Alcohol in Flavourings and Non-Alcoholic Drinks: A Buyer's Guide for Australia and New Zealand

Standard 2.7.1 of the Food Standards Code uses 0.5% and 1.15% alcohol by volume in several labelling and representation provisions, and each section words its limit differently, as "more than", "not less than" or "no less than" Standard 2.7.1, ss 2.7.1-2 to 2.7.1-8. A standard drinks statement is required for a beverage containing more than 0.5% alcohol by volume, with the alcohol measured at 20°C, and such a beverage must not be labelled "non intoxicating" Standard 2.7.1, ss 2.7.1-4(1) and 2.7.1-6. Standards 2.7.1, 1.1.2 and 1.2.4 do not define "alcohol free" or "zero alcohol" Standard 2.7.1; Standard 1.1.2; Standard 1.2.4. Section 2.7.1-7 provides that "A food containing alcohol must not be represented in a form which expressly or by implication suggests that the product is a non-alcoholic confection or non-alcoholic beverage", and it states no threshold Standard 2.7.1, s 2.7.1-7. Changes mandating energy labelling for prescribed beverages were gazetted on 13 August 2025, with a transition period ending on 13 August 2028 FSANZ, Labelling of alcoholic beverages; P1059 variation, F2025L00923 cl 4(4); Standard 2.7.1, compilation endnote. If your drink is sold as no or low alcohol, ask your flavour supplier to state the flavouring's alcohol content and measurement basis on its specification before you settle the drink's label.

The 0.5% and 1.15% Alcohol Thresholds

The compilation read here is Standard 2.7.1 as compiled on 13 August 2025 (F2025C00838), which the Federal Register of Legislation listed as the latest version on 13 October 2026 Standard 2.7.1, compilation F2025C00838. The two figures sit in different sections, and the wording at each boundary decides whether a drink at exactly 0.5% or exactly 1.15% is caught. The standard drinks statement applies to a food that is capable of being consumed as a beverage and "contains more than 0.5% alcohol by volume", measured at 20°C, while a prescribed beverage, for which an energy statement is required subject to the applicable exemptions and transition arrangements, includes "a beverage containing no less than 0.5% alcohol by volume" Standard 2.7.1, ss 2.7.1-4(1), 2.7.1-2 and 2.7.1-4A(1) and (2); P1059 variation, F2025L00923 cl 4. A standard drink is "the amount that contains 10 grams of ethanol when measured at 20°C" Standard 2.7.1, s 2.7.1-2.

The alcohol-content, standard drinks and energy requirements in the table operate through the labelling provisions in Standard 1.2.1, which was not reviewed here; this table does not establish that every sale requires a package label Standard 2.7.1, ss 2.7.1-3(1), 2.7.1-4(1) and 2.7.1-4A(1), Notes. Three rows use the phrase "alcoholic beverage", which the current Standard 1.1.2 does not define as a term; it defines "standardised alcoholic beverage", "prescribed alcoholic beverage" and "non-alcoholic beverage" Standard 1.1.2, s 1.1.2-2(3) and s 1.1.2-3(2). A standardised alcoholic beverage "means beer, brandy, cider, fruit wine, fruit wine product, liqueur, mead, perry, spirit, vegetable wine, vegetable wine product, wine or wine product" Standard 1.1.2, s 1.1.2-2(3). The statement required by s 2.7.1-4 must appear separately from the energy statement or nutrition information panel (NIP) Standard 2.7.1, s 2.7.1-4(1A). Separate per-serving standard-drinks information is required in the energy statement and generally in a prescribed beverage's NIP Standard 2.7.1, s 2.7.1-4(1A) Note, ss 2.7.1-4B(1)(d) and 2.7.1-4F(1). NIP inclusion is optional where the labelled total equals the per-serving number; any number included must be accurate to one decimal place and appear in brackets immediately after the serving quantity Standard 2.7.1, s 2.7.1-4F(2) to (4). Section 2.7.1-4 also sets the statement's precision and exempts beverages packaged before 20 December 2002, s 2.7.1-3(4) sets accuracy tolerances for alcohol content statements, s 2.7.1-8(2) to (4) sets where the pregnancy warning goes when there is more than one layer of packaging, with exceptions, and ss 2.7.1-9 to 2.7.1-13 prescribe the warning's form and size; read those sections before finalising a label Standard 2.7.1, ss 2.7.1-3(4), 2.7.1-4(2) and (3), 2.7.1-8(2) to (4) and 2.7.1-9 to 2.7.1-13.

