Why allergen management is now a HACCP priority
Allergen management is now explicitly a food safety issue — a chemical hazard that must be systematically identified and controlled within your HACCP-based Food Safety Program. AMES Food Advisory regularly reviews Food Safety Programs in NSW food businesses where biological and physical hazard management is thorough but allergen management receives only a brief mention or is absent entirely.
If your HACCP plan was developed before 2022 and has not been reviewed since, it almost certainly does not address the 2021 FSANZ allergen requirements — particularly the elevation of sesame to mandatory declaration status. Updating your allergen management is an immediate compliance priority.
The 2021 FSANZ amendments — what actually changed
Sesame elevated to mandatory major allergen
From the end of the two-year transition period in February 2024, sesame must be declared as a major allergen on all packaged food labels in Australia. For Sydney cafes and restaurants, sesame is present in sesame-topped bread rolls and artisan loaves, tahini (in hummus, salad dressings, and dips), dukkah, and sesame oil in Asian-inspired dishes. The cross-contact risk from shared bread boards, toasters, and dressing equipment is real and must be assessed.
Strengthened advisory statement requirements
Advisory statements must now be based on a genuine assessed risk of cross-contact — they cannot be used as blanket legal disclaimers when no actual cross-contact risk exists.
Lupin confirmed as a mandatory major allergen
Lupin flour and lupin meal, increasingly used in gluten-free and high-protein baked goods, are confirmed major allergens requiring mandatory declaration.
The complete current list of major allergens in Australia
| Allergen | Common Food Sources | Cross-Contact Risk in Food Service |
|---|---|---|
| Gluten (wheat, rye, barley, oats) | Bread, pasta, flour, sauces, many processed foods | Very high — flour dust, shared surfaces, fryers |
| Milk (dairy) | Cheese, cream, butter, yoghurt, many sauces | High — shared dairy ingredients, equipment |
| Eggs | Many baked goods, pasta, sauces, mayonnaise | Moderate — shared equipment in baking |
| Peanuts | Peanut butter, satay sauce, many snacks | High — shared equipment, sauces, oils |
| Tree nuts | Almonds, cashews, walnuts, pistachios, macadamias | High — shared chopping boards, pestos, desserts |
| Sesame | Tahini, hummus, sesame oil, dukkah, bread | High — bread boards, dressings, toasters |
| Fish | All fish species and fish products | Moderate — shared cooking oils, surfaces |
| Shellfish (crustacean) | Prawns, crab, lobster, crayfish | Moderate — shared cooking equipment, stocks |
| Molluscs | Oysters, squid, scallops, mussels | Moderate — shared cooking equipment |
| Soy | Tofu, edamame, soy sauce, miso, many processed foods | Moderate — sauces, marinated proteins |
| Lupin | Gluten-free flour blends, some pasta, protein products | Low-Moderate — gluten-free baking |
Building allergen management into your HACCP plan
Complete an allergen inventory for every ingredient. Assess cross-contact risks at every process step: shared preparation surfaces, shared cutting boards, shared equipment, shared cooking oils, and food handler hands. Establish control measures: dedicated equipment for allergen-free preparation, documented cleaning procedures, colour-coded equipment systems, and staff training. Maintain a customer communication procedure and consider an allergen matrix for all menu items.
AMES Food Advisory integrates allergen management into every Food Safety Program we develop. If your current FSP does not address the 2021 FSANZ allergen amendments, contact us for a review. View our fixed-price packages.