Understanding The Basics of Country of Origin Labelling in Australia

Country of Origin Labelling

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In the food industry, understanding and complying with labelling rules is paramount for food manufacturers and packers. These regulations, designed to promote transparency and consumer awareness, require clear and precise information to be displayed on food labels.

One such regulation is the Country of Origin labelling (CoOL) scheme, which requires most foods sold in Australia to display a label that discloses the country or countries where a product was grown, produced, or packaged. Navigating these rules can seem daunting, but it is entirely manageable with the proper knowledge and understanding.

This article aims to shed light on Country of Origin labelling regulations, helping you, as a food producer and packer, to ensure compliance and build trust with your consumers.

What is Country of Origin Labelling?

What do you mean by country of origin labelling

Country of Origin labelling (CoOL) is a federal consumer labelling law that seeks to inform consumers about the country of origin of food products they purchase. The law requires most foods sold in Australia to display a label that discloses the country or countries where a product was grown, produced, packaged or imported from.

On 1st July 2016, Australia implemented a new country of origin food labelling system. This new system is designed to provide more clarity and transparency to help consumers easily and quickly identify the origin of their food. Under the new Standard, most foods produced, grown or made in Australia need to display a label.

  • Kangaroo in a triangle – identifies the food’s Australian origin
  • Bar chart –  showing the minimum proportion of Australian ingredients by ingoing weight, shown as a percentage amount
  • Text statement – indicating that the food was grown, produced or made in Australia

 

Country of Origin labelling is enforced by the Australian Competition and Consumer Commission (ACCC) and other Australian Consumer Law regulators like Australian Consumer Law (ACL). Non-compliance with CoOL will result in civil penalties, including fines and other legal action.

In addition to indicating the country of origin, it is equally important to adhere to other food labelling laws, such as disclosing food allergens on the label. However, navigating through the complex world of allergen labelling compliance is overwhelming.

To assist with navigating through these complexities, we have provided an article focused on understanding allergen labelling compliance. This resource offers in-depth information, providing readers with a better understanding of how to meet allergen declaration requirements and avoid any possible issues.

When is Origin Labelling on Food Required?

Under the new scheme, the country of origin labelling is mandatory on all food products that are sold (including those offered or displayed for sale) in Australia. It does not apply to food sold outside of Australia.

The labelling requirements of country of origin labels on food products will vary depending on.

  • The category of food
  • Whether it was grown, produced, made or packed in Australia
  • Whether it was grown, produced, made or packed in another country
  • Is offered for sale loose or in a package
  • Whether the food is a ‘priority’ or ‘non-priority’ food

When is Origin Labelling on Food Not Required?

List of eight food where country of origin labelling will not apply

As per the Standard, the country of origin labelling will not apply to food, that is.

  • Otherwise unpacked (e.g. unpacked sandwich, cheese or pastries)
  • Solely intended for export to overseas market
  • Sold in restaurants, canteens, schools, caterers, self-catering institutions, prisons, hospitals, medical institutions
  • Sold at fund-raising events (e.g. school fetes)
  • Made and packaged on the same premises where it is sold (e.g. cafes and bakeries)
  • Delivered, packaged and ready for consumption, as ordered by the consumer (e.g. home food delivery of pizza and burger)
  • For special medical purposes
  • Not for human consumption (e.g. pet food)

 

Although the Country of Origin Food labelling standard does not cover the above-mentioned foods, businesses can still declare the product’s origin voluntarily. This means that the businesses that sell food items exempt from the Standard can make origin claims as long as they aren’t false or deceptive.

However, if companies choose to voluntarily mention the origin country, they must comply with the Standard rules regarding the use of the kangaroo logo or bar chart graphics.

Types of Origin Claims - Key Definitions

Four types of origin claims

Origin Claims are assertions made by manufacturers about the origin of their products. The type of Origin Claim for food depends on where it was grown, produced, made, or packed.

Food businesses need to understand the specific terminology to make accurate claims about their products. This understanding will help them to provide detailed and factual information about the origin of their products, thereby ensuring higher semantic richness and clarity in their communication.

Let’s take a look at the definitions of common origin claims used in the Australian Country of Origin Food Labelling Standard.

"Grown In"

A ‘grown in’ claim refers to the food or ingredients being grown in a specific country. This claim is mostly used for fresh food like fruits, vegetables, whole fish, eggs, etc.

According to the information standard, a ‘grown-in’ claim will be used.

  1. For a food or ingredient if it was.
    1. Materially increased in size or materially altered in substance in that country by natural development
    2. Germinated or otherwise arose in, or issued in that country
    3. Harvested, extracted or otherwise derived from an organism that has been materially increased in size or materially altered in substance in that country by natural development
  2. For food with more than one ingredient, if.
    1. Each of its significant ingredients was grown in that country
    2. All, or virtually all, of the processing occurred in that country

"Product Of" or "Produced In"

A ‘product of’ or “produced in” claim is used when a food or ingredient is processed in a particular country, from ingredients grown in the same country. This claim is mostly used for processed foods like sauces, jams, canned vegetables, etc.

For example, if an apple pie contains apples grown in Australia and pastry and filling made in Australia, the claim will be “Product of Australia”.

According to the information standard, a ‘product of’ or ‘produced in’ claim will be used if.

  1. Each of its significant ingredients was grown or otherwise wholly obtained in that country
  2. All, or virtually all, of the processing occurred in that country

 

Please note that in Australia, the food packaging can only display one of the following: ‘Grown in Australia’, ‘Product of Australia’ or ‘Produced in Australia’ on the label. A combination of claims is not permitted.

"Made In"

A ‘made in’ claim is used when a food or ingredient underwent its last substantial transformation in a particular country, from ingredients that may have been grown, produced or made in the same or another country. This origin claim focuses on the production of food rather than its content.

For example, if peanut butter is made from peanuts grown in China and oil produced in Australia with further and final processing taking place in Australia, the claim will be “Made in Australia”.

