The hold shows up on the label. A scientific name, a group word such as tree nuts, or no separate Contains line is enough to stop a listing, and enough for the warehouse to hold the pallet.
Written for supermarket category managers, private-label and controlled-brand managers, and QSR or foodservice buyers. Shiiv Imports Pty Ltd trades as Shiiv Imports. We are a sourcing agent, importer and private-label builder, not a manufacturer. The partner plant owns the formulation. We check the declaration against the specification and your brief, beside the spec pack and the lead time from sample to first purchase order. Public email sales@shiv-impex.com. The desks are in Sydney, Auckland, Singapore and Ahmedabad.
What the Code now requires
Plain English Allergen Labelling sits in Standard 1.2.3 and Schedule 9 of the Australia New Zealand Food Standards Code. FSANZ sets out the format for businesses.
Allergens are declared in the statement of ingredients using the required names, in bold, in a type size no smaller than the other ingredients. A separate summary statement begins with the word Contains, in bold, in the same field of view and directly next to the statement of ingredients.
The required names include, among others, wheat, fish, crustacean, mollusc, egg, milk, lupin, peanut, soy, soya or soybean, and sesame. Tree nuts are named one by one: almond, Brazil nut, cashew, hazelnut, macadamia, pecan, pistachio, pine nut and walnut. Barley, oats and rye are named when they contain gluten. Sulphites are declared when added at 10 mg/kg or more. Individual tree nuts, individual cereals containing gluten, and molluscs are declared separately.
In the Contains summary, gluten is listed with wheat if gluten is present. For barley, rye, oats, or a hybrid containing gluten, the summary lists gluten, not the cereal name, in the pattern in FSANZ guidance. The ingredient statement still uses the required name for that cereal.
Why 25 February 2026 matters for shippers already on the water
The new mandatory requirements came into force on 25 February 2024 for food manufactured or produced after that date. Older compliant packs could remain on sale through a stock-in-trade period. That period ended on 25 February 2026. From that date, all food available for sale in Australia must meet the new rules.
A booking made before the cut-off does not keep the old format available for sale. Imported food sold in its intended packaging and label must meet the labelling standards in the Code. The Department of Agriculture, Fisheries and Forestry set that out for importers in Imported Food Notice 10-25, under the Imported Food Control Act. If a vessel is already at sea on the previous format, agree whether those packs can still be sold, or whether they need a corrected label before ranging. Judge compliance on the date the food is available for sale. A Contains line that meets the Code does not repair a date mark that misses the receipt rule. See the note on remaining shelf life for that mark.
Where allergens hide on an import file
Allergens can be present as ingredients, inside compound ingredients, as additives, or as processing aids. When they are in scope, they must be declared. A spice blend written as one line can hide wheat flour or sesame. A processing aid can leave egg, milk or soy in the food that ships. Sulphites added at 10 mg/kg or more belong on the declaration even when the plant records them as a preservative.
The Certificate of Analysis and the spec pack have to use the same required names as the pack. Country of origin labelling does not stand in for the allergen line. The checks before you range should put the declaration on the same file as identity, lot and shelf life. A document that still says tree nuts, or cereals, as a class is not ready for artwork.
What to lock in the brief before artwork
Lock the required-name list and the Contains line before anyone draws the pack. On a private-label program the recipe, the specification and the label are signed together. A retail jar and a foodservice pack can share a recipe and still need their own declarations if the ingredient list, the added sulphites, or a compound ingredient differs.
Write the summary as it will be printed: Contains in bold, in the same field of view, directly next to the statement of ingredients, using the gluten pattern above. An export label written for another market is an Australian label only when the required names, the bold type and that summary are in place. Put the check in the lead time from sample to first purchase order.
Who owns the declaration
The factory owns the formulation facts, including allergens that entered as an ingredient, a compound ingredient, an additive or a processing aid. Shiiv Imports Pty Ltd, trading as Shiiv Imports, checks the proposed label against that specification and the buyer's brief. We do not complete a declaration the plant has not documented.
Plant certificates belong to the factory and to the scope on the certificate. Shiiv Imports holds ISO 9001 for sourcing, supplier selection and the file. ISO 9001 is not a plant food-safety certificate. We work with factories that hold GFSI-benchmarked certifications where the program requires it. Where a partner factory holds HACCP, or a GFSI-benchmarked scheme, the certificate belongs to that site and scope. A named scheme is confirmed on the factory certificate, not on our ISO 9001. The quality page sets out how the file is held. We do not name major-chain private-label clients.
Before you range
Check the pack against the file before the purchase order.
- Required names in the ingredient statement, in bold, no smaller than the other ingredients.
- A Contains summary in bold, in the same field of view, directly next to that statement.
- Tree nuts, cereals containing gluten, and molluscs named individually.
- Gluten listed with wheat in the summary when gluten is present. For barley, rye, oats or hybrids, the summary lists gluten.
- Sulphites declared when added at 10 mg/kg or more.
- Compound ingredients, additives and processing aids mapped, with the spec pack matching the label.
- Goods on the water checked against 25 February 2026, so every pack available for sale complies.
- Retail and foodservice packs checked separately where the ingredient list can differ.
Send the product, the pack, the channel and the draft ingredient list with a sourcing brief, or a private-label brief when the artwork is yours. We reply the same business day on how the file is shared under NDA.
Questions buyers ask
When did the new allergen labelling rules apply to every food on sale in Australia?
The new mandatory allergen labelling requirements came into force on 25 February 2024 for food manufactured or produced after that date. The stock-in-trade period for older compliant packs ended on 25 February 2026. From that date, all food available for sale in Australia must meet the new rules.
What format does Standard 1.2.3 require on a labelled pack?
Allergens are declared in the statement of ingredients using the required names in bold, in a type size no smaller than the other ingredients. A separate summary statement begins with the word Contains in bold, placed in the same field of view and directly next to the statement of ingredients.
Must imported food meet the same allergen labelling rules?
Yes. Imported food sold in its intended packaging and label must meet the labelling standards in the Australia New Zealand Food Standards Code. The Department of Agriculture, Fisheries and Forestry set that out for importers in Imported Food Notice 10-25, under the Imported Food Control Act.
Who owns the allergen declaration on an imported own-brand pack?
The factory that makes the food owns the formulation facts, including allergens present as ingredients, compound ingredients, additives or processing aids. Shiiv Imports Pty Ltd, trading as Shiiv Imports, is a sourcing agent and importer, not the manufacturer. We check the label against the specification and the buyer's brief. Shiiv holds ISO 9001 for sourcing and the file. That is not a plant food-safety certificate.
Shiiv Imports Insights. Shiiv Imports Pty Ltd (ABN 15 158 243 442 / ACN 158 243 442). Trading name Shiiv Imports. Public email sales@shiv-impex.com. Cities: Sydney, Auckland, Singapore, Ahmedabad. Allergen labelling: FSANZ, DAFF Imported Food Notice 10-25, and Standard 1.2.3.