Impacts of New Labelling Requirements

Registered Nutritionist Sara Lake has worked in Quality Assurance and Operations. New labelling requirements will have more stringency around allergens, impacting manufacturing significantly.

Lake shared that while it has significant impacts, some manufacturers will be affected more than others.

“The impact on the industry will vary depending on the products made,” said Lake.

Lake explained that the critical factor affecting manufacturers would be the separation of allergens in storage, transport, and processing.

“Where previously, companies may have had one area of the warehouse dedicated to gluten-containing cereals or fish products, now they will have to separate products that contain wheat and keep their fish, crustaceans and molluscs separate.” Consequently, this will create difficulties for dedicated equipment when handling a single defined allergen. Lake explained that while cleaning processes would minimise cross-contamination, the new labelling requirements may result in consumers noticing more the industry standard term, ‘it may contain traces of’ on product labels.

The increase of this statement on packaging will be the company’s method of guarding against the risk that traces of wheat have made their way into a cereal marketed as oat-based. Previously, these two products would have been under one identifiable label as a ‘gluten-containing cereal’, which would need to be specified separately with these changes.

Lake shared that Standard Operating Procedures around handling allergens and cleaning between products may need to change and be re-documented, requiring manufacturers to adjust operations to cater to these changes.

The Nutritionist revealed that the U.S.A. was a prime example of how manufacturers can embrace these labelling changes.

“I was very interested in what happened in the US with the new sesame labelling law. Rather than get sued for traces of sesame in products that didn’t have it on the label, companies are adding it into all their products and declaring it on the label.”

Lake shared that this approach was likely adopted because it is a more cost-effective solution than manufacturers completely reinventing and changing their line cleaning processes.

Another impact that would have a costly effect is the need for design and reprinting of labelling across a multitude of brands and products which are not already compliant by the end of the transition phase in February 2026.

While there are technically no new allergens to be advised, allergens were previously under a single identifiable category. For example, gluten-cereal, fish, tree nuts and otherwise would be required to be specified either with more depth or made more evident on the label.

The Nutritionist revealed that while these may have significant impacts on manufacturers, the specifications for consumers of having allergen identified with more detail would be reassuring for those with allergies. For example, Lake shared that having ‘tree nuts’ means a product containing almonds or walnuts would help consumers make more informed purchasing decisions.

However, Lake shared that it may be surprising for non-allergic consumers to see more allergens emboldened on a product’s ingredients list. Furthermore, the specification requirements may also impact a brand or company’s ability to market their products to consumers, potentially limiting their opportunities to claim their products are free from specific allergens. n

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