According to the information standard, a ‘made in’ claim can be used if the food.

  1. Was grown or produced in that country
  2. Is, as a result of one or more processes in that country, fundamentally different in identity, nature or essential character from all of its ingredients or components that were imported into that country

 

Basic processing techniques like slicing, canning, freezing, coating, crumbing, or repacking of food products are not considered a substantial transformation. As a result, these processing methods will not make a food product eligible for a ‘made in’ claim.

The table below summarises the ACCC’s view on when processing would or would not result in a ‘fundamentally different’ product. 

Processing
Substantially transformed?
Roasting, grinding and blending imported whole spices to make a curry paste
Yes
Blending imported dried herbs to make herbal tea
No
Roasting an imported nut
No
Roasting a green coffee bean to make coffee for drinking
Yes
Chopping up imported fruit to make a fruit salad
No
Chopping up imported apples and combining it with other ingredients to make an apple pie
Yes
Slicing/dicing/grating imported fruits and vegetables, meats or cheeses
No
Mixing imported meat with sauces, spices and vegetables to make a ready-to-bake meatloaf
Yes
Adding a marinade to imported chicken meat
No
Forming imported mince into patties
No
Curing and drying imported pork to make bacon
Yes
Smoking imported bacon to add flavour
No
Mixing imported ingredients together and using the mixture to bake a cake
Yes
Dry blending of imported rice and imported herbs to make a spiced rice mix
No
Adding a chocolate coating to an imported biscuit
No
Baking a frozen raw imported pie
Yes
Browning or finishing off par-baked imported bread
No
Juicing imported fresh fruit and vegetables to make juice
Yes
Reconstituting an imported fruit liquid concentrate to make a juice
No
Mixing imported prawns and squid, seasoning and processing them to make a mixed seafood snack
Yes
Crumbing an imported prawn
No
Cooking imported dried pasta, rice or legumes
Yes

"Packed In"

A ‘packed in’ claim is used when food or ingredients are grown, produced or made in two or more countries and are combined for packaging without any substantial transformation. This claim is only used when a food cannot have any ‘grown in’, ‘produced in’ or ‘made in’ origin claims on the label.

For example, if a processed fruit salad containing apples grown in New Zealand, mangos grown in India, strawberries grown in China and canned peaches from the United States are merely combined for packaging in Australia without further processing, the claim will be “Packed In Australia”.

Type and Format of Country of Origin Labelling Mark

The Australian food labelling standard has provided three generic types of country of origin labels for food, each with its own mandatory requirements on usage. These three types of labels are.

  • Three Component Standard Mark
  • Two Component Standard Mark
  • Country of Origin Statement

Three Component Standard Mark

Detailed three component standard mark

The three-component standard mark is a graphic and text-based label that includes three components.

  1. Logo – A kangaroo inside a triangle-shaped symbol. Indicates that the product was grown, produced or made in Australia
  2. Bar chart – A single rectangular-shaped horizontal bar chart. Provides visual indication of the percentage of Australian content
  3. Explanatory text – A text statement. States if the food was grown, produced or made in Australia, along with the percentage of Australian ingredients used.

 

All three components are present and clearly defined in a vertical arrangement inside a box with a border. The kangaroo logo must be the first element in the mark, followed by a bar chart and explanatory text.

Two Component Standard Mark

Two component standard mark

The two-component standard mark is a simplified graphic and text-based label that includes two components – Bar chart and Explanatory text.

Country of Origin Statement

Country of Origin Statement

The Country of Origin statement is a text-only label which has a text statement indicating the country of origin information about the food. It has “Made in” text followed by the country name.

The Country of Origin statement should be clearly defined inside a box. However, if the food is unpackaged, then the statement can be mentioned without a box.

How to Calculate Australian Content in Food?

By law, if a food is grown, produced, made or packed in Australia, its country of origin labelling must (unless stated otherwise) disclose the proportion of Australian content in the product. “Australian content” refers to the ingredients or parts of compound ingredients that are completely grown or produced in Australia.

The bar chart shown on a food origin label indicates the percentage of Australian content in that product.

The first step in calculating the percentage of Australian content in food is to break down the food into its individual ingredients or components and determine the weight of each one. This is done according to the ingoing weight of the ingredients, which means that the weight is based on the product’s recipe rather than the final weight of the ingredients after cooking, baking, curing or processing.

For example, if a cookie is baked, its Australian content would be calculated based on the weight of its raw ingredients (e.g., flour, sugar, butter) before baking and not its final weight after baking.

Once the individual ingredient or component weights have been determined, the calculation of Australian content will depend on the following.

  • If the ingoing weight of Australian ingredients is consistent
  • If the ingoing weight of Australian ingredients varies
  • Compound ingredients

How to Calculate Australian Content When Ingoing Weight of Australian Ingredients is Consistent?

Three steps to calculate Australian content when ingoing weight of ingredients is consistent

For foods that always contain a consistent ingoing weight of Australian ingredients, businesses must determine the minimum proportion of Australian ingredients in each item. This can be done by calculating the weight of Australian ingredients as a percentage of the total weight of all ingredients.

To calculate the weight of Australian ingredients as a percentage of the total weight of all ingredients, follow these steps.

  1. Calculate the total ingoing weight of ingredients exclusively grown or produced in Australia
  2. Calculate the total ingoing weight of all ingredients
  3. Use the formula – (total ingoing weight of ingredients exclusively grown or produced in Australia / total ingoing weight of all ingredients) * 100

 

The percentage determined in Step 3 is the minimum proportion of Australian content for all products with this recipe. This percentage should then be used to indicate the proportion of Australian ingredients on the food label.

For example, if you are making an orange jam with the ingoing weight of oranges grown in Australia is 40 kg and the total weight of all other ingredients being 50 kg, then the Australian content ratio would be calculated as follows:

(40/50)*100 = 80%

Therefore, 80% is the minimum proportion of Australian content and should be indicated on the label.

