Gluten-Free Claims and Flavourings: Australian Rules

In Australia, a gluten-free claim on a finished food requires no detectable gluten, no oats or oat products, and no cereals containing gluten that have been malted or their products. A low-gluten claim allows no more than 20 mg gluten per 100 g of the food. These are the conditions in Schedule 4, s S4-3, Gluten rows. A flavour's cereal ingredients and carriers therefore form part of the finished-food assessment. Allergen declaration also reaches ingredients and components of a flavouring under Standard 1.2.3, s 1.2.3-4(5).

Schedule 4: the gluten-free conditions

As of October 2026, Schedule 4, s S4-3, compiled 30 April 2026, says a food carrying a gluten-free claim "must not contain" detectable gluten, oats or oat products, or malted gluten-containing cereals or their products. Each exclusion matters. A flavour containing an oat ingredient would bring that ingredient into the recipe, even if its specification addressed gluten alone. The same issue arises with a product of a malted gluten-containing cereal. The claim depends on the composition of the whole food, including what enters through its flavouring.

Gluten and the low-gluten condition

The Code's definition helps explain the cereal scope. Standard 1.1.2, compiled 9 June 2026, defines gluten as "the main protein in wheat, rye, oats, barley, triticale and spelt" relevant to coeliac disease and dermatitis herpetiformis. Schedule 4 gives the low-gluten claim a separate condition: "no more than 20 mg gluten/100 g of the food". That limit is expressed against the finished food. A figure for an individual flavour or carrier describes that ingredient; the recipe and the amount used determine what it contributes to the food carrying the claim.

Carriers and the wheat glucose syrup exemption

Carriers are relevant because cereal-derived ingredients can sit inside a flavour formulation. Schedule 9, s S9-3, table item 3, exempts glucose syrups from wheat starch refined to the lowest achievable gluten level and with gluten protein that does "not exceed 20 mg/kg". Both conditions belong to the refined syrup. This exemption concerns wheat declaration. It does not establish a gluten-free claim for the finished food. A specification identifying the syrup and documenting its refinement and gluten protein level provides the information needed to assess whether that particular carrier meets the exemption.

The cereal rows in Schedule 9

The cereal declaration rows use different conditions. Barley, oats and rye are declared "if they contain gluten" under Schedule 9, s S9-3, table item 2. Wheat has its own row in item 3 and is declared "irrespective of whether it contains gluten", subject to that row's exemptions. Spelt is not named in the S9-3 table. The wheat row also exempts wheat in beer or spirits and alcohol distilled from wheat. Those exemptions explain why the ingredient's identity and form matter alongside the cereal from which it came.

Allergen declaration reaches inside a flavour

The reach into a flavouring is explicit. Standard 1.2.3, s 1.2.3-4(5)(b), covers "a substance used as a food additive, or an ingredient or component of such a substance". A cereal ingredient used within a flavouring therefore belongs in the declaration assessment. The flavour name alone does not describe those components. Our Australian flavour regulations reference sets out the declaration framework, while the FSANZ flavour labelling article explains how the wider ingredient statement treats flavourings and their named exceptions.

Composition information for the finished recipe

For a product developer, the useful specification is one that connects the flavour to the recipe. Its cereal ingredients, carrier composition and allergen declaration establish what the flavour adds to the finished food. Where a wheat glucose syrup exemption is relevant, the supporting information needs to identify the syrup covered by it. A general statement about the flavour cannot resolve an unidentified carrier. Combining the flavour specification with the finished recipe gives the assessment a defined food, a defined claim and the ingredient information to which the cited conditions apply.

Gluten claims and other pack wording

A pack may also carry natural or clean-label wording. Those descriptions raise separate labelling questions, covered in our flavour labelling guide and clean-label guide. They do not supply the cereal composition information needed for a gluten claim. The same flavour can be considered for several pack statements, so the brief should include the actual wording proposed for each. This lets the supplier address the ingredient information relevant to each statement and lets the developer assess the gluten claim against the food that will carry it.

Bring the claim into the flavour brief

VKA Australia provides flavour specifications, allergen declarations and documentation aligned to the Australia New Zealand Food Standards Code. Bring the proposed pack wording, the finished recipe and any carrier questions to the Southport team. These details give the flavour brief a clear claim target and identify the composition information needed for the assessment. For offshore supply, our guide to importing flavourings into Australia explains the separate imported-food rules, including how ingredients and concentrates can fall within the risk food list.