New ingredient suppliers? Don’t forget the label.

Most packaged foods for retail sale in Australia must comply with country of origin labelling (CoOL) requirements. Visit parts 1 and 2 of our CoOL series for a refresher on the CoOL requirements.

Global supply chains have been interrupted due to COVID-19. Given this, businesses with new, temporary suppliers of ingredients need to ensure labels continue to be accurate and compliant with CoOL requirements.

My labels are already printed – is it too late?

Not at all. Businesses should review their packaged food labels and take steps to correct any CoOL that is no longer accurate due to changes in sources of ingredients or manufacturing processes.

Some examples of corrective action include:

• printing updated labels and in-pack leaflets
• stickering over incorrect country of origin claims
• updating point of sale information and product descriptions on websites
• explaining the changes to a product’s country of origin on the websites and social media pages of the business

The corrective action taken should have regard to the additional labour, cost and time involved, the length of time the temporary measures are expected to be in place and the number of consumers likely to be misled.

The good news is the ACCC has confirmed it will take a proportionate approach to enforcement and is unlikely to take action against businesses that have made genuine and reasonable efforts to comply with CoOL requirements and keep consumers informed of the changes.

Next steps.

Check those labels! While the ACCC has indicated it will take a pragmatic approach, it will be important for a business to be able to demonstrate it has taken reasonable steps to prevent consumers from being misled by inaccurate country of origin claims.