How to Calculate Australian Content When Ingoing Weight of Australian Ingredients Varies?

Two Steps to Calculate Australian Content When Ingoing Weight of Australian Ingredients Varies

In the world of food manufacturing, it is not uncommon for circumstances to arise where the origin of individual ingredients or components varies. This could be due to a range of factors, such as reduced availability, seasonal changes, or changes in suppliers.

To allow for such variability, the Standard permits food to carry or display a label setting out the average proportion of Australian content.

The average proportion of Australian content labels is determined by averaging the minimum Australian content over a continuous period of 12, 24 or 36 months. This calculation period must conclude no later than two years before the date the labelling is affixed to the package.

After two years, businesses must reassess their claims and change their labels as needed. For example, if the average Australian content in a food is worked out based on the period 1st September 2020 – 30th August 2022, then the percentage can be used up until 30th August 2024 and must be reassessed and changed after this date.

Businesses using average content claims on labels must maintain sufficient records and documentation to back up the claims. These records can include information related to.

  • The proportion of Australian ingredients
  • Contact details of suppliers or distributors
  • Transaction dates
  • Batch or lot identification numbers
  • Volume or quantity of products
  • Relevant production records

 

To calculate the average proportion of Australian content in a food as a percentage, follow these steps.

  1. Calculate the percentage of Australian content for each month or batch by using the formula – (weight of ingoing Australian content / total weight of ingoing content) * 100 {Assume the answers are K}
  2. Calculate the average proportion of Australian content as a percentage by using the formula – SUM (K1+K2+K3……KN) / total number of months/batches in the period

 

The percentage determined in Step 2 is the average proportion of Australian content for all products with this recipe and should be indicated on the food label.

For example, you are manufacturing a Granola bar in bulk with one batch per month. However, due to seasonal changes, you are required to import and use some ingredients, such as oats and nuts.

You now have to calculate the percentage of Australian content for each batch using the formula stated in Step 1. On calculating the percentage, you found that it varied each month over a continuous period of 12 months (1st January 2021 – 31st December 2021) as follows.

  • January – 90% Australian
  • February – 70% Australian
  • March – 90% Australian
  • April – 60% Australian
  • May – 40% Australian
  • June – 50% Australian
  • July – 60% Australian
  • August – 40% Australian
  • September – 50% Australian
  • October – 80% Australian
  • November – 70% Australian
  • December – 80% Australian

 

Now, to determine the average proportion of Australian content in this Granola bar over a continuous period of 12 months, you have to use the formula mentioned in Step 2, i.e. –

(90+70+90+60+40+50+60+40+50+80+70+80) / 12 = 65%

Therefore, based on the 1-year continuous period (1st January 2021 – 31st December 2021), 65% is the average proportion of Australian content and should be indicated on the label. This 65% can be used up until 31st December 2024 and must be reassessed and changed after this date.

Additional Requirements for Foods that Contain Varying Australian Content

The use of an average proportion of Australian content claim can sometimes be misleading, as the actual percentage of Australian content in a food may be less than what is represented on the label. Therefore, to address this issue and prevent consumers from being misled, the Standard mentions several requirements that must be met for such food items. These requirements are.

  1. Mentioning the following standard text on the country of origin labels – ‘ingredient sources vary – average x% Australian ingredients’
  2. Directing consumers to a telephone number, website, or smartphone application or program where they can access more information about the product
  3. Including further information, such as a barcode, batch number, lot, date of manufacture or date mark, to enable the consumer to obtain further information on the percentage of Australian ingredients in the food in that package.

 

Food manufacturers and packers must take the responsibility of ensuring that consumers can easily find information on the method used to calculate the average time period and the proportion of Australian ingredients by weight in the package.

The following phrases can be used to explain how to obtain additional information.

  • ‘Scan barcode for details’ – if using a phone app or software
  • ‘Call [phone number] for details’ – if using a telephone number
  • ‘Visit [website address] for details’ – if using a website

How to Calculate Australian Content for Compound Ingredients?

Four points on how to calculate Australian content for compound ingredients

Compound ingredients are ingredients that are made by a mixture of two or more other ingredients. For example, mayonnaise (made using sub ingredients eggs, oil and lemon juice) in ready-to-eat sandwiches, ketchup (made with sub ingredients tomatoes, vinegar and spices) in beef bolognese pasta meal.

In the case where a compound ingredient has both Australian and non-Australian sub-ingredients, it becomes necessary to break down the ingoing weight of the sub-ingredients to determine the overall percentage of Australian content. This is because only the Australian portion of the compound ingredient, locally produced or grown, can be considered when calculating the Australian content.

Follow these steps to calculate the Australian content for compound ingredients in a food item as a percentage.

  1. Calculate the total ingoing weight of all sub-ingredients
  2. Identify and calculate the percentage of Australian content in all sub-ingredients
  3. Based on the percentage of Australian content, now calculate the weight of Australian content in each sub-ingredient
  4. Finally, use the formula – (total ingoing weight of Australian ingredients / total ingoing weight of all ingredients) * 100

 

For example, you are making a lasagna ready-to-eat meal with the following compound ingredients.

  • 150g beef and sausage
  • 200g vegetables
  • 80g sauce
  • 100g cheeses
  • 50g spices and seasonings
  • 150g lasagna noodles

 

In these compound ingredients, Australian content is as follows.

  • 150g beef and sausage – 100% Australian content
  • 200g vegetables – 100% Australian content
  • 80g sauce – 80% Australian content
  • 100g cheeses – 50% Australian content
  • 50g spices and seasonings – 80% Australian content
  • 150g lasagna noodles – 100% Australian content

 

Based on the Australian content in each ingredient, you now have to calculate the weight of Australian content in each sub-ingredient as follows.

