Plain English Allergen Labeling for Cafe Packaging Is Now the Standard and Cafes Must Provide Allergen Info on Request

Cafe packaging supplies must now comply with tougher allergen disclosure regulations throughout Australia due to a significant modification to food labelling laws. The mandatory national standard for plain English allergen labeling, which was previously simply a transition phase, must be complied with by all food companies by February 25, 2026.

For café operators, the change affects more than just packaged goods. In compliance with Standard 1.2.3 and Schedule 9 of the Food Standards Code, businesses must ensure that allergy information is prominently displayed on labels and available to customers upon request. Compliance is the responsibility of Food Standards Australia New Zealand.

Recognising the Regulatory Schedule

In February 2021, PEAL was signed into law with a three-year transition phase. The changeover concluded on February 25, 2024. After this date, all food manufactured and packaged for sale must include allergen declarations in the necessary format.

A stock-in-trade provision covers products labelled correctly under the previous system before February 2024. These products may remain on shelves until 25 February 2026. After that deadline, every food item available for sale must meet PEAL requirements. Products with old-format allergen declarations must be removed from circulation.

Cafe operators ordering cafe packaging supplies today must ensure materials already comply with current standards. The stock-in-trade exemption does not protect newly purchased packaging materials. Continuing to source non-compliant materials after the February 2024 production cutoff violates the regulation.

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What the Law Requires on Packaged Food

For allergy declarations, the PEAL framework prescribes the format and content. Allergen information must be included in the ingredient statement in strong font according to the Food Standards Code. Compared to other substances specified, the font size cannot be smaller.

The term “contains” must start a separate allergen summary statement, which must likewise be bolded and placed in the same field of view as the ingredient list.

Key Changes Include:

• Almonds, cashews, hazelnuts, walnuts, pecans, pistachios, macadamias, Brazil nuts, and pine nuts are among the tree nuts that must be identified by name.
• Instead of grouped categories, distinct declarations are needed for fish, crustacea, and mollusks. 
• Wheat and gluten must each be named individually
• Sulphites must be declared when present at 10 milligrams per kilogram or greater

Certain substances carry conditional exemptions. These include highly refined soybean oil and glucose syrups derived from wheat starch. These exemptions are not automatic. Each product must be verified against Schedule 9 of the Food Standards Code.

The “On Request” Requirement for Unpackaged Foods

Display cabinet items and freshly assembled products do not always require printed labels. They are subject to clear allergen disclosure obligations under the Food Standards Code.

For food not required to bear a label, allergen declarations must be displayed in connection with the product or provided upon request. This requirement applies regardless of business size or preparation volume. Cafe businesses have three practical options:

1. Display allergen information directly beside each food item through printed cards
2. Maintain a written allergen register that staff can access during service
3. Use a digital allergen chart on a menu board or tablet system

The method of disclosure remains at the operator’s discretion. The obligation to disclose is mandatory. Staff must know allergen content across all menu items to ensure compliance.

For businesses managing both packaged and unpackaged food categories, Complete Wholesale Suppliers provides operational guidance for aligning packaging and display systems with regulatory requirements. Their takeaway packaging compliance guide offers practical resources for Australian hospitality operators.

The Public Health Context Behind the Legislation

The PEAL framework reflects a documented public health concern across Australia. Between 1997 and 2013, Australia recorded 22 food-related anaphylaxis deaths. Fifteen occurred while individuals were eating outside the home. This places food service environments directly within the risk profile that PEAL addresses.

Australia records one of the highest rates of food allergy in the developed world. More than 10% of infants are affected by challenge-confirmed food allergies. Hospital admissions for food anaphylaxis rose nine-fold between 1998 and 2019. The rate increased from 2.0 per 100,000 population to 18.2 per 100,000 population during that period.

These figures explain why the government moved from advisory guidance to legislated requirements with hard enforcement deadlines. The extension of PEAL obligations to unpackaged and display foods reflects this evidence base. Allergen mislabelling in food service settings contributes to severe and sometimes fatal health outcomes.

Procurement Decisions and Cafe Packaging Supplies

Compliance with PEAL has direct implications for how cafe operators assess and procure packaging materials. Packaging acceptable under the pre-2024 regime may not satisfy current standards. Materials must include correct bold-text formatting and the required allergen naming conventions. The mandatory “contains” summary statement must appear in the prescribed location.

Operators sourcing takeaway containers, deli labels, sticker rolls, or paper bags should confirm with suppliers that materials support PEAL-compliant label application. Custom-printed packaging designs must accommodate bold allergen text at the minimum required font size. The summary statement must be positioned adjacent to the ingredient list.

Procurement decisions now carry compliance implications beyond design preferences or unit cost. The suitability of cafe packaging supplies must be assessed against regulatory requirements as standard purchasing practice. Complete Wholesale Suppliers operates among hospitality packaging suppliers in Australia with resources for businesses reviewing materials against PEAL requirements.

Core Compliance Obligations for Cafe OperatorsEssential Requirements:

• All food packaged after 25 February 2024 must carry PEAL-compliant allergen declarations using bold, plain English and a separate “Contains” summary
• Pre-2024 stock with old-format labels must be sold or removed by 25 February 2026
• Unpackaged and display foods must have allergen information available beside the product or on request
• Individual tree nuts, fish, crustacea, and molluscs require specific name declarations
• Staff must be trained to answer allergen queries accurately for all menu items
• New cafe packaging supplies must support PEAL formatting before operational use

Available Resources and Tools

The FSANZ website provides a free allergen declaration generator tool. Food businesses can produce correctly formatted declarations for specific products. The Allergen Bureau’s Food Industry Guide to Allergen Management and Labelling was updated in December 2024. It offers detailed guidance for both packaged and unpackaged food contexts.

State food authorities publish jurisdiction-specific compliance resources. The NSW Food Authority and Safe Food Queensland make these materials freely accessible to food businesses.

The Path Forward

The 25 February 2026 deadline represents a firm regulatory endpoint. No further stock-in-trade provisions will be available after that date. Full compliance across the market becomes the expected standard.

For cafe operators, meeting this standard requires attention to multiple operational areas. Staff training forms the foundation of compliance. Allergen management systems must be implemented and maintained. Display practices need regular review and updating.

The cafe packaging supplies procured and applied in daily food service play a crucial role. Every label, sticker, wrapper, and display card must meet current requirements. This is not simply an administrative adjustment. It is a public health imperative supported by evidence of real harm in Australian communities.

Cafe owners who take immediate action to comply with PEAL regulations safeguard both their clients and their companies. There is less time to prepare as the deadline draws near. Individuals who have not yet examined their packaging materials and allergen disclosure procedures ought to give this task top priority right away.

The regulatory structure is unambiguous. The timetable is set. Every food firm that serves Australian customers is accountable.