Since February 2024, all packaged food in NZ and Australia must declare allergens in Plain English Allergen Labelling (PEAL) format. This guide shows you what to look for, where to find it, and how to read 'contains' vs 'may contain' without standing in the supermarket aisle for 20 minutes.
The first month after my kid's nut allergy diagnosis, I spent more time in the Countdown North Shore packaged-snack aisle than I did at home. Every box turned around. Every label squinted at. Every ingredient list parsed for the word "may contain" because I had read three different articles online about whether "may contain" was a real warning or a legal hedge.
Then in February 2024, Plain English Allergen Labelling (PEAL) became mandatory across NZ and Australia. The whole game changed. Allergens now have to appear in a specific, standardised place on the label, in plain English, in bold, and the differences between "contains" and "may contain" are now defined by regulation rather than each company's lawyer. If you have an allergy in the family, learning the PEAL format cuts your label-reading time from 5 minutes to 30 seconds.
This is the version of that knowledge I wish someone had handed me on day one of the diagnosis.
What PEAL Is and Why It Matters
Plain English Allergen Labelling (PEAL) is a 2021 amendment to the joint Food Standards Australia New Zealand (FSANZ) Standard 1.2.3, which became mandatory for all packaged food sold in NZ from 25 February 2024. There was a three-year transition during which manufacturers could choose either old-style or PEAL — that transition is now over.
The headline changes PEAL brings:
1. Declared allergens must use the standardised plain-English name — not a technical synonym.
2. The declaration must appear in a Summary Statement directly under the ingredient list, on the same panel, in bold type.
3. "Contains" is regulated — it means the food intentionally contains the allergen as an ingredient.
4. "May contain" or "may be present" statements are *voluntary* but follow industry best-practice guidance — they mean a real (though usually small) cross-contamination risk.
5. Some allergens were renamed for clarity — "soya bean" everywhere instead of "soya" sometimes and "soybean" elsewhere.
The practical effect: the same 14 declared allergens, in the same format, in the same place, in the same words, on every NZ packaged food product. The 5-minute label scan becomes a 30-second one.
The Allergens That Must Be Declared
PEAL requires mandatory declaration of these specific allergens when present:
| Allergen group | Plain English label term |
|---|---|
| Peanut | "peanut" |
| Tree nuts | each named individually: "almond", "cashew", "hazelnut", "pecan", "pistachio", "macadamia", "walnut", "Brazil nut", "pine nut" |
| Milk | "milk" |
| Egg | "egg" |
| Fish | "fish" |
| Crustacean | "crustacean" with the specific type (e.g., prawn, crab) |
| Mollusc | "mollusc" with the specific type (e.g., oyster, mussel) |
| Wheat | "wheat" |
| Gluten-containing cereals | "wheat", "rye", "barley", "oats", or "spelt" — named separately |
| Soybean | "soybean" |
| Sesame | "sesame" |
| Lupin | "lupin" |
| Sulphites | "sulphites" when 10 mg/kg or more |
A key change from pre-PEAL: tree nuts are now individually named. "Tree nut" on its own is not allowed. If a product contains almond, the label must say "almond". This matters because tree-nut allergies are often allergen-specific — a child allergic to cashew may safely tolerate almond.
Where to Look on the Label
PEAL specifies that allergens must appear in two places on the packaging:
1. In the ingredient list itself
Each allergen, when present as an ingredient, must be in bold text within the ingredient list. So:
> Ingredients: wheat flour, sugar, sunflower oil, milk solids, salt, raising agents...
The bold immediately catches the eye. You no longer need to read every word — you scan for bold.
2. In the Summary Statement directly below the ingredient list
A new mandatory line starting with "Contains:" (or in some products, also "Allergen Information:") followed by the consolidated list:
> Ingredients: wheat flour, sugar, sunflower oil, milk solids, salt, raising agents, may contain traces of peanut and tree nuts.
>
> Contains: wheat, milk.
The Summary Statement is the 30-second read. If your child is allergic to milk, you scan the "Contains:" line — if "milk" appears, the product is out. If not, you check the "may contain" statement for cross-contamination risk and make a judgement based on your child's reaction severity.
"Contains" vs "May Contain": The Critical Distinction
This is the single most important thing to understand about NZ food labels.
"Contains [allergen]" — regulated, intentional
The allergen is deliberately in the product. It is an ingredient. If your child is allergic to that allergen, the product is unsafe. No exceptions, no risk assessment, no "small amount" tolerance.
