Transitioning from a smaller to larger food production operation, online to retail, will always have its teething and growing issues. Labelling does not need to be one of them! Label re-runs and product recalls can be costly (in terms of money and brand reputation) so it pays to investigate the labelling compliance framework and options ahead of time to make ‘future-proof’ decisions concerning your product.
So, when do you actually need to start thinking about a product label?
From the start! Your branding is what will identify your product and attract target consumers so establishing that aspect and consumer loyalty early on may be a good way to get a product up and running.
That said, labelling can be an expensive start-up cost so it may be something you may want to delay (if possible) until you have more certainty about your market and any health messaging you want to use on labels or advertising.
Exemptions from labelling requirements
In Australia, some retail food products are exempt from full labelling requirements such as foods:
- not in a package; or
- made and packaged on the premises from which they are sold (for example, bakery bread); or
- packaged in the presence of the purchaser; or
- that are whole or cut fresh fruit and vegetables (other than seed sprouts or similar products) in a package where the contents (nature and quality of the food) is clearly visible; or
- that are delivered packaged, ready for consumption, at the express order of the purchaser (for example, take-away pizza), except where the food is sold from a vending machine; or
- sold at a community or charitable organisation fundraising event; or
- displayed in an assisted service display cabinet (for example a deli cabinet).
While exempt from full labelling requirements, these retail foods do need to provide the name of the food and certain other information such as mandatory warning statements (like sugar alcohols and caffeine) and if the product contains ‘genetically modified’ or irradiated ingredients, for instance. Required information must accompany or be displayed with the food, declared to the purchaser, or provided to the purchaser on their request.
Importantly, where a product makes health claims, a nutrition information panel must be provided (and it must be compliant!). This extends to products sold online only and using website advertising with health claims.
There are also some exemptions for packaged foods with more than 1 layer of packaging, sold in individual portion packs (but not designed for individual sale) and some foods for catering purposes.
Hampers
Did you know, food sold in hampers must be labelled appropriately? This includes each food in the hamper, and the hamper itself.
We can see that the exemptions are quite limited and if in doubt, check it out rather than have the regulator at your door! Food Envy Labelling Services can help you determine your labelling requirements and explore with you health messaging that will help you achieve your target market goals. Contact Michelle today to discuss your product and labelling needs.
Michelle
References
Australia New Zealand Food Standards Code – Standard 1.2.1 – Requirements to have labels or otherwise provide information. Available from: https://www.legislation.gov.au/Details/F2020C00727.
Australia New Zealand Food Standards Code – Standard 1.2.3 – Information requirements – warning statements, advisory statements and declarations. Available from: https://www.legislation.gov.au/Details/F2021C00202.
Australia New Zealand Food Standards Code – Schedule 9 – Mandatory advisory statements and declarations. Available from: https://www.legislation.gov.au/Details/F2021C00195.
