A&AA Position Statement: Allergen labelling of packaged foods


Food allergy has increased in prevalence in recent years. 1 in 10 infants, 6% of children, 5% teens and up to 4% of adults now have a food allergy.

People (consumers) with a food allergy are required to avoid the food they are allergic to. This includes any products which contain the food they are allergic to.

Consumers must always read the ingredient information on all food products purchased. We encourage consumers to read the ingredients on the food pack as well as any precautionary allergen labelling (PAL) statement (e.g. May contain…) and allergen summary statement (i.e. the Contains statement) when purchasing the food, when unpacking the food at home and then just before cooking/eating the food. This is a very time consuming, onerous task.

Consumers with food allergy and consumers who care for someone with food allergy depend on food packs to clearly identify ingredients and make an informed choice about eating the food, or not.

Consumers need to be aware of:

  • companies possibly changing ingredient content. This includes removal or addition of an allergen between one purchase and another
  • two versions of the one product being on shelf during transition from one recipe to another
  • different varieties of a very similar product containing different allergens
  • different size packs of the one product possibly having different ingredient content
  • parallel imports –where an Australian made product and the same product from another country (parallel import) contain different allergens and are for sale at the same time. Parallel imports are often sold in small variety stores and not grocery type stores. They are generally cheaper than the Australian made version.

Packaging of similar varieties of the one product (e.g. biscuits or chocolate) containing different allergens should be easily recognisable to consumers however consumers should always read ingredient information.

Consumers should be notified when a new variety (with different allergen content) or changes to the formulation (different allergen content) of a product is being introduced. Allergy & Anaphylaxis Australia (A&AA) encourages placement of standout alert on front of pack notifying consumers of the ingredient/recipe change. This alert should remain on the pack for 6 months after the change of ingredients. Ideally, a universal symbol indicating change in allergen ingredients should be developed and mandated for all packaged food products.

Importantly, manufacturers are encouraged to provide Allergy & Anaphylaxis Australia (A&AA) with information on ingredient changes involving common food allergens. Details on the ingredient changes and graphics of the products can then be shared with members and followers via social media, email and on the website. For more information on notifications food manufacturers can contact us

Other ways manufacturers can proactively notify consumers of a new variety or ingredient formulation change involving an allergen/s include:

  • Introduction of different colour packaging for a new variety
  • Placement of accurate allergen information on manufacturers’ website/social media site.
  • Shelf wobbler to highlight a change to customers in store

Manufacturers should clearly identify different size packs of the same food products that have different allergen content.

Manufacturers should aim to have all package sizes of the same products contain the same allergens. Differences in allergen content in different size packs increases risk of allergic reactions.

If the above cannot be avoided, manufacturers should actively communicate on same products having different allergen content. Serious consideration should be given to notification on front of pack that alerts consumers to different size packs contain different allergen content. A&AA should also be contacted so that a food alert can be sent to consumers via social media, A&AA website and email.

Allergen information on packaged food should include wording that is in plain English and can be easily understood. The font (including size) should be clear and readable. Allergens should be listed in bold type. If a food product has a PAL and/or contains statements, these should be placed directly under the ingredient list on the pack.

Precautionary Allergen Labelling

A&AA supports the mandatory use of the VITAL process for all packaged foods in Australia to assess the need for precautionary allergen labelling. A&AA advocates that foods that have been through the VITAL process use a symbol to indicate that they have been assessed using the VITAL process and tested using the VITAL calculator. See www.allergenbureau.net

In summary

In relation to packaged food, consumers must:

  • Always read food labels every time they purchase a product.
  • Read ingredients of every pack when purchasing more than one of the same product.
  • Be aware that very similar products made by the one company may have different allergen content.
  • Be aware that different size packs of the same product may have different ingredients
  • Not eat a food if information on content is unclear
  • Contact the manufacturer if more information is required
  • Report a food if they think it is not labelled correctly
  • Report a food they think has triggered an allergic reaction if the allergen is not listed on the label.

Manufacturers need to communicate:

  • Allergen content, changes, discrepancies etc. that may increase risk of allergic reactions in consumers with food allergy. This should be part of risk assessment and management.
  • Changes in formulation of a product
  • With A&AA when changes to allergen content are made so we can alert consumers via social media, email and website posts

Consumers and manufactures are encouraged to contact A&AA to discuss challenges in food labelling with the aim of improving food safety for all.

Allergy & Anaphylaxis Australia
Website www.allergyfacts.org.au
Email contact us
Telephone 1300 728 000

Content created June 2020

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