Continued correspondence: I write again to Haigh's, or: I want my dark chocolate frogs!

Thanks Lisa for the suggestion! Still confused by Haigh's reply to my letter, I emailed them again:

Hi Olivia,

Thanks for your response and sorry for the delay. I have been unable to find any recent changes to food labelling standards and would very much appreciate it if you could direct me to the guidelines issued to you by the government. Perhaps this is a Commonwealth Government guideline?

As I understand it, the principal State Act that controls the sale of food in Victoria is the Food Act 1984. The Act is also the means through which the Australia New Zealand Food Standards Code is applied as the law in Victoria, but the Code's website contains the following statement in relation to 'may contain traces of':  

"You’ll notice some labels say ‘may contain’ certain allergens, for example ‘may contain nuts. This is put on by the manufacturer who may be concerned that, while nuts aren’t added to the food, traces may be present due, for example, the product having been made on the same equipment as products containing nuts. Allergy consumer support groups are working with the food industry to make these labels more helpful to allergy sufferers."

I am also still confused because Standard 1.2.4 of the Code: "Labelling of Ingredients" provides the definition used in the Code and therefore also in the Act. It is: "ingredient means any substance, including a food additive, used in the preparation, manufacture or handling of a food". From your email it appears that Haigh's does not use or add milk in the preparation of dark chocolate.

I would really appreciate it if you could tell me what the trace levels of milk are when they must qualify as an ingredient. As I'm sure Haigh's will appreciate, this is an issue of interest and importance to all dairy-free people so I would like to be able to fully understand the reasoning behind Haigh's decision.

Thank you once again for your assistance and for your previous reply,

Regards,
Rachel Templeman