© Silliker Australia Pty Ltd 2017
Keep your CoOL - New Country of
Origin requirements
Heather Hunt - Compliance Manager
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© Silliker Australia Pty Ltd 2017
Speaker
Heather Hunt
Compliance Manager
Mérieux NutriSciences
© Silliker Australia Pty Ltd 2017
Webinar Disclaimer
DISCLAIMER: Information presented on INFORM presentations and webinars are for updates and information purposes only. They do not constitute legal advice or legal opinions. Mérieux NutriSciences Australia makes no claims, promises or guarantees about the accuracy, completeness or adequacy of the information presented in this INFORM webinar.
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Who is Mérieux
NutriSciences?
Click on the image to play the video.
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MERIEUX NUTRISCIENCES CONNECT
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A cost effective integrated program of leading scientific and
technical services
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Agenda
• Background and purpose • Commencement & transition period • Key changes • Applicable products • Non Priority Foods • Key features of required information • Design requirements • Options available for different origin products • Current versus future state • Points to be considered • Take home points • Questions
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Objective of Webinar
On 1st July 2016 the new Country of Origin labelling requirements commenced.
This webinar will discuss the new Country of Origin requirements and endeavour to provide the participants with pointers on what to consider in the label development process to be ready to comply.
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For many years consumers have been demanding clearer and more meaningful country of origin claims on food labels.
Consumers are interested in where something was made/packaged and how much of the food was grown in Australia.
Surveys found that consumer don’t care about the country of origin of some types of foods.
The new requirements aim to enable consumers to make more informed choices about the food they buy.
The new requirements aim to ensure that most consumers get adequate information to purchase products according to personal preferences.
Background and purpose
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New Country of Origin requirements commenced on 1st July 2016.
Businesses have two years to comply with the new requirements.
Stock in trade made and labelled until the 30th June 2018 will be compliant if it meets current Food Standards Code and Australian Consumer Law requirements.
Stock made and labelled from 1st July 2018 must meet the new Country of Origin requirements.
Commencement and transition period
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Most retail foods that are grown, produced or made in Australia will include the following Country of Origin Information, presented in a box known as the standard mark:
a logo (kangaroo in a triangle symbol),
a bar chart (showing the proportion of Australian ingredients),
an explanatory statement (declaring the proportion of Australian ingredients).
From 1st July 2018 the Australian Made Australian Grown (AMAG) licenced logos will not be able to be used on food products.
Licenced non food products can continue to use the AMAG logos.
Safe Harbour Requirement for “Made in…” have changed Product only needs to be substantially transformed.
50% of manufacturing costs requirement has been removed.
Records must be kept for 1 year to substantiate how the explanatory statement was obtained/calculated.
Key changes to Country of Origin
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Applicable regulations:
Country of Origin Food Labelling Information Standard 2016 Reformed Australian Consumer Law (ACL) Safe Harbours
Note: Country of Origin requirements will be removed from Food Standards Code.
Support tools:
ACCC guideline to substantial transformation (expected completion March 2017) Country of Origin Food Labelling Factsheet
Country of Origin Food Labelling – Frequently Asked Questions
Media campaign for consumers
Country of Origin Food Labelling Style guide
Country of Origin Tool (online calculator)
Key changes to Country of Origin
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Country of Origin websites:
Country of Origin Labelling (CoOL) website -
http://www.industry.gov.au/industry/IndustrySectors/FoodManufacturingIndustry/Pages/Country-of-Origin-Labelling.aspx
Business CoOL website - https://www.business.gov.au/info/run/goods-and-services/selling-goods-and-services/selling-goods/country-of-origin-food-labelling
Consumer CoOL website - http://www.foodlabels.industry.gov.au/
Country of Origin Online Calculator - http://www.originlabeltool.business.gov.au/
Key Changes to Country of Origin
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“Priority foods” will have to comply with the new requirements. Include all retail foods eg foods sold at supermarkets, delicatessens, farmers markets.
Excludes foods sold for immediate consumption at restaurants, canteens, schools, catered functions, prisons, hospitals and medical institutions.
Excludes food sold on premises where its made and packed, at express order of purchaser, at fund raising events and food for special medical purposes.
