PEAL Allergen Labelling: The Rules Changed and the Transition Is Over

The Plain English Allergen Labelling (PEAL) standard came into force on 25 February 2024, with a two-year stock-in-trade transition period. That transition ended on 25 February 2026. As of now, all food products on shelves in New Zealand must comply with the new allergen labelling requirements. There is no further grace period.

What Changed

PEAL made three significant changes to allergen labelling in New Zealand:

1. The Allergen List Expanded from 10 to 21

The previous standard required declaration of 10 allergen groups. PEAL expanded this to 21 specific allergens. This isn’t just a longer list. It requires more specific identification.

For example, under the old rules you could declare “tree nuts.” Under PEAL, you must specify which tree nut: almonds, cashews, hazelnuts, macadamias, pecans, pistachios, or walnuts, each declared individually.

Similarly, wheat must be declared separately from other gluten-containing cereals (barley, oats, rye).

2. Specific Naming Required

Allergens must be declared using their common names as specified in the standard. You can’t use technical or scientific names that consumers might not recognise.

Key examples:

• Cashews, not “tree nuts” or “Anacardium occidentale”
• Wheat, declared separately from “gluten”
• Cow’s milk, not just “milk” (to distinguish from other animal milks)
• Crustacea must specify the type (prawns, crab, lobster, etc.)

3. Declaration Method

Allergens must be declared in two ways on the label:

1. In bold (or otherwise emphasised) within the ingredients list wherever an allergen or allergen-derived ingredient appears
2. In a separate “Contains” statement immediately after the ingredients list, listing all allergens present in the product

Both are required. Having one without the other does not comply.

Who This Applies To

PEAL applies to all packaged food products sold in New Zealand, whether manufactured domestically or imported. This includes:

• Pre-packaged food sold in retail stores
• Food sold online
• Imported food products

Exemptions

Cafés, restaurants, and takeaway businesses are exempt from PEAL labelling requirements on food prepared and sold on-site. However, they are not exempt from allergen management obligations under their Food Control Plan. Food service businesses must still:

• Be able to identify allergens in their menu items
• Provide allergen information to customers on request
• Display allergen information (e.g., “Ask staff about allergens” signage)

If a café or restaurant also sells packaged products (e.g., bottled sauces, packaged baked goods for retail), those packaged products must comply with PEAL.

The Full List of 21 PEAL Allergens

1. Cow’s milk
2. Eggs
3. Fish
4. Crustacea (specify type)
5. Molluscs (specify type)
6. Wheat
7. Barley
8. Oats
9. Rye
10. Almonds
11. Cashews
12. Hazelnuts
13. Macadamias
14. Pecans
15. Pistachios
16. Walnuts
17. Peanuts
18. Sesame seeds
19. Soybeans
20. Lupin
21. Sulphites (at 10mg/kg or more)

What You Need to Do Now

The transition is over. If your labels don’t comply:

1. Audit your labels. Check every packaged product you sell. Does the ingredients list bold all allergens? Is there a separate “Contains” statement?

2. Check the specificity. Are you declaring allergens at the correct level of detail? “Tree nuts” is no longer sufficient. You need to name the specific nut.

3. Review your supplier information. If you use pre-made ingredients, confirm with your suppliers what allergens are present and how they should be declared.

4. Update non-compliant labels immediately. Any product on shelves after 25 February 2026 with old-format labels is non-compliant. This applies to existing stock. The transition period covered stock-in-trade, and that’s now expired.

5. If you’re a food service business, make sure your staff can identify allergens in every menu item and that you have a system for communicating allergen information to customers.

Allergen labelling errors are among the most serious food safety issues. Incorrect or missing allergen declarations can trigger recalls, enforcement action, and, most importantly, put consumers at genuine risk. If an allergen incident occurs, make sure you record it as a corrective action. Get this right.