  • 150g beef and sausage – 100% Australian content = 150g
  • 200g vegetables – 100% Australian content = 200g
  • 80g sauce – 84% Australian content = 67g
  • 100g cheeses – 50% Australian content = 50g
  • 50g spices and seasonings – 80% Australian content = 40g
  • 150g lasagna noodles – 100% Australian content = 150g

 

Now, to calculate the average proportion of Australian content in this Lasagna meal, you must add all the ingoing weights and Australian ingoing weights together as follows.

Total ingoing weight = (150+200+80+100+50+150) = 730g

Total ingoing weight of Australian content = (150+200+67+50+40+150) = 657g

Finally, use the formula mentioned in Step 4 to calculate the average proportion of Australian content as a percentage.

Australian Content % = (657 / 730) * 100 = 90%

Therefore, based on the calculation above, you have determined that 90% is the average Australian content of your lasagna meal and should be indicated on the label.

What is Count as "Ingredients" When Determining the Weight of Australian Content for Country of Origin Labelling?

Simply put, any component that goes into a recipe or forms part of a food is considered an ingredient and will be counted when determining weight. However, certain ingredients warrant a closer examination of whether they should be included in the weight calculation. These include the use of.

  1. Processing aids
  2. Food additives
  3. Water

In the Case of Processing Aids

Processing aids are natural or synthetic origin substances that have a technological purpose (such as baking, solidifying, or separating) in processing raw materials, foods or ingredients but do not have any technological purpose in the final food product.

Processing aids are not listed as ‘ingredients’ and are excluded from the weight calculations for country of origin labelling.

For example, for baking a cake, you use various ingredients such as flour, sugar, eggs and baking powder. Baking powder is a processing aid that helps the cake rise during baking but does not appear in the final product. Therefore, it should not be counted as an ingredient when calculating the weight of Australian content in the cake.

In the Case of Food Additives

Food additives are substances of natural or synthetic origin that are added to achieve a particular technological function (improving freshness, enhancing flavour or adding colours) in the final food product.

Food additives are listed as ‘ingredients’ and are included in the weight calculation for country of origin labelling.

In the same cake example, food additives like artificial sweeteners and emulsifiers are added to improve the taste of the cake. These should be counted as ingredients when calculating the weight of Australian content in the cake.

In the Case of Water

When added as an ingredient in food, water will be counted in the weight calculation for country of origin labelling. The country of origin for the water is the country where it was collected or harvested.

However, there are some exceptions.

  • When water is used to reconstitute dehydrated, concentrated ingredients or other components of food, including food additives, the country of origin for the water will be the same as that of the ingredient or component being reconstituted. The key factor is not only that the ingredient or component is dehydrated or concentrated but also that the water is used to ‘reconstitute’ (‘to constitute again; reconstruct; recompose’) the food item to its original state.
  • Water can be used as a ‘liquid packing medium’ for food, such as the brine in a jar of pickles or the water in a can of tuna. In such cases, water in a liquid packing medium is only counted towards the weight of ingredients if it is or can be consumed as part of the food. If the liquid packing medium is not generally consumed, the water in it does not count towards weight.

How to Display the Percentage of Australian Ingredients on a Country of Origin Label?

The percentage of Australian ingredients is displayed on the Country of Origin label via the Bar Chart (components of Standard Mark).

The bar chart mark represents the ‘P%’ of Australian ingredients, which should always be a whole number. The bar chart has 20% incremental markings and must be filled in 10% increments, rounding down to the lower decile.

The following rules apply when marking the bar chart.

  • For food products with less than 10% Australian ingredients, the bar chart should be filled to the 5 per cent mark
  • For food products that contain between 10% and 94%, the percentage should be a whole number and rounded down to the lower decile
  • For food products that contain between 95% to 99% Australian ingredients, the bar chart should be filled to the 95 per cent mark

The below image can be used as a reference for the representation of P% in the bar chart.

Bar chart to display the percentage of Australian ingredients

How to Label Country of Origin on a Food Product?

In Australia, the country of origin must be clearly labelled on food products for retail sale. Two important questions need to be considered when determining the labelling requirements.

  1. Is the food item a priority food product or a non-priority food product?
  2. Was the food grown, produced, made or packed in Australia or another country?

 

Let us now understand what is a priority food product and a non-priority food product.

What are Priority Food Products and Non-Priority Food Products?

The Standard has classified food products into two categories: ‘priority’ and ‘non-priority’.

A food product will be categorised as a priority item unless it belongs to one of the following non-priority food categories.

  1. Seasonings
  2. Confectionery
  3. Biscuits and snack foods
  4. Soft drinks and sports drinks
  5. Alcoholic drinks
  6. Tea and coffee
  7. Bottled water

 

As a way to help businesses determine if a food item is not a priority, the Standard offers specific examples of foods that belong to each category. It also highlights certain items excluded from the non-priority category and thus belongs to the priority category. The examples are listed in the table below.

