Grass fed beef – what needs to go on your label

If you are selling grass fed beef or an associated product and want to label it as such, you will need to be aware of your labelling obligations under the Australian Consumer Law (ACL), and the required standards as set out in the Australia New Zealand Food Standards Code (“the Code”).

Firstly – what does the ACL require?

The ACL requires that if you put “grass fed beef” on your label, you must be able to substantiate it:

  • Claiming the beef is grass-fed must not be a false, misleading or deceptive representation of the quality of the beef;
  • Claims that are not misleading and that can be substantiated may be put on your label – in relation to grass-fed beef you may label your product offers a moral or social benefit; is environmentally sustainable; or is of a particular level of quality.

If your label is misleading as to the nature of the beef, the manufacturing process, its characteristics, the quality or suitability for certain consumers you could be penalised with a hefty fine (and also receive some bad press).

  • You may substantiate the claims you make on your label by backing up the claims with facts and documented evidence where appropriate;
  • Be prepared to substantiate that your beef is in fact grass-fed in writing from the source; and
  • Have a written guarantee from your supplier that the cattle used for your product spend no more than a certain percentage of the time in a feedlot prior to being sold to a processor (you may be specific on your label by saying the product is a certain percentage – either 100% or less – grass-fed.)

Secondly – how do I ensure my label also complies with “the Code”?

When naming or describing the beef used in your product, the labelling must accurately describe the true nature of the beef. You need to look at your suppliers and what evidence they hold that their cattle that is being used in your product is in fact grass-fed.

  • If you are both the supplier and the manufacturer, then you must hold a formal certification that beef is grass-fed and a formal specification as to how long the cattle is grass-fed for;
  • If you buy your grass-fed beef from a supplier, ensure they hold and pass to you both certification that the beef is grass-fed and a written guarantee as to how long their cattle is grass-fed for; and
  • Make sure you/your supplier holds accreditation with Ausmeat A+, BRC Global Standards – Food & Codex Alimentarius, ARA, and HACCP.

According to the Cattle Council of Australia, grass fed cattle producers wishing to use ‘pasture fed’ as a marketing claim, cattle need to have:

  • Never been fed separated grain or grain by-products and have continuous access to graze pasture with the diet;
  • The cattle’s diet must be derived solely from forage consisting of grass (annual and perennial), forbs such as legumes and Brassica, browse, or cereal grain crops in the vegetative (pre-grain) state for its lifetime with the exception of the milk consumed prior to weaning.

Labelling standards in Australia are strict, and unless you are satisfied that labelling your beef as “grass-fed” is accurate, and you can substantiate that, then it is best to be cautious. If you would like further advice about labelling, or whether your supplier contracts can be amended to ensure and guarantee quality of product, give Sinclair + May a call.

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

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