Do retail trade businesses need to comply with Plain English Allergen Labelling (PEAL)?
A computed answer from the Rules Mate applicability engine, with the exact condition, the outcome for every structure and size, and the primary source.
Short answer: Only if
Only if you supply packaged, labelled food. Being in this industry makes the obligation worth checking (Industry: Retail trade), but the trigger is a fact the industry alone does not settle.
The obligation in brief
Comply with Plain English Allergen Labelling (PEAL). 3 of the Food Standards Code (amended February 2024 with a 3-year transition) requires allergens to be declared on packaged food in a standardised plain-English format including a 'Contains' statement, bolding requirements, and specific terminology. Applies to packaged foods sold in Australia and New Zealand.
Trigger: Manufacturing or supplying packaged food.
Why retail trade get a different answer
Rules Mate runs its applicability engine across 9 business structures and 6 size bands for each of the 35 industries it maps. For 32 of those industries the answer for "Comply with Plain English Allergen Labelling (PEAL)" is no. Retail trade is one of the 3 where the answer is different: only if.
The deciding fact for retail trade businesses: Industry: Retail trade; applies only if you supply packaged, labelled food.
About the industry: Retailers covered by the General Retail Industry Award and ACL product safety.
Compare a professional services (general) business with 6–19 employees structured as a Pty Ltd company: the obligation does not apply (Requires a trigger outside this questionnaire).
Answer by business structure and size
Each cell is the engine's outcome for a business in retail trade with that structure and size, assuming it sells to consumers and small businesses and holds customer contact details. "Check" means the obligation turns on a fact the industry does not settle.
| Structure | No employees | 1–5 employees | 6–19 employees | 20–99 employees | 100–499 employees | 500+ employees |
|---|---|---|---|---|---|---|
| Sole trader | Check | Check | Check | Check | Check | Check |
| Partnership | Check | Check | Check | Check | Check | Check |
| Trust | Check | Check | Check | Check | Check | Check |
| Pty Ltd company | Check | Check | Check | Check | Check | Check |
| Public company | Check | Check | Check | Check | Check | Check |
| Not-for-profit (unregistered) | Check | Check | Check | Check | Check | Check |
| Registered charity | Check | Check | Check | Check | Check | Check |
| Super fund | Check | Check | Check | Check | Check | Check |
| Foreign company | Check | Check | Check | Check | Check | Check |
What the obligation requires
- When due
- From 25 February 2026 — full compliance after 3-year transition.
- Evidence to keep
- Updated labels, allergen risk assessments, supplier specifications.
- Maximum penalty
- State-based fines + product recall obligations
- Regulator
- FSANZ and ACCC
- Jurisdiction
- Commonwealth (national)
Other obligations where retail trade differ from the norm
- Food Act state licensing + food safety supervisor: Only if
- Implement Food Safety Management Tool (Standard 3.2.2A): Only if
- Button + coin battery safety standard (mandatory): Only if
- Comply with Heavy Vehicle Chain of Responsibility (CoR): Only if
- Comply with mandatory product safety standards + bans (ACL): Yes
- Food and Grocery Code of Conduct (now mandatory): Only if
- All 16 answers for retail trade
Other industries with a non-default answer
Questions
- Do retail trade businesses need to comply with Plain English Allergen Labelling (PEAL)?
- Only if you supply packaged, labelled food. Being in this industry makes the obligation worth checking (Industry: Retail trade), but the trigger is a fact the industry alone does not settle.
- Is the answer the same for every industry?
- No. For 32 of the 35 industries Rules Mate maps, the answer is no. Retail trade is one of 3 industries with a different answer.
Related
Sources
Computed by the Rules Mate applicability engine from the published obligation corpus; facts last checked 3 October 2026. Rules Mate is not a law firm and this is general information, not legal advice. Confirm your position with the regulator source or a qualified adviser before acting.