Non-Priority Food Category
Includes
Excludes
Seasonings
Pepper, salt and salt substitutes; Dried herbs and spices; Spice blends and other seasonings or flavourings in powder or paste form; Dry cures or rubs for meat or fish; Meat tenderisers
Mustards; Sauces, chutneys and relishes
Confectionery
chewing gum; cocoa and chocolate products e.g. chocolate bars, and cocoa or chocolate spreads; ice-cream, edible ices (including sherbet and sorbet), flavoured ice blocks and other frozen confectionery; Popcorn; crystallised fruit, glacé fruit and edible cake decorations; products that primarily contain sugars and their dietetic counterparts e.g. non-chocolate-based lollies and jellies
sugar, icing sugar or icing sugar mixes; jams, honey, marmalades and other spreads
Biscuits and snack foods
chips, rice cakes, biscuits, cookies, crackers, pretzels, cones or wafers; ready to eat savoury snacks such as potato or other vegetable crisps, sticks or straws, bacon or pork crackling or prawn chips.
Cakes; muesli bars; processed nuts, including coated nuts and nut mixtures (e.g. mixed with dried fruit)
Soft drinks and sports drinks
water-based flavoured drinks (carbonated and non-carbonated) e.g. iced tea; ‘sport’, ‘energy’ and ‘electrolyte’ drinks; carbonated fruit or vegetable drinks; powder, syrup, liquid and frozen concentrates used to make water-based non-alcoholic beverages (e.g. fountain syrups, fruit syrups for soft drinks, and frozen or powdered concentrate for lemonade and iced tea)
non-carbonated fruit or vegetable drinks; Milk; cereal, nut or legume based drinks sold as milk substitutes (e.g. almond milk, soy milk)
Alcoholic drinks
any beverage with more than 0.5 per cent alcohol (by weight/volume)
Tea and coffee
the following, in dry or ready to drink form: – coffee and coffee substitutes, including instant and decaffeinated coffee; tea and herbal infusions, including instant tea; other similar cereal and grain beverages, excluding cocoa
Bottled water
natural mineral water, non-carbonated water, mineral and source waters, soda water and carbonated mineral water

How to Label Country of Origin on a Non-Priority Food Product?

When it comes to labelling the country of origin on non-priority foods, the requirements mandated by the Standard are reasonably straightforward.

According to the standard laws, non-priority food items should include a country of origin statement indicating where they were grown, produced, or made. The statement must not be inside a box but must be legible and prominent against the label background.

Even though the Standard only requires non-priority foods to have country of origin text statements, businesses can voluntarily choose to label their products in accordance with the requirements for priority foods. However, if businesses opt for this, they must comply with the Standard’s requirements by treating the food as a priority food item.

Let us now learn how to label non-priority foods based on the origin claims.

For Food that is Grown, Produced or Made in a Single Country

The Standard mandates that non-priority foods must carry a statement indicating the food’s country of origin, i.e., the country where the food was grown, produced, or made. This text statement does not have to be defined in a specific box. Nonetheless, compliance with the Standard’s requirements elucidated in the “Types of Origin Claims” section remains vital for any claim of being grown, produced or made concerning non-priority foods.

For example, tea leaves grown, produced, and packed in Australia for retail sale. As tea is a non-priority food item, the packaging must only carry a text statement such as – “Product of Australia”

Another example, chocolate crackers made in Switzerland using local and imported ingredients from other European countries. As raw ingredients were transformed into crackers in Switzerland, the food packaging must only carry a text statement – “Made in Switzerland”

For Food Packaged in a Country Using Food From Another Country

In cases where non-priority food has been packed in a particular country using food sourced from another country where this food was not subjected to any form of substantial transformation, the text statement must include.

  • If the food was ‘grown’, ‘produced’ or ‘made’ in a single country – a statement of the country of origin of the food. Additional text may be made about where the food was packed
  • If the food in the package is from more than one country – a statement that identifies where the food was packaged and indicates the food is from multiple origins or comprised of imported ingredients

 

For example, meat tenderiser powders made from ingredients imported from multiple countries to Canada, where they are combined and packaged for sale and then imported into Australia. This product, as per the Standard, will be required to carry a text statement as “Packed in Canada from Imported Ingredients.”

Another example, spices from India (70 per cent), China (20 per cent) and Australia (10 per cent) mixed and packed for sale in Australia. This spice mix will be required to carry a text statement as “Packed in Australia With Ingredients from India, China and Australia.”

As an alternative to a “text statement”, businesses are free to voluntarily adopt a standard mark label (with a bar chart) to showcase the percentage of Australian content

How to Label Country of Origin on a Priority Food Product?

Food products classified as “priority food” must carry a label called the “standard mark,” which includes graphics and text. This label should be prominently displayed on the product packaging and must comply with the requirements of the Standard.

The labelling requirements for priority food differ depending on whether the food was.

  • grown, produced or made in Australia
  • packed in Australia, or
  • imported into Australia

Food Grown, Produced or Made in Australia

How to Label Country of Origin on a Priority Food Product - Food Grown, Produced or Made in Australia

Priority foods grown, produced, or made in Australia are mandatorily required to carry a three-part standard mark label.

In specific situations, a food item may qualify to carry a ‘grown in’, ‘product of’ or ‘made in’ standard mark label. When this situation occurs, businesses must select the most appropriate and suitable type of claim for their product.

For 'Grown in' or 'Produced in' Australia Claim

  • A single-ingredient food can only bear a ‘Grown in Australia’ or ‘Product of Australia’ three-component standard mark label if grown or produced in Australia.
  • A food containing more than one ingredient can only carry a ‘Grown in Australia’ or ‘Product of Australia’ three-component standard mark label if all of its ingredients (not merely the significant ingredients) were grown or produced in Australia and all or virtually all, of the processing occurred in Australia.

 

The terms’ grown in’ and ‘produced in’ on standard mark labels are usually interchangeable, meaning a product that is ‘Grown in Australia’ can also, in most cases, claim to have been ‘Produced in Australia’. In such a case, the choice of explanatory text will be based on which claim the business believes is more relevant for the product.

Acceptable variations of the mandatory explanatory text are listed below.

For ‘Grown in’
For ‘Product of’
Grown in Australia
Produced in Australia
Australian grown
Product of Australia
Australian [type of food item] e.g. ‘Australian Finger Lime’
Produce of Australia
Australian [type of food item] e.g. ‘Australian milk’
Australian product

For the 'Made in Australia' Claim

The ‘Made in Australia’ standard mark label signifies that a food product underwent its last significant transformation in Australia. This claim focuses on food production rather than its content.

A ‘Made in Australia’ standard mark has different requirements and can be used for food products that contain.

  • Exclusively Australian content
  • No Australian content
  • A mix of Australian and imported content

 

The Standard allows businesses to add text to their labels to highlight the origin of an individual ingredient, giving consumers clarity on the composition of the product they are purchasing.

