Food Labelling Laws in Australia: Compliance Essentials For Businesses

If you’re launching a food product in Australia - from a cafe takeaway line to a packaged snack or an online pantry brand - your label isn’t just a design decision. It’s a legal document.

Australia’s food labelling rules exist to protect consumers and ensure a fair market. Getting them right from day one helps you avoid recalls and fines, and it also builds trust with retailers and customers.

In this guide, we’ll walk through who regulates food labelling, what must appear on your label, recent changes (including plain English allergen rules), and practical steps to stay compliant. We’ll also cover key contracts and documents that support your broader compliance and reduce risk as you grow.

Why Food Labelling Compliance Matters

Food labels tell people what they’re eating, how to store it safely, and whether it’s suitable for them (especially if they have allergies). That’s good for customers - and it’s essential protection for your business.

Here’s the big picture of who does what in Australia:

• Food Standards Australia New Zealand (FSANZ): develops the Australia New Zealand Food Standards Code (the Food Standards Code). FSANZ does not enforce the law - it sets the standards.
• State and territory food authorities and local councils: enforce the Food Acts in each jurisdiction and compliance with the Food Standards Code (including inspections and infringement notices).
• Australian Competition and Consumer Commission (ACCC): enforces the Australian Consumer Law (ACL), including the Country of Origin Food Labelling Information Standard. The ACL also prohibits misleading or deceptive conduct and false claims.

Strong labels reduce safety risks, demonstrate professionalism to retailers, and help you meet ACL obligations around truthful descriptions and claims. If you make any statement on packaging (for example, “low sugar” or “made in Australia”), it must be accurate and appropriately substantiated or you risk issues under Australian Consumer Law.

What Must Appear On Your Food Label?

Exact requirements depend on the product and packaging, but most packaged foods sold in Australia must include the following core elements under the Food Standards Code and related instruments.

Name Or Description Of The Food

Use a name/description that identifies the food’s true nature (for example, “Greek yoghurt”). Don’t rely solely on a brand name.

Ingredients List

List all ingredients in descending order by ingoing weight. If your product has characterising ingredients (for example, “strawberry yoghurt”), percentage labelling of those ingredients is required so consumers can see how much is actually in there.

Allergen Declarations (Plain English Allergen Labelling)

Allergens must be declared clearly and consistently. Under the Plain English Allergen Labelling (PEAL) updates, you must use prescribed names and a “Contains” statement so it’s easy to find and understand.

Mandatory allergens include: cereals containing gluten (wheat, rye, barley, oats and their hybrids), crustacea, egg, fish, milk, peanuts, soybeans, sesame, tree nuts, lupin, molluscs, and added sulphites (≥10 mg/kg).

Make sure allergens appear in the ingredients list using required names, and add a separate “Contains: …” statement. If there’s a plausible cross-contact risk you can’t control, precautionary statements (for example, “May contain …”) must be truthful and not used as a substitute for good manufacturing practices.

Nutritional Information Panel (NIP) And Claims

Most packaged food needs a Nutrition Information Panel showing energy, protein, fat (total and saturated), carbohydrate, sugars and sodium per serving and per 100g/100mL. There are limited exemptions (for example, some small-package foods and very simple single-ingredient products).

If you make nutrition or health claims (for example, “high in fibre” or “good source of calcium”), you must meet specific criteria under the Food Standards Code (Standard 1.2.7), including the nutrient profiling scoring criterion and evidence to substantiate the claim. Voluntary systems like the Health Star Rating must be used in line with their style guidelines and must not mislead consumers.

Business Name And Address

Include the name and a physical street address in Australia or New Zealand for the supplier, manufacturer or importer (not just a website or PO box). This supports traceability and consumer contact.

Lot Identification

A lot/batch identification or date code is required so you can trace and, if necessary, recall specific batches.

Date Marking

• Use by date: for foods that are unsafe to consume after a certain date (it’s illegal to sell after this date).
• Best before date: for foods that may lose quality after this date but are generally still safe if stored correctly.

Net Quantity

Show net weight or volume. Use the correct units and ensure the declaration is easy to read on the principal display panel.

Directions For Use And Storage

Where needed for safety or quality (for example, “Keep refrigerated at or below 4°C”, “Cook thoroughly before eating”), include clear instructions.

Country Of Origin Food Labelling

Most food sold in Australia must comply with the Country of Origin Food Labelling Information Standard 2016 (under the ACL). Different wording is required for “Grown in”, “Made in” and “Packed in” claims, and there are rules about when you can use the Australian kangaroo logo. Imported foods need accurate origin statements so consumers aren’t misled.

Legibility And Placement

There are rules about legibility, contrast and minimum type size (which can vary by package size). Place mandatory information together where required and ensure it’s easily seen and read by the average consumer.

Selling Online?

For e‑commerce, key information must be available to the consumer before they buy and again at delivery. That includes essential details like ingredients, allergens, country of origin and net quantity. Your website should also be backed by fit‑for‑purpose Online Shop Terms & Conditions to set expectations about ordering, delivery and returns.

Recent Changes And Common Traps

Food labelling evolves, and many of the recent changes focus on clarity, allergens and origin information. Three areas to pay attention to are below.

Plain English Allergen Labelling (PEAL)

FSANZ updated allergen rules to require prescribed plain English terms and a “Contains” statement, and to add molluscs to the list. Transition timelines applied (including a stock-in-trade period), but by now most businesses should be using the PEAL format. If you’re still running older packaging, prioritise an update - undeclared or poorly presented allergens are a leading cause of recalls.

