Alex is Sprintlaw’s co-founder and principal lawyer. Alex previously worked at a top-tier firm as a lawyer specialising in technology and media contracts, and founded a digital agency which he sold in 2015.
- What’s Actually New In Australian Labelling Laws?
- Which Laws And Regulators Apply To Labels In Australia?
How To Make Your Labels Compliant (Step‑By‑Step)
- 1) Map the rules that apply to your products
- 2) Gather complete and accurate product data
- 3) Draft claims and mandatory statements carefully
- 4) Design for legibility and permanence
- 5) Run an ACL and category‑specific legal check
- 6) Align your website and e‑commerce with your packaging
- 7) Keep records and implement version control
- 8) Monitor updates and schedule reviews
- Contracts And Policies That Support Labelling Compliance
- What Happens If You Get It Wrong (And How To Stay Ahead)
- Key Takeaways
If you sell products in Australia, your labels and packaging aren’t just design choices - they’re a core part of legal compliance, consumer trust and your brand’s reputation.
In the last few years, regulators have tightened rules and sharpened their enforcement focus, especially around safety information, allergens, pregnancy warnings and environmental claims. That means it’s important to understand which rules apply to your products, what’s changed, and how to build a practical, defensible labelling process.
In this guide, we’ll walk through the key Australian labelling laws, recent updates that may affect your labels, and a step-by-step approach to staying compliant - so you can keep growing with confidence.
What’s Actually New In Australian Labelling Laws?
Australian labelling requirements evolve regularly. Rather than a single “new law”, there’s been a series of updates and enforcement priorities that product businesses should know about. Here are some of the important developments that are currently in force (or in transition):
- Plain English Allergen Labelling (PEAL) for food: FSANZ has introduced clearer, plain English allergen statements and specific formatting rules for priority allergens (e.g. “milk”, “peanut”, “tree nut”). Businesses have been in a transition period to update labels; products must comply by the end of the transition dates (with a further sell-through period for existing stock). If you sell food, this is a significant change to how allergens appear on pack.
- Pregnancy warning labels on alcohol: Packaged alcoholic beverages must display the prescribed pregnancy warning label. The transition period has ended, and non‑compliant products risk enforcement action.
- Button battery safety and warnings: Consumer goods containing button/coin batteries must meet mandatory safety standards, including child‑resistant packaging, performance testing and prominent warning labels. These standards are fully in force.
- Environmental and sustainability claims (“greenwashing”): The ACCC has made environmental claims a priority area. Claims like “biodegradable”, “compostable”, “plastic‑free”, “carbon neutral” or “recyclable” must be accurate, specific, and backed by evidence. Vague or unqualified claims are at risk.
- Country of origin for food (and other goods): Country of Origin Food Labelling requirements are now well‑established for most foods. If you make origin or “Australian made” claims on non‑food goods, those claims must still be truthful and supportable under Australian Consumer Law.
Beyond these highlights, sector‑specific standards and codes continue to refresh. If you’re launching new products or updating packaging, build in time to review current requirements before you print.
Which Laws And Regulators Apply To Labels In Australia?
Most product labels in Australia must comply with a combination of general consumer law and industry‑specific rules. At a glance:
- Australian Consumer Law (ACL) - ACCC: All labels, packaging and advertising must not be misleading or deceptive. This covers claims about ingredients, quality, performance, sustainability, pricing and origin, and also includes mandatory safety warnings for certain goods. If you make representations on pack or online, they need to be true, clear and supportable. For core principles around misleading conduct, see Section 18 of the ACL and the elements of misleading or deceptive conduct.
- Food Standards Australia New Zealand (FSANZ): The Food Standards Code sets detailed rules for ingredient lists, allergen labelling (including PEAL), nutrition information panels, and date marking (“best before”/“use by”). Many food products must also carry country of origin information.
- Therapeutic Goods Administration (TGA): Therapeutic goods (like medicines and certain health products) have specific labelling and advertising rules. Advertising pre‑approval has been abolished, but businesses must comply with the Therapeutic Goods Advertising Code and relevant standards. Note: most everyday cosmetics are not therapeutic goods; they’re regulated separately unless you make therapeutic claims (e.g. “treats eczema”).
- Cosmetics and industrial chemicals (AICIS): Cosmetics are generally regulated under the Australian Industrial Chemicals Introduction Scheme (AICIS) and must meet ingredient labelling rules and safety obligations. If your cosmetic makes therapeutic claims, TGA rules can be triggered - so be careful with the wording on pack.
