Australia and New Zealand's Food Standards Code names 23 separate items that must be declared when they are in a dish, nine of them tree nuts listed individually, and for unpackaged restaurant food that information must be displayed or given on request.
Skai Solutions counted the list off the FSANZ allergen labelling page because the count is the part that catches venues out. Most floor training still runs on four or five categories, and the question a caller asks on the phone before they book is now much more specific than the answer most venues have ready.
Almost everything written about allergens is written about labels, and a plate of food does not have a label. That is why operators read the rules and come away thinking they do not apply. They do. The Food Standards Australia New Zealand allergen labelling page says that where food is not in packaging, or does not require a label, the allergen information must be displayed with the food or be able to be requested from the supplier.
The same distinction between an outcome and a document runs through restaurant pest control requirements: the Food Standards Code sets a result, not a contract, and no pest control certificate appears anywhere in it.
Read that clause the way a customer uses it and the obligation moves. In a restaurant the second limb is the one that gets used: someone asks. They ask at the door, they ask the person taking the order, and, more often than most venues realise, they ask on the phone before they will commit to a booking. The Code does not care which of your staff is holding the handset.
This is the part that has quietly changed underneath the industry. The declarable list is not the four or five categories that most floor training still uses. It runs to 23 entries, and the tree nuts are named one at a time.
| Group | Named in the Code | Count |
|---|---|---|
| Cereals | Wheat, plus barley, oats and rye where they contain gluten | 4 |
| Seafood | Fish, crustacean, mollusc, each separately | 3 |
| Animal products | Egg, milk | 2 |
| Legumes and seeds | Lupin, peanut, soy, sesame | 4 |
| Tree nuts, each named individually | Almond, Brazil nut, cashew, hazelnut, macadamia, pecan, pistachio, pine nut, walnut | 9 |
| Additives | Added sulphites at 10 mg per kg or more | 1 |
Source: Food Standards Australia New Zealand allergen labelling page, list read 15 September 2026. Counting the entries as the Code groups them is Skai Solutions' arithmetic, not an FSANZ figure.
Two consequences fall straight out of the table. The first is that "does it have nuts in it" is no longer a question with one answer. A cashew allergy and a walnut allergy are different facts about the same dish, and the Code treats them that way. The second is that seafood splits three ways. Prawns are crustacean, mussels are mollusc, snapper is fish, and a customer who says "I am allergic to seafood" has told you less than they think.
FSANZ is also explicit on quantity: these foods must be declared whenever they are present as ingredients, or as components of food additives or processing aids, however small the amounts present. There is no trace-level floor. The one stated threshold in the whole list is the 10 milligrams per kilogram that applies to added sulphites.
Plain English allergen labelling became compulsory on 25 February 2024. From that date allergens have to be declared in the ingredient list using the exact name from the Code and in bold, and a separate bolded summary statement starting with the word contains has to sit near the ingredient list. Where a gluten-containing cereal is present the summary statement has to say gluten.
The transition mattered more than the change. Food packaged and labelled before 25 February 2024 was allowed to be sold for a further two years, which ran out on 25 February 2026. As at September 2026 that window closed about seven months ago. Most restaurant operators never noticed either date, because both read as a manufacturer problem, and for the dish coming out of your kitchen they are. They are not a manufacturer problem for the packaged goods you resell: the retail fridge, the counter display, the jars on the shelf, the sauces you bottle and sell at the till.
Here is where the compliance question and the operations question turn out to be the same question. The Code's fallback is information "requested from the supplier". The supplier is the venue. In practice that request arrives in three places, and venues train for one of them.
| Where the question arrives | Who takes it | Usually trained? |
|---|---|---|
| At the table, before ordering | Floor staff | Yes, this is what allergen training covers |
| At the counter or the pass | Whoever is closest | Sometimes |
| On the phone, before a booking or a takeaway order | Whoever picked up, often mid service | Rarely |
The phone case is the worst of the three and it is the one nobody plans for. The call lands during service. The person who answers is holding something. They are being asked a question with 23 possible subjects, about a dish they did not cook, by a caller who will make a booking decision on the answer. The safe reply is not a guess and it is not "I think so". It is "let me check that with the kitchen and call you straight back", which requires that someone actually takes the number down.
That is the same failure mode as covering a shift at short notice and the same one behind no-shows: a job that needs attention arrives at the moment nobody has any. The difference is that this one has a food safety consequence rather than a financial one.
