FSANZ A1342: Beta-casein protein preparation from GM Komagataella phaffii

24 August 2026

AFGC supports FSANZ’s assessment that BCPP1 may be permitted as a genetically modified food, subject to appropriate conditions of use and specifications. We also support FSANZ’s proposal to require declaration of “milk” when BCPP1 is present in food, given the conclusion that the beta-casein component presents the same allergenicity risk as bovine milk proteins for consumers with milk allergy.

The existing allergen labelling framework, including mandatory declaration of milk and the Plain English Allergen Labelling requirements, provides a clear and effective mechanism for communicating this risk to consumers. AFGC supports maintaining the existing ingredient-naming requirements in the Code, which already provide an appropriate framework for describing the true nature of BCPP1, including its fermentationderived or non-animal origin.

We consider that the existing labelling framework is largely fit for purpose and that any regulatory response should be limited to addressing clearly identified allergen-related risks. AFGC does not support in principle the proposed mandatory front-of-pack advisory statement that a product is “not suitable for persons with milk allergy”.

While we recognise that consumer understanding of fermentation-derived allergenic proteins is an emerging issue, an allergen-specific front-of-pack statement may create unintended consequences by directing attention to a single allergen and reducing the likelihood that consumers check the full ingredient list, allergen declaration and precautionary allergen labelling.

AFGC supports consumers to refer to the established allergen information without prioritising one allergen over another providing a more consistent approach for future precision fermentation applications.