The new Country of Origin Labelling (CoOL) deadline is fast approaching. Infact, it is in 11 weeks, the deadline is 1 July 2018.
Recently, I have had a few enquiries about how to implement the Country of Origin Food Labelling Information Standard 2016 (Standard). So I have decided to review the most common queries. The CoOL regulations will be a lawful requirement for all food and beverage products sold in a retail environment.
3 Key Aspects About Country of Origin Labelling
Firstly, the ‘retail environment’ includes private corner stores, fruit shops, big supermarkets and even street/farmers markets.
Secondly, you will need to determine if you have a ‘priority’ or ‘non priority’ product.
Thirdly, calculating the correct percentage in the bar chart is your responsibility.
Statement, Symbol, Format
Using the correct Country of Origin Labelling statement or symbol will be crucial to implementing the law. There are the four formats:
1. 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 will use 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
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.
‘Priority’ foods grown, produced, or made in Australia must use a three component standard mark label. You can choose the horizontal or vertical format.
Determining 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. 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, for example:
There are many versions of the statement – refer to page 10-12 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.
To make a ‘grown’, ‘produced’ or ‘made’ claim for a non-priority product, you are still required meet the Standard code, see page 6.
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 for more information.
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
– 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”
– if the products Australian ingredient quantities vary from time to time then an ‘average’ claim may be made when the criteria is met – refer to page 18
– 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 calcultation and the flour not – refer to page 17.
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:
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.
The Bar Chart Display
Whilst the true claim may be 88% Australian contents the bar chart would need to indicate 80%. 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. 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!
Over time the standard mark (kangaroo and bar chart) will become a symbol of safe, clean food. It will provide Australian consumers with a sense of reassurance about the origin (and often quality) of the product so best embrace this change!
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.
Note: this article a summary of the Standard, not legal advice. Refer to the Standard Guide for more detailed information.
If you enjoyed this article then you may also like to have a read of our Label Design Checklist – 9 Essential Tips.