With Australia witnessing an upsurge in the number of food recalls, it is crucial for food businesses to adhere to the standard labelling requirements outlined in the Food Standards Australia New Zealand (FSANZ) code.
The purpose of food labels is to not only help consumers make informed choices with the help of the information provided but also aid food organisations in complying with food standards and regulations.
Furthermore, food labels also help to protect public health and safety by displaying information such as use by dates, ingredients, certain allergens, instructions for storage and preparation, and advisory and warning statements.
This blog is a standard guide outlining the requirements set by FSANZ for what information must be on food labels.
Food Labelling Requirements
Below are the essential food labelling requirements food businesses should adhere to as per FSANZ:
1) Allergen Labelling
Allergen labelling enlists details of all allergens present in the food to alarm people with allergies.
Some foods and components can induce allergic reactions like anaphylaxis, immunological reactions like Coeliac disease, and other negative health effects including asthma.
New plain English allergen labelling regulations for certain goods known to be common allergens were adopted in February 2021. Food allergy information on food labels will be clearer and simpler to access as a result of these improvements.
Furthermore, food companies must include all allergen information even in cases where the allergen is present in small proportion or is not harmful,
2) Country of Origin Labelling requirements
i) Country of Origin Labelling Requirements in Australia
On July 1, 2016, the Australian Government implemented a country-of-origin food labelling system under Australian Consumer Law. The Country of Origin Food Labelling Information Standard 2016, enacted under the Competition and Consumer Act 2010, specifies the rules for food country of origin labelling.
These restrictions came into effect on July 1, 2018. At the same time, the Food Standards Code was revised to remove the necessity for country of origin labelling.
ii) Country of Origin Labelling Requirements in New Zealand
On February 12, 2022, New Zealand implemented nation-of-origin labelling requirements for certain items. The website of the Ministry of Business, Innovation, and Employment contains information regarding these standards.
Grape wine must be marked with the country or countries of origin in New Zealand. The Ministry of Primary Industries website has further information about grape wine labelling.
All food must be labelled with the contact information of the food provider in New Zealand or Australia so that consumers may contact the source and obtain more information about the product.
3) Energy Labelling of Alcoholic Beverages
FSANZ is exploring energy labelling of alcoholic beverages to address consumer value, understanding, and behaviour issues.
An evidence assessment in June 2021 found that labels on packaged alcoholic beverages lack information about energy content, which is not provided in most other foods and beverages.
Furthermore, a preliminary analysis in December 2021 identified:
- On-label energy content information is the best option.
- Shortened nutrition information panel (NIP) as the most appropriate format.
- Mandatory approach for greater consumer coverage and consistency.
4) Fish Names
The Food Standards Code does not define fish names.
The seafood sector has collaborated with Standards Australia to create the Australian Fish Names Standard, which gives guidelines on standard fish names that should be used in Australia.
5) Food Additive Labelling
Food additives in packaged food must be listed on the label by their class name, followed by their name or number. Enzymes and flavourings can be labelled by their class name, while food additive numbers can be used as an alternative to lengthy and confusing names.
The class name describes the purpose of the food additive.
Food additive numbers (based on an internationally agreed numbering system) can be used as an alternative to long and complicated names.
Some products, such as unpackaged or small packaging, are exempt from ingredient labelling. Compound ingredients, which are made up of two or more substances, are occasionally utilised. If the compound component constitutes less than 5% of the finished food, its constituents (including additions) are not needed. However, if additives have a function, they must be stated in the ingredient list.
ii) Food Additives and Allergies
Allergens must be declared in food, including additives, for safety.
6) Genetically Modified (GM) Food Labelling
GM food labelling enables customers to identify a GM food or a product containing GM components.
It is mandatory for businesses to test GM foods and ingredients for safety and authorisation before they are sold in Australia and New Zealand.
GM foods and ingredients (including food additives and processing aids) containing new DNA or protein must be marked with the phrase “genetically modified.” This labelling statement is also necessary for GM foods that differ in some way (e.g., nutritional profile) from a non-GM equivalent (e.g., soybeans with higher oleic acid content).
i) Locating ‘GM’ on Food Label
The phrase ‘genetically modified’ will appear on the label either next to the name of the item (for example, ‘genetically modified soybeans’) or in conjunction with the particular GM component in the ingredient list (for example, ‘soy flour (genetically modified)’. If the item is not packed, the information must be included or displayed with the food.
ii) ‘GM-free’ and ‘Non-GM’ Claims
‘GM-free’ and ‘non-GM’ claims are made voluntarily by food manufacturers and are subject to relevant fair trading laws in Australia and New Zealand which prohibit representations about food that are, or are likely to be, false, misleading or deceptive.
