Australia’s Country of Origin Labelling (CoOL) system is a symbol of the safe, clean food we are known for globally.
The CoOL laws became mandatory for all producers and manufacturers of food and beverage products on 1 July 2018.
Even though the laws changes some time ago, but I am still asked how to implement the Country of Origin Food Labelling Information Standard 2016 (Standard). I have decided to review the most common queries.
I have sifted through the The Australian Competition and Consumer Commission (ACCC) guidance, the official Style Guide and the Information Standard to provide answers to the most common queries.
3 Key Steps To Country of Origin Labelling
The CoOL regulations is a lawful requirement for all food and beverage products sold in a retail environment. The ‘retail environment’ includes private corner stores, fruit shops, cafes, big supermarkets and even farmers markets.
Firstly, you will need to determine if you have a ‘priority’ or ‘non priority’ product.
Secondly, calculating the correct percentage in the bar chart is your responsibility.
Thirdly, determine the appropriate CoOL Statement, Symbol and the format.
1. What Is A ‘Priority’ Or ‘Non Priority’ Product?
All foods must carry Country of Origin Labelling or statement. Whether it is classified as a ‘priority’ or ‘non priority’ product will determine the type of label or statement. Non priority foods ONLY need a country of origin text statement about where the food was grown, produced or made. Non priority products DO NOT need to be in the box. Sure, this is great news if you have a non priority product. However, vast groups of Australian consumers do prefer to know where their food came from. So use it if you can.
The standard mark for non priority foods is actually optional. The simple statement is the legal obligation, for example:
There are many versions of the statement – refer to page 13-24 of the Country of Origin Food Labelling Information Standard 2016 to determine which you are permitted to carry.
Non Priority Product List
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.
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.
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.
Soft drinks and sports drinks: water-based favoured 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).
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, 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.
Alcoholic drinks: any beverage with more than 0.5 per cent – alcohol (by weight/volume).
Whilst there are many non priority products, my advice is if your product scores a high rating on the bar chart you would be wise to include it on your labels. Australian consumers will not grasp all the non priority food categories and if you do not have the symbol many will simply assume it is imported. Consumer ignorance may harm your sales so why not transition to using the correct symbol next time you print your labels or packaging, whether or not your product is classified as non priority.
Country of Origin Labelling and Imported Products
‘Priority’ imported food and beverages not grown, produced or made in Australia, may be represent in a variety of formats:
Refer to pages 27-29 of the Country of Origin Food Labelling Information Standard 2016 for more information.
Grown, Produced and Made in Australia
I am often asked which claim should I use? Grown in or produced in? This one seems to confuse people.
Using either of these statements and ‘Made in’ for your label will indicate to a consumer that your product meets the requirements to make an Australian origin claim.
‘Grown in or produced in’
Both statements have a 2 part meaning: all of the ingredients are Australian AND major processing of the product occurred in Australia. The on you choose will depend on whether the product is basically a pure product for example ‘vanilla paste’ or has involved more processing like ‘vanilla syrup’.
This claim means substantial transformation in that country in which it was made. The product may not contain 100% Australian ingredients but major processing of the raw ingredients occurred. So, you may ask then what does ‘substantial transformation’ mean? The answer is, when the end product is something fundamentally different from its imported ingredients.
Methods of substantial transformation for food production include:
• Chopping or slicing of agricultural produce
• Curing food, grinding and marinating
• Boiling, broiling, frying, grilling, steaming and mixing
• Food fermentation
Minor processing includes shredded, slicing, roasting, canning, bottling, crumbing, freezing, reconstituting or e-packing. The ‘made in’ claim cannot be employed if only minor processed has been used to change the presentation of the food.
‘Packed in Australia’
This claim a little easier to grasp. If a product has only had minor processing after being imported then packaged you must claim ‘Packed in Australia’.
Major processing examples:
– imported blueberries and made into jam could claim ‘Made in Australia from X% Australian ingredients’ assuming the sugar and other ingredients are Australian.
– imported oats, toasted with honey and cinnamon, mixed with fruit and nuts and sold as a muesli could claim ‘Made in Australia from X% Australian ingredients’.
– imported avocados, made into guagamole could claim ‘Made in Australia from X% Australian ingredients’ assuming some of the other ingredients are Australian.
Minor processing examples:
– importing blueberries, freezing and packaging could claim ‘Packed in Australia’
– importing oats, grinding them and packaging to make instant oats you could claim ‘Packed in Australia’
– importing avocados, extract the oil and package as avocado oil could claim ‘Made in Australia from 0% Australian ingredients’
If you are struggling to determine whether your product has undergone substantial transformation the CoOL online tool is your best bet. Don’t be daunted by the ‘Before you start checklist’ and make sure your answers are correct before proceeding.
2. Determining The Correct Percentage
Ok so this part is creating a few frustrated producers out there or at least that is the feedback I am getting. Simply put, ‘priority’ food and beverages must disclose the amount of Australian ingredients when a product is grown, produced, made or packed in Australia.