"Alcohol Free" and "Zero Alcohol" Have No Definition in the Standards Read

The words "alcohol free", "alcohol-free", "zero alcohol" and "dealcoholised" do not appear in Standard 2.7.1, Standard 1.1.2 or Standard 1.2.4 as compiled Standard 2.7.1; Standard 1.1.2; Standard 1.2.4. The titles and snippets returned by the FSANZ searches for "alcohol free" and "zero alcohol" on 13 October 2026 did not identify guidance on these claims; the linked result pages were not reviewed. The New Zealand Food Safety guide has no passage on "alcohol free" or "non-alcoholic" claims New Zealand Food Safety guide.

"Non-alcoholic beverage" is a defined term. Standard 1.1.2 defines it as "(i) packaged water; or (ii) a water-based beverage, or a water-based beverage that contains other foods (other than alcoholic beverages); or (iii) an electrolyte drink; and (b) does not include a brewed soft drink" Standard 1.1.2, s 1.1.2-3(2). The definition states no alcohol percentage. A brewed soft drink, which the definition excludes, has a two-limb definition: a product-description limb and a ceiling of "no more than 1.15% alcohol/volume" Standard 1.1.2, s 1.1.2-3(2). The ceiling alone does not define the category Standard 1.1.2, s 1.1.2-3(2). Standard 2.6.2, titled "Non-alcoholic beverages and brewed soft drinks" in the Standard 1.1.1 structure table, was not reviewed here; check it for your product category Standard 1.1.1, s 1.1.1-2.

Section 2.7.1-7 is the only provision read here that restricts presenting a product as non-alcoholic: "A food containing alcohol must not be represented in a form which expressly or by implication suggests that the product is a non-alcoholic confection or non-alcoholic beverage" Standard 2.7.1, s 2.7.1-7. The section sets no alcohol threshold. This guide does not give a level at which a drink can be called alcohol free, non-alcoholic or zero alcohol, because no text read for it sets one. For an interpretation of how s 2.7.1-7 applies to a particular pack, ask your food regulator.

Energy Labelling Applies to Prescribed Beverages, With a Transition to 2028

FSANZ states that on 13 August 2025 changes to the Code were gazetted "to mandate energy labelling on packaged alcoholic beverages that are standardised alcoholic beverages or beverages containing no less than 0.5% alcohol by volume (ABV) that are not standardised alcoholic beverages" FSANZ, Labelling of alcoholic beverages. The variation instrument commenced on the date of gazettal, which it gives as 13 August 2025 P1059 variation, F2025L00923 cl 3 and gazettal note. Its transition period runs from commencement and ends 36 months later; the compilation endnote gives the end date as 13 August 2028 P1059 variation, F2025L00923 cl 4(4); Standard 2.7.1, compilation endnote. During the transition period, a food product may be sold if it complies with either the Code without the P1059 variations or the Code as amended by them P1059 variation, F2025L00923 cl 4(2). A product packaged and labelled before the end of the transition period may be sold after it if the product complies with one of the options in cl 4(3), which FSANZ describes as a stock-in-trade exemption P1059 variation, F2025L00923 cl 4(3); FSANZ P1059 Approval report, pp. 1 to 4. The variation switches off the usual 12-month compliance rule in s 1.1.1-9 P1059 variation, F2025L00923 cl 4(1); Standard 1.1.1, s 1.1.1-9(1).

The energy statement must give the number of servings in the package, the average quantity in a serving in millilitres, the average energy content in kilojoules, or in kilojoules and kilocalories, per serving and per 100 mL, and the approximate number of standard drinks in one serving Standard 2.7.1, s 2.7.1-4B(1). It is not required for a prescribed beverage that has a nutrition information panel required by Standard 1.2.8, has a voluntary nutrition information panel under s 2.7.1-4E, or is sold in a small package, defined as "a package with a surface area of less than 100 cm2" Standard 2.7.1, s 2.7.1-4A(2); Standard 1.1.2, s 1.1.2-2(3). The voluntary-NIP exemption refers specifically to s 2.7.1-4E, which applies to food containing more than 1.15% alcohol by volume that is not required to have a NIP under Standard 1.2.8 Standard 2.7.1, s 2.7.1-4E(1). That voluntary panel must meet the specified content and format requirements Standard 2.7.1, s 2.7.1-4E(3). Displaying the required energy statement "does not constitute a nutrition content claim" Standard 1.1.2, s 1.1.2-9(5). This also applies when that statement is displayed on a packaging layer that is not required to carry it Standard 1.1.2, s 1.1.2-9(6). Section 1.1.2-9 separately governs whether mandatory or voluntary NIP information constitutes such a claim Standard 1.1.2, s 1.1.2-9(2) to (4). Sections 2.7.1-4A(3) and 2.7.1-4B to 2.7.1-4D also set the statement's prescribed format, the identification of average quantities, standard drinks per serving to one decimal place, a limit of three significant figures for energy, accurate package descriptions in place of "package", the "LESS THAN 40 kJ" option and the 8700 kJ reference for optional percentage daily intake information; read those sections before finalising a label Standard 2.7.1, ss 2.7.1-4A(3), 2.7.1-4B(2) and (3), 2.7.1-4C and 2.7.1-4D.

