Who must comply with Plain English Allergen Labelling (PEAL)?
The applicability test for Comply with Plain English Allergen Labelling (PEAL) (FSANZ and ACCC), computed across 35 industries, 9 business structures and 6 size bands.
Short answer: Only if
Applies only if you supply packaged, labelled food. Whether it applies turns on a fact that no industry, structure or size settles on its own.
What the obligation is
From 25 February 2026, allergen labelling must use plain English and a standardised format.
Standard 1.2.3 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.
The applicability test
Applies only if you supply packaged, labelled food. Whether it applies turns on a fact that no industry, structure or size settles on its own.
How the regulator frames it: Food manufacturers and suppliers of packaged food in Australia.
What triggers it: Manufacturing or supplying packaged food.
Jurisdiction: Commonwealth law, so the test is the same in every state and territory.
Which industries are in or out
Outcome across the 35 industries Rules Mate maps (3 of 35: only if a further fact applies; 32 of 35: no).
| Industry | Answer |
|---|---|
| Cafés & restaurants | Only if a further fact applies |
| Retail trade | Only if a further fact applies |
| Manufacturing | Only if a further fact applies |
| No | 32 other industries |
Business structure and size
Structure does not change the answer in the 3 industries it can reach: for every structure the answer is "only if a further fact applies".
Size does not change the answer in the 3 industries it can reach: at every size band the answer is "only if a further fact applies".
Worked examples
Each line is one run of the Rules Mate applicability engine for a single business profile, with the reason the engine gives:
- Pty Ltd company in real estate agents with 6–19 employees, turnover $1M–$3M: does not apply. Requires a trigger outside this questionnaire.
- Pty Ltd company in cafés & restaurants with 6–19 employees, turnover $1M–$3M: check whether it applies. applies only if you supply packaged, labelled food.
When you need to check further
The engine shows this obligation as "check whether this applies" when a business has industry: Cafés & restaurants / Retail trade / Manufacturing. It then applies only if you supply packaged, labelled food. That fact is not something Rules Mate can infer from industry, structure or size.
What you must do, and when
- When due
- From 25 February 2026 — full compliance after 3-year transition.
- Frequency
- Ongoing
- Evidence to keep
- Updated labels, allergen risk assessments, supplier specifications.
- In force from
- 25 February 2026
- Status
- Current
- Priority
- High
Penalty for not complying
Maximum penalty: State-based fines + product recall obligations.
Audit or assurance level
Rules Mate has not yet classified the audit or assurance level for this obligation. Any audit, review or certification requirement is set by the regulator source listed below.
Where it sits in the corpus
Rules Mate tracks 5 published obligations tagged "food safety", 0 of them rated critical. For a professional services Pty Ltd company with 6–19 employees operating in every state, 0 of those apply outright. This obligation is rated high priority, and is an ongoing duty.
Regulator, legislation and tools
Regulated by Food Standards Australia New Zealand and Australian Competition and Consumer Commission.
FSANZ: Sets the Australia New Zealand Food Standards Code — labelling, allergen, additive, and food safety standards.
ACCC: Competition and consumer regulator administering the Competition and Consumer Act 2010 and Australian Consumer Law, plus industry codes and infrastructure access regimes.
Free tools that help with this obligation:
Questions
- Who must comply with Plain English Allergen Labelling (PEAL)?
- Applies only if you supply packaged, labelled food. Whether it applies turns on a fact that no industry, structure or size settles on its own.
- Do sole traders need to comply with Plain English Allergen Labelling (PEAL)?
- Only if a further fact applies. Looking in the 3 industries it can reach and every size band, the engine's answer for a sole trader is: only if a further fact applies.
- Do businesses with 1–5 employees need to comply with Plain English Allergen Labelling (PEAL)?
- Only if a further fact applies (1–5 employees, turnover $100K–$1M).
- When is "Comply with Plain English Allergen Labelling (PEAL)" due?
- From 25 February 2026 — full compliance after 3-year transition.
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.