SINGLE INGREDIENT foods grown or produced in Australia with exclusively Australian contents will have the 100% bar chart -bold
MULTIPLE INGREDIENT foods grown, made or produced in Australia need to claim the minimum proportion of Australian ingredients in a percent format, e.g. ‘…. from at least xx% of Australian ingredients’
VARYING INGREDIENTS: if the Australian ingredient quantities vary from time to time then an ‘average’ claim may be made when the criteria is met
COMPOUND INGREDIENTS: many products will contain compound foods. Only the Australian grown or produced portion may be included in the calculation. For example if a pasta is made of flour, eggs and water. And the flour is from another country then the eggs must be included in the calculation and the flour not.
The percentage of Australian content is determined based on the individual ingredient weight. Each is ingredient should be calculated on ‘ingoing weight’ (weight of raw ingredients NOT the weight of the ingredient after processing or cooking). This is the calculation for ingredients that do not vary in weight and is most commonly used:
You are allow to identify a particular ingredient which is sourced from another country. For example if the product is a curry and the spices come from India. You may want to emphasis the authenticity of the product. Naming the origin of that ingredient can be added to the standard mark.
Once you have all the ingredients individual percentage then you just calculate the total percentage. Refer to pages 14-19 for more information about calculations.
More details about using the appropriate bar chart may can be found on page 6 & 7 of the Country of Origin Food Labelling Information Standard 2016.
The Bar Chart Display
Using the appropriate bar chart is a legal obligation. The standard states that the “bar chart is generally shaded in 10 per cent increments; rounding down”. This should be adhered to except with foods that contain less than 10% and more than 95% Australian ingredients
Whilst the true claim may be 88% Australian contents the bar chart would need to indicate 80%. If a product contains 98% Australian ingredients the bar chart is shaded to 95%. Likewise when a product contains 8% Australian ingredients the bar chart is shaded to 5%. Percentages between 11 and 94 are required in 10% increments. I know this will be disappointing to many of you!
3. Choosing The Correct Label: Statement Or Symbol
Using the correct format for the Country of Origin Labelling statement or symbol will be crucial to implementing the law.
There are the four formats:
- Text only
2. Text in a box
3. Text and bar chart graphic in a box (two component standard mark)
4. Text, bar chart and kangaroo triangle in a box (three component standard mark)
The format you choose is based on five considerations for each product – NOT each brand or range but each individual product:
- where it was grown
- where it was produced
- where it was made
- where it was packed
- where are the ingredients from
‘Priority’ foods grown, produced, or made in Australia must use a three component standard mark label. You can choose the horizontal or vertical format. This symbol is the pinnacle and if you CAN use it then by all means do. A product can only carry ‘Produced in Australia’ with the 100% bar chart if it contains exclusively Australian ingredients.
For more information about the format refer to pages 13-24 of the Country of Origin Food Labelling Information Standard 2016.
The way the symbol is portrayed also has guidelines. Considerations include the label placement, orientation, clear space, minimum size, incorrect label usage. The typeface for the label, symbol or text statement is Interstate Bold. Although it is only a recommendation and is not enforced by law.
Colour usage must be adhere to. The label can be portrayed in one colour (any colour) or green, gold and black. The colour breakdowns are available in the Country of Origin Labelling Style Guide.
For the four colour process or digital printing applications the CMYK version should be employed. This will be most useful for packaging, labels and printed marketing materials. The Pantone colour reference is most likely to be used for outer cartons. The RGB colours refer to digital applications like in website, social media and video.
Country of Origin Label Library
In the library you will find the three component standard mark: Text, bar chart and kangaroo triangle in a box as a whole and individual elements. The country of origin label should be customised to suit your product. Once you know what type of standard mark you should have, the percentage value then you can create you own label.
Professional graphics software such as Adobe Illustrator or Adobe Acrobat Pro is required to edit these files. They are provided in PDF and EPS files. Choose whether the portrait and landscape version will fit best on your packaging or label.
Its not mandatory but the recommended typeface is Interstate Bold – for text within or without the label boundary.
Simply go to the library and download the set, it includes:
• Label boundary (resize proportionately to not skew the corners and as appropriate)
• Kangaroo in triangle – be careful not to distort when resizing
• Bar chart (fill the bar chart in accordance with the Information Standard – see above percentage breakdowns)
Edit or insert the text which is most appropriate for your product.
In this article I have accessed the following resources to help you decide which symbol and bar chart or statement is correct for your product. Resources include:
– Country of Origin Food Labelling Information Standard 2016
– Country of Origin Labelling Style Guide
– Country of Origin Label Online Tool
– Country of Origin Label Library
Remember you may need a different label for each individual product. One label will often NOT represent the product range as whole.
Yes, the Country of Origin Food Labelling Standard can be complex but, adopting the code and using it as a badge of honour will be a smart strategy providing your ingredients are primarily Australian.
For more information on Country of Origin Food Labelling you can call me or visit business.gov.au/foodlabels.
If you enjoyed this article then you may also like to have a read of our Label Design Checklist – 9 Essential Tips.
Note: this article a summary of the Standard, not legal advice. Refer to the Standard Guide for more detailed information.