4. Labeling Requirements

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4. Labeling Requirements

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General Foods
Australia

This section provides information on labeling requirements and the label approval process.

4.1 Mandatory Labeling Parameters

General labeling requirements for all foods are covered under a number of individual general standards in Part 1.2 (Labeling and other information requirements) of the FSC [1].

Figure 1. Screenshot of Part 1.2 [1] the Standards relating to labeling.

The mandatory elements for a food in retail packaging are described in Standard 1.2.1 [2].

Figure 2. Required label information from clause 1.2.1-8 (1) of ref [2].

Some of the items listed in Figure 2 are not required on alcoholic beverage labels. For example, a Nutrition Information Panel (NIP) as described in Standard 1.2.8 [3] is not mandatory. Details for a list of relevant parameters are provided in Table 1.

Item	Details	Standard
Name/description (Mandatory)	There is no prescribed name. ‘Whisky’ and a brand name would be suitable. Other terms can be added such as ‘single malt Scotch’, ‘blended whisky’, ’12 year old’ and ‘Japanese pure malt whisky’. Geographic locations can be added, provided the information is accurate and truthful. E.g. A single malt Scotch would need to be aged and bottled in Scotland.	Clause 1.2.2-2 [ref 4] (see Figure 3)
Lot identification (Mandatory)	Each alcoholic beverage must have a unique ‘lot’ or ‘batch’ identifier on its packaging. There is no standardized format for creating and placing these identifiers on the label. However, in general, they commonly take the form of an alpha-numeric sequence and are placed near the barcode.	Clause 1.2.2-3 [ref 4] (see Figure 4)
Name and address of supplier (Mandatory)	This could be the manufacturer, packer, or importer. The business address should be complete and include street number, street name, suburb, town, and state/territory in Australia. It must be a physical address, not a post office box.	Clause 1.2.2-4 [ref 4] (see Figure 5)
Statement of ingredients (not mandatory except where there are allergens present)	Listing ingredients on the label of an alcoholic beverage is generally not mandatory. However, some substances require an allergen warning on product labels.	Refer to Section 4.7 below.
Nutrition Information Panel (NIP) (Not mandatory)		Refer to Section 4.7 below.
Allergens statement (mandatory if allergens present)	Some substances require an allergen warning on product labels.	Refer to Section 4.7 below.
Date marking (optional)	‘Best before’ dates are generally not included on spirit labels since the date is generally more than two years after the date marking. If used, then storage conditions must appear on labels.	1.2.5 [ref 5]
Storage conditions (optional unless a ‘best before’ date appears on the product label)	If used, options could include: ‘Store in a cool, dark place’.	1.2.6 [ref 6]
Country of Origin (Mandatory)		Refer to Section 4.7 below.

Table 1: Relevant general labeling parameters.

The following figures provide screenshots relevant to items in Table 1.

Figure 3: Product name/description from clause 1.2.2-2 of ref [4].

Figure 4: Requirement to have a lot identification from clause 1.2.2-3 of ref [4].

Figure 5: Requirement to have a business name and physical address from clause 1.2.2-4 of ref [4].

4.2 Languages

Labels should be in English, although additional foreign language text is also permitted on shared overseas labeling, provided it complies with clause 1.2.1-24 (2) [2]:

Figure 6. Language and legibility requirements for labels from clause 1.2.1-24 of ref [2].

4.3 Mandatory Information on Stickers

It is acceptable to provide mandatory information on a sticker or label attached to an existing product label provided the conditions are met (refer to Figure 7 below).

Figure 7. Use of over stickers from clause 1.2.1-22 of ref [2].

4.4 Product Legal Name

N/A. Please refer to Section 4.4 of specific product Guidebooks.

4.5 Product-specific Labeling Statements

N/A. Please refer to Section 4.5 of specific product Guidebooks for product-specific requirements.

4.6 Authority Approval

Product labels do not need to be approved by the authorities.

4.7 Additional Notes on Labeling

Statement of ingredients

A list of ingredients is not mandatory on alcoholic beverage labels.

Figure 8: Exemption from ingredients list from clause 1.2.4-2 (3) of ref [7].

