Food labelling in New Zealand
Understanding what ingredient lists and allergen warnings actually mean — especially "May contain" statements.
Two types of allergen information on NZ labels
New Zealand food labels can carry two very different types of allergen information. They look similar but mean quite different things.
Declared ingredient
The allergen is an intentional ingredient in the recipe. The manufacturer deliberately adds it. This is a mandatory declaration under FSANZ Standard 1.2.3.
Precautionary allergen label (PAL)
The allergen is not an ingredient, but it might end up in the product due to shared manufacturing equipment or ingredient sourcing. This is a voluntary cross-contamination warning.
What "May contain" actually means
A "May contain" or "May be present" statement means the manufacturer cannot guarantee the product is free of that allergen. This happens when:
- Shared equipment — the same production line or machinery is used to make products that contain the allergen. Even with cleaning, trace amounts may transfer.
- Shared facility — allergen-containing products are made in the same factory, and airborne particles or cleaning cross-contamination is possible.
- Ingredient sourcing — an ingredient supplier uses shared equipment, introducing risk before the product even reaches the manufacturer.
The statement is voluntary — the Food Standards Code does not require it. Some manufacturers add it proactively as a precaution; others in identical production environments may not. The absence of a "May contain" statement does not guarantee a product is allergen-free.
How DietTribe handles PAL statements
DietTribe distinguishes between confirmed ingredients and PAL statements when analysing products:
- Allergens listed as ingredients are shown under Unsafe ingredients — the product definitively contains that substance.
- Allergens appearing only in a "May contain" section are shown under May be present — marked separately in blue to make the distinction clear.
For people with coeliac disease, even trace amounts of gluten can cause intestinal damage. The Allergy New Zealand guidance is that individuals with severe food allergies or coeliac disease should treat "May contain" statements seriously and make their own judgement based on their sensitivity level.
Ingredients with an unclear source
Some ingredients are listed by name on the label without any indication of where they came from. The same ingredient name can refer to a product derived from completely different sources — one safe for a particular diet, one not.
Unclear gluten source
Certain ingredients can be derived from wheat (which contains gluten) or from gluten-free sources such as corn, potato, or tapioca. The label may not specify which.
Unclear animal source
A number of common additives can be produced from either plant or animal material. Without further information, vegetarians and vegans cannot determine suitability from the label alone.
These are not allergen labelling failures — manufacturers are not required to declare the source of these ingredients under current NZ food standards. However, the ambiguity is real and can matter for people with coeliac disease, gluten intolerance, or plant-based diets.
The Unclear gluten source and Unclear animal source filters on the product search page surface products that contain one or more of these ingredients, making it easier to identify which manufacturers to contact. Where a brand's contact details are available, they appear directly on the product page.
High-FODMAP ingredients
FODMAPs (Fermentable Oligosaccharides, Disaccharides, Monosaccharides And Polyols) are short-chain carbohydrates that are poorly absorbed in the small intestine. For people with IBS or other digestive sensitivities, common trigger ingredients can cause bloating and discomfort — even when clearly declared on the label.
Unlike the source-ambiguous ingredients above, high-FODMAP ingredients are not hidden or unclear — they're named directly on the label (garlic, onion, inulin, polyol sweeteners like sorbitol and xylitol, and certain legumes and nuts). The issue isn't ambiguity, it's awareness: these ingredients are easy to miss when scanning a long ingredient list, and how much matters — a trace of onion powder low in the list is very different from onion as ingredient #2.
Most people with IBS are only sensitive to one or two of the six FODMAP subtypes — not all of them — which is why the FODMAP filter on the product search page lets you select specific subtypes to avoid (Fructans, GOS, Sorbitol, Mannitol, Fructose, Lactose) rather than a single all-or-nothing toggle. Selecting only the subtypes that affect you surfaces more products than avoiding everything at once.
A few ingredients (asparagus, apple, mushroom, and some syrups) are only high-FODMAP in larger amounts — a packaged product's ingredient list can't tell us the actual quantity used, so by default we exclude these too, out of caution. An optional checkbox lets you include products containing them instead, each shown with a note about the serving size the caution applies to — most useful on a product's own page, where you can weigh that note against how much of the product you'd actually eat.
See our FODMAP guides for a plain-language explanation of the diet, a starting-point low FODMAP food list, and individual food guides like is cauliflower low FODMAP.
Diabetic-relevant ingredients
Some ingredients cause a much faster rise in blood glucose than others, even at the same sugar content. Glucose syrup, dextrose, maltodextrin, rice syrup, and golden syrup all have a high glycaemic index and can cause a rapid spike — maltodextrin in particular is easy to miss since it doesn't taste sweet and is common in protein powders and processed snacks.
On the other hand, some "sugar-free" sweeteners have a genuinely negligible effect on blood glucose — xylitol, erythritol, stevia, and monk fruit are flagged as informational notes rather than warnings, since they're generally well-tolerated.
Important: this is ingredient-level flagging, not a computed glycaemic index score for the product as a whole. A product's overall glycaemic impact depends on portion size, fibre content, fat, protein, and cooking method — factors we don't attempt to model. Use the Diabetic friendly filter on the product search page to hide products containing a known high-glycaemic-impact ingredient, but treat it as a starting point.
The law in New Zealand
Food allergen labelling in New Zealand is governed by the Australia New Zealand Food Standards Code, specifically Standard 1.2.3 — Mandatory Warning and Advisory Statements and Declarations.
The mandatory allergens that must be declared when present as ingredients include: peanuts, tree nuts, milk, eggs, sesame seeds, fish, shellfish, soy, wheat, and lupin. Gluten from wheat, rye, barley, and oats must also be declared.
PAL statements are not regulated — they are written by manufacturers at their own discretion. Work is ongoing internationally (including through FSANZ) to standardise PAL wording to make it less confusing for consumers.