Australia and New Zealand Food Label Allergens: 3 Practical Boundaries — Bold Declarations, Individual Tree Nuts, and the Sulphite Threshold: The 3 Data Sets Printers Should Request First for ANZ Orders

In August 2026, a client selling roasted nuts sent us a new retail box design marked for use in English. The allergen declaration read: “Contains: Almonds, Milk, Soy” — three terms joined by commas, set in regular type, and placed at the end of the ingredients list.

We forwarded the design to the client's Australia and New Zealand agent. The agent replied the same day:

“This will not clear customs. You need each tree nut separately, in bold, inside the ingredients list, and milk has to be called milk, not milk solids if that's what the ingredient is. Please also check your sulphite level — over 10 mg/kg it has to be declared and it's not optional.”

The client replied: “We printed our previous batch the same way, and it cleared customs.”

Under this regulatory system, the fact that a previous batch cleared customs is not a defence, because the rules have changed. When the new mandatory allergen declaration requirements took effect on 25 February 2024, a transitional period was provided: products manufactured and labelled before that date in accordance with the former requirements could continue to be sold until 25 February 2026. The new packaging therefore arrived precisely as that transitional period was ending.

This article addresses three points: how the Australia and New Zealand system differs from those of China and the EU, what bold declarations and individual listing requirements mean for the artwork, and who is responsible for applying the 10 mg/kg sulphite threshold.

The First Boundary: Australia and New Zealand Operate an Independent System

Australia and New Zealand share the Australia New Zealand Food Standards Code. Its core labelling standards are Standard 1.2.3, covering information requirements, warnings, advisory statements and declarations, and Standard 1.2.1, covering general labelling requirements. The system follows neither China's GB 7718 nor the EU's Regulation (EU) No 1169/2011.

That means three assumptions made by printers must be avoided:

There is also an important timing difference. The new allergen rules in Australia and New Zealand took effect in February 2024, more than a decade after the EU's mandatory allergen-labelling requirements under Regulation 1169/2011. A client selling into both the EU and Australia or New Zealand cannot simply translate an EU label design and send it for ANZ use, because the allergen sections of the two labels have different structures.

Our approach is to produce separate artwork files for the allergen section whenever the same product is packaged for two language versions. Although this adds a step, it prevents the need to return an entire production batch.

The Second Boundary: Bold Is an Inspectable Requirement, Not a Design Preference

Under the Australia and New Zealand allergen declaration rules, bold text is mandatory rather than a visual recommendation. There are three core requirements:

• Placement: The allergen declaration must appear within the statement of ingredients. It cannot appear separately on the back of the pack with wording such as “See ingredients for details.”
• Form: Use the common name in plain English, set it in bold, and place it in parentheses after the ingredient. For example: dried whey powder (contains milk), rather than dried whey powder (contains milk solids).
• Granularity: Individual tree nuts, molluscs, and cereals must be listed separately and cannot be combined.

The third requirement is among the most stringent aspects of the Australia and New Zealand system. “Nuts” is unacceptable; the specific nut must be named, such as almond, cashew, or pecan nut. “Tree nuts” is also unacceptable. The same approach applies to cereals: individual cereals must be listed separately rather than collectively described as “cereals.” Molluscs are treated in the same way.

The reason is straightforward. If a consumer is allergic to one type of nut, the word “nuts” gives no indication of whether the product contains that specific allergen. The consumer can only avoid the entire product category. The more specific the declaration, the less burdensome it is for consumers to avoid their allergen.

For printers, the critical production control is font weight. A common technical pitfall is that bold text in a design file does not always appear bold in print. A designer may change Regular to Bold on screen and consider the visual difference satisfactory. During printing, however, several factors can reduce that difference, including differences in paper absorption, ink spread, and gloss changes after film lamination.

Our approach is to produce a separate 1:1 black-and-white proof for the allergen section and use it to assess three points: the bold contrast, whether bold terms remain legible on a solid dark background, and whether the bold treatment remains evident when the text is reduced to the minimum printable size. If the allergen line is printed in white on a dark background, such as dark brown, we additionally request a light-colored block behind the text to preserve contrast. Otherwise, even a heavy bold weight may remain difficult to read.

One requirement is also easily overlooked: compound ingredients such as syrups, concentrates, and flavourings in the ingredients list must be expanded if they contain allergens. A client may believe that a natural flavouring contains no nuts, even though a compound flavouring may contain whey ingredients. This is primarily a formulation issue rather than a printing issue, but it directly determines whether the printed declaration is correct.

