The outcome between VITAL 3.0 and VITAL 4.0 indicates that the packaging no longer requires a PAL. What should I do?
Since the risk profile of your product remains unchanged, front of pack communications is not necessary.
Front of pack communications should only be used for:
- Formulation changes that affect an intentionally present allergen, where different labels with different information and therefore different risk might be on the market at the same time.
- If a new PAL is required on an existing product (because the risk assessment indicates that the outcome is now AL2), the consumer should be notified as there may be products with different risk profiles on the market at the same time.
Suggested actions to take:
- Ensure your labelling outcome is consistent across all pack sizes.
- Ensure all digital and printed resources, including your website and National Product Catalogue (NPC), reflect the new label information.
- Inform your Customer Service team about the packaging change and its reason.
- Prepare a FAQ for consumer inquiries: The Allergen Bureau VITAL 4.0 summary and FAQ can provide additional insights (see Section 2: “What does this change mean for consumers” as well as “VITAL and the Consumer”).
- Notify Allergy & Anaphylaxis Australia or Allergy New Zealand, explaining that the labelling outcome changed under VITAL 4.0, although the risk profile remains unchanged.