FSANZ is responsible for approving GM foods and ingredients for use in the food supply in Australia and New Zealand. These permissions can be found in Schedule 26 of the Food Standards Code. . Food businesses should provide this information.
iii) Exemptions from GM labelling
GM foods without novel DNA or protein are not labelled due to their comparable composition and features to non-GM foods. These food items are often refined, with the processing, eliminating DNA and protein.
Besides, GM flavours are also excluded from labelling.
Furthermore, labelling is not necessary when 1% of an authorised GM item is accidently combined with a non-GM component.
iv) Novel DNA and Protein
The Food Standards Code defines novel DNA and novel protein as DNA or protein created using gene technology that has a distinct chemical sequence or structure when compared to non-gene-derived competitors.
v) Altered Characteristics
Any genetically modified food that has been altered must be labelled as “genetically modified” under Schedule 26 of the Food Standards Code. This applies to all foods, regardless of the presence of novel DNA or protein. The factors that are taken into consideration when determining whether a food is genetically modified include the extent of the genetic modification, the intended use of the food, and its nutritional qualities as compared to non-GM foods.
FSANZ determines whether a food has altered characteristics or not. It also assesses if any altered feature requires extra labelling. High lysine corn, for example, requires additional labelling to show that it has been genetically engineered to have higher amounts of lysine.
7) Health Star Rating System
The Health Star value (HSR) is a voluntary front-of-pack labelling system that analyses the entire nutritional profile of packaged food and provides it with a star value ranging from 12 to 5. It gives a quick, simple, and consistent approach to evaluating similar packaged meals. The more are the stars, the healthier or better is the choice.
The HSR system was launched in Australia and New Zealand in June 2014, with funding provided by the Australian, state, territory, and New Zealand governments.
8) Nutrition Content Claims and Health Claims
Nutrition content claims and health claims are optional declarations made on food labels and in food advertising by food companies.
The standards for making these claims are outlined in Standard 1.2.7.
i) Nutrition Content Claims
Nutrition content claims are about the content of certain nutrients or substances in a food, such as ‘low in fat‘ or ‘good source of calcium’. These claims need to meet certain criteria.
For example, food with a ‘good source of calcium’ claim needs to contain at least the amount of calcium specified in the Standard.
ii) Health claims
The connection between food and its impact on our health is what health claims are all about. It’s important to note that any health claims made about foods must be backed up by scientific evidence. Additionally, health claims can only be made on foods that meet the Nutrient Profiling Scoring Criterion (NPSC). This means that food items that are high in saturated fat, sugar, or salt are not allowed to have health claims attached to them according to the Standard.
There are 2 types of health claims – general and high-level.
a) General Level Health Claims
General-level health claims concerning a nutrient or ingredient in a food, or the food itself, and its influence on health. For example, ‘calcium for strong bones and teeth’.
These claims are either based on one of the more than 200 pre-approved food-health associations in the Standard, or on a food-health relationship self-substantiated by the food industry following the scientific procedure outlined in the Standard. Self-substantiated general-level health claims must be reported to the FSANZ.
b) High-Level Health Claims
When it comes to health, high-level claims refer to how a nutrient or substance in food can affect serious diseases or biomarkers of serious diseases.
For example, a diet that is high in calcium might lower the risk of osteoporosis in those who are 65 years and older. Another example is that phytosterols could help reduce blood cholesterol levels. However, these claims must be based on food-health relationships that have been pre-approved.
Currently, there are 13 pre-approved food-health relationships for high-level health claims listed in Schedule 4 of the Australia New Zealand Food Standards Code.
Endorsements that make nutrition content or health claims are permissible provided the endorsing entity fulfils the requirements of the Standard.
Individuals in Australia who are concerned about a nutrition content or health claim on a specific food product should contact their state’s or territory’s health agency or department. In New Zealand, complaints concerning nutrition content and health claims should be referred to the Ministry for Primary Industries. Furthermore, fair trading laws in Australia and New Zealand compel labels not to mislead consumers by false, misleading, or deceptive assertions.