For Food Made in Australia With Exclusively Australian Content

Exclusive Australian content food items must use either of the following mandatory text statements.

  • ‘Made in Australia from Australian ingredients’ or
  • ‘Made in Australia from 100% Australian ingredients.’

 

A fully shaded bar chart should also indicate the exclusivity of Australian ingredients in the food product.

For Food Made in Australia From Exclusively Imported Content

Food items that are made in Australia using exclusive imported ingredients must include one of the following explanatory text.

  • ‘Made in Australia from imported ingredients’ or
  • ‘Made in Australia from 0% Australian ingredients’

 

In this case, the product packaging should also include an empty bar chart.

For Food Made in Australia With a Mix of Australian and Imported Content

Food items made in Australia using a mix of local and imported ingredients must have the explanatory text ‘Made in Australia from at least x% Australian ingredients’. However, this explanatory text should be modified if.

  • Australian ingredients are between 1 and 9 per cent – the label may read ‘Made in Australia from less than 10 per cent Australian ingredients’
  • A business wishes to instead rely on an average Australian content claim
  • A business wishes to add text highlighting the origin of a particular ingredient

For Food Products in Mixed bins

Mixed bins are containers containing multiple packed goods from the same or different countries of origin.

When products such as unpackaged fish, certain meats, fruit or vegetables (including nuts, spices, herbs, fungi, legumes and seeds) are displayed for sale in ‘mixed bins’, it is mandatory to display the country of origin labelling via a text statement – ‘mixed origins.’

However, it’s important to note that the “mixed origins” label should only be used for mixed bins of single-ingredient foods, such as a mixed bin of apples or potatoes. The kangaroo logo and bar chart should not be used for mixed bins because not all the food in the bins is Australian, and there is no assurance that the proportion of Australian food will remain constant.

For Food Products With Minor Processing Overseas

Food products grown, produced or made in Australia may be exported for minor processing and then re-imported into the country. In this case, the product will still carry a grown-in, produced-in, or made-in-Australia standard mark label provided the food.

  • Has not been substantially transformed overseas
  • Has not been combined with non-Australian ingredients whilst overseas
  • Still satisfies the criteria to make that origin claim, bearing in mind the processing that has occurred overseas

 

However, additional mandatory text requirements will apply to foods with minor processing overseas. In addition to declaring the origin statement, the standard mark must include a detailed description within brackets of the overseas processing. A generic description of processing, such as processed in Thailand,” will not suffice.

If the processing carried out overseas prevents the three-component standard mark from being used, then the food item must be labelled according to the regulations for imported products.

Food Packed in Australia

How to Label Country of Origin on a Priority Food Product packed in Australia

If food is imported into Australia and simply packed here without substantial transformation being made to it, it cannot be classified as being of ‘Australian origin’. Therefore, it is not permitted to carry the three-component standard mark label, which displays the kangaroo logo, even if the package contains some Australian food.

In the majority of instances where food is packed in Australia, it is required to carry a two-component standard mark label, which includes a bar chart and a clearly defined box with explanatory text.

The Standard offers the option for businesses that pack food in Australia to include text on labels to specify the origin of particular ingredients.

For Ingredients Sourced From Multiple Countries

A food product containing ingredients from multiple countries and packaged in Australia must have a two-component standard mark label. This applies to priority foods that cannot claim to have been grown, produced, or made in one country.

If none of the food in the package was grown or produced in Australia, the label must state that the food was.

  • ‘Packed in Australia from imported ingredients’ or
  • ‘Packed in Australia from 0% Australian ingredients’

 

This product type will also need to include an empty bar chart on the label.

If Australia was one of the countries where the food originated, it should be mentioned in the text statement and the bar chart. The explanatory text on the label should be ‘Packed in Australia from at least x% Australian ingredients’. However, this text should be modified if.

  • Australian ingredients are between 1 and 9 per cent – the label may read ‘Made in Australia from less than 10 per cent Australian ingredients’
  • A business wishes to rely on an average Australian content claim
  • A business wishes to highlight the origin of a particular ingredient

For Ingredients Sourced Exclusively From a Single Overseas Country

In the event that all the ingredients for a food item packaged in Australia are solely obtained from a single foreign country, then the product label must indicate that it was grown, produced or made in the originating country. In this case, using the standard mark label is optional, and businesses may label the food with either.

  • A country of origin statement stating where the food was grown, produced or made in a defined box, or
  • A two-component standard mark label with an unshaded bar chart and explanatory text stating the country of origin and that the food was packed in Australia

 

However, businesses must be aware that if they decide to disclose that their food was packaged in Australia, they will be obliged to adopt the two-component standard mark label and show the absence of Australian ingredients through a bar chart.

Additionally, if the food packed in Australia is sourced from a single country, but that country changes from time to time, the label must be modified to identify the specific country from which the food in that particular package originates.

For Food Made in a Single Overseas Country With Australian Ingredients

In some cases, Australian grown or produced ingredients are sent overseas, substantially transformed, either with or without other ingredients being added and then re-imported into Australia for packing.

For example, Australian milk is exported and processed into cheese in a foreign country and then imported back to Australia for packaging.

Such food product labels must identify that the food was ‘made in’ that foreign country. In this case, the use of the standard mark label is optional. However, businesses must label the food with either.

  • A country of origin statement specifying where the food was made in a defined box, or Made in China
  • A two-component standard mark label with a bar chart and explanatory text setting out the country in which the food was made and the percentage of Australian content in the food. The addition of the words ‘packed in Australia’ is optional.

 

If a food product is made entirely with ingredients from Australia, and the business has decided to use a two-component Standard mark, the label must clearly indicate whether the food was either.

  • ‘Made in (country) from 100% Australian ingredients’ or
  • ‘Made in (country) from Australian ingredients’

 

When a food product consists of ingredients not solely Australian, the explanatory text on the label for the two-component standard mark will be ‘Made in (country) from at least x% Australian ingredients’. However, this text should be modified if.

  • Australian ingredients are between 1 and 9 per cent – the label may state either ‘Made in (country) from at least x% Australian ingredients’ or ‘Made in (country) from less than 10% Australian ingredients’
  • The business wishes to highlight the origin of a particular ingredient

Food Imported into Australia

How to Label Country of Origin on a Priority Food Product for

Imported food refers to food products that are not grown, produced, made, or packed in Australia.

According to the Standard, most imported priority food must, at a minimum, include a country of origin text statement in a clearly defined box.

In a situation where imported food cannot claim to have been grown, produced or made in a single overseas country, it should carry a ‘packed in’ statement. The label must.

  • Identify the country where it was packed and
  • Indicate that the food is of multiple origins, or from imported ingredients

For Imported Foods That Contain Australian Ingredients

If a food imported into Australia contains some ingredients from Australia, the label should carry a two-component standard mark as an alternative. The mandatory explanatory text should identify the origin food labelling country and state the percentage of Australian ingredients in the food.

The explanatory text on the label can be modified if.

  • Australian ingredients are between 1 and 9 per cent – the text will state that the food was grown, produced, made or packed ‘from less than 10 per cent Australian ingredients’
  • The business wishes to highlight the origin of a particular ingredient

How to Design Country of Origin Labels?

Once a business has determined the type of label that is suitable for their product, they must design it according to the requirements set out by country of origin labelling laws.

The Standard has set out several specific rules, which we will discuss in this section. However, here are some generic rules to follow.

  • Wording should be legible
  • Wording should be prominent enough to stand out against the label’s background
  • The wording should be in English. In case another language is used, the information in that language must not negate or contradict the information in English

Label Colour

Three points about label colour to design country of origin labels

The country of origin label can be.

  • In green, gold and black colour combination
  • In monochrome, i.e. in black, white and grey colour
  • With a transparent background providing sufficient contrast and legibility

 

The Standard recommends using the green, gold and black colour combination wherever possible. The recommended shades are Pantone 341 Green, Pantone 137 Gold and a pure 100% K Black.

Please note that there are no restrictions on the choice and usage of colours, but it is necessary to meet the following eligibility requirements at all times.

  1. All the components of the label, including the origin statement, should be legible
  2. All the label’s components, including the origin statement, should be prominent so as to contrast distinctly with the label’s background.

Label Orientation

Two points on label orientation for designing country of origin labels

Country of origin labels can be of the following orientations.

  1. Portrait – Logo and bar chart above explanatory text
  2. Landscape – Logo and bar chart to the left of explanatory text

Label Typeface and Size

Three points about label typeface and size to design country of origin labels

The Standard recommends using the “Interstate Bold” typeface for all texts present on the country of origin label. It does not specify a minimum font size but requires all text on the label to be easily legible and visible from a normal viewing distance.

Here are some practical font size recommendations to follow.

  • 5 mm minimum font size – For labelling displayed in a refrigerated assisted service display cabinet
  • 9 mm minimum font size – For all other labelling displayed in association with food products

Label Component Minimum Size

Two points on label component minimum size to design country of origin labels

The size of the components of the country of origin label will vary depending on the size of the overall label, which further depends on the size and shape of the food package. However, the following practical recommendations should be followed.

  • The length of the bar chart should be equal to the length of the triangle’s side
  • The height of the bar chart should be equal to the height of the explanatory text capital letters

Clear Spacing

Point about clear spacing to design country of origin labels

Clear spacing, similar to quiet zones in barcodes, is an empty space that surrounds all four sides of the country of origin label. This area is designated as a non-print area, meaning no other markings should be present within this area.

As per the Standard, the country of origin label must be surrounded by a clear spacing of 3 mm on all four sides.

Make Country of Origin Labelling Easy With Seagull Scientific's BarTender Software

Template of BarTender Country of Origin Labels

As a food manufacturer or packer, complying with country of origin labelling requirements can be a real challenge. Fortunately, there is a solution: Seagull Scientific’s BarTender software.

Seagull Scientific’s BarTender is the world’s most trusted label design and print software. This software has a vast library of ready-to-use label templates, including the Australian country of origin label. All that is required is to select the template and enter your product information, and BarTender will generate a compliant label. It’s that easy!

What’s more, BarTender has a highly intuitive user interface that makes it easy to design labels without technical knowledge. It seamlessly integrates with major business systems and existing infrastructure, providing a centralised and efficient label printing process.

With BarTender, designing labels with images, texts, barcodes, and RFID tags is a breeze. With built-in data validation and intelligence, BarTender prevents errors from entering the label printing process. The best part? You can automate the entire label designing and printing process. Refer to our understanding BarTender software article to learn more about this top-tier label printing and designing software.

Triton Store is proud to be a trusted provider of Seagull Scientific’s BarTender Software solutions. As a team, we understand that every business has varying needs, hence why we provide all four BarTender editions, namely, Starter Edition, Professional Edition, Automation Edition and Enterprise Edition.

The Starter Edition is ideal for small teams, while the Professional Edition provides an amplified experience to those with complicated labelling requirements. Businesses preferring automated processes would benefit from the Automation Edition, whereas the Enterprise Edition caters to large organisations.

Not to mention, Triton also provides BarTender Cloud, a cloud-based version of the software that gives businesses the convenience of printing labels from anywhere. Our article on BarTender Cloud vs. BarTender software will help you decide which package best suits your needs.

So, if you’re looking for an easy way to design compliant country-of-origin labels, look no further than Seagull Scientific’s BarTender Software. Get in touch with the Triton Store team today via the live chat widget, or fill out a form here. We’ll be more than happy to answer all your questions about BarTender software.

How to Print Country of Origin Labels?

The Standard does not provide specific instructions on printing country of origin labels. However, it does recommend the label file type to be used.

  1. For printing labels – CMYK (PDF) file
  2. For displaying on computer and television screens – RGB (PNG)

 

Here are some generic instructions for printing labels.

How to Display Country of Origin Labelling on Food Items?

Once correct origin labels are designed and printed, they must be affixed to the food items per the regulations. The Standard provides different rules based on the food packaging and label usage.

For Packaged Products

Two points about displaying country of origin labels for online sales

Packaged products can be priority or non-priority items and can have either a standard mark or a country of origin statement.

The standard mark or country of origin statement can be placed at any visible location on the packaging. However, placing the label at the base of the packaging is not recommended.

Country of origin labels for point-of-sale displays are optional for packaged products.

For Small Packages

Priority foods sold in small packages with a surface area of less than 100 cm2 are exempt from using the kangaroo logo or bar chart on their labels. For such packages, it is enough to display the relevant label wording within a box on the package.

For Unpackaged Food

Two points to display country of origin labels for unpackaged food

If a product is an unpackaged fish, certain meats (pork, beef, veal, lamb, hogget, mutton, chicken), fruit or vegetables (including nuts, spices, herbs, fungus, legumes, and seeds), or a mix of any of this food, the label can be displayed on.

  • anywhere on the product
  • Near the product via a hanging sign, display card and other similar items

 

There are additional font size requirements for unpacked products. If the food is to be displayed in a refrigerated assisted service display cabinet, the label text size must be at least five millimetres. However, if the food is displayed in any other manner, the text size must be at least nine millimetres.

For Fresh Fruit and Vegetables in Transparent Packaging

Fresh fruit and vegetables, when packaged in transparent packaging such as plastic wrap, netting, or citrus bags, can be considered either packaged or unpackaged foods. This distinction will determine the appropriate placement of the country of origin label.  

For Online Sales

Display country of origin labels for online sales

The obligation to display a country of origin label for online food sales will be satisfied if.

  • The food, as delivered to the consumer, bears the relevant label
  • The food, as delivered to the consumer, is accompanied by the relevant label or
  • The label is visible to the consumer online at the point of sale

 

Although, the Standard does not mandate labels to be shown on online food-selling web pages. However, retailers are encouraged to voluntarily display the country of origin statement or standard mark on their websites to assist customers.

For Advertising and Marketing Material

Display country of origin labels for advertising and marketing material

Country of origin food labels can be used in advertising material such as store websites, TV, print and online advertisements. In such cases, the following guidelines must be followed.

  • Labels should always be associated with the relevant food product
  • Information on the marketing materials matches with the label on the product
  • Single labels can be used for a group of food products if they share the same origin statement and the same percentage of Australian ingredients
  • Country of origin food labels cannot be used for non-food products, corporate store signage or sponsorships without a licence

Common Mistakes to Avoid When Designing Country of Origin Food Label

Distorted Label mistake to avoid when designing country of origin food label
Split label mistake to avoid when designing country of origin food label
Incorrect explanatory text mistake to avoid when designing country of origins food label

Here is a list of common mistakes to avoid when working with country of origin food labels.

  • Distorting label – Never increase the size of the label once it has been generated.
  • Splitting label – The components of the label should not be placed on different parts of the product.
  • Incorrect explanatory text – Text must meet guidelines as per the Information Standard
  • Incorrect bar chart – The bar chart must have four incremental markings at 20% each and filled in 10% increments
  • Insufficient contrast with background – The foreground and background colour of the label must be of sufficient contrast.
  • Part usage of label – Using kangaroo in a triangle and bar chart without explanatory text or using only kangaroo in a triangle or kangaroo in a triangle and explanatory text without bar chart is not allowed.

 

Our best practices for designing perfect labels and barcode article will help you understand more about the important details of label and barcode creation.

Incorrect bar chart mistake to avoid when designing country of origins food label
Insufficient contrast with background to avoid when designing country of origin food label
Part use of label mistake to avoid when designing country of origins food label

Penalties on Non-Compliance With Country of Origin Rules

As of 1st July 2018, businesses have been required to follow a strict new labelling system for the products they sell. Not adhering to these regulations could lead to a contravention of the Australian Consumer Law (ACL) and potential enforcement action by the Australian Competition and Consumer Commission (ACCC).

Non-compliant businesses can face severe consequences, including financial penalties of up to.

  • $10 million,
  • Three times the value of the benefit received,
  • Where the benefit cannot be calculated, 10 per cent of annual turnover in the preceding 12 months for corporations and up to $500 000 for an individual

 

When a business violates the ACL, a court may issue various orders, such as injunctions, compensatory orders, and corrective advertising orders. Third parties who have suffered losses or damages due to a breach of the ACL may take legal action.

Country of Origin Checklist

Before using any tool to generate a label, it is important to have the following information prepared.

  1. Whether or not your food product contains any Australian ingredients
  2. The percentage of Australian ingredients in your food product
  3. Name of the country where your food product was made (last substantially transformed)
  4. Whether your food product will be sold packed or unpacked
  5. Name of the country where your food product was packed or packaged
  6. A list of your product’s processing activities that occurred overseas
  7. The average percentage of Australian ingredients
  8. The origin of specific ingredients you want to highlight in your label

Final Words

In conclusion, adhering to Australia’s country of origin labelling rules is pivotal for food manufacturers and packers. Beyond mere legal compliance, CoOL increases transparency and instils customer trust in the products they consume.

Missteps in CoOL can lead to severe penalties, including hefty fines and legal consequences. Therefore, it’s essential to fully understand and consistently apply these regulations in all aspects of product packaging, online sales, marketing materials, and advertising.

Fostering a culture of compliance safeguards not only businesses and their reputation and contributes to a fair and transparent marketplace for consumers. We hope this article guides you in the right direction as you navigate the rules and regulations of the country of origin labelling in Australia.

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