Allergens in Supplements: What Australian Labels Must Declare and Where They Hide (2026 Guide)
The ingredients list is not the only place to look
Most people scanning a supplement label for allergens read the active ingredients and stop. That is the wrong half of the label.
Allergens in supplements are rarely the active ingredient. They are usually in the capsule shell, the carrier oil, the flow agent, the sweetener, or the source material a vitamin was extracted from — all of which sit further down, in smaller print.
Here is what Australian law requires, and where the gaps tend to be.
What the law actually requires
Allergen declaration in Australia and New Zealand is governed by Standard 1.2.3 of the Food Standards Code, administered by FSANZ. Complementary medicines sold as foods, and supplements generally, are caught by it.
The rules were significantly tightened by the Plain English Allergen Labelling (PEAL) amendment. PEAL became fully mandatory in February 2024 after a three-year transition. Any product you buy now should comply.
What PEAL changed
Three things, and all three make labels easier to read:
- Plain English names are mandatory. A label must say "milk", not "casein". "Wheat", not "semolina". The technical name alone is no longer sufficient
- Bold type is mandatory for allergens inside the ingredients list
- A separate "Contains" statement is mandatory, grouped together in one place
PEAL also required more specificity: tree nuts must be named individually (almond, cashew, walnut — not "tree nuts"), and crustacea and molluscs are now declared separately rather than lumped as "shellfish".
The declared allergen groups
- Cereals containing gluten — wheat, rye, barley, oats, spelt and their hybrids
- Crustacea
- Molluscs
- Fish
- Egg
- Milk
- Peanuts
- Soy
- Sesame
- Tree nuts, named individually
- Lupin
- Added sulphites at 10mg/kg or more
If one of these is present, it must appear in the Contains statement. There is no threshold of "too small to mention" for a deliberately added ingredient.
Where allergens hide in supplements
This is the part worth memorising if you have a genuine allergy.
1. Fish oil, krill oil and marine collagen
Obvious when you think about it, easy to miss on a product marketed as "omega-3" or "collagen peptides". Krill is crustacea, not fish. Marine collagen is fish. Green-lipped mussel is mollusc. Our guides to reading a fish oil label and choosing a collagen cover the source question in more depth.
2. Glucosamine
Most glucosamine on the market is derived from crustacean shells — crab, prawn, lobster. Vegetarian glucosamine from corn fermentation exists and will say so explicitly.
3. Soy lecithin
An emulsifier used in softgels, liquids and powders. Extremely common and almost never the headline ingredient.
4. Vitamin E
Tocopherols are frequently soy-derived. Also used as a preservative in oil-based products, meaning soy can appear in a fish oil capsule.
5. Capsule shells
Gelatin capsules are usually bovine or porcine — not allergens under the Code, but relevant if you avoid them for other reasons. Fish gelatin capsules exist and are a fish declaration. If format matters to you, our guide to capsules, drops and gummies explains what each shell is made from.
6. Lactose as a filler
Used as a bulking agent in tablets and capsules. A milk declaration, and one that surprises people in a product with nothing dairy about it.
7. Whey and casein in powders
Expected in protein powders, less expected in greens blends and meal replacements.
8. Wheat-derived ingredients
Wheat starch as an excipient, and wheatgrass — which can carry gluten depending on harvest and processing.
9. Nut-based carriers and extract solvents
Some liquid botanical preparations use nut oils as a carrier. Almond oil is the common one.
10. Sesame
Sesame oil as a carrier in liquid and oil-based products. Sesame became a named allergen relatively recently in several markets and is easy to overlook.
11. Sulphites in dried botanicals and gummies
Used as a preservative. Declarable at 10mg/kg and above.
What "may contain" actually means
Precautionary statements — "may contain traces of…", "made on equipment that also processes…" — are voluntary in Australia. They are not mandated by Standard 1.2.3.
Two consequences worth understanding:
- A product without a may-contain statement has not necessarily been tested for cross-contact. The absence of a warning is not a guarantee
- A product with one is not necessarily more contaminated than one without. It may simply have a more cautious manufacturer
The industry framework for assessing this is VITAL (Voluntary Incidental Trace Allergen Labelling), run by Allergen Bureau. A manufacturer using VITAL has done a quantitative risk assessment. One that has not may be guessing, in either direction.
If you have a diagnosed allergy with a serious reaction, a may-contain statement should be treated as a real risk, not marketing caution.
How to read a label in thirty seconds
1. Find the Contains statement first. It is required to be grouped in one place. Read it before the ingredients list.
2. Then scan the ingredients list for bold. Bold is mandatory for allergens. Anything bold is a declaration.
3. Read past the actives. Capsule shell, carrier oil, excipients, flow agents, sweeteners. This is where the surprises are.
4. Check the precautionary line separately. It is voluntary and sits outside the Contains statement.
5. Check the sponsor details. An Australian supplier name and address means someone local is accountable for the label. If a product has no Australian sponsor address, you have no one to ring.
These five sit alongside the broader checks in our guide to reading a supplement label.
If a label looks wrong
It happens, and it is worth acting on rather than shrugging at.
- Contact the supplier first. Their details are required to be on the pack
- Report it to the TGA for therapeutic goods, or to your state or territory food authority for products regulated as foods
- Keep the packaging and the batch number. Without the batch, a supplier cannot trace it
Undeclared allergens are one of the most common causes of product recalls in Australia. The system relies partly on people noticing.
The short version
Read the Contains statement before the ingredients list. Scan for bold. Read past the active ingredients into the capsule shell and carriers. Treat may-contain as a real risk if your allergy is serious. Check there is an Australian sponsor address.
The law does most of the work for you now — PEAL made labels considerably more honest. The remaining job is knowing which part of the label to read first.
Related reading
- How to Read a Supplement Label: 10 Things Most People Miss
- Fish Oil in Australia: EPA vs DHA and How to Read the Label
- Capsules, Liquid Drops or Gummies: Choosing a Format
- Hidden Iodine in Supplements: Sea Moss, Kelp & Bladderwrack
- Why Do Supplements Have 20 Ingredients?
Always read the label and follow the directions for use. This article is general information about Australian allergen labelling requirements, not health or allergy advice. If you have a diagnosed food allergy, talk to your health professional before taking any supplement.