9) Ingredient lists and percentage labelling
i) Ingredient lists
In an ingredients list, the ingredients must be stated in decreasing order by ingoing weight, with the first contributing the most and the final contributing the least. The incoming weight of added water must be indicated, with an allowance for water lost during processing. Compound ingredients (two or more components combined) must be stated in the ingredient list unless used in proportions less than 5% of the finished dish. Regardless of the dosage, if an ingredient is a recognised allergy, it must be stated.
ii) Percentage labelling
Labels on packaged goods indicate the percentage of key ingredients or components present to help compare similar products.
For example: Strawberry yoghurt’s distinguishing component would be strawberries, and the label would state, for example, 9% strawberries.
However, some foods may not have any distinguishing ingredients or components like white bread or cheese may not have any distinguishing ingredients or components.
10) Labelling for Religious, Animal Welfare, Environmental, and Consumer Value Issues
Some food labels include information that relates to the personal values/ethics of consumers, or about the environment and animals, such as:
- Religious grounds (for example, ‘halal’ or ‘kosher’)
- Environmental issues (for example, carbon footprint labelling and palm oil labelling in connection to rainforest devastation).
- Animal welfare concerns (e.g. ‘RSPCA approved’, ‘dolphin friendly’)
- Human rights issues (e.g. fair trade, child labour).
This type of labelling is not required by the Food Standards Code. This is because the Code’s rules are primarily intended to safeguard public health and safety (for example, a norm requiring required notifications of food allergies).
Food providers can voluntarily include this type of information on their product labels as long as it is not incorrect, deceitful, or deceptive in accordance with consumer and fair trading rules.
If the information that people want is not included on a label, they can contact the source directly. According to the Food Standards Code, food must be tagged with the name and address of the provider, and many suppliers include a free call telephone number on the label.
Alternatively, food sellers can provide information too.
The governments of Australia and New Zealand have recently reinforced their support for the current non-regulatory approach to this type of labelling.
11) Labelling of Alcoholic Beverages
The Food Standards Code has particular information requirements for alcoholic beverage labelling. These may differ based on the amount of alcohol present in the beverage. This is expressed in terms of alcohol by volume (ABV).
i) Statement of Alcohol Content
According to Standard 2.7.1, any drink with at least 0.5% ABV must display its alcohol content on the label.
In the case of alcoholic beverages that have over 1.15% ABV, the label is required to indicate the alcohol concentration as a percentage of ABV or mL/100 ml.
For example, the label might read that the beverage contains 5% ABV or the alcohol content is 5ml/100ml of the beverage.
The alcohol level of alcoholic beverages having 1.15% ABV or less must be indicated in terms of the effect ‘contains not more than X% alcohol by volume’.
The label may state, for example, that the beverage contains no more than 1.0% alcohol by volume.
ii) Standard Drinks
All beverages with an ABV of more than 0.5% must include a label specifying the number of standard drinks (Standard 2.7.1).
Alcohol content and standards statement Drinks must meet the Code’s general readability criteria (Standard 1.2.1).
iii) Pregnancy Warning Labels
Section 1.1.2, 1.2.1, and 2.7.1 of the FSANZ standard require a pregnancy warning label in the form of a pictogram or a pictogram and wording for alcoholic products with an ABV of more than 1.15%.
Pregnancy warning labels must also have certain form, readability, and design aspects (Standard 2.71).
Australian food businesses have three years from July 31, 2020, to comply with these rules,
iv) Nutrition Information and Claims
A Nutrition Information Panel (NIP) for alcoholic beverages is not necessary unless a claim requiring nutrition information is made. Alcoholic drinks may incorporate an NIP voluntarily. The presence of an NIP does not imply a nutrition content claim.
All alcoholic beverages that contain more than 1.15% ABV (Alcohol by Volume):
- can only make claims concerning energy content, carbohydrate content (for example, ‘reduced carbohydrate’), or gluten content.
- are prohibited from making health claims.
- cannot be marketed as a low-alcohol beverage.
v) Current Proposals to Change the Code
FSANZ is currently considering two proposals regarding labelling requirements for alcoholic beverages:
- P1049 – Carbohydrate and sugar claims on alcoholic beverages.
- P1059 – Energy labelling on alcoholic beverages
vi) Energy Labelling of alcoholic beverages
FSANZ is actively investigating regulatory and non-regulatory possibilities for alcoholic beverage energy labelling.
In 2021, FSANZ conducted a survey to determine how much it costs the alcohol industry to modify their labels.
