Food Standards Australia New Zealand — allergen labelling
Food allergen labelling in New Zealand — obligations for food businesses
Incorrect allergen information can be fatal. NZ food businesses have strict labelling obligations under Food Standards Australia New Zealand. Here's what's required.
📋 Food Standards Australia New Zealand Code — Standard 1.2.3 (allergens)
The 14 major allergens requiring declaration
The following must be declared whenever present as an ingredient or as a component of a compound ingredient:
Cereals containing gluten (wheat, rye, barley, oats)
Crustacea and products
Eggs and egg products
Fish and fish products
Milk and milk products
Tree nuts (almonds, cashews, walnuts, etc.)
Peanuts and peanut products
Sesame seeds
Soybeans and products
Lupin and products
Molluscs
Sulphites (≥10mg/kg)
Labelling requirements for packaged food
Must be declared clearly in the ingredient list
For packaged food sold to consumers, each allergen must be declared in the ingredient list. The allergen can be identified by its common name in the list — e.g. "wheat flour", "milk solids". Bold formatting is not legally required in NZ but is strongly recommended best practice.
If an allergen is present but not as an ingredient (cross-contamination), a "may contain" advisory may be used — but this is voluntary, not mandatory.
Unpackaged food — café, restaurant, takeaway
Allergen information must be available on request
For food sold without packaging (cafe meals, restaurant dishes, takeaway food), NZ law does not currently require menus to list allergens. However:
- You must be able to provide accurate allergen information when asked
- Your Food Control Plan must include allergen management procedures
- Staff must be trained on your allergens and how to respond to allergen queries
- Cross-contamination risks must be managed and disclosed
Best practice: display allergen information on your menu or have a printed allergen sheet available. This reduces risk and builds trust.
Managing cross-contamination
- Separate storage for allergen-containing ingredients
- Dedicated utensils, chopping boards, and cookware for allergen-free preparation
- Clear labelling of allergen-containing items in the kitchen
- Staff training — every person handling food must understand allergen risks
- A clear communication pathway when a customer declares an allergy
- Document your allergen controls in your Food Control Plan
Anaphylaxis — the life-threatening response
Have a plan for when it goes wrong
Food businesses should have an anaphylaxis response plan: call 111 immediately, administer an epinephrine auto-injector (EpiPen) if available and the person or their companion consents, lay the person flat with legs raised, stay with them until ambulance arrives. Document the incident.
Source: Food Standards Australia New Zealand Code, Standard 1.2.3. MPI:
mpi.govt.nz. General information only — this is a rapidly evolving area; check for current requirements.
Frequently asked questions
Is 'may contain' labelling mandatory?
No. 'May contain' advisory labelling for cross-contamination risks is voluntary in NZ and Australia. However, if you use it, it must be accurate. Some businesses avoid 'may contain' on everything as it becomes meaningless — only use it where there is a genuine cross-contamination risk.
What if a customer claims an allergy and has a reaction?
This is a serious event. Call 111 if there is any sign of anaphylaxis. Document everything. Preserve any food samples if possible. Contact your insurer. Review what allergen information you provided and whether your procedures were followed. You may face a liability claim.
Do gluten-free claims have specific requirements?
Yes. Food labelled 'gluten free' must contain no detectable gluten (below 3ppm in NZ). 'Low gluten' is a different claim with a higher threshold. Be very cautious with these claims — they create real safety expectations.
Does my FCP need to address allergens?
Yes. Allergen management should be a specific section of your FCP — identifying which allergens are present, how cross-contamination is prevented, how customer allergen requests are managed, and how staff are trained.