Plain English Allergen Labelling is now fully in force across Australia and New Zealand. The transition period ended 25 February 2024, and the two-year stock-in-trade period for old-format product ended in late February 2026. There is no grace period left.

If you print ingredient labels on a scale or labeller in a deli, butchery, seafood counter or bakery, this affects the words on those labels and how they are formatted.

This article covers what PEAL actually requires, how the rules apply differently to food packed on your own premises, what non-compliance now risks, and how Ezi Scale and Ezi Labeller handle the formatting through EM Cloud™.

What is Plain English Allergen Labelling?

PEAL is the set of allergen labelling rules introduced by FSANZ Proposal P1044, approved in December 2020 and gazetted into the Australia New Zealand Food Standards Code on 25 February 2021. It changed how allergens must be named and formatted on food labels.

Three requirements matter most:

• Specific required names. Allergens must be declared using a prescribed plain-English name. Tree nuts and molluscs must be named individually — “almond”, “cashew”, “walnut”, not just “nuts”. Generalised allergen declarations are not permitted.
• Bold formatting. Required names must be printed in a bold font that provides a distinct contrast with any other text, in a size of type not less than the size of the other text.
• A summary statement. A separate statement must commence with the word “Contains”, list the required name of each declarable allergen, and contain no other words. It must sit in the same field of view as, and directly next to, the statement of ingredients.

That last requirement catches people out. “Contains milk, wheat” is compliant. “Contains milk and wheat. May contain traces of nuts.” is not, because the summary statement must contain nothing else.

What a compliant label looks like

The same product, labelled the old way and the PEAL way:

Illustrative example only. Note what changed: “mixed nuts” becomes the individual nuts; the allergen hidden inside “natural flavours” is declared; “sodium metabisulphite” carries its required name “sulphites”; every required name is bold; and a “Contains” statement sits directly beneath.

Does PEAL apply to deli and butcher scale labels?

This is where a lot of published guidance gets it wrong in one direction or the other, so it is worth being precise.

Under Standard 1.2.1 of the Code, food made and packaged on the premises from which it is sold — along with food packaged in the presence of the purchaser, and food in assisted-service display cabinets — is exempt from carrying a full label. Unpackaged food does not require a label either.

But the exemption is from the label, not from the allergen declaration. The Code still requires that mandatory declarations for this food be displayed in connection with the food, or provided to the purchaser on request, using the required allergen names. You cannot simply not say.

Two further points that catch multi-site operators. The exemption is premises-specific: product packed at a central kitchen, production room or another store and transported to the selling store is not “made and packaged on the premises from which it is sold”, and needs a fully compliant label. And imported deli lines re-portioned in store must not lose their allergen information in the re-labelling — the Department of Agriculture, Fisheries and Forestry has been actively enforcing PEAL on imported food since issuing Imported Food Notice 10-25 in October 2025.

What happens if labels are wrong?

Undeclared allergens are the leading cause of food recalls in Australia, and the numbers went the wrong way last year. FSANZ coordinated 92 food recalls in 2025, above the ten-year average of 87. Undeclared allergens accounted for 38% of them — 35 recalls. The most common allergens involved were milk, wheat or gluten, and tree nuts.

The root causes are the uncomfortable part for anyone printing labels in store. Across 2021–2025, FSANZ recorded 197 undeclared-allergen recalls, with packaging errors, label errors and cross-contamination leading the list. These are not exotic failures. They are a wrong template, an out-of-date ingredient record, or the right label on the wrong product.

Enforcement sits with state and territory food regulators and local councils under state Food Acts. Penalties are substantial — under the NSW Food Act 2003, for example, failing to comply with a Code requirement carries up to 500 penalty units for an individual and 2,500 for a corporation. Beyond the fine, a recall costs you stock, staff time and customer trust.

How Ezi Scale and Ezi Labeller handle PEAL formatting

If you run an Ezi Scale or Ezi Labeller from GaP Solutions, the formatting side of PEAL is handled in software rather than by whoever is building the label.

Once the ingredient list for a product is captured in EM Cloud™, the system applies the required format automatically:

• Declarable allergens are identified within the ingredient list and set in bold
• The “Contains” summary statement is generated and placed adjacent to the ingredient statement
• The required plain-English name is used rather than the technical ingredient name
• The same product record drives every connected scale, so a correction made once applies everywhere

That last point is the one worth dwelling on for multi-store operators. Given that label errors are among the leading causes of allergen recalls, the risk is rarely that a business does not know the rule. It is that the ingredient data is maintained in more than one place, and the versions drift apart.

Ezi Scale and Ezi Labeller are compatible with a number of other back-office systems, so this does not require replacing everything else you run. Support is available by phone and email during business hours, with online help videos available at any time.

One caveat worth stating plainly: software formats what you give it. The accuracy of the underlying ingredient and allergen data for each product remains the business’s responsibility, and it is worth auditing that data rather than assuming it is right.

Sources

• FSANZ — Allergen labelling for food businesses
• FSANZ — Proposal P1044 Plain English Allergen Labelling
• FSANZ — 2025 food recall statistics released (13 May 2026)
• FSANZ — Australian food recall statistics
• Food Standards Code — Standard 1.2.3 Information requirements: warning statements, advisory statements and declarations
• Food Standards Code — Schedule 9 Mandatory advisory statements and declarations
• DAFF — Imported Food Notice 10-25: mandatory allergen labelling requirements
• Allergen Bureau — PEAL stock-in-trade period now concluded (February 2026)
• New Zealand MPI — A guide to allergen labelling