“Priority Foods” are any foods that are not “Non Priority Foods”
“Non priority foods” will not have to comply with the new requirements. The Country of Origin statement will still need to be declared and meet the ACL
Country of Origin Safe Harbours.
“Non priority foods” can voluntarily comply with the requirements.
Non food products will not have to comply to the new requirements. The Country of Origin statement will still need to be declared and meet the ACL
Country of Origin Safe Harbours ie. Product of and Made in.
Applicable products
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Non Priority Foods are:
Seasonings Includes salt, salt substitutes, pepper, dried herbs and spices, spice, seasoning or
flavour powders/pastes, dry cures and surface rubs for meat or fish, meat tenderizers.
Does not include mustards, sauces, chutneys or relishes.
Confectionery Includes chewing gum, cocoa and chocolate products (including spreads), ice cream
and ice confections, other frozen confectionery, popcorn, crystallised/glace fruit, edible cake decorations, other products that primarily contain sugar or sugar products.
Does not include sugar, icing sugar, icing sugar mixes, jam, honey, marmalade, non cocoa/chocolate based spreads.
Biscuits and snack foods Includes chips, crackers, rice cakes, biscuits, cookies, crackers, pretzels, cones, wafers,
ready to eat savoury snacks (eg potato or vegetable crisps/sticks/straws, bacon/pork crackling and prawn chips).
Does not include cakes, muesli bars, processed nuts (including coated nuts and nut mixtures like mixed fruits and nuts).
Non Priority Foods
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Non Priority Foods are:
Bottled water Includes natural mineral water, non-carbonated water, mineral and source waters,
soda water and carbonated mineral water.
Soft drinks and sports drinks Includes water based carbonate/non carbonated flavoured drinks, sports drinks,
energy drinks, electrolyte drinks, carbonated fruit or vegetable drinks, powders or syrups for making these drinks.
Does not include non carbonated fruit or vegetable drinks, milk, cereal/nut/legume drinks sold as milk substitutes.
Tea and coffee Includes coffee, coffee substitutes, instant coffee, decaffeinated coffee, tea, herbal
infusions, instant tea, other similar cereal and grain beverages, excluding cocoa (in dry or liquid form).
Alcoholic beverages Any beverage with more than 0.5% alcohol by weight or volume.
Non Priority Foods
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Key features of Standard Mark
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Bar chart
Explanatory statement
- Indicates whether Grown, Produced,
Product of, Made or Packed in
- Indicates percentage Australian Ingredients
Logo
Option of calling out country of origin of
individual ingredients
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The percentage Australian ingredients is represented in the bar chart using the following icons:
Appropriate bar chart graphic
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Calculation must be based on the proportion of ingoing weights of Australian ingredients and total food weight.
ie. not after water loss on cooking or rehydration by consumer.
Special rules for average proportion calculation.
Processing aids are not included in the calculation.
An ingredient is “Australian” only if fully grown and produced in Australia. For compound ingredients, only the sub ingredients that were fully grown and
produced in Australia can be counted towards the Australian ingredients.
Water has special calculation rules.
Calculation rules for Australia proportion
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Information must appear together in a box – cannot be split
Recommended 3mm clearance around box.
Can appear anywhere on label in a legible format base not recommended
Colour combinations green, gold & black combination
monochrome
Information can be orientated in portrait or landscape
Recommended typeface for text is “Interstate Bold”
No minimum text height, only bar chart proportions: bar chart length should equal triangle side length
bar chart height should equal explanatory text capital letter height
Other display requirements
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Requirements vary based on where the product is made, packaged and the origin of its ingredients.
Products Made from 100% Australian ingredients.
Product of/Made in Australia products with some imported ingredients.
Product of/Made in Australia products exported and re-imported.
Product of/Made in Australia products with variable Australian content.
Food Packed in Australia
Varies depending on how many countries substantially transformed in and whether it has Australian ingredients.
Imported Food
Varies depending on how many countries substantially transformed in and whether it has Australian ingredients.
