New allergen labelling exemptions in Australia and New Zealand – an example of industry collaboration

Allergen Labelling Exemptions

The Australia and New Zealand Food Standards Code has been changed to remove mandatory allergen labelling requirements for some foods and ingredients derived from allergenic sources. These foods and ingredients have been assessed as safe, because they are processed in a way that makes them suitable for consumers who are allergic to wheat, soy or dairy.

The products now exempt from the requirement are:

  • glucose syrups made from wheat starch (subject to low limits)
  • fully refined soy oil
  • soy derivatives (tocopherols and phytosterols)
  • distilled alcohol from wheat or whey.

Glucose syrups must have no more than 20 mg/kg detectable gluten to meet the requirements for an exemption from mandatory labelling of wheat.

The process that led to these exemptions is a wonderful example of what can be achieved through a food industry collaboration – in this case an Allergen Bureau Working Group – working proactively with a regulatory authority.

Starting as a small, dedicated group, the Allergen Bureau Allergen Labelling Exemptions Working Group met with Food Standards Australia New Zealand (FSANZ) in Dec 2011 to discuss potential ways of working collaboratively to respond to the recent FSANZ Review of the Regulatory Management of Food Allergens, published in 2010, and progress allergen labelling exemptions for highly refined substances. In particular, the recommendation in this review that stated:

FSANZ to consider, on a case-by-case basis, the scientific and clinical data available on the allergenicity of food ingredients derived from allergenic sources. In consultation with the food industry, FSANZ to develop options to reflect the evidence base through guidance and/or regulatory amendments.

To this end, two key pieces of work were undertaken by the Allergen Labelling Exemptions Working Group:

  1. Determining local ANZ industry prioritisation for the allergen exemptions granted in other internationally regulated countries/regions; and
  2. Determining the status and availability of information to support labelling exemptions for highly refined substances.

Based on the results of an industry prioritisation questionnaire, the top three industry prioritised allergen labelling exemptions were identified for the Allergen Labelling Exemptions Working Group to progress as a first stage with FSANZ. These were:

  • Wheat & other cereals containing gluten (glucose syrups and maltodextrins)
  • Soy (fully refined oil or fat)
  • Soy (E306, natural D-alpha tocopherol, natural D-alpha tocopherol acetate, natural D-alpha tocopherol succinate)

The Working Group co-ordinated with key industry stakeholders to provide FSANZ with a dossier of available material to feed into the proposal. This material included contributions from Australian and New Zealand companies (specifically Cargill for RBD soybean oil, Danisco-DuPont for soy tocopherols and Manildra for glucose syrup from wheat), as well as contributions from international companies (Unilever) who were well linked in with the EU allergen labelling exemptions work. Key industry organisation contributors were the: Australian Food and Grocery Council; New Zealand Food and Grocery Council; Ai Group Confectionery Sector; Australian Oilseeds Federation; and Food and Beverage Importers Association.

After many years of work, FSANZ called for submissions on Proposal P1031 – Allergen Labelling Exemptions in August 2015. FSANZ conducted a thorough risk assessment on the proposed changes, and no public health or safety concerns were identified. FSANZ approved the draft variation in March 2016 and the changes were gazetted in May 2016.

The collaborative approach of the Allergen Bureau Exemptions Working Group is a good example of the food industry working together pre-competitively for mutual benefit. The Allergen Bureau wish to thank the members of the Working Group and all industry and stakeholder contributions towards the finalisation of this project

For more allergen labelling exemptions information visit

 The final stages of this Exemptions Working Group were incorporated into the VITAL Phase 2 – Risk Communication (Labelling) Working Group – watch out for the VITAL® Best Practice Labelling Guide for Australia and New Zealand which will be released through the Allergen Bureau soon.