PEAL Labelling Countdown: A Small Business Compliance Story
With the stock-in-trade period ending 25 Feb 2026, one small caterer’s scramble to meet PEAL allergen labelling and Standard 3.2.2A becomes a step-by-step playbook any food business can copy.
1) The Wake-Up Call: New Rules, Real Deadlines
“PEAL? Isn’t that just a label tweak?” our café-caterer, Mia, asked—until a client’s booking form listed “nut-free” while her menu said “tree nuts.” The gap wasn’t cosmetic; it was compliance-critical. Plain English Allergen Labelling (PEAL) now requires allergens to be declared using required names, and Standard 3.2.2A is actively enforced across Australia. The deadline to exhaust old stock-in-trade is 25 Feb 2026. After that, mislabelling could mean enforcement action.
Authorised officers can inspect, verify and enforce to ensure food is safe, suitable and correctly labelled.
- What changed: Allergen names must match the required terms across labels, menus and booking forms.
- What it means: All food businesses—local or importing—are responsible for correct declarations under the Food Standards Code.
2) The Label Audit: Finding the Mismatches
Mia’s team ran a rapid audit of every touchpoint where allergens are named.
Audit scope
- Packaged item labels (stickers, sleeves, delivery seals)
- Dine-in and event menus (printed, PDF and online)
- Booking forms and third-party platforms (pre-orders, dietary notes)
- Supplier specs and recipes (ingredients, sub-ingredients, may-contain claims)
Common gaps they found
- Non-PEAL terms (e.g., “nuts” instead of “tree nuts” or “peanuts”).
- Inconsistent wording between labels and menus.
- Missing cross-contact statements where risks were material.
- Legacy artwork using outdated allergen icons.
Lesson: If you can’t point to the exact required name in writing, it won’t be used consistently in production.
3) The Single Source of Truth: An Allergen Matrix Aligned to PEAL
Mia embraced a mantra: “Document your business or get out.” They built a living allergen matrix that serves as the single source of truth for every product.
Matrix essentials
- PEAL-required names only (no colloquialisms).
- Each recipe mapped to ingredients, sub-ingredients and supplier SKUs.
- Clear flags for “contains,” “may contain (cross-contact),” and “free from.”
- Version control, owner, last review date.
Why it works
Design, kitchen, sales and remote admin all draw from the same matrix, so labels, menus and booking forms can’t drift. Remote workers follow the same instructions because the matrix is the one approved reference.
4) People and Roles: Standard 3.2.2A in Practice
Regulation became role clarity. Mia appointed a trained Food Safety Supervisor and scheduled mandatory food handler training for all staff, including casuals.
Operational controls
- Temperature-control records for high-risk foods (delivery, cold holding, hot holding, transport).
- Documented cleaning and segregation to prevent cross-contact.
- Purchasing and receiving checks to ensure supplier labels meet PEAL.
Proof beats memory
Logs, checklists and sign-offs—kept in a compliance folder—made it easy to demonstrate due diligence if inspected.
5) Updating Everything Customer-Facing
Design-led fixes turned into business wins.
- Label templates: Locked text fields pull allergen names directly from the matrix.
- Menus: Standardised allergen callouts appear under each item using required names.
- Booking forms: Drop-down options match PEAL terms to avoid free text like “nut-free.”
- Digital ordering: Allergen filters mirror the matrix; no ad-hoc wording.
“If it isn’t in the matrix, we don’t print it or sell it.”
This removed ambiguity and reduced rework caused by last-minute copy changes.
6) Briefing the Crew: Pre-Event Playbooks for Zero Cross-Contact
Before every event, Mia’s Food Safety Supervisor runs a 10-minute stand-up with the whole roster, including casuals.
Event brief checklist
- Menu walk-through: highlight allergen items and PEAL names.
- Segregation map: colour-coded prep benches, labelled utensils, dedicated fryers.
- Glove and utensil protocols for allergen-free orders.
- Delivery and transport temperatures recorded with timestamped photos.
- Service scripts: staff know how to describe allergens accurately.
Result: Near-miss incidents dropped to zero in four weeks, and the team could articulate controls confidently if asked on-site.
7) The Inspection (and the Win)
When an authorised officer visited, the team walked through their systems, not just their intentions.
- Allergen matrix aligned to PEAL, version-controlled.
- Sample labels and menus matching required names.
- Food Safety Supervisor certificate and handler training records.
- Temperature logs for high-risk foods, including transport to a pop-up.
The officer’s feedback: “Clear, consistent, and verifiable.” No corrective notices—only a recommendation to schedule quarterly matrix reviews.
8) The Takeaway: Your 6-Step Countdown to 25 Feb 2026
- Map the gap: Audit all labels, menus and booking forms for PEAL names.
- Build the matrix: Create your single source of truth; lock templates to it.
- Assign roles: Appoint a Food Safety Supervisor; train every food handler.
- Prove it: Keep temperature-control and cleaning records—especially for high-risk catering.
- Brief the team: Pre-event huddles for cross-contact prevention and correct customer messaging.
- Review quarterly: Update the matrix when recipes or suppliers change; retire old stock before 25 Feb 2026.
PEAL isn’t just a label update—it’s an operating system. Document once, publish everywhere, and let your team—on-site and remote—execute with confidence.