"May contain [allergen]" — voluntary, cross-contamination risk
The allergen is not an ingredient, but the product is made in a facility (or on equipment) where that allergen is also handled. Cross-contamination through shared lines, shared utensils, or airborne particles is possible.
The "may contain" statement is voluntary under NZ/Australian law — there is no regulation forcing manufacturers to disclose cross-contamination risk. Most reputable manufacturers do, following the VITAL (Voluntary Incidental Trace Allergen Labelling) programme guidance, which uses risk-based thresholds to decide when a "may contain" warning is appropriate.
For mild allergies and intolerances: "may contain" is usually a manageable risk. The actual exposure level, if any, is typically far below intentional ingredient levels.
For anaphylactic allergies: "may contain" should be treated as contains. The risk of a severe reaction from trace exposure is real, and most NZ allergy specialists (including those at Starship Children's Health and Allergy New Zealand) recommend that anaphylactic patients avoid "may contain" products entirely.
This split decision — manageable risk for mild allergies, full avoidance for anaphylaxis — is the most important judgement an allergy parent makes. It should be made *with your child's allergist*, not from an internet article, but the framework above is the one NZ allergy clinicians actually use.
The 30-Second Scan Routine
In the supermarket, with three more things on the shopping list, this is the routine I now use for every packaged food I have not bought before:
Step 1: Find the Summary Statement (3 seconds)
Directly below the ingredient list. Look for the bold "Contains:" line.
Step 2: Scan for your child's allergens (5 seconds)
If any are listed in the "Contains:" line — the product is out. Put it back.
Step 3: Check the "may contain" line (5 seconds)
If a "may contain" line follows, scan for your child's allergens. Apply your child's risk tolerance (mild = often fine, anaphylactic = avoid).
Step 4: Sanity-check the ingredient list (10 seconds)
Skim for bold ingredients you might not have expected. PEAL bold-formatting catches things you would have missed in a fast scan.
Step 5: Decision (7 seconds)
In the trolley, or back on the shelf. Move on.
That is 30 seconds of label reading per new product. Compared to the 5-minute pre-PEAL squinting session, the time savings compound across a weekly shop with multiple new products.
Common Hidden Allergens to Watch
Even with PEAL bold-formatting, a few ingredient names can catch parents off-guard. These are the ones most commonly missed in NZ products:
Wheat hidden as
PEAL requires all of these to be in bold and declared in "Contains: wheat".
Milk hidden as
All trigger a "Contains: milk" declaration under PEAL.
Egg hidden as
All trigger "Contains: egg".
Soybean hidden as
The key change from pre-PEAL: even soy lecithin must trigger "Contains: soybean" if it derives from soy — there is no longer a "highly refined" exemption for labelling purposes in NZ.
What PEAL Did Not Change
A few things that allergy parents sometimes assume PEAL handles but does not:
1. Restaurants and unpackaged food
PEAL only applies to packaged food at retail. Restaurants, school canteens, bakeries selling unwrapped items, and food markets are not subject to PEAL labelling. NZ Food Safety has separate guidance for restaurants but the bold-Summary-Statement format does not apply.
2. Imported products
Imported packaged food sold at NZ retail must comply with PEAL. But specialty imports (small ethnic grocers, online imports for personal use) sometimes slip through. Be more cautious with these.
3. Allergen-free certification
"Contains no peanut" or "Made in a nut-free facility" claims on the front of the pack are not regulated by PEAL. They follow separate fair-trading rules. Some are accurate; some are marketing. Cross-check with the back-of-pack ingredient list and Summary Statement.
How to Build a NZ Lunchbox Around PEAL
Once you know the format, lunchbox shopping becomes routine:
For nut-free schools (most NZ schools)
For dairy-free children
For gluten-free children (coeliac)
For more detail on building school-safe lunchboxes around specific allergens, see:
References
This article is informational and based on the public PEAL and FSANZ Standard 1.2.3 framework. It is not personalised medical or allergy advice. For diagnosed allergies and anaphylaxis management, always work with your child's allergist or paediatrician.
Plan Allergy-Safe Lunches
The Kiwi Lunchbox Planner lets you tick the allergens to avoid (nut, dairy, egg, gluten, plus vegetarian/vegan options) and filters the entire menu library to only suggest meals that are safe for your child. Cross-contamination tags are flagged where relevant.