- National Measurement Institute (NMI): Trade measurement laws require correct and properly marked quantity statements (e.g. net weight/volume) with prescribed units and positioning.
- Other product‑specific frameworks: Examples include electrical safety marks, toys and children’s goods safety warnings, hazardous chemicals/poisons schedules, tobacco plain packaging, state or territory container deposit labelling and more. Always check whether your category has a dedicated standard.
Your e‑commerce materials are in scope too. The same rules that apply to packaging apply to claims made on websites and product listings, including pricing representations covered by advertised price laws.
How To Make Your Labels Compliant (Step‑By‑Step)
Compliance is an ongoing process, not a once‑off exercise. The most reliable approach is to build repeatable steps into your product development and marketing workflow.
1) Map the rules that apply to your products
- Confirm your category (e.g. food, alcohol, cosmetic, electronics, toys, chemicals, household items) and distribution method (retail, wholesale, online, import/export).
- List the relevant frameworks (ACL, FSANZ, TGA or AICIS, NMI, any mandatory safety standards) and any state‑specific rules.
- If you sell variants (sizes, flavours, limited editions), note any labelling differences early so nothing gets missed in production.
2) Gather complete and accurate product data
- Ingredients and sub‑ingredients, including potential allergens and their sources.
- Manufacturing and batch codes, storage conditions, and shelf life to support “best before” or “use by” dates where required.
- Objective substantiation for all claims (e.g. test reports, certifications, LCA or emissions data for environmental claims, origin documentation).
- Packaging specifications (e.g. pack size, inner/outer configurations, presence of button batteries or small parts) that can trigger mandatory warnings.
3) Draft claims and mandatory statements carefully
- Use plain English, avoid vague qualifiers (“eco‑friendly”, “sustainable”, “chemical‑free”) unless you can define and substantiate exactly what you mean.
- Check you have the right allergen bolding, summary statements and formatting for food under PEAL.
- Ensure symbols or icons don’t contradict or dilute legally required text, and that warnings are clearly visible in normal use.
- Verify that pricing or promotional blurbs used on swing tags or stickers are consistent with pricing obligations.
4) Design for legibility and permanence
- Keep mandatory information on a contrasting background with sufficient font size and spacing.
- Place critical warnings where consumers will reasonably see them (e.g. front or main panel when required by a standard).
- Ensure labels are durable for the product’s lifespan and distribution conditions (e.g. moisture, abrasion, freezing).
5) Run an ACL and category‑specific legal check
- Audit every representation on pack against the ACL (accuracy, clarity, no omissions that could mislead). If in doubt, cross‑check the general prohibition on misleading conduct and your obligations around specific representations under Section 29.
- Confirm product‑specific rules: PEAL for food, pregnancy warnings for alcohol, button battery warnings and safety symbols for electronics, measurement marks under NMI, and ingredient naming for cosmetics.
6) Align your website and e‑commerce with your packaging
- Make sure online descriptions match your pack claims. Differences between on‑pack and online can create ACL risk.
- Publish clear customer terms, including delivery, returns and warranties. Many businesses use Terms of Sale alongside Website Terms & Conditions.
- If you use QR codes that collect personal information, ensure your Privacy Policy covers the data you collect and why.
7) Keep records and implement version control
- Retain substantiation files for claims, supplier attestations, test reports, and artwork version histories.
- Use a simple approval sheet capturing who approved each label and when, with references to the standards checked.
8) Monitor updates and schedule reviews
- Set calendar reminders to review labels before reprints or new production runs.
- Watch for regulator guidance updates, especially around green claims and product safety.
Sector‑Specific Labelling Essentials
While the ACL applies across the board, many industries have additional, highly specific labelling obligations. Here are some common categories and what to watch:
Food and Beverage
- Allergens: Apply PEAL requirements - plain English names and prescribed formatting for priority allergens. Cross‑contamination advisory statements must be accurate, not boilerplate.
- Nutrition and ingredients: Follow the Food Standards Code for ingredient lists, characterising ingredients and nutrition information panels.
- Date marking: “Use by” vs “best before” has legal consequences, including for recalls and food safety inspections.
- Country of origin: Ensure the right bar chart and text (for food) or accurate origin claims (for non‑food) - unsupported “Australian made” statements are risky under the ACL.
Alcohol
- Display the mandated pregnancy warning label as prescribed (size, colours, wording and placement matter).
- Standard drinks information and other category rules must be clear and consistent with alcohol labelling requirements.
Cosmetics and Personal Care
- Cosmetics typically require ingredient lists using appropriate names and must comply with AICIS obligations.