Requirements for Standard Mark
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The following standard marks can be used:
where: ‘X’ is the phrase ‘Grown in’, ‘Produced in’, ‘Produce of’ or ‘Product of’
‘Y’ is the word ‘Grown’, ‘Produce’, ‘Product’ or the kind of food eg ‘Peas’
There a number of various options the Country of Origin statement can be declared
Options for products made from 100% Australian ingredients
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If a food is grown, produced or made in Australia; and exported from Australia and then re-imported to Australia, the below standard mark can be used if:
the mark include a description, in brackets, of the processing that occurred outside Australia,
the product has not undergone a substantial transformation when overseas,
the product has not been combined with non-Australian ingredients when overseas,
the product may have undergone some processing (e.g. cleaning, shelling, packaging, re-packaging) and may be combined with other Australian ingredients.
eg. The standard mark for Australian macadamias sent to Fiji for shelling before being returned to Australia would be:
Options for Product of/Made in products exported and re-imported
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Products can indicate an average content if variable Australian content, if:
The explanatory statement declares the information needed for a consumer to obtain information about actual origin.
Eg barcode or other device, batch number, lot, date of manufacture or date mark
If this information enables a consumer to be able to find out: the proportion by weight of Australian ingredients of the food in that batch
the period that was used to calculate the average (if not declared in the mark)
where ‘BC’ is the appropriate bar chart to represent ‘P%’,
‘P%’, is at least average percentage Australian ingredients
[how to get details]’ identifies information for consumers
Standard mark can indicate origin of ingredients:
a phrase added at the end of the explanatory statement that declares the country of origin of each ingredient named, if
“with” used at start of the phrase
each ingredient named originates exclusively in the country specified
Other declaration options
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Unpackaged products
Unpackaged meat, fish, fruit and vegetables must provide a Standard Mark in one of the following ways:
1. A Standard Mark label/sticker on the food or accompanying the food (ie tag), or
2. Standard Mark displayed with the food. Must provide all required information.
Minimum text height of 5mm for food in refrigerated assisted service display cabinet.
Minimum text height of 9mm in all other instances.
Note: Fruit and vegetables with transparent packaging can provide a Standard Mark on the package or displayed with the food.
Small packages (Retail Package with a surface area of <100cm2)
If a product is in a small package:
Only the Country of Origin explanatory statement needs to be provided in a box (even if the kangaroo logo and bar chart would normally be required)
Unpackaged products and small packages
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100% Australian honey.
100% Basmati rice, grown and processed in India.
Mixed nuts packed in Australia with 35% Australian ingredients.
Current versus future state
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Current versus future state
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Frozen ready meal that has not undergone substantial transformation in Australia with 42% Australian ingredients.
Musk sticks that have undergone substantial transformation with 99% Australian ingredients.
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Will standard marks be voluntarily provided for Non Priority Foods?
Need to determine when to start transitioning product label artwork.
Need to decide preferred format options and standard marks to use for consistency.
Need a plan for training of stakeholders.
Need a plan for modifications required to support documents eg. Product Specifications, Label Templates.
Need to decide system for record keeping.
Points to be considered
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Take home points
Only applies for Priority Foods and may be voluntarily provided for Non Priority foods.
Australian Made Australian Grown licenced logos cannot be used on any foods from 1st July 2018.
Ensure Style Guide requirements are met.
Kangaroo logo can only be used on products qualifying as Australian Grown, Product of Australia or Made in Australia.
Will your labels be compliant with the new requirements by 1st July 2018?
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Technical Services
What we do:
Food label compliance assessment:
Label compliance with FSC; Claim verification (ACL); Trade measurement & other relevant Standards & Codes of Practice
Food label development consulting
Nutrition and health claims assessment and Health Star Rating consulting
Crisis management (recalls, withdrawals, impounded goods etc)
Customer complaints – Investigation and management
Training
Project work on request
Non food compliance work
With over 15 years experience with all major National Grocery Retailers and 100’s of both Australian and off shore suppliers.
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Webinar program
Visit our website to have a look at our webinar program and access our
webinar recordings and presentations:
www.merieuxnutrisciences.com/au/digital-solutions/mxns-inform-webinar
Thank you for attending and interacting today.
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