Australian Food Labelling Compliance in 2026: PEAL, Alcohol Energy Labelling & 2D Barcodes Explained

What Australian food & beverage manufacturers need to know before their labels fall out of compliance

Three separate labelling changes are currently working their way through Australian food and beverage packaging: PEAL, which is already mandatory; alcohol energy labelling, which is partway through a multi-year transition; and 2D barcodes, which are steadily becoming the retail standard. This guide is designed to make food labelling compliance more manageable by bringing together what each one requires, why it exists, and what manufacturers need to do to stay compliant.

Between production schedules, supply chains, and everything else involved in running a manufacturing business, regulatory tracking can easily slip down the priority list. Treat this as your single reference point for where all three currently stand.

Australian food labelling requirements at a glance

Change	Status	Deadline
PEAL (allergen labelling)	Mandatory now	Stock-in-trade exemption ended 25 February 2026
Alcohol energy labelling	Transition period	Full compliance required by 13 August 2028
2D barcodes (Sunrise 2027)	Voluntary, strongly recommended	Retailer/POS scanner readiness by 31 December 2027

Plain English Allergen Labelling (PEAL): What It Means for Your Ingredient List

The problem with technical ingredient names

For someone with a severe milk allergy, the gap between "casein" and "milk" on a label can be the difference between a safe snack and a trip to hospital. For years though, ingredient lists were full of scientific or technical naming conventions that even attentive, well-informed shoppers found genuinely difficult to decode.

Food allergies affect roughly 1 in 10 infants, 1 in 20 children, and 1 in 50 adults in Australia. A trace amount of the wrong ingredient can be enough to trigger anaphylaxis, and undeclared allergens are already the leading cause of food recalls nationally, they were behind 57% of all recalls recorded in 2024. Clear, immediately recognisable labelling is one of the most effective safeguards against this: it puts the right information directly in front of the people who need it, at the exact moment they're deciding what to eat or buy.

FSANZ (Food Standards Australia & New Zealand) addressed this in 2021 by introducing Plain English Allergen Labelling (PEAL for short). The requirement itself is simple to state: allergens must appear in everyday English, printed in bold, in both the ingredient list itself and a separate "Contains" statement, following a specific format and placement.

The rule took effect for all newly produced food from 25 February 2024, with a stock-in-trade allowance letting older stock remain on shelves until 25 February 2026. That window has now closed. Getting allergen labelling right isn't optional anymore. PEAL compliance is now a baseline legal requirement, not a best-practice recommendation.

[Image source:Oscar Care Group]

Getting your labels PEAL-compliant

Audit all SKUs against the PEAL required names in Schedule 9 of the Food Standards Code
Bold every allergen in the ingredient list using the exact required name
Add or update the "Contains" summary statement in bold, adjacent to the ingredient list
Declare wheat AND gluten separately where applicable; name each tree nut and cereal individually
Review all processing aids for allergen content
Download the free FSANZ Allergen Labelling Poster
Use the NSW Food Authority Food Labelling Assistant tool
Download the free PEAL nutrition label template from BarTender

With PEAL now settled, the next deadline is one that's caught a surprising number of producers by surprise.

Alcohol Energy Labelling: FSANZ's New Mandatory Requirements

The transparency gap alcohol labels are closing

Very few people could tell you offhand how many kilojoules are in their evening glass of wine as historically, nothing on the label was designed to help them find out. Clear energy information gives drinkers a genuine, concrete basis for making informed choices. And yet before this change, only around 2% of alcoholic beverage SKUs carried any energy information voluntarily, despite 69% of consumers saying they'd actively support it being made mandatory.

FSANZ closed that gap on 13 August 2025, gazetting amendments to the Food Standards Code that require a mandatory "energy statement" on every packaged alcoholic beverage. That statement must cover:

Servings per package
Serving size in mL
Standard drinks per serving
Energy per serving, shown in both kJ and Cal
Energy per 100mL, shown in both kJ and Cal

The requirement applies to all standardised alcoholic beverages (beer, wine, spirits, cider, RTDs, hard seltzers, etc.) provided the product sits at 0.5% ABV or higher.

A 3-year transition period is currently underway, during which both old and new label formats remain acceptable, giving manufacturers flexibility on timing. A stock-in-trade exemption also applies: any product packaged and labelled before 13 August 2028 won't need to be recalled or relabelled once the deadline arrives.

[Image source:FSANZ]

Getting your labels compliant for alcohol energy statements

Confirm the rule actually applies to your product: 0.5%+ ABV, no existing Nutrition Information Panel, and label surface area above 100 cm²
Use the free FSANZ alcohol energy content calculator to determine your product's energy values.
You'll need: ABV%, specific gravity, serving size (mL), servings per package, standard drinks per package, and any other energy-contributing components.
Factor in label space early. Wine Australia has noted that many wine labels will likely need a full redesign to accommodate the new statement
Line up your changeover with your next scheduled print run rather than a standalone update, to keep costs down

FSANZ's website hosts a full set of tools and guidance for working through the specifics of your own product range.

PEAL and alcohol energy labelling both concern what's printed on the label. The next change is about what's embedded inside it.

2D Barcodes and Sunrise 2027: What's Changing in Retail Scanning

Why the standard barcode has reached its limit

The 1D barcode has done one job for decades: hold a basic product identifier, and nothing more. That's now a genuine constraint rather than a feature. A 1D barcode can't carry an expiry date, a batch number, a serial number, or a web link. And it has no way to show where a product came from, flag an allergen, or surface a live recall.

Industry's Ambition 2027 is the global response to that limitation, built around 2D barcodes (QR codes and DataMatrix symbols). A single 2D code can hold all that extra data, and it's scanned at the checkout exactly the way a 1D barcode is today. One scan now does considerably more work: it gives a shopper full product detail on their phone, gives a warehouse team live batch-level visibility, and gives a brand the traceability trail it needs for compliance and recall management.

