PEAL in Practice: A Plain‑English Playbook for Small Food Businesses

PEAL allergen labelling is now live. Here’s how one small catering business translated the rules into plain‑English labels, safer buffets, and documented systems that any staff member—on‑site or remote—can follow.

1) Introduction: The Day the Labels Changed

“From today, every label, menu and word we say must use the same plain‑English allergen names,” the owner told her team at the morning huddle. The Australia New Zealand Food Standards Code now requires certain allergens to be declared using required names—consistently—across packaged labels, menus, and verbal advice. There’s a sell‑through period too: foods labelled before 25 Feb 2024 may be sold until 25 Feb 2026. For a small business juggling retail, catering, and events, this wasn’t just a compliance tweak; it was an operational overhaul.

2) Challenge: Inconsistent Language, Real Risk

Symptom: Mixed terms everywhere

Old packaging said “contains dairy,” menus read “may contain nuts,” and staff sometimes said “wheat/gluten.” That inconsistency created confusion, customer risk, and compliance exposure. PEAL expects plain‑English required names like milk, egg, wheat, sesame, peanut, soy, tree nuts (e.g., almond, cashew), fish, crustacea, mollusc, lupin, and sulphites at certain levels—named the same way, everywhere.

What we changed

Built a controlled vocabulary of required allergen names from the Code.
Updated label templates, menu legends, and POS prompts to pull from that single source.
Scripted verbal responses so staff use identical wording: “This product contains milk and sesame.”

“If it isn’t written down, it isn’t real.”

In short: we removed guesswork from language.

3) Transition Trap: Old Stock Meets New Rules

Reality check

The sell‑through window (labels pre‑25 Feb 2024 may be sold until 25 Feb 2026) sounded simple—until mixed stock hit the shelves. Staff kept asking, “Is this legacy stock or PEAL‑compliant?” and customers wanted clarity.

Solution: A two‑bucket system and an audit trail

Physical segregation: Legacy stock in a clearly marked bay; PEAL‑compliant stock elsewhere.
Signage and POS cues: Shelf talkers explained the transition; POS flagged legacy items so staff gave accurate verbal advice.
Single source of truth: A living spreadsheet listing every SKU, its current label status, and the exact allergen declaration, accessible to remote workers and in‑store via QR.
Routine verification: A weekly 15‑minute sweep to spot drift—because drift happens.

Result: No more “I think so.” The system answered the question before it was asked.

4) Catering Flashpoint: Buffets, Grazing Tables, and Last‑Minute Swaps

Catering magnifies risk: shared utensils, guest flow, and inevitable late menu changes. At one corporate lunch, pesto crostini were swapped in at 9 a.m.—the pesto contained tree nuts (cashew). The old way would have been frantic relabelling and crossed fingers. Under PEAL, that’s not enough; cross‑contact must be actively minimised and declarations must remain accurate.

Key exposure points

Shared tongs and boards between nut‑containing and nut‑free canapés.
Display cards lagging behind last‑minute menu changes.
Casual verbal advice from rushed staff.

The lesson: speed without systems creates avoidable risk.

5) Systemising Safety: The Event‑Specific Allergen Matrix

We built an event‑specific allergen matrix as the operational brain of each job.

How it worked

Matrix first, menu second: For each dish, the chef listed ingredients and mapped allergens using required names. Variations and backups were pre‑approved.
Prep segregation: Color‑coded boards and utensils; nut/sesame prep in a contained area; separate storage and clearly labelled containers.
Briefing ritual: A 10‑minute pre‑service huddle: “Allergen map” reviewed, display cards printed from the matrix, verbal scripts rehearsed.
Remote readiness: Casual staff received the matrix link and SOPs the night before—no excuses. Remote workers followed step‑by‑step instructions in the same document.
Supplier label at hand: Digital copies (and a binder on site) for verification on request.

Mantra: “Document your business or get out.” When everyone uses one document, everyone gives one answer.

Side benefit

New hires onboarded in minutes because the matrix made the work visible.

6) Verification, Training, and the “Challenge Me” Culture

Authorised officers can check that food is safe, suitable, and correctly labelled. We prepared to pass on our best day and our worst.

What locked compliance in place

Supplier‑label verification: Every recipe in the matrix linked to current supplier labels; a runner carried the binder for on‑the‑spot checks.
Micro‑drills: Weekly 5‑minute drills: “Guest asks, ‘Does the tart contain egg?’” Staff must check the matrix and answer with required names.
Challenge Me protocol: Any staff member could halt service to resolve an allergen mismatch—no blame, just fix it.
Refreshers: Short, mandatory training modules on food allergy risks and PEAL requirements, tracked in our LMS.

Outcome by month two: consistent answers across labels, menus, and verbal advice—and buffers against cross‑contact at busy services.

7) Results: Fewer Close Calls, Faster Service, Real Confidence

Concrete wins

Zero misstatements: Staff answers matched labels and the matrix in spot checks for six straight weeks.
Time saved: 30% faster pre‑service setup; display cards auto‑generated from the matrix.
Incident prevention: A last‑minute swap (dairy‑free dessert to standard) was caught before plating because the matrix flagged “contains milk.”
Audit‑ready: We welcomed an inspection; documents, labels, and verbal advice aligned.

The deeper change was cultural: one “single source of truth” reduced friction and anxiety. People stopped guessing and started checking.

8) Outro: Make Compliance the By‑Product of Good Systems

PEAL isn’t a paperwork burden—it’s a customer‑safety promise you can operationalise. Start small but start now:

Adopt the required allergen names and make them your controlled vocabulary.
Create a living, event‑specific allergen matrix—use it to generate labels, cards, and staff scripts.
Segregate prep and utensils; verify with supplier labels; drill your team.
Treat the sell‑through period as a project with clear signage and POS prompts.
Write it once, use it everywhere—let remote and on‑site staff follow the same page.

When your systems are documented, PEAL compliance becomes the natural outcome—and your customers can eat with confidence.

PEAL in Practice: A Plain‑English Playbook for Small Food Businesses