Dairy-Free: How to read food labels

Labelling laws in Australia (as of FEB 25th 2024) require food products to declare all of the major allergens if they are present in the food.

The phasing in of this new labelling law is 2 years from FEBUARY 25th 2024.

Packaging before this date needs to adhere to previous labelling laws: allergen ingredients are bolded but an allergen declaration (allergen statement) does not need to be included.

Dairy is one of the recognised top allergens in Australia. The other top allergens are egg, soy, wheat, fish, seafood, tree nut, peanut and lupin.

When dairy is present in a food, it may occur for the following reasons:

- Dairy may be in a food as an ingredient

- An additive may be used which is made from dairy

- Dairy may have been used as a 'processing agent'

Any of these mean that the food contains dairy and need to be avoided if following a dairy free diet.

This is especially important as small amounts can cause significant issues if there is a dairy allergy.

How can you tell if a food contains dairy?

1. There needs to be an ALLERGEN statement

The allergen statment needs to include the word "CONTAINS' for example: 'contains milk'

The allergen statement needs to be placed near the ingredient list.

If the food is not in packaging or does not need to have a label, the information must be displayed with the food or can be requested from the supplier. For example, by asking about allergens in food prepared and sold from a takeaway shop. 

2. In the Ingredient list, dairy ingredients needed to be bolded and declared

All packaged foods, by law, have to have a food ingredient list.

Ingredients are listed from greatest to smallest by weight, which means the ingredients at the top of the list are present in the highest amounts and the ingredients in the bottom of the list are present in the lowest amounts.

All of the following are dairy ingredients so would need to be bolded in the ingredient list and declared as milk:

• A2 milk

• butter

• butter fat

• buttermilk or cultured buttermilk

• casein or caseinate (eg ammonium caseinate, rennet casein))

• cheese

• chocolate

• condensed milk

• cream

• curds

• custard

• evaporated milk

• ice-cream

• lacto acidophilus

• lactalbumin

• lactoglobulin

• low fat milk

• malted milk

• milk

• milk solids

• non fat milk solids

• milk powder

• nougat

• skim milk

• sour cream

• rennet

• whey or whey powder or whey protein or whey solids or sweet whey

• yoghurt

AN EXAMPLE OF LABELLING LAWS IN PRACTICE:

Uncle Toby's Oats- berry quick sachets

Ingredients: Whole Grain Rolled Oats ( 74%), Sugar, Skim Milk Powder, Blueberry Fruit Pieces [Blueberry (1.9%), sugar, tapioca starch, Humectant (Glycerol), Vegetable Gum (pectin), Rice Flour, Lemon Juice Concentrate, Wheat Flour], Freeze Dried Berries (1%) [Raspberries, Strawberries], Flavour.

An allergen statement would need to declare these 3 allergens (Oats- will need to incude the work gluten, Milk and Wheat).

What about 'may contain' statements?

'May contain' statements cause such confusion!

This statement is voluntary but at the end of the day is not at all useful. This is why..

The idea behind the 'May contain...' statement is to indicate if there is a risk of accidental contamination of an allergen such as dairy.

The recommendation is to fill out a risk assessment following set questions/prompts to determine the risk of the allergen contamination.

Based on the results of this assessment, a conclusion as to the risk of contamination of the allergen (for example dairy) is reached (by the company).

If there is a risk then a 'may contain' stament is recommended, if the risk is low then use of this statement is not justified.

As it is a voluntarty code, it means that companies may or may not follow the set risk assesment and may or may not issue a 'may contain' statment.

Some may decide to issue the statement wihtout assessing the apparent risk, while other companies that maybe should assess the risk, may not do so.

Until it is not a voluntary code, the vlaue of the 'may contain' statment does not offer any true insight into risk of dairy (or any other allergen) containination.

At the end of the day, a product without the 'may contain' statement may carry the same risk as another product with the 'may contain' statement- there is currently no way of the consumer being able to determine actual risk.

Whether you avoid a food based in this claim is personal preference only.

Take Home Messages

1. AWAYS check ingredient lists each and every time you buy food as ingredients can (and do) change without warning. This is especially important for dairy allergy.

2. When avoiding dairy, companies will have to provide this information using an allergen statement and bolding the dairy ingredients in the ingredient list.

3. The 'may contain' statement offers little value in determine actual risk of dairy contamination and at this point in time remains a personal preference choice.

References

1. FSANZ (Food Standards Australia New Zealand) https://www.foodstandards.gov.au/consumer/labelling/allergen-labelling

2. 2. Personal communication: FSANZ (Food Standards Australia New Zealand), Scientist/researcher, May 2019.