The initiative sets 31 December 2027 as the date by which point-of-sale systems and retail scanners must be able to read 2D formats (QR code, DataMatrix, or Digital Link). For now, that obligation sits with retailers and their scanning infrastructure, not with brand owners' packaging. Once that date passes, though, 1D barcodes are expected to be phased out progressively, with retailers pushing suppliers toward 2D as a condition of shelf placement. Several major retailers (Woolworths, Coles, Chemist Warehouse, and ALDI among them) are already encouraging early adoption among their suppliers.

[Image source:GS1]

Dual-marking is permitted throughout the transition, meaning a brand can print both a 1D and a 2D barcode on the same label, keeping things workable for retailers who haven't upgraded their scanning systems yet.

The good news is that transitioning to 2D doesn't mean starting from scratch. it's more about being deliberate with your next print run. Here's what that involves:

Register or confirm your GS1 membership to obtain a GS1 Company Prefix (the foundation of any GS1 barcode)
Choose the 2D format that fits your product: QR codes suit consumer-facing items and scan easily with a smartphone, DataMatrix is better suited to smaller packaging, and a Digital Link URI supports dynamic linking to web content
Decide what to embed in the code: your GTIN at minimum, with batch/lot numbers, expiry dates, and a GS1 Digital Link URL to your product page all worth adding.
Use the GS1 Australia Sunrise 2027 readiness toolkit and free verification tools to generate and test your 2D symbol
Use dual-marking on your next label print run to maintain backwards compatibility with retailers not yet fully upgraded
Update your label and packaging design. Current layouts will not accommodate 2D barcodes without redesign. Key considerations: minimum size and quiet zones; account for substrate, print process, and surface type; real estate for dual 1D + 2D barcodes during transition; sufficient contrast (dark barcode on light background)
Upgrade your printing infrastructure: not all printers can produce high-quality 2D barcodes. Key requirements: minimum 300 DPI (600 DPI preferred for DataMatrix); thermal transfer printers are industry standard; variable data printing capability needed for batch, expiry, or serial data; print quality verification to ISO/IEC 15415 grading recommended for all products; ERP/WMS integration required for variable data print jobs
Check with major retail partners (Woolworths, Coles) about their specific timelines and any supplier requirements they have communicated

Three changes, one print run: your action plan

Most teams underestimate how long a proper label transition actually takes. To keep the process manageable, here are three moves worth making early.

Roll all three changes into your next scheduled print run to avoid paying for three separate design, setup, and print runs. With PEAL already at deadline, alcohol energy labelling due by 2028, and 2D barcodes recommended before 2027, the smart move is to tackle all updates in one coordinated label refresh.
Audit your label real estate early: the new "Contains" summary statement, energy table, and a 2D barcode all require physical space. Designs may need adjustment to ensure everything is legible and compliant. A label audit now prevents costly reprints later.
Engage your label printer and graphic designer as soon as possible: lead times for label redesigns can be longer than expected, and compliance deadlines wait for no one.

Three regulations, one coordinated print run: manufacturers who move on this early will spend less, face less last-minute pressure, and stay comfortably ahead of the compliance curve.

Frequently asked questions

What is PEAL (Plain English Allergen Labelling)?

PEAL is a FSANZ requirement that allergens be declared using plain English terms, in bold, within both the ingredient list and a separate "Contains" statement. It's been mandatory for all newly produced food since 25 February 2024, and the stock-in-trade exemption for older stock ended 25 February 2026.

Do I need to relabel existing stock for PEAL?

No, stock packaged and labelled before the stock-in-trade deadline (25 February 2026) was exempt and didn't need to be recalled or relabeled. Anything produced now, though, needs to be fully PEAL-compliant.

What does PEAL compliance actually involve?

PEAL compliance means every SKU has been audited against the approved allergen names in Schedule 9 of the Food Standards Code, with each allergen bolded in the ingredient list and repeated in a "Contains" statement. It also means checking processing aids for allergen content and declaring wheat, gluten, tree nuts, and cereals individually rather than under a general term.

When do alcoholic beverages need energy labelling?

Alcohol energy labelling has a 3-year transition period from 13 August 2025, with full compliance required by 13 August 2028. Stock packaged before that date under the stock-in-trade exemption won't need to be recalled.

Do I need to switch to 2D barcodes right now?

Not yet, Sunrise 2027 is currently a retailer/POS infrastructure deadline (31 December 2027), not a mandatory brand packaging requirement. That said, major retailers are already asking suppliers to start transitioning early, and dual-marking (1D + 2D on the same label) is allowed in the meantime.

What's the difference between a 1D and 2D barcode?

A 1D barcode only stores a basic product identifier. 2D barcodes (QR codes, DataMatrix) can hold considerably more data (batch numbers, expiry dates, web links) in the same footprint, and are scanned the same way at checkout.

How can manufacturers stay on top of food labelling compliance?

The most practical approach is to treat food labelling compliance as an ongoing process tied to your print schedule rather than a one-off task: auditing labels against current requirements at each print run, rather than waiting until a deadline is imminent. Bundling multiple changes, such as PEAL and alcohol energy labelling, into a single label redesign is generally the more cost-effective way to manage food labelling compliance as new FSANZ labelling requirements are introduced.

Where can I check current Australian food standards labelling requirements?

The Food Standards Code, maintained by FSANZ, is the primary reference for Australian food standards labelling ,including the allergen naming conventions in Schedule 9 used for PEAL. The FSANZ website also hosts specific tools relevant to Australian food standards labelling, such as the Allergen Labelling Poster and the alcohol energy content calculator.

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