Lactose labelling requirements: FSANZ

The recent recall of a Cream Stout for the undeclared presence of an allergen highlighted confusion amongst brewers around the labelling requirements for lactose, a commonly used ingredient.

Stone & Wood Brewing recently recalled its Counter Culture Eirinn Irish Cream Stout, due to “the presence of an undeclared allergen – Milk” and advised any consumers with a milk allergy or intolerance to avoid the product. 

The beer was made using Irish Cream essence, but no actual Irish cream, and lactose for sweetness and body. 

The announcement sparked discussion amongst brewers, as Australia New Zealand Food Standards Code (FSANZ) specifically states milk, not lactose, as an allergen that must be clearly labelled on products.  

When asked whether lactose needs to be declared according to the code, an FSANZ spokesperson said that it does, however, did not specify whether there is a threshold level. 

“The Australia New Zealand Food Standards Code (the Code) requires milk to be declared when present in a food or beverage as it is an allergen,” an FSANZ spokesperson told Brews News

“If a beer contains milk (lactose), it must have a summary statement advising that it is present in the food – the Code requires it to be declared.” 

The FSANZ website states that the code requires food and ingredients to be declared using certain names, which includes milk. 

“New requirements to make declarations on food labels clearer and easier to find have been introduced,” the spokesperson said. 

“The changes include requirements for declaration font type and location on the label. 

“Foods not required to display a statement of ingredients must still provide declarations on the label (such as in a summary statement) using the required names. 

“Food manufacturers have until 25 February 2024 to implement the new requirements.” 

While the FSANZ code doesn’t specifically state lactose as an allergen, the Independent Brewers Association’s labelling guidelines uses lactose in a milk stout as an example of required declaration. 

“Allergens must be declared if they are present in the product whether as an ingredient, part of a compound ingredient, an additive, a processing aid or component of these,” the guidelines state. 

“Allergens that may be present in beer that require declaration include: Milk and milk products except for alcohol distilled from whey (for example: lactose in milk stout).” 

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