Developing food labels can be a confusing and difficult task. Most packaged foods are required to meet strict labelling requirements, including identification of the product and manufacturer or supplier, information for people with food allergies, food additives, product nutritional information, date marking, food storage instructions and country of origin.
A recent review of the South Australian dairy industry has found that some ingredients are not being correctly represented on labels. A number of products were identified at point of sale with labels listing characterising ingredients in the ingredient declaration, but failing to include the proportion of characterising ingredients.
The Food Standards Code defines a characterising ingredient or characterising component as an ingredient, a category of ingredients or a component of the food that:
- Is mentioned in the name of the food; or
- Is usually associated with the name of the food by a consumer; or
- Is emphasised on the label of the food in words, pictures or graphics.
Percentage labelling information may appear anywhere on the label. For example, the declaration may appear near the name of the food or in or near the statement of ingredients. However, if the declaration of a characterising ingredient is made in the statement of ingredients, it must appear immediately after the name of the ingredient in the statement of ingredients.
Food Standards Australia New Zealand (FSANZ) develops and maintains Australia’s Food Standards Code, which covers a range of food standards including food labelling requirements for your products, which can be accessed here: https://www.foodstandards.gov.au.
Standards are enforced by all Australian states and territories. Chapter 1 of the Food Standards Code outlines general labelling and information requirements relevant to all foods. It details how requirements apply in different situations (e.g., food for retail sale, food for catering purposes, or intra-company transfer). Chapter 2 of the Code also includes specific information and labelling requirements that only apply to certain foods; part 2.5 refers to dairy products.
SA Health is the lead agency in South Australia responsible for enforcing the labelling provisions of the Food Standards Code and the Food Act 2001. Dairysafe works collaboratively with SA Health to ensure accredited dairy processing businesses are compliant with labelling requirements.
Label development and label review, in tandem with parallel auditing from batch make up to finished product, will be included regularly as part of your routine food safety audits.
Country of origin and weights and measures requirements are regulated by the Australian Competition and Consumer Commission (ACCC) and the Australian National Measurement Institute respectively. Additional labelling information can be found at:
- https://www.accc.gov.au/publications/country-of-origin-food-labelling
- https://www.industry.gov.au/strategies-for-the-future/national-measurement-institute
It is the responsibility of each business to develop compliant food labels. If this proves to be challenging, you may need to consider seeking technical advice from a professional food safety or food labelling consultant.
Extensive guidance for labelling requirements can be found on the FSANZ website here:
- https://www.foodstandards.gov.au/code/userguide/Pages/default.aspx
- https://www.foodstandards.gov.au/consumer/labelling/Pages/default.aspx
Alternatively, you can find guidance material on labelling on the Dairysafe website’s ‘Food Safety Toolbox’ page.