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Plain English allergen labelling - what it means for dietitians and consumers 

The new Plain English allergen labelling (PEAL) introduced in February makes it much simpler for consumers to know which foods contain allergens.  

“It’s a big improvement, especially for anyone who’s newly diagnosed, for children and young adults and people whose first language isn’t English,” says  Ingrid Roche, an APD specialising in paediatric food allergy at Perth Children’s Hospital and in private practice,  and co-lead on the food service project of the National Allergy Strategy.

She explains some of the new labelling changes here.  

What’s different about the new label?

• The information is easier to understand… “Under the old labelling, an ingredient like lactoperoxidase, a processing agent, could be declared on the ingredient list with no need to explain it came from milk,” Ingrid explains. “If you didn’t know what it meant and ate the product you could have a reaction. Now the wording is simpler: if an ingredient with an obscure name is derived from an allergen - like milk, for example - it’s listed with ‘milk’ in brackets.
• …and easier to find. There are now only two places on a package where allergens must be declared - the ingredient list and summary statement. All allergens in the ingredient list and summary statement must be printed in a bold font to stand out clearly. The summary statement (once voluntary, now mandatory) must be displayed next to the ingredient list so consumers can easily see them together. 

 Some groups of foods have been expanded.  

“You might be allergic to just one or two nuts, not all nuts, so listing ‘tree nuts’ is no longer allowed - almonds, cashews, hazelnuts, walnuts, pecans, macadamias, Brazil nuts, pine nuts and pistachios must be listed individually,” Ingrid explains. “Instead of ‘cereals including gluten’ on the ingredient list, cereals containing gluten like barley, wheat, rye and oats must all listed separately, with wheat and gluten listed separately in the summary statement. This will make it easier for consumers with wheat allergy to see if wheat is an ingredient.

“Molluscs have been included as an allergen, and labels must list them separately to fish and crustacea - they’re all different allergies. The term ‘shellfish’ is no longer used - you can be allergic to molluscs, but not crustacea, and the other way around.”   

But Precautionary Allergen Labelling (PAL) is still hit and miss

PAL means statements like   ‘may contain traces of….’ or ‘made in the same facility as ….’ that allow for the risk of accidental cross-contamination with allergens during production.   

But these statements are problematic because PAL is unregulated and voluntary.

“A whopping 65 % of supermarket products carry PAL – that’s a lot of products to avoid. You can’t tell from the packaging whether the manufacturer has applied a risk assessment process to decide there’s a definite risk of cross contamination and that’s why the PAL is there. And you can’t tell whether the other 35% of products that don’t have PAL have undergone a risk assessment either,” says Ingrid Roche.

“It can be confusing for consumers who don’t know if the PAL statement means there’s definitely a risk - or if the company added the statement because they use an allergen in the factory but don’t know whether it will end up in a  product or not.”

It’s also risky because different PAL statements can be interpreted differently, she adds. “Some consumers see ‘…may be present’ as less risky than ‘made in the same factory as …’, for example. They ignore some statements but not others.”

Yet there’s a way to take the guesswork out of these precautionary statements. VITAL (Voluntary Incidental Trace Allergen Labelling), an assessment process developed by the Allergen Bureau, can assess the risk of cross contamination in food products. Products found to have a significant risk of a reaction then carry the statement ‘may be present‘: (name of allergen)’

But not all manufacturers use VITAL - even though it’s encouraged by the Allergen Bureau and the Australian Food and Grocery Council. Those that do can be part of a certification program that allows them to put a VITAL symbol on the label - but not all companies which use VITAL have taken this up yet, says Ingrid.   

“This means that unless products carry the V symbol, it’s still up to consumers to contact the manufacturer and ask if a risk assessment has been applied.”

The new labelling won’t be fully implemented until 2026 - why so long?

“I think FSANZ was taking food companies into consideration because some may have already ordered a two year supply of packaging. But we may see the new labelling adopted by many manufacturers before 2026 - the Allergy Bureau and the Australian Food and Grocery Council are encouraging companies to use it on new packaging now, and some manufacturers are already using it,” she says. 

What does the new labelling mean for dietitians? “We still have to explain both the old and new allergen labelling and recommend that consumers ask manufacturers if they’ve used VITAL so they can make an informed choice about a product.

“The real change will be in 2026 when we no longer have to give clients long lists of ingredients with obscure names to check for on ingredient lists.”

Should ingredients derived from insects be declared as allergens too? “Insects have similar proteins to the allergens in crustacea so people will have to be careful with these novel foods,” says Ingrid. “There’s no requirement to list insect ingredients as an allergen yet - you just have to check that it’s not declared on the ingredient list or elsewhere on the package. We know there’ll be some reactions, but for now there are plenty of other foods to choose from, and use of insects in food products is not very common. But we need to encourage patients with crustacea allergy to check food labels every time they buy a food, and avoid foods from insects until they discuss it with their allergy specialist.” 

 For more in depth information about PEAL including the problems raised by Precautionary Allergen Labelling, listen to Ingrid Roche‘s presentation here.

You can read a review of her presentation here