FSANZ's guidance for the food service industry sets out what the Allergen Collaboration agreed venues should do: run a food allergen management program, train all staff in allergen risks, management and communication, and provide clear, up to date and accurate information on the allergen status of the food you serve. Turned into something you can do this week, in order of how much it costs:
None of that needs software. If your venue is small, has a fixed menu and one person who cooks everything, a printed matrix on the wall and a rule that the kitchen takes allergy questions is a complete answer and you should stop there.
Yes, with a different enforcement wrapper. The Food Standards Code is a joint Australian and New Zealand instrument, so the 23 declarable entries and the 25 February 2024 labelling format apply on both sides of the Tasman. What is not shared is the registration regime. FSANZ notes that New Zealand's Food Act 2014 requires food businesses to register under a food control plan or a national programme, and that those documents carry their own allergen management requirements. For most New Zealand venues the practical effect is that allergen procedure is something your verifier looks at, which makes what a food control plan costs and covers the more useful page to read next.
In Australia the equivalent hook is staff competency rather than a registered plan, which is where food safety supervisor requirements and food handler certification sit.
Two gaps, stated rather than filled. There is no published Australian or New Zealand figure we could find for how many allergic reactions are traced to food service rather than retail, so this page does not claim one. And penalties sit in state and territory food acts rather than in the Code itself, so the fine for getting this wrong depends on where you trade and is not a single national number. If you need that figure, it comes from your state food authority or your council, not from FSANZ.
Skai Solutions builds an AI receptionist for restaurants and cafes in Australia and New Zealand, and setup takes five days. On this particular job its value is narrow and worth being honest about: it answers every call during service, it takes the booking, and when a caller asks an allergen question it takes the name, the number and the question rather than guessing. What it does not do, and must not do, is issue an allergen ruling on a dish. That answer belongs to the kitchen and to your matrix. If your phone rarely rings and your allergen questions all arrive at the table, this is not the problem you have, and a good voicemail or a message-taking plan is the cheaper honest answer.
When a guest rings to say they were made ill, the first hour decides how the rest of it goes. Our guide to a customer food poisoning complaint sets out who investigates, the 10 business day sample window and what the penalty notice actually costs.
A customer arriving with a requirement you have to accommodate raises the other question at the door too. Can a restaurant refuse service sets out what an Australian venue may and may not refuse, and why the food safety rule on animals says the opposite of what most operators assume.
The other Food Standards Code obligation that gets handled from memory rather than from the text: the 2 hour 4 hour rule, and the mandatory two stage cooling rule that uses the same two numbers in the opposite direction.
Restaurant food is not packaged, so it does not carry a label. Under the Australia New Zealand Food Standards Code the allergen information still has to reach the customer: FSANZ says that where food is not in packaging, or does not need a label, the information must be displayed with the food or be able to be requested from the supplier. In a restaurant that means a menu, a board, or a staff member who can answer accurately, and the answer has to cover the 23 items the Code names.
The Code's list runs to 23 entries: wheat, fish, crustacean, mollusc, egg, milk, lupin, peanut, soy, sesame, the nine tree nuts named one by one (almond, Brazil nut, cashew, hazelnut, macadamia, pecan, pistachio, pine nut and walnut), barley, oats and rye where they contain gluten, and added sulphites at 10 milligrams per kilogram or more. The old shorthand of asking about nuts, dairy, eggs and shellfish covers about a third of it.
Plain English allergen labelling became compulsory. Allergens must be declared using the exact names in the Code, in bold, plus a separate bolded summary statement beginning with the word contains. Tree nuts, molluscs and individual gluten-containing cereals stopped being groupable and now have to be named separately. This is a labelling rule, so it lands on the packaged goods a venue buys and resells rather than on a plated dish.
No. FSANZ allowed food packaged and labelled before 25 February 2024 to be sold for a further two years, and that period ended on 25 February 2026. Packaged product in the old format is now outside the transition, which matters for the retail fridge, the counter display and anything a venue packs and sells to take away.
The Food Standards Code is a joint Australia and New Zealand instrument, so the declarable list and the 25 February 2024 labelling change apply in both countries. What differs is the enforcement framework. FSANZ notes that New Zealand's Food Act 2014 requires food businesses to register under a food control plan or a national programme, and those documents carry their own allergen management requirements.
There is no single national allergen poster that a restaurant is required to display. The obligation in the Code is about the information reaching the customer, whether that is on the menu or by answering a question. A sign telling customers to ask is good practice and it is not a substitute for the person being asked knowing the answer.
FSANZ states that these foods must be declared whenever they are present as ingredients, or as components of food additives or processing aids, however small the amounts present. There is no minimum quantity below which an allergen stops being declarable, with the single exception of sulphites, which carry a stated threshold of 10 milligrams per kilogram.