The Federal Government released details of its proposed country of origin labelling (CoOL) scheme in a joint statement (Joint Statement) of the Prime Minister, Minister for Industry and Science and the Minister for Agriculture on 21 July 2015.

This announcement, which was not expected until August, follows a public consultation on CoOL reform options which received over 17,800 submissions.

A key feature of the proposed CoOL scheme is the mandatory labels for food produced or packed in Australia which are intended to provide a quick reference tool for consumers to easily identify the origin of food products. Interestingly the mandatory labels approved by the Federal Government don't actually require the origin of the food to be stated.

The Government has opted instead for a percentage bar that indicates the proportion of Australian ingredients. While this will identify if food is 100% made from Australian ingredients, any food product containing imported ingredients will still leave consumers wondering, what is the country of origin of my food?

Examples provided in the Joint Statement include:

Click here to view the image.

Under the proposed scheme companies are also permitted to include a 'packed in' statement if it is accompanied by an origin claim.

It is uncertain how the proportion will be calculated (i.e. value, weight or volume) although industry briefings indicate that the existing "50% costs rule" for “made in” claims will be abolished.

In response to concerns raised by industry it is also anticipated that:

  • some products, including alcohol, soft drinks, sports drinks, seasonings, biscuits, snacks and confectionery will be exempt; and
  • the scheme will include some flexibility around 'average' percentages and allowances for seasonal variation.

The Federal Government is yet to obtain the necessary State and Territory Governments' agreement to the scheme. While CoOL reform has garnered strong public support it is uncertain whether the Federal Government's proposed labels are missing the key ingredient to secure support across the states.

It is also remains to be seen whether the exemptions and flexibility of the regime are sufficient to address concerns raised from within the food industry.

Notwithstanding these potential hurdles, the Joint Statement indicates that the mandatory roll out of the scheme will commence in 2016 and, perhaps optimistically, it refers to voluntary take up of the CoOL mandatory labels in 2015.

What do you need to do?

Food manufacturers using imported ingredients should start to review the proportion of ingredients which are Australian grown or manufactured in preparation for the roll out of the CoOL scheme.

Food labels containing other statements such as 'Australian 'Made' or 'Product of Australia' will also need to be reviewed and most likely removed from the product if these are not consistent with the information on the mandatory CoOL label.