The Third Boundary: The 10 mg/kg Sulphite Threshold Is Determined by Formulation, While Printing Merely Executes the Decision

Sulphites are included in the Australia and New Zealand allergen list. The rule is that they must be declared when the added amount is equal to or greater than 10 mg/kg. This concentration is not arbitrary, as levels below it generally do not trigger reactions in sensitive consumers.

The threshold is distinctive because it is the only declaration obligation determined by quantity, whereas other allergens must be declared whenever they are present. For the same product, adding 8 mg/kg does not trigger a declaration, while adding 12 mg/kg does.

This creates a question that a printer is almost unable to answer independently: if the client says a product does not need a sulphite declaration, what evidence should the printer rely on?

Our approach is to return the decision to the formulation stage while requiring supporting evidence. We do this in three ways:

1. Request the supplier's sulphite content specification — not a general statement that the ingredient is free of sulphites, but test data or a specified concentration limit.
2. Request a tested value for the finished product, or accept a theoretical value calculated by weighting the sulphite levels of the ingredients and clearly identifying it as a theoretical value.
3. State the printer's responsibility limits in the quotation — the printer lays out the label according to the data and declarations supplied by the client, while the client remains responsible for allergen determinations and threshold calculations.

One client asked us: “Do printers understand all this? Why do you ask so many questions every time?”

Our response was: “Printing the ingredients list incorrectly is our responsibility, but deciding how much sulphite exceeds the threshold belongs to formulation and testing. What we can guarantee is that we will print the list you provide exactly as supplied. That list must also be supported by evidence, because without it, both of us remain exposed if something goes wrong.”

In addition to these three allergen data sets, printers should clarify two Australia and New Zealand-specific requirements before accepting an order. The first is whether the product contains anything requiring an advisory statement, such as replicated macadamia nuts, caffeinated beverages, or certain insufficiently processed allergens. These are not mandatory allergen-list items but require advisory statements using prescribed wording. The second is label language requirements. If the product is also sold in New Zealand, printers should confirm whether additional local New Zealand requirements must be met.

The 3 Data Sets to Request Before Accepting an ANZ Order

For ANZ orders, we consistently request the following three items. If any one is missing, we return the order to the client for completion:

• First: An allergen list cross-referenced to the ingredient names. The list must use common names in plain English and identify the ingredient after which each allergen should appear. This provides the direct input for the artwork.
• Second: Supporting evidence for the sulphite content. This must be a supplier specification or a finished-product test report, not an assumption that the product “should not contain” sulphites.
• Third: The items requiring advisory statements and the corresponding prescribed wording. Clients may phrase these statements incorrectly, so the required source is the standard text.

Once these three items are available, together with our three checks — a 1:1 black-and-white proof to assess font weight, a light block behind light text on dark backgrounds to preserve contrast, and a line-by-line reconciliation of compound ingredients against the allergen list — the production run is ready for reasonable confidence.

If a client says, “Our previous batch was printed the same way and cleared customs,” our standard response is: “The previous batch cleared customs because the former rules remained available only until 25 February 2026. This batch was manufactured after the new rules took effect, so it must follow the current requirements. If you wish to retain the former artwork, we can prepare a side-by-side comparison and mark the required changes, but the artwork itself must be updated.”

Further Reading

• GB 7718-2025 Food Packaging Allergen Labelling: 4 Practical Pitfalls for Printers — Adjacent-Allergen Principle / 1.8 mm Letter Height / Concentration Thresholds / Ingredient Order — China's threshold logic and placement rules provide a useful reference for understanding the differences in Australia and New Zealand.
• 6 Mandatory Food Packaging Statements — Ingredients / Allergens / Best Before / Nutrition Information / Net Quantity / Origin — Among these six mandatory statements, allergen labelling varies the most between countries.
• Canadian Packaging Label Bilingual Requirements: 3 Practical Boundaries — French Version Length / Accent Characters / Responsibility Allocation — This example of a failure caused by insufficient space reflects the same need for typographic margin that applies to ANZ font-size requirements.
• Exporting Food Packaging to Japan: 3 Hidden Compliance Requirements — Japanese Labels / JAS Organic / Food Sanitation Act — The approach is consistent across third-country markets: identify the applicable regulatory system before developing the artwork.
• 3 Real Categories of Packaging Test Reports — Which One the Client Needs to Avoid Noncompliance — When a client says testing has already been completed, first establish which type of report was produced.