PEAL Compliance Is No Longer Optional: What Food Manufacturers Need to Know

The deadline has passed. As of 25 February 2026, the stock-in-trade grace period for Plain English Allergen Labelling — known as PEAL — officially closed. Every packaged food product currently on shelves in Australia and New Zealand must now fully comply with the new requirements. No exceptions.

If you're a food manufacturer and you haven't fully audited your labels yet, the time to act is right now.

What Changed — and Why It Matters

FSANZ introduced PEAL requirements under Proposal P1044, which came into force on 25 February 2024 after a three-year transition period. The changes were designed to make allergen declarations clearer and more consistent across all packaged food products — and they're more detailed than many manufacturers initially anticipated.

Under the new requirements, allergen information must be:

Declared using prescribed "Required Names" in plain English — for example, "milk" not "dairy solids"

Written in bold font, making allergens visually prominent on the label

Declared consistently regardless of how small or incidental the amount

Until February 2026, businesses could still sell existing stock produced under the old labelling format. That window has now closed. Any product manufactured and labelled today must meet PEAL in full — and any non-compliant stock remaining on shelves should be removed to avoid regulatory action.

Why Manufacturers Are Still Getting Caught Out

You might assume that after a three-year transition, compliance would be near-universal. The recall data suggests otherwise.

FSANZ's own statistics show that labelling errors made up a larger proportion of allergen-related recalls in 2024 than in previous years — and FSANZ directly attributed this spike to the PEAL transition. Manufacturers knew the rules. They still got it wrong.

The reason is usually the same: allergen labelling isn't managed as a live system. It's treated as a one-time label update rather than an ongoing control.

The problem is that allergens don't stay static. A recipe change that swaps one ingredient for another can introduce a new allergen. A supplier reformulation that isn't caught in your incoming goods process can add something your label no longer declares. A packaging artwork update that goes through design without a food safety review can strip out a bold declaration or use the wrong required name.

Each of these is a compliance failure waiting to happen — and under PEAL, each one is a potential recall.

The Real Risk: What PEAL Non-Compliance Costs You

A food recall in Australia or New Zealand is not just a regulatory inconvenience. It means coordinating a product withdrawal across every state and territory where the product is sold, issuing a public consumer warning, managing retailer relationships, and absorbing the operational cost of pulling product from distribution.

Beyond the direct costs, there's the brand impact. For a food manufacturer building trust with retailers and consumers, a recall — particularly for an allergen that should have been clearly declared on the label — is reputationally damaging in a way that's difficult to quantify and slow to recover from.

The PEAL requirements exist because food allergies can be life-threatening. The allergens covered under the Food Standards Code aren't edge cases — they affect millions of Australians and New Zealanders. Getting labelling right isn't just a compliance checkbox. It's a genuine consumer safety obligation.

How to Build Allergen Labelling Control Into Your System

The manufacturers who have navigated PEAL most successfully share one characteristic: they've made allergen control a system, not a task.

That means allergen labelling isn't reviewed once at product launch and then forgotten. It's connected to your change management processes — so any recipe change, ingredient substitution, or packaging update triggers a label review as a matter of course.

Practically, this looks like:

Supplier change alerts that flag when an incoming ingredient changes formulation, potentially introducing or removing an allergen

Recipe-to-label verification that cross-checks declared allergens against current ingredient specifications

Change approval workflows that require sign-off before a label update goes to print

Audit-ready records that document every label version, every change, and the sign-off trail behind each one

When these controls are embedded in your quality management system rather than managed manually across spreadsheets and email chains, the gaps that lead to recalls become a lot harder to miss.

Check Your Labels Before a Regulator Does

The grace period is gone, but the compliance window is very much open — meaning FSANZ and state regulators can act on non-compliant products right now.

If you haven't done a full PEAL audit of your current product range, that's the logical first step. Go through every SKU, check that every allergen is declared using the correct required name, that bold formatting is applied correctly, and that your ingredient lists reflect your current formulations — not what was in the original product registration.

It's painstaking work. But it's significantly less painstaking than a recall.

How QTRACA's AI Label Review Can Help

Manually auditing every label across a full product range is time-consuming — and the margin for human error is real, particularly when you're checking formatting requirements and required names across dozens or hundreds of SKUs.

QTRACA's AI Label Review tool is designed to take the manual effort out of exactly this process. Upload your product labels and let the AI check for allergen declaration compliance — identifying missing required names, flagging formatting issues, and cross-referencing declared allergens against your ingredient data.

It's not a substitute for your food safety team's judgement. But it's a fast, systematic first pass that catches the issues that are easy to overlook when you're reviewing labels one by one.