Country Of Origin Claims

The Country of Origin Food Labelling Information Standard tightened how “Grown in”, “Made in” and “Packed in” claims work. This Standard sits under the ACL and is enforced by the ACCC. If you make an origin or ingredient claim, ensure it’s correct and that you can substantiate it with supply chain records.

Nutrition And Health Claims

There’s increased scrutiny on nutrition and health messaging. Before you say “low sugar”, “source of protein” or similar, check the specific qualifying criteria in the Food Standards Code and keep evidence on file. Incorrect or overstated claims can breach both the Code and the ACL prohibitions against misleading conduct.

Common traps we see include:

• Allergens highlighted in a brand style but not using required PEAL terms.
• “Made in Australia” used where processing is minor and ingredients are primarily imported.
• Small packages missing a lot/batch code or address details.
• Online listings that omit allergens or origin details visible on the physical pack.

How To Make (And Keep) Your Labels Compliant

Compliance is much easier when you follow a consistent process and document your decisions. Here’s a practical workflow you can adapt to your food business.

1) Map Your Product And Supply Chain

List the complete recipe and all inputs (including additives and processing aids), and note their origins. Capture allergen and cross-contact information from every supplier. Keep current specifications on file.

2) Build Your Label Checklist

Use the Food Standards Code schedules as a master checklist: name/description, ingredients and percentage labelling where needed, allergens (PEAL), NIP, date marking, net contents, lot ID, business name and address, storage/use instructions, and country of origin. Add any product‑specific items that apply to your category.

3) Draft With Legibility In Mind

Design around compliance, not the other way around. Set mandatory text in clear fonts with sufficient contrast. Group required elements where the Code expects them together. For small packs, confirm any modified size rules that might apply before finalising artwork.

4) Validate Claims

Run your nutrition panel using reliable data (lab testing or robust calculation from specifications) and test any claims against the Code’s criteria. Keep substantiation files for everything displayed on‑pack, including origin claims and images that could imply a benefit.

5) Review Against The ACL

Sanity‑check all wording, imagery and comparative statements against the ACL. Phrases like “all natural”, “made fresh”, “no added sugar” and “Australian made” have specific implications - they must be true and not mislead in context. If in doubt, get consumer law advice before you print.

6) Implement Change Control

Ingredients, suppliers and processes change. Bake compliance into your operations by requiring sign‑off before any recipe or supplier change goes live, and re‑run the label checklist each time. Schedule a periodic audit (for example, every 6–12 months) to capture regulatory updates.

7) Prepare A Recall Plan

Every supplier should have a documented recall procedure and current contact lists. Store batch records and distribution logs so you can quickly identify affected stock. A clear plan limits disruption if an issue arises and can help satisfy enforcement authorities after an incident.

Beyond The Label: Legal Documents And Consumer Law

Getting the label right is one part of the compliance picture. A solid set of contracts and policies will also help you manage risk and meet your obligations as you sell and scale.

• Supply Agreement: lock in product quality, specifications, allergen disclosures, origin information and recall responsibilities with your ingredient and packaging suppliers. A tailored Supply Agreement helps you pass through legal obligations and protect your position if something goes wrong.
• Wholesale Or Distribution Terms: if you sell to retailers or distributors, set out delivery, pricing, chargebacks, returns and compliance expectations in a clear Wholesale Agreement.
• Online Shop Terms & Conditions: for direct‑to‑consumer sales, publish fair, transparent Online Shop Terms & Conditions covering orders, delivery windows, refunds and liability limits.
• Privacy Policy & Data Practices: if you collect personal information (for example, via your website, online orders or loyalty program), have a clear Privacy Policy and appropriate data notices. Good privacy hygiene builds trust and supports compliance with the Privacy Act.
• Warranties And Returns: any written warranty must meet ACL requirements. If you offer your own product guarantee, you may need a compliant Warranties Against Defects Policy with the prescribed wording.
• Brand Protection: protect your name and logo early with a registered trade mark, and ensure your packaging doesn’t infringe someone else’s IP.
• Confidentiality: when sharing recipes, product specs or supplier pricing with third parties, use a Non‑Disclosure Agreement to protect your confidential information.

It’s also important to remember your broader ACL obligations. Your advertising, pricing and refund practices must not mislead consumers, and mandatory consumer guarantees apply to most goods you sell. Align your customer communications and contract terms with the ACL to avoid disputes and regulator scrutiny.

Key Takeaways

• FSANZ sets the Food Standards Code, while state and territory authorities and the ACCC enforce food and consumer laws - make sure your labels meet both sets of requirements.
• Core label elements usually include a true name/description, ingredients and percentage labelling (where required), allergen declarations using PEAL, a compliant NIP, business name and address, lot ID, date marking, net contents, storage/use instructions and a valid country of origin statement.
• PEAL, origin rules and nutrition/health claim criteria are current hotspots - double‑check your allergen wording, substantiation for claims and the accuracy of “Grown/Made/Packed in” declarations.
• Build compliance into your process: keep supplier specs current, validate claims, audit artwork for legibility, maintain a change‑control workflow and have a recall plan ready.
• Support your labels with strong paperwork: use a Supply Agreement, clear Online Shop Terms & Conditions, a transparent Privacy Policy, compliant warranties wording and registered trade marks to reduce legal risk.
• Treat your label as a living document - review it whenever ingredients, suppliers or laws change to stay compliant and protect your brand.

If you’d like a consultation on food labelling compliance - including packaging reviews, consumer law risk and the contracts that support your supply chain - reach out to us at 1800 730 617 or team@sprintlaw.com.au for a free, no‑obligations chat.