many hours of research and painstaking work to produce labels in several languages. Even then, you may still need third-party validation to check your allergen information is correct. 

Rather than shoulder the burden of localisation internally, many food and beverage brands outsource product labelling work to a food compliance expert like Hooley Brown. 

We help companies selling all over the world adapt their packaging and labelling for local audiences, ensuring their products meet regional regulations without diluting their global brand identity.  

Visit our product and packaging localisation page to learn more about our label compliance services, or book a 30-minute call with our Co-Founder, Clare Daley, to discuss your allergen labelling requirements. 

This blog post was written in January 2024. Facts were correct at the time of writing. 

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