12) Nutrition Information Panels
Nutrition information panels (NIP) on product labels contain information on the average amount of energy in kilojoules or kilocalories, as well as the following nutrients:
- Saturated fat
- Sodium – A Component of Salt.
If a claim is made, an NIP will provide information regarding additional nutrients. For example, if a food is marketed as a “good source of fibre,” the quantity of dietary fibre in the item must be included in the NIP. The NIP must be supplied in a standard format that includes the average quantity per serving and per 100 g, or 100 mL if it is a liquid.
There are certain foods that don’t require an NIP, which are listed below:
- Food products are sold without any packaging.
- Food prepared and packed at the point of sale, such as bakery bread.
- Spices, herbs, bottled water, tea, and coffee, have little nutritional benefit.
However, if a nutrition-related claim is made (for example, ‘excellent source of calcium’ or ‘reduced fat’), an NIP must be supplied.
13) Sugar Labelling
According to the Australia New Zealand Food Standards Code (the Code), food labels must mention the total quantity of sugars in the nutrition information panel (NIP).
Total sugars comprise sugar that is naturally present in food as well as sugar that has been added as an ingredient.
The Code sets regulations for foods that make claims about sugar.
For example, foods claiming to be ‘low sugar’, cannot include more than 2.5 g of sugar per 100 mL of liquid or 5g per 100g of solid.
There are further restrictions for statements like “reduced sugar,” “x% sugar-free,” “no added sugar,” and “unsweetened.”
Current Work on Sugar Labelling
In April 2022, FSANZ began work on proposal P1058 – Nutrition labelling concerning added sugars – to propose the inclusion of added sugars information in the NIP. This suggestion follows FSANZ’s study of nutrition labelling for added sugars, which was completed in 2021. Read the report on the Review of Nutrition Labelling for Added Sugars.
14) Truth in Labelling, Weights and measures and legibility
i) Truth in Labelling
In Australia and New Zealand, fair trading laws and food laws mandate that labels must not deceive consumers with false or misleading information. The Australian Consumer Law (ACL) as outlined in the Competition and Consumer Act 2010, as well as state and territory Fair Trading Acts and Food Acts, are among the legislations in Australia. Meanwhile, the Food Act 2014 and Fair Trading Act 1986 are the laws in New Zealand that regulate this matter.
The Australian Competition and Consumer Commission (ACCC) is in charge of enforcing the Competition and Consumer Act 2010.
However, the Commerce Commission is in charge of implementing the Fair Trading Act 1986 in New Zealand.
ii) Name or Food Description
Foods must be marked with an appropriate name or description that reflects their genuine nature.
For example, ‘Strawberry Yoghurt’ must contain strawberries. If it contains strawberry flavouring rather than actual strawberries, the label should read “strawberry-flavoured yoghurt.”
iii) Weights and Measures
Suppliers must label food goods with precise weights and measurements (the amount of food in a package). The Australian National Measurement Institute and Trading Standards New Zealand oversee weights and measures declarations.
iv) Legibility Requirements
The Food Standards Code mandates that labels be readable and conspicuous, distinguishable from the backdrop, and written in English. The type in warning statements must be at least 3 mm high, except for compact products, when it must be at least 1.5 mm high.
15) Use-by and Best-before dates
The two forms of date marking are use-by dates and best-before dates. Most foods have a best-before date. It is the responsibility of the food provider to mark food with a use-by or best-before date.
If certain storage conditions are necessary for a product to keep until its best-before or use-by date, producers must express this information on the label, for example, ‘This yoghurt should be kept refrigerated’.
Individuals should also follow any usage or cooking instructions that the provider has included on the label.
16) Warning and advisory statements
Advisory statements must be given for foods or components that may pose health concerns to specific consumers. These include aspartame, guarana or guarana extracts, plant sterols, and caffeine. Labels should state if the product is part of a healthy diet, acceptable for children under the age of five, pregnant or breastfeeding women, and does not give extra advantages when ingested in excess of three grams per day.
When individuals are unaware of a significant health danger posed by a product or an ingredient, a warning statement must be included. Food containing the bee product royal jelly, for example, is obliged to include a warning statement that states: ‘This product contains royal jelly which has been reported to cause severe allergic reactions and, in rare cases, fatalities, especially in asthma and allergy sufferers.’
So this was our exclusive guide outlining FSANZ mandatory food labelling requirements.
Our experienced food safety consultants can further help food businesses understand and implement these food labelling requirements customized as per an organisation’s requirements.
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