FSANZ Labelling Requirements for Gelato Producers

The labelling duties on a gelateria depend almost entirely on how the product reaches the customer. Scooped over a counter, packed into a tub for the freezer cabinet, and supplied wholesale to a restaurant are three different cases under the Australia New Zealand Food Standards Code, and the differences are large.

This is orientation, not legal advice. The Code is the authority, it is amended regularly, and it is enforced by your state or territory agency and your local council. Where a decision carries commercial or safety consequences, check the current standard or take advice.

The three cases

Sold unpackaged from a display cabinet. Most of the packaged-food labelling requirements do not apply, because there is no label. What does still apply is allergen information: it must be available to the customer, and "available" generally means displayed or provided in writing on request rather than left to whoever happens to be on shift.

Packed into a retail tub. Now you are labelling packaged food, and the full set of requirements engages: the name of the food, a statement of ingredients, allergen declarations, date marking, storage directions, lot identification, supplier name and address, and a nutrition information panel.

Supplied wholesale to another business. A middle case with its own rules about what must accompany the goods, and the receiving business is relying on your information to meet its own obligations. This is the case where getting it wrong propagates.

Which standard governs what

Rather than reproduce thresholds that change, here is the map — go to the current text of each for the detail:

• Standard 1.2.1 — when a label is required, and what applies to food sold unpackaged or made and sold on the same premises.
• Standard 1.2.2 — the name of the food, and lot identification.
• Standard 1.2.3 — mandatory declarations, including allergens.
• Standard 1.2.4 — the statement of ingredients.
• Standard 1.2.5 — date marking.
• Standard 1.2.6 — directions for use and storage.
• Standard 1.2.7 — nutrition, health and related claims. This is the one that governs "gluten free", "dairy free", "no added sugar" and similar.
• Standard 1.2.8 — the nutrition information panel.
• Standard 1.2.10 — percentage labelling of characterising ingredients.
• Standard 2.5.6 — compositional requirements for ice cream. If you sell a product as ice cream, it has to meet the composition set out here. Check the current figures before you name a product.

Allergens are the part that bites

Plain English Allergen Labelling changed how declarations must be made, and the transition period has ended. Declarations use specified plain-English terms, in bold within the ingredient list, plus a separate summary statement. If your tub labels were designed before that change, they need reviewing.

Three practical points for a gelateria:

A product name is not an allergen declaration. "Pistachio" on a tub tells a customer about flavour, not about what is in it. And the reverse trap is worse: a biscuit ripple contains cereals whether or not the name says so.

Cross-contact is real in a gelateria and is not covered by an ingredient list. Shared scoops, a shared pan wash, a shared batch freezer between a nut flavour and a nut-free one — these are handling controls, and how you communicate them is a decision to make deliberately rather than by default.

The declaration comes from the specification sheet, not the catalogue. This is the single most important sentence in this article. A supplier's catalogue describes what a product is for. The specification sheet carries the ingredient list, the allergen declaration, the shelf life and the storage conditions, and it is a controlled document updated independently of the catalogue.

We apply that rule to our own product pages. Where we do not hold the Elenka specification sheet, the allergen section on the page is not published at all — because an empty allergen list asserts that a product is allergen-free, and that is a claim nobody should make on your behalf. It is why Fanta Crumble Pistacchio states plainly that it contains pistachios while publishing no allergen declaration, and why Copertura Limone publishes none either. Request the spec sheet by product code before you serve to a customer who has asked.

Claims you should be careful with

"Gluten free" is a claim with a defined meaning under Standard 1.2.7 and it is absolute — it is not a synonym for "no gluten-containing ingredient added". It requires substantiation, which in practice means the manufacturer's documentation.

"Dairy free" and "vegan" are not defined in the same way, which makes them easier to say and harder to defend. If you make a plant-based line with Base Vegan Lovers, the base being plant-based does not by itself make the finished product suitable for someone avoiding dairy — the ripples, coverings and the shared equipment all matter.

"Traditional", "artisan", "homemade" are not regulated in the Code but are still covered by Australian Consumer Law's prohibition on misleading conduct.

"Made in Australia" and country-of-origin labelling operate under their own regime. Gelato produced here from imported ingredients has a specific correct form of words; guessing at it is a common and avoidable error.

A practical starting checklist

• Decide, per product, which of the three cases applies.
• Collect the specification sheet for every ingredient you buy, filed by product code, and re-request it when a supplier reformulates.
• Write your allergen statement from those sheets, not from product names.
• Review any tub label designed before the Plain English Allergen Labelling transition ended.
• Check any "free from" claim against Standard 1.2.7 before it goes on a menu board.
• Have a compliance professional review your labels once, properly, before you print several thousand of them.

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Requesting specification sheets is the practical first step, and they are issued per product by Elenka code. The 2026 catalogue carries the code for every product in the range — which is the reference you will need to ask.