Scope is where a no alcohol drink maker needs care. The Code defines a prescribed beverage as "(a) a *standardised alcoholic beverage; or (b) a beverage containing no less than 0.5% alcohol by volume" Standard 2.7.1, s 2.7.1-2; Standard 1.1.2, s 1.1.2-2(3). The FSANZ Approval report for P1059 states: "Beverages with less than 0.5% ABV are out of scope of the proposal" FSANZ P1059 Approval report, p. 7. The same report records that "some standardised alcoholic beverages are represented as having zero or less than 0.5% ABV, such as ‘zero alcohol beer’", notes that "the definition for standardised alcoholic beverage does not specify an alcohol content", and states: "Regardless, all beverages represented as zero or less than 0.5% ABV will be required to have energy labelling, either in the form of an energy statement or a NIP, subject to whether they are a standardised alcoholic beverage" FSANZ P1059 Approval report, p. 25. The report also states that P1059 does not change the definition for standardised alcoholic beverages and that existing regulatory determinations for these products will continue to apply FSANZ P1059 Approval report, p. 25. The New Zealand Food Safety guide says energy content information must be declared as an energy statement "on beverages containing 0.5% or more ABV or standardised alcoholic beverages or versions of these beverages that have less than 0.5% ABV (e.g. reduced alcohol wine, zero alcohol beer etc.)", subject to its stated exceptions for NIPs, small packages, label-exempt retail foods and transportation outers intended to be removed before retail sale New Zealand Food Safety guide, p. 10. This guide sets these texts side by side and does not reconcile them. If your drink is a beer, cider, wine or other standardised alcoholic beverage with less than 0.5% alcohol, confirm its standardised-beverage status with your food regulator before you settle the label.

How a Flavouring Appears in the Ingredient List

A flavouring substance listed as an ingredient appears in the statement of ingredients "by using: (a) the word ‘flavouring’ or ‘flavour’; or (b) a more specific name or description of the flavouring substance" Standard 1.2.4, s 1.2.4-7(4). A statement of ingredients need not list "an ingredient of a *flavouring substance", although s 1.2.4-7(5) and (6) require some, such as L-glutamic acid, monosodium glutamate and caffeine, to be declared or listed Standard 1.2.4, s 1.2.4-3(2)(a) and Note; s 1.2.4-7(5) and (6). Section 1.2.4-3(2) also contains separate exemptions for a completely removed volatile ingredient, specified added water and processing aids Standard 1.2.4, s 1.2.4-3(2)(b) to (e). This guide makes no finding that alcohol in a particular flavouring meets any of those exemptions Standard 1.2.4, s 1.2.4-3(2). A standardised alcoholic beverage does not need a statement of ingredients, and when one is listed as an ingredient of another food its own ingredients do not need to be listed Standard 1.2.4, s 1.2.4-2(3)(b) and s 1.2.4-5(8). The s 1.2.4-2(3) exemption does not remove mandatory declarations of the presence of certain ingredients under Standard 1.2.3, as Note 2 explains Standard 1.2.4, s 1.2.4-2(3) Note 2.

A compound ingredient is one "made from two or more ingredients" Standard 1.1.2, s 1.1.2-2(3). When it is listed by name, the bracketed list that follows depends on its share of the food: at 5% or more of the food for sale, all of its ingredients; below 5%, the ingredients that s 1.2.3-4 or s 1.5.2-4 requires to be listed, and any substance used as a food additive in it that performs a technological purpose in the food for sale Standard 1.2.4, s 1.2.4-5(5) and (6). A compound ingredient may instead be declared by listing its ingredients individually Standard 1.2.4, s 1.2.4-5(5)(b). The by-name option does not apply to food for infants Standard 1.2.4, s 1.2.4-5(7). The applicable ingoing-weight rules and the standardised-alcoholic-beverage exception also apply Standard 1.2.4, s 1.2.4-5(1) to (4) and (8). Standards 1.1.2 and 1.2.4 do not say in terms whether a flavouring is itself a compound ingredient Standard 1.1.2; Standard 1.2.4.