This does not mean that the label cannot contain references to individual ingredients such as: ‘cinnamon flavored’ whisky, ‘elderflower liqueur’ or ‘rye whisky’. Where allergens are present (refer below) these would often need a label warning for the ingredients in question which would appear on the product label in advisory statements but would still be exempt from a complete ingredients list under clause 1.2.4-2 (3) [7].

Allergen statements

Standard 1.2.3 [8] outlines the requirements for allergens statements on product labels. Since these messages are generally stated in conjunction with the statement of ingredients there is no set format for their presentation in the case of alcoholic beverages labels due to the exemption for an ingredients list in this type of product. Any allergen statements need to be clearly stated and prominent enough to be seen by consumers. Usually they take the form of, ‘Contains x’.

Schedule 9 [9] provides a list of substances for which statements are required. The allergen may be present as a result of an ingredient, food additive or processing aid used in the manufacture of the food:

Figure 9: Sources of allergens from clause 1.2.4-4 (5) of ref [7].

Examples of such statements on alcoholic beverage labels:

“This product is produced with milk products. Traces may remain” (on a wine).
“Produced with egg and milk products and traces may remain” (on a wine).
“Contains gluten” (on liqueur).

Any alcoholic beverage which contains added sulphites in concentrations of 10 mg/kg or more requires the statement: “Contains sulphites”. Spirits distilled from barley, rye, oats, or wheat are not required to declare these allergens on the label since the distilling process renders some allergens safe to consume. Likewise, distilled beverages made from whey are exempt from declaring milk products [10]. However, use of milk products for fining purposes needs to be declared.

Figure 10: Exemptions for allergens declarations from the FSANZ website ref [10].

The exemptions above do not affect the Code requirements for ‘gluten free’ labeling statements. Such claims can only be made when food product does not contain detectable gluten, or oats or oat products; or cereals containing gluten that have been malted, or products of such cereals.

Figure 11: ‘Gluten free’ and ‘low gluten’ claims requirements from clause S4-3 in ref [11].

Nutrition Information Panel (NIP)

Alcoholic beverages are exempt from the requirement for a NIP unless a claim is being made in relation to a nutritional content claim which requires an associated entry in the NIP. For example, ‘low carbohydrate’ or ‘gluten free’.

Figure 12: NIP requirements in relation to a claim on an alcoholic beverage from ref [3].

The only claims that can be made for alcoholic beverages are in relation to energy or carbohydrate levels (e.g., ‘low in carbs’). A claim in relation to gluten does not require a label NIP.

Figure 13: No NIP requirement in relation to a claim on gluten content from ref [3].

Country-of-Origin Labeling (COOL)

In Australia, food labels must include information about the country-of-origin labeling (COOL) of the product, including where each of the ingredients were sourced from and where the product was manufactured [12]. Food that is repacked in Australia may include ‘Packed in Australia’. The Australian Competition and Consumer Commission (ACCC) overseas the COOL requirements and has guidance on its website [13]. There is also an Information Standard [14]. The rules are dependent upon the type of food and the way in which it is sold and are complicated. Alcoholic beverages are categorized as non-priority foods, making including a Country-of-Origin statement on the label a mandatory requirement.

Proposed changes impacting alcoholic beverages

There are two FSANZ proposals underway that will impact these products:

Proposal P1049 – Carbohydrate and sugar claims on alcoholic beverages
Proposal P1059 – Energy labeling of alcoholic beverages

FSANZ is working on both in tandem to enable alignment of potential changes with alterations to the alcohol labeling requirements.

P1049 [15] has undergone industry consultation, with FSANZ putting forward three proposals. FSANZ’s preferred option is to clarify the existing permission to make nutrition content claims about carbohydrate by including an express permission for claims about sugar on food that contains more than 1.15% Alcohol by volume. The submissions are being reviewed and it is expected that a final proposal and gazettal will occur in February 2025 (subject to change).

P1059 [16] considers amending the Code to provide energy (kilojoule) labeling information on alcoholic beverages. This has undergone rounds of consultation and is now planned to follow the same timeline as P1049. The proposed label changes will be a similar format to an NIP as per the example: