From 1 July 2016, new country of origin labelling requirements will become a reality in Australia, with a new food labelling system commencing under the Australian Consumer Law. The implementation of the new system will have a two year transition period. From 1 July 2018, the new system will be mandatory and something which both consumers and businesses need to be aware of.


Earlier this year, we reported on possible changes to country of origin food labelling in Australia, following a call for submissions from food industry stakeholders by the Department of Industry, Innovation and Science. At the time, stakeholders were encouraged to provide commentary on proposed changes to country of origin labelling for food in Australia prior to the 29 January 2016 deadline. For the full article, please click here.

The changes

The intention of the new system is to ensure that labels are clear on where food products are produced, grown, made or packed. Different labelling requirements are to be implemented depending on whether foods are:

  • grown, produced or made in Australia;
  • packaged in Australia;
  • grown, produced or made in another country; or
  • packaged in another country.

The labelling requirements will also vary depending on whether the food is:

  • packaged food, other than fresh fruit and vegetables in transparent packaging;
  • fresh fruit and vegetables in transparent packaging; or
  • unpackaged meat, fish, fruit and vegetables.

For the majority of foods grown, produced, made or packaged in Australia, from 1 July 2018 labels must include a standard mark made up of a bar chart supported by a text statement, which shows the percentage by ingoing weight of Australian ingredients. The bar chart percentages will be displayed in 10% interval segments. A kangaroo image in a triangle will also be displayed where all of the food is grown, produced or made in Australia. A sample of the standard mark for a food which is 100% grown in Australia is below.

The design of this standard label will change slightly, depending on whether foods have minor processing overseas, are imported, have varying degrees of Australian ingredients, or where businesses wish to highlight specific ingredients. Non priority foods will also have differing requirements, which are voluntary rather than mandatory. Non priority foods include seasonings, confectionary, biscuits and snack food, bottled water, soft drinks and sports drinks, tea and coffee and alcoholic beverages.

Once implemented, the new system also ensures consumers remain able to access more detailed information about the foods they are buying, by requiring that food product labels include barcodes for scanning, telephone numbers, or website links which consumers can easily access.

The new system also deals with requirements for legibility of labels, record keeping standards, and other mandates for the implementation and management of the new labels.

The full extent of the new labelling system is set out in the Country of Origin Food Labelling Information Standard 2016 (the Information Standard) available here.

The transition

There is a two year period of transition within which businesses must work to ensure that labels meet the new standards. Until the end of the transition period, any food products offered for retail sale in Australia will be expected to comply with the already existing Food Standards Code, unless businesses elect to adopt the new system earlier. The new system however will become mandatory on 1 July 2018.

To assist with the implementation of the changes by businesses, the Federal Government is already providing a number of resources, including the Information Standard which sets out the details of the new system, as well as style guides to assist in the creation of labels for foods. A Country of Origin Labelling (CoOL) label library will also be an available resource in June 2016. The CoOL will provide a resource for businesses to find and download, or otherwise design the correct label for specific food products.


A key focus of the Government has been to ensure that businesses and consumers are aware of the changes and remain able to easily access information about food labelling going forward. Already, social media and general advertising campaigns are being rolled out which are targeted at consumers to ensure they are aware that the changes are coming.

It is anticipated that consumers will begin to see products which comply with the new labelling system in supermarkets, grocery outlets and other outlets at which food is offered for retail sale, after 1 July 2016.

It remains to be seen whether the drafting of the Information Standard provides sufficient direction for businesses and whether the supporting resources provided by the government will be adequate to ensure a smooth transition.

With a full overhaul of the current labelling regime and the mandatory implementation by businesses, the true test of the new system will be whether an appropriate balance has been achieved between informing consumers as against the costs to businesses and the compliance efforts required.