An allergen matrix is only as good as the last change that reached it. In most food businesses the same allergen information lives in four places: the supplier's specification, the recipe, the allergen matrix spreadsheet and the label artwork. When a supplier changes an ingredient or the team tweaks a recipe, all four have to change together, and that is where undeclared allergens get onto shelves. This article explains why, using the recall figures from Food Standards Australia New Zealand (FSANZ), and how to link those records so a change in one place can't be missed in the others. It is not food safety or regulatory advice; check your obligations with FSANZ and your state food authority.
Undeclared allergens are the most common reason for food recalls
According to FSANZ, undeclared allergens were the leading cause of Australian food recalls from 2021 to 2025: 197 of the 427 recalls in those five years. Over the same period, FSANZ lists errors during packaging (for example, product packed into the wrong packaging), label errors (including ingredients reformulated without the label changing) and accidental cross-contamination as the most common causes. Milk, wheat/gluten and tree nuts were the allergens most often missed off the label. In its 2024 recall data, FSANZ described these recalls as "mostly due to labelling errors".
FSANZ's earlier root-cause analysis (2017 to 2022) adds one more cause that matters for anyone who runs the records: supplier verification, where a raw ingredient contained an allergen but that information was not passed on. FSANZ also notes that customer complaints were the most common way these problems were found.
In other words, most of these recalls were information problems, not cooking problems.
Where the information lives, and where it drifts
A typical food manufacturer holds allergen information in at least these places:
- Supplier specifications. PDFs or emails from each supplier, often tracked in a spreadsheet with renewal dates.
- Recipes or formulations. In an inventory or production system, a recipe spreadsheet, or both.
- The allergen matrix. A spreadsheet listing every product against every allergen, plus may-contain statements and changeover notes.
- Label artwork and specs. Held by the technical team, a designer or the packaging supplier.
- Customer product specs. The information you send to retailers and distributors.
Each of these is updated by a different person, at a different time. That is the classic set-up for data silos (information stuck in separate systems that don't talk to each other). The usual failures:
- A supplier changes an ingredient and sends a new spec. It is filed, but the recipe and matrix aren't updated, so the label is now wrong.
- Production substitutes an ingredient because of a shortage, using the same packaging.
- The matrix is updated, but an old label artwork version is still loaded at the printer.
- The same ingredient has two names in two systems, so nobody notices it is in a new product.
Every one of these is a change that stopped before it reached the place it was needed. And because the allergen matrix is usually rebuilt by hand from the other records, it is a report built by hand: it shows what someone remembered to copy in.
The labelling rules make consistency more important
Since 25 February 2024, food labelled in Australia has had to follow the Plain English Allergen Labelling (PEAL) rules in Standard 1.2.3 of the Food Standards Code. That means allergens declared in bold in the ingredient list, using set plain-English names, plus a separate bold summary statement starting with "Contains" next to the ingredient list. The two-year stock-in-trade period for older labels ended on 25 February 2026.
PEAL means the same allergen has to appear correctly in two places on every label, and match your customer specs. The more places the same fact is written, the more important it is to write it once and copy it automatically.
How to keep the records in step
Make the recipe the single source of truth for allergens
A [single source of truth](/guides/plain-english-glossary#single-source-of-truth) means one place everyone takes the answer from. For allergens, that should be the ingredient and recipe records:
- Each raw material record holds its allergens, may-contain status and the current supplier spec, with an expiry date.
- Each recipe takes its allergens from its ingredients, never typed in separately.
- The allergen matrix becomes a report generated from the recipes, not a spreadsheet maintained by hand.
Treat a supplier change as a workflow, not an email
When a new or changed spec arrives, it should start a short, tracked process:
- Update the raw material record.
- Show every recipe and finished product that uses it.
- Flag any allergen or may-contain change.
- Put affected finished goods on hold until labels are checked.
- Record who approved the change and when.
This is workflow automation (the system moves each step to the next person and records it) rather than relying on someone remembering. See our business process automation service for how we set this up.
Link label versions to recipe versions
Each label artwork version should point to the recipe version it was approved against. If the recipe changes, the label is automatically flagged for review. This stops the "right recipe, old label" error.
Clean up the ingredient list first
Duplicate ingredient names, old suppliers and missing specs make all of this harder. A one-off clean-up of raw material and supplier records is usually the first job. Our data cleansing services cover exactly this kind of work.
What it looks like when it's fixed
A supplier emails a spec showing their crumb now contains soy. Someone updates one ingredient record. The system lists the six products that use it, flags two that will need a new "Contains" statement, and puts current stock of those two on hold. The technical manager approves the new label artwork against the new recipe version, and the customer product specs update from the same record. The allergen matrix for the next audit is printed from the system, already correct, with a dated history of every change.
Frequently asked questions
What is an allergen matrix?
It is a table listing every product (or ingredient) against each allergen, showing whether it contains it or may contain it. Many businesses also use it to plan production order and cleaning between runs. The risk is when it is kept by hand separately from the recipes.
Do I need special software for allergen management?
Not always. Many businesses can link the systems they already have, such as their inventory or production system and their spec records, so the matrix is generated rather than retyped. Dedicated product specification software exists and suits some businesses; the right choice depends on how many products and suppliers you manage.
Who has to have a food recall plan?
Under Standard 3.2.2 of the Food Standards Code, food businesses that manufacture, wholesale or import food must have a written recall system. FSANZ's Food Industry Recall Protocol explains what it should cover. Our guide to food recall traceability and mock recalls shows how to make a trace quick and reliable.
How often should supplier specs be reviewed?
FSANZ doesn't set one interval for every business; it depends on your food safety program and your customers' requirements. What matters is that every spec has an expiry or review date recorded and a reminder before it lapses.
Where to start
Our food and beverage page explains how we work with food manufacturers on recipe, supplier and production records. If you want a written map of where your allergen information lives and where changes get lost, the $5,000 Process & Systems Audit covers it. Or book a free initial chat.
Sources: FSANZ: food recall statistics · FSANZ: 2024 food recall data · FSANZ: undeclared allergen recall statistics · FSANZ: Plain English Allergen Labelling · FSANZ: Food Industry Recall Protocol