The alcohol statement, the standard drinks statement and the representation rules are worded by the alcohol the food or beverage contains Standard 2.7.1, ss 2.7.1-3(1), 2.7.1-4(1), 2.7.1-5 and 2.7.1-6. The New Zealand Food Safety guide has no passage on ethanol in flavourings, the FSANZ search results reviewed for this guide (titles and snippets only) did not identify one, and in Standard 1.1.2 the word "ethanol" appears only in the standard drink definition New Zealand Food Safety guide; Standard 1.1.2, s 1.1.2-2(3). Ask your supplier how much alcohol the flavouring contributes to your finished drink, and confirm with your food regulator how that contribution is treated in your alcohol statement and in any no alcohol representation.

What to Ask Your Flavour Supplier

Standards 2.7.1, 1.1.2 and 1.2.4 do not use the word "carrier" Standard 2.7.1; Standard 1.1.2; Standard 1.2.4. In this guide, carrier means the liquid or base in which the flavouring is supplied. Before you approve a flavouring for a no or low alcohol drink, ask for these points in writing:

The flavouring's alcohol content, stated on the specification as a percentage by volume or by weight, with the basis named.

What the carrier is, and whether ethanol is part of it.

Whether the same flavour profile is available on a carrier without alcohol, and whether its specification differs.

Whether the flavouring contains any standardised alcoholic beverage, such as wine or spirit, as an ingredient, because s 1.2.4-5(8) treats that ingredient differently in the statement of ingredients Standard 1.2.4, s 1.2.4-5(8).

Whether the flavouring contains any substance that s 1.2.4-7(5) or (6) requires to be named Standard 1.2.4, s 1.2.4-7(5) and (6).

A current specification, an allergen declaration and a statement of the flavouring's Code status, dated, with the lot or version they apply to.

New Zealand

Standard 1.1.1 provides that the Code applies to food "sold, processed or handled for sale in Australia or New Zealand" or "imported into Australia or New Zealand", unless the Code provides otherwise Standard 1.1.1, s 1.1.1-3(1). Note 1 to s 1.1.1-3(1) lists the provisions not incorporated by reference into a New Zealand food standard, and Standard 2.7.1, Standard 1.2.4 and Standard 1.1.2 are not on that list Standard 1.1.1, s 1.1.1-3(1) Note 1. Standard 2.7.1's front matter Note 2 says the provisions that apply in New Zealand "are incorporated in, or adopted under, the Food Act 2014 (NZ)" Standard 2.7.1, front matter Note 2. These are Notes, which are not operative text.

The New Zealand Food Safety guide, A guide to Alcoholic Drinks (July 2026, V3), describes itself as "NOT LEGAL ADVICE" New Zealand Food Safety guide, p. 1. It lists "13 August 2028 - Labels must comply with new rules" for the energy statement, and says drinks packaged and labelled before that date may be sold after it without meeting the new rules New Zealand Food Safety guide, p. 1. It tells businesses that a pregnancy warning label is required "if your drink contains more than 1.15% Alc/Vol and is for retail sale" New Zealand Food Safety guide, p. 9. The same page says a pregnancy warning label is not required on the outer package if the label is clearly visible on the individual bottles, or "on the bladder within a box, when packed in front of the customer (e.g. fill your own container at a bottle store or when packed and labelled before 1 August 2023)", and s 1.1.1-3(2) excludes from s 1.1.1-3(1) certain wine bottled before 20 December 2002; read those passages before finalising a label New Zealand Food Safety guide, p. 9; Standard 1.1.1, s 1.1.1-3(2). It says the words low alcohol must not be used above 1.15% Alc/Vol, and the words non-intoxicating, or words meaning the same thing, must not be used above 0.5% Alc/Vol New Zealand Food Safety guide, p. 11. The MPI web pages on alcoholic drink labelling and on food standards amendments were not reviewed here, so how Amendment No. 241 (P1059) was adopted in New Zealand is not confirmed; check those pages.

Bringing the Question to VKA Australia

VKA Australia provides flavour specifications, allergen declarations and documentation aligned to the Australia New Zealand Food Standards Code. Bring your proposed pack wording, your finished recipe and any carrier questions to the Southport team. A flavourist reads your brief and replies inside one Australian business day.