New Country of Origin labelling for food coming to a store near you…
In a post last year we discussed in detail the Government’s proposed reforms to the Country of Origin Labelling (COOL) requirements for food. On 31 March 2016, the Consumer Affairs Ministers agreed to the final form of those reforms.
When does it commence?
The new labelling requirements will apply from 1 July 2016, with a two-year transition period within which to update food product labels. However, food that is labelled and already in stock or trade before 1 July 2018 may still be sold until the end of its stated shelf life.
What has changed from the Government’s Proposed Reforms?
Government research has shown that consumer concern about country of origin varies across food categories. As a result, we will now have different labelling requirements depending on whether the food is classified as priority or non-priority (i.e. foods for which Australian consumers are least concerned about origin information).
The new country of origin labelling requirements are mandatory for priority foods and optional for non-priority foods.
Priority foods fall into three categories:
- packaged food (other than fresh fruit and vegetables in transparent packages)
- fresh fruit and vegetables in transparent packaging and
- unpackaged meat, fish, fruit and vegetables.
There are seven categories of non-priority foods:
- biscuits and snack food
- bottled water
- soft drinks and sports drinks
- tea and coffee and
- alcoholic beverages.
How difficult will the new labelling be for businesses?
In a word VERY! And confusing too.
The predominant change is the introduction of the bar chart and text statement to show the proportion of Australian ingredients in the product. When you look at the Standard there are a bewildering multiplicity of issues to be determined when working out what labelling is required. This includes choosing the correct bar chart for each product from 13 different options.
The label for Priority foods ‘grown’, ‘produced’ or ‘made’ in Australia must have:
- the kangaroo logo
- a bar chart (from those shown below) showing the minimum percentage (by ingoing weight) of the food’s Australian content
- an explanatory text that states the food was “grown”, “produced” or “made” in Australia and the proportion of ingredients of Australian origin.
The labelling requirements for priority foods ‘packed’ in Australia will vary depending on whether the ingredients come from one or more countries. The labelling cannot include the kangaroo logo, as the food is not of Australian origin.
Labels for food products that have varying percentages of Australian sourced ingredients during the course of the year must also contain explanatory text stating:
- the average Australian content of ingredients, by ingoing weight. The average can be calculated over a continuous one, two or three year period and the labelling must be reviewed and updated at least every two years; and
- where consumers can find more information about the proportion of Australian ingredients in the food (by including a barcode which links to the details, or a website or telephone number to contact.)
All imported priority foods produced, made or grown in an overseas country, must have a country of origin statement in a clearly defined box.
The Standard does not impose country of origin labelling requirements for foods intended purely for export. However, if you intend using the kangaroo logo on any exported food, you must obtain a licence from the Australian Made Campaign Limited.
So what does this mean for your business?
Country of Origin labelling has always been a high priority area for enforcement action by the Australian Competition and Consumer Commission (ACCC). The ACCC will certainly be keeping a very close eye on the implementation of the new labelling requirements.
Given the level of change involved, we strongly recommend that you start reviewing your labelling as soon as possible. Remember there are 13 options for the bar chart alone! Taking action now will make it easier to tie in the necessary changes with the timing for your normal print runs.
Call us to help steer you through the maze.
Image sourced from mucca.com