- Avoid therapeutic claims (e.g. “treats acne”, “heals dermatitis”) unless your product is a therapeutic good - which would trigger TGA rules.
- Claims like “hypoallergenic”, “dermatologically tested” or “natural” must be truthful and supportable to comply with the ACL.
Electronics, Toys and Household Products
- Products containing button/coin batteries must comply with the mandatory safety standards, including warning statements and secure battery compartments.
- Toys and children’s products often require age‑grading, hazard warnings (e.g. small parts) and, where relevant, testing to applicable standards.
- Check for electrical safety marks and any state registration requirements if you sell electrical equipment.
Online‑Only Or Direct‑To‑Consumer Brands
- Your online product pages, imagery and advertising are treated the same way as labels under the ACL - consistency is critical.
- Clear online terms help set expectations and reduce disputes. Consider pairing Website Terms & Conditions with robust Terms of Sale covering refunds, delivery and warranties.
Contracts And Policies That Support Labelling Compliance
Strong paperwork behind the scenes helps you maintain accurate labels, manage risk and respond quickly if something changes. Depending on your business model, consider:
- Supply Agreement: Set expectations around ingredient/component specifications, change notifications, evidence for origin/sustainability claims, and indemnities if supplier information is wrong. A tailored Supply Agreement can build these obligations in from day one.
- Manufacturing Agreement: Allocate responsibility for label content, proofing, artwork sign‑off, quality checks and non‑conforming product. A clear Manufacturing Agreement can help prevent costly misprints and recalls.
- Terms of Sale: Outline product descriptions, delivery, refunds, and any limitations that are lawful and fair under the ACL. Use comprehensive Terms of Sale that match what you say on your labels and online.
- Warranties Against Defects Policy: If you offer a warranty, the ACL prescribes specific wording and information. A compliant Warranties Against Defects Policy ensures customers get the right details and reduces legal risk.
- Privacy Policy: If your packaging or marketing funnels customers to a QR code, app or website that collects personal data (e.g. for promotions or warranties), make sure your Privacy Policy covers those collections and uses.
- Trade mark protection: Protect your brand name and logos on pack. Registering your brand through trade mark helps you stop copycats and defend your reputation.
The right mix of documents will depend on your products and channels. If you’re unsure what you need, it’s worth getting tailored advice so your legal documents match how you operate in practice.
What Happens If You Get It Wrong (And How To Stay Ahead)
Labelling mistakes can be expensive. Consequences include regulator investigations, product warnings or recalls, infringement notices, penalties, delisting by retailers or marketplaces, and reputational damage. Where labels or online claims are misleading, you may face action under the ACL - the misleading conduct provisions are broad and actively enforced.
Practical ways to minimise risk:
- Substantiate before you claim: Build a habit of collecting proof before approving labels (not after a complaint).
- Use checklists and sign‑offs: A simple compliance checklist for each SKU helps catch formatting and wording issues, especially for allergens and warnings.
- Keep your web copy in sync: Marketing, e‑commerce and packaging should say the same thing, in the same way.
- Schedule periodic reviews: Re‑check labels ahead of reprint cycles or when suppliers change specs.
- Train your team: Anyone who writes copy or artworks labels should understand the basics of the ACL and your category rules.
If you do identify a problem on market, act quickly. Early, transparent steps to fix, relabel or notify customers can reduce enforcement risk and preserve trust.
Key Takeaways
- There isn’t one single “new law” - Australian labelling compliance has evolved through updated standards (like PEAL), mandatory warnings (pregnancy and button batteries) and a stronger focus on environmental claims.
- The ACL applies to every label and online listing. Claims must be accurate, clear and backed by evidence, and some categories impose extra, specific labelling rules.
- Build a step‑by‑step process: map the rules, collect data, draft precise claims, design for legibility, run legal checks, align your website, and keep records.
- Food, alcohol, cosmetics, electronics and children’s products each have unique requirements - don’t copy generic labels without checking your category’s standards.
- Use contracts and policies (Supply Agreement, Manufacturing Agreement, Terms of Sale, Privacy Policy and trade marks) to support accurate labelling and manage risk across your supply chain.
- If something changes - ingredients, suppliers, claims or standards - update labels promptly and document your decisions to stay on the right side of the law.
If you would like a consultation on how Australian labelling laws apply to your products - or a review of your labels, packaging and legal documents - you can reach us at 1800 730 617 or team@sprintlaw.com.au for a free, no‑obligations chat.








