May contain: Milk, Gluten, Soy. That’s the entire allergen line on Woolworths’ listing for Little Bellies Organic Blueberry Puffs, 12g. Its five ingredients: Organic Corn Flour (82%), Organic Sunflower Oil or Organic Rapeseed Oil, Organic Blueberry Powder (8%), Mineral (Iron), Organic Antioxidant (Organic Rosemary Extract). Not one of them is milk, gluten or soy.
It’s a warning about what else runs through the same production line as the puffs, in wording Little Bellies chose. Two different systems sit under the word “allergens” on an Australian label, and only one of them has rules attached.
Which allergens must a label declare?
Declared allergens get set names and mandatory formatting under Australia’s Food Standards Code. FSANZ requires it in the statement of ingredients using bold font and a font size no smaller than that used for other listed ingredients. It also requires a separate allergen summary statement in bold font beginning with the word “contains”. That statement has to sit in the same field of view and directly next to the statement of ingredients.
An Australian ingredient list has other rules too, on order, percentages and class names like “natural flavour”, covered in How to read a baby food ingredient list in Australia.
FSANZ’s declared list runs to:
- wheat
- fish
- crustacean
- mollusc
- egg
- milk
- lupin
- peanut
- soy
- sesame
- almond
- Brazil nut
- cashew
- hazelnut
- macadamia
- pecan
- pistachio
- pine nut
- walnut
Barley, oats and rye join the list wherever they carry gluten, declared using the word “gluten” in the summary statement. Those rules took effect 25 February 2024. FSANZ confirms the grace period for stock packed under the old rules closed 25 February 2026. After that date, stock carrying the old labelling can no longer be sold.
Does “may contain” mean anything?
“May contain” lives entirely in the other system. FSANZ is explicit that “the use of voluntary precautionary allergen labelling (PAL) statements such as ‘may contain’ or ‘may be present’ are not regulated by the Food Standards Code.” No required wording, no required trigger for when a manufacturer reaches for one, and no font rule either. A brand can write “may contain traces of,” “may be present,” or nothing at all, and stay equally compliant.
The nearest thing to a shared standard is one a business opts into, not one the law hands down. VITAL is the Allergen Bureau’s Voluntary Incidental Trace Allergen Labelling program. It runs a standardised cross-contact risk assessment and turns the result into a line shaped like “May be present: allergen x, allergen y.” Nothing requires a label to say which one produced its wording.
The pack where the law does reach
Rafferty’s Garden Banana Milk Teething Rusks, 6+ Months, 100g has a different ingredient list: Wheat Flour, Banana (5%), Skim Milk Powder (1.5%), Wheat Germ, Yeast, Natural Flavour, Salt, Mineral (Iron). Wheat and milk are both on the declared list. So the law requires this label to carry two markers: wheat and milk bolded inside the ingredient statement, and a “Contains” line beside it. Its Woolworths listing carries no Allergens field.
The decision sits with a specialist
ASCIA draws the same line from the clinical side. “Voluntary information on food labels includes precautionary allergen statements, which are used to declare cross contamination risk (such as ‘may contain…’), and these are not compulsory for food manufacturers.” Its next line hands the actual decision to a specialist, not the label: “It is important that people with food allergy discuss what to do about foods that include precautionary allergen statements with their clinical immunology/allergy specialist.”
On the shelf, the tell is on the pack itself. The in-force Standard 1.2.3 is the primary legal text behind the mandatory side (warning statements, advisory statements and declarations), for anyone who wants it instead of FSANZ’s plain-English page.
General information, not medical advice. Chat with your GP or child health nurse.