What changed in 2021 and why it affects your cafe
The 2021 amendments to the FSANZ Food Standards Code introduced three changes with direct implications for Sydney cafes and restaurants:
- Sesame elevated to mandatory major allergen status — from February 2024, sesame must be declared on all packaged food labels and, for food service, must be included in allergen information provided to customers on request
- Strengthened advisory statement requirements — "may contain" statements must now reflect a genuine assessed cross-contact risk, not be used as blanket legal protection
- Lupin confirmed as a mandatory major allergen — affecting cafes using gluten-free flour blends and protein products
For a typical Sydney cafe — sourdough bread with sesame seeds, tahini in dressings and hummus, dukkah on dishes, sesame oil in Asian-influenced items — sesame cross-contact is now a systematic food safety issue requiring documented assessment and control.
Gluten (bread, pasta, sauces) · Dairy (throughout) · Eggs (hollandaise, aioli, baked goods) · Sesame (bread, tahini, dukkah, sesame oil) · Tree nuts (granola, cakes, pestos) · Peanuts (satay, some desserts) · Soy (milk alternatives, sauces)
Building allergen management into your HACCP plan
Allergen management is a chemical hazard under the HACCP framework and must be systematically addressed in your Food Safety Program. Most pre-2022 cafe FSPs treat allergens as a labelling and customer communication issue — not as a food safety hazard requiring systematic control.
AMES Food Advisory builds allergen management into every Food Safety Program as a structured section covering: allergen inventory for every ingredient, allergen matrix for every menu item, cross-contact risk assessment at each preparation step, control measures for allergen-free requests, and staff training requirements.
What a compliant allergen management program looks like
Book a free scoping call to discuss your cafe's allergen management requirements, or view our fixed-price packages.