Food labelling

Are you uncertain of what needs to be on your food label? You have probably spent some time working on the aesthetics and marketability of your label, but there are also specific legal labelling and information requirements that you must work into your label design. Read on to find out more…

What legal entities regulate food labelling?

Food labelling is regulated by the Food Standards Code, set by Food Standards Australia and New Zealand (FSZNA). In addition to the Code, the Competition and Consumer Act 2010 prohibits false, misleading or deceptive representations on labels. Country of Origin Labelling laws also apply and become mandatory for packaged and some unpackaged food from 1 July 2018.

What information must my label include?

Accurate weight and measures information;
Accurate name or description of the packaged food. Ensure you particularise between whether something is a flavour or actually an ingredient in the food, for example the difference between lemon kombucha and lemon flavoured kombucha;
A statement of ingredients is required on label for retail food only (food provided for catering may put statement of ingredients in a document rather than a label).
Differentiate as to the origin of your food – grown, produced, made or packed, and if partially Australian origin this must be worked out as a percentage.

Perfect your statement of ingredients:

List ingredients in descending order of ingoing weight – except where you are using a dehydrated food. In that case you may use the weight of the food before it was dehydrated;
If your food is to be reconstituted as per instructions, then you may list ingredients in descending order by weight when reconstituted – but you must make it clear on the statement that you are listing ingredients when reconstituted;
When there is a substance such as water that is added to food but removed during manufacture then state that ingredient reflecting the final amount remaining in finished product rather than ingoing amount (if there is none left at the end then you do not need to declare it at all);
Water itself does not need to be declared when it makes up less than 5% of the food;
Compound ingredients (a food made from other ingredients) such as dark chocolate may be declared using the title dark chocolate followed by what is in the dark chocolate, or just in descending order as individual ingredients of final food;
Any genetically modified (GM) ingredients, and irradiated food (food exposed to radiation) must be declared;
You can provide for using alternate ingredients if that is what you are doing and going to do;
Food additives are treated the same way as other ingredients – list according to ingoing weight – but they must be named by class (as determined by the Code) with the additive code number in brackets;

The label must be legible and prominent and in English:

You can place your statement of ingredients anywhere you like on your label; an ingredients heading may be used to make it more defined.
In warning statements writing must be at least 3 mm high, except on small packages (surface area less than 100cm squared) where the type must be at least 1.5 mm high.

Generic names:

Generic names are permitted in the statement of ingredients for the following foods: cereals, cheese, cocoa butter, crystallised fruit, fats or oils, fish, fruit, gum base, herbs, meat, milk protein, milk solids, nuts, poultry meat, spices, starch, sugar, vegetables. But there are special conditions around this…

If a particular food is the characterising ingredient on the label, or the name of the food, then it must be on the list and not be lumped in as a generic food. For example, if you are selling blueberry and sprouted almond pudding, blueberries and sprouted almonds must be named with specific percentages (not just as ‘fruit’ or ‘berries’ or ‘nuts’ or ‘almonds’.)

There are some instances when simply naming the food on the label is enough and no ingredient list is necessary:

This exception applies to 100% orange juice, 100% sugar and so on.
If there are any preservatives, or additives, in the food – then you must create your list of ingredients accordingly.

It is your responsibility to ensure your food label is meeting Australian standards – if you want to make sure your label is up to scratch we are happy to help.

This is general advice only. Liability limited by a scheme approved under Professional Standards Legislation. 

Published Apr 19, 2018

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