Free R146 Allergen Matrix Template (Excel)

What is in it

An Excel allergen matrix built on the common allergen list in regulation 1 of R146, the labelling regulations in force in South Africa.

  • One row per product or recipe, with a code or version so you know which recipe was checked.
  • A column for each R146 common allergen: egg, cow’s milk, crustaceans and molluscs, fish, peanuts, soybeans, tree nuts and significant cereals. Goat’s milk has its own column, because regulation 44(2) requires it to be labelled the same way.
  • A drop-down in every allergen cell: Contains, May contain or Free from, colour-coded as you pick.
  • Columns for the cross-contact risk, a draft Contains line built by formula, who checked the label and when.
  • A How to use sheet that explains regulations 42 to 46 in plain language, including the R146 lists of tree nuts and significant cereals.

Who it is for

Food manufacturers, bakeries, caterers and kitchens that label food or answer customer allergen questions, and technical staff who sign off labels.

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Questions about the matrix

Which allergens does R146 list? Egg, cow’s milk, crustaceans and molluscs, fish, peanuts, soybeans, tree nuts and any significant cereals, plus ingredients derived from them that keep their allergenicity in the final product.

Can I print “free from” on my label if the matrix says Free from? Not on that basis alone. Regulation 46(2)(b) of R146 allows a free from claim only if the food has been tested to confirm the allergen is absent. In the matrix, Free from is a working status, not a label claim.

Should I use the R3337 draft instead? No. R3337 is still a draft and not in force, so the matrix follows R146 as amended. We will update it if the law changes.

Allergen control is a hazard control. Our HACCP for Supervisors and HACCP Teams course shows how to build it into your food safety plan.

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