Allergens on a beer label in New Zealand

In New Zealand, as in Australia, beer gets a break that it doesn't get in the UK: the barley, wheat, oats and rye in the malt don't have to be declared. Everything else on the allergen list does – the lactose in a milk stout, the hazelnuts in a brown ale, the sulphites from a fruit purée. And because beer needs no ingredients list, the declaration has to go somewhere else on the label.

The rules are in Standard 1.2.3 and Schedule 9 of the Australia New Zealand Food Standards Code, which applies in New Zealand through the Food Act 2014. Since 25 February 2024 they follow the Plain English Allergen Labelling (PEAL) format, with set names for each allergen (FSANZ). Like the rest of the label, the declaration must be in English.

Barley, wheat, oats and rye: exempt in beer

Schedule 9 lists the foods that must be declared, and the exemptions next to them (section S9—3). For barley, oats and rye, the exemption is "the cereal or its hybridised strain that is present in beer or spirits"; wheat has the same exemption. FSANZ puts it plainly: beer or spirits do not have to declare barley, rye, oats or wheat.

So a pale ale, a wheat beer or an oatmeal stout needs no "Contains barley" or "Contains gluten" line for its malt. The exemption covers only the cereals: anything else you add to the beer is judged on its own.

Isinglass

Isinglass made from fish swim bladders and used as a clarifying agent in beer or wine doesn't have to be declared as fish (section S9—3, item 7). Other finings do count: a food is declared even when it is only used as a processing aid (section 1.2.3—4(5)), so finings made from egg or milk must be declared.

What you still have to declare

Everything else in Schedule 9 must be declared when it is in the beer, including in an additive or processing aid (section 1.2.3—4). These are the names you use when the beer has no ingredients list (column 4 of the table to section S9—3):

Milk. A milk stout or pastry stout with lactose must declare milk.

Nuts. The tree nuts are declared one by one, so a brown ale with hazelnuts says "hazelnut", not "tree nuts". Peanut has its own entry. Coconut isn't on the list, so a coconut porter declares nothing for the coconut.

Sulphites. Added sulphites must be declared at 10 mg/kg or more (section S9—3, item 1). They can come from a sulphited fruit purée or from sulphite you add yourself, so ask your supplier how much is in the fruit and check the total in the finished beer.

How to word it

Beer doesn't need an ingredients list (section 1.2.4—2(3)), so the PEAL rule that allergens go in the ingredients list plus a summary statement next to it doesn't apply (section 1.2.3—6(3)). The declaration just has to state the required name (section 1.2.3—6(1)). FSANZ says foods without an ingredients list must still provide declarations elsewhere on the label, "such as in a summary statement", using the required names.

In the Code, a summary statement starts with the word "Contains", then lists the required names and contains no other words (section 1.2.3—7(3)):

Contains milk

Contains milk, hazelnut

Each name may be singular or plural (section 1.2.3—8), so "Contains hazelnuts" is fine too. Printing the line in bold, as PEAL requires next to an ingredients list, makes it easy to find.

Examples from common beer styles

If you add an ingredients list anyway

PEAL sets out how required names appear in a statement of ingredients (section 1.2.3—7(1) and (2)), and these rules aren't limited to lists the Code requires. Each required name is printed in bold, in text no smaller than the rest of the list, next to the ingredient it comes from: "lactose (milk)". The barley and oats aren't required names in a beer, so they stay in plain type.

PEAL also puts a summary statement directly next to the list – in the same field of view but distinctly separated from it, in bold and in the same typeface and size as the names in the list – but only where the Code requires the ingredients list (sections 1.2.3—6(3) and 1.2.3—7(6)). Beer doesn't need one, but you can add one in the same form:

Ingredients: Water, malted barley, oats, lactose (milk), hops, yeast. Contains milk

Cider, mead and fruit wine are not exempt

The cereal exemption covers only beer and spirits – not cider, perry, mead or fruit wine (in the Code, cider and perry are kinds of fruit wine, section 1.1.2—3). If one of them contains wheat, or barley, oats or rye that contains gluten, it must be declared. Outside an ingredients list, the required name for barley, oats and rye is "gluten", and for wheat it is "wheat", plus "gluten" if gluten is present (section S9—3, column 4).

The isinglass exemption names beer and wine, and in the Code "wine" means wine made from grapes (section 1.1.2—3). Isinglass in a cider or mead therefore has to be declared as fish. Sulphites follow the same 10 mg/kg rule as in beer.

"Gluten free" and "low gluten"

A beer brewed with malted barley or wheat can't be called gluten free, however it is treated. A "gluten free" claim is only allowed when the food contains no detectable gluten, no oats or oat products, and no cereals containing gluten that have been malted, or products of them (Standard 1.2.7, section 1.2.7—12, and Schedule 4, section S4—3). A beer brewed only from sorghum, rice or millet can qualify if it has no detectable gluten.

"Low gluten" means no more than 20 mg of gluten per 100 g (section S4—3). Claims about gluten are among the few nutrition content claims allowed on a drink over 1.15% alcohol (section 1.2.7—4). A "low gluten" claim means the label also needs a nutrition information panel; a "gluten free" claim on a drink doesn't (sections 1.2.8—5 and 1.1.2—2).

"May contain"

Precautionary statements such as "may contain" or "may be present" are voluntary and not regulated by the Food Standards Code, according to FSANZ, which points to the Allergen Bureau for guidance. Like everything on a label, they must not be false or misleading – in New Zealand under the Food Act 2014 and the Fair Trading Act 1986 (FSANZ).

A way to work

Go through the recipe one ingredient at a time, including finings, fruit, spices and anything added at packaging, and check it against Schedule 9. Leave out the barley, wheat, oats and rye, and isinglass finings, then gather what's left in one "Contains" line. If you brew cider or mead as well, remember that the cereal exemption doesn't apply there.

With Brewlabel, the labelling check in Plus leaves barley, wheat, oats and rye off a beer's label, checks that milk, sulphites and nuts are named when your ingredients have them, and names the cereals in cider and mead. You remain responsible for the label.

---

Last checked: 21 October 2026

This guide explains labelling and is not legal advice. Rules can change – if you sell your drink, check with the Ministry for Primary Industries (MPI) or your local council.

Sources

• Australia New Zealand Food Standards Code (Federal Register of Legislation): Standard 1.2.3, information requirements – warning statements, advisory statements and declarations · Schedule 9, mandatory advisory statements and declarations · Standard 1.1.2, definitions · Standard 1.2.4, statement of ingredients · Standard 1.2.7, nutrition, health and related claims · Standard 1.2.8, nutrition information requirements · Schedule 4, nutrition, health and related claims
• Food Standards Australia New Zealand: Allergen labelling for food businesses · Product exemptions from allergen labelling · Truth in labelling, weights and measures and legibility