Food Labelling Standards Compliance

Food Labelling in Australia

Food Labelling in Australia


Food Labelling Compliance

Food Standards

Food labels provide important information such as nutrition, allergens, and warning statements to help customers make food choices and protect public health and safety.

The standards in the Australia New Zealand Food Standards Code are legislative instruments under the Legislation Act 2003. This Food Standards Code outlines detailed requirements on food labelling.

Food manufacturers and suppliers are responsible to ensure the product label complies with various regulatory schemes in Australia. Compliance with the code is enforced by authorities in all states and territories.

Labelling Requirements

Food labels must be provided and correctly placed for most foods offered for retail sale. Different labelling requirements apply depending on the type of product. Some of the mandatory and voluntary information are outlined below.

Date Marking Information

Food packages must include a “use by date” or a “best before date.” The label must also include instructions for specific storage conditions required to ensure the food will keep for the period specified in the “use by date” or the “best before date.” Date formats must be expressed so that it is easy to identify which number is the day, the month, or the year.

Country of Origin

It is mandatory to add country of origin labelling for food that is sold (including offered or displayed for sale) in Australia. Most food for retail sale in Australia must be labelled with a country of origin. There are different labelling requirements depending on whether the food was grown, produced or made in Australia; packaged in Australia; grown, produced or made in another country; packaged in another country.

Ingredient List

The ingredient list must be in descending order of ingoing weight and a nutrition panel must be included on the label. However, a nutrition information panel is not required for small packages, unless any nutrition claims are made and then it must include a declaration of average quantities of prescribed nutrients.

Health Star Rating System

The Health Star Rating (HSR) is a voluntary front-of-pack labelling system that rates the overall nutritional profile of packaged food and assigns it a rating from ½ a star to 5 stars. The HSR system was implemented in 2014.

The system was reviewed in 2019 and a Review Implementation Plan was endorsed on 17 July 2020. The implementation of the Plan started on 15 November 2020. A two year transition period for the implementation of changes will apply, with all changes to be fully implemented by 14 November 2022.

Contact BWES for a food labelling review and to help prepare for Health Star Rating.

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Former Director, Lloyd Knipe

BWES Director Moves Away From Consulting

BWES Director Moves Away From Consulting


BWES wishes to announce that Mr. Lloyd Knipe has resigned from his position as joint Managing Director BWES, (Black & White Engineering Solutions Pty Ltd). Lloyd’s resignation took effect as of Wednesday 30 June 2021.

The senior management and team at BWES wish to place on record their gratitude for Lloyd’s substantial contribution to the growth and development of BWES over the past 20 years. Lloyd has accepted a senior position in an organisation outside of the consulting field. We all wish Lloyd very much success in his new endeavour.

As a consequence of the above, Mr Geoffrey Booth, Managing Director of BWES, will assume all directors’ duties.


Luminaires Product Marking Requirements

Standards for Eye Safety and Luminaires

Standards for Eye Safety and Luminaires


Radiation emitted by lamps, luminaires and other artificial light sources can present hazards to skin and eyes. Only the skin and eyes are affected as optical radiation does not penetrate deep into tissues.

Luminaire manufacturers need to ensure products present no photobiological hazards (the undesirable effects of optical radiation on human tissue).

Optical radiation is a type of electromagnetic radiation in the wavelength range between 100 nm and 1 mm, comprising of ultraviolet radiation, visible radiation and infrared radiation.

Wavelengths of different optical radiation from artificial sources of light.

The effects on the eyes and skin of exposure to optical radiation varies depending on the wavelength and intensity. It can have harmful consequences as shown in the table.

Due to their possible photobiological hazard, regulators’ are paying particular attention to LED light sources which have increasingly become the most popular source of lighting, due to their high efficiency, cost and longevity. Also, the inclusion of LED technology in several applications such as smart TVs, computer screens and smart phone backlighting, means that we are becoming more and more exposed to such lighting.

Wavelengths of optical radiation from artificial sources of light


Bioeffect of optical radiation

Bioeffect of optical radiation

While the content of UV in LEDs for general purpose lighting are not usually found to be a concern, there is a notably high concentration of blue light in its spectrum that poses a risk of photoretinitis (by photo chemical reaction on the retina) and retinal thermal hazard excess, which can both be severely detrimental to the eyesight.

Shown below is a typical spectrum of a cool white LED light, clearly having the highest peak of blue light radiation which penetrates the cornea of the eye and gets focused on the retina by the eye lens. The hazard is dependent upon the size of the source and maximum limits are expressed in terms of radiance.

The applicable standard for determining photobiological safety of lamps and systems is AS/NZS 62471 which assesses all optical radiation. However, a standard called IEC TR 62778 has been specifically developed for the assessment of the blue light hazard of light sources which is called up by the generic standard above as well. It is worth noting that product-level electrical safety standard for luminaires AS/NZS 60598.1, has made it mandatory to assess the blue light hazard.


Luminaires are classified into four groups according to the photobiological risk posed by them. This risk is determined by testing to the standard IEC 62471 for UV, blue light and infrared radiation in which IEC TR 62778 is for blue light.

Photobiological risk group of luminaires

Photobiological risk group of luminaires

Notes: Blue light is measured at 200mm from the source. If RG1 is complied at 200mm, it is called RG1 unlimited.


Luminaires product marking requirement according to risk group

Do not stare at the operating light source
  • No marking for RG0, RG1 and RG1 unlimited.
  • If RG1 exceeds at 200mm, the minimum distance from the light source at which the RG1 limit is complied with, is determined by testing.
  • For portable and hand-held luminaires, when RG1 is met at > 200mm, the below symbol, meaning ‘Do not stare at the operating light source’, is marked on the product.
Due to the same reason, however for the fixed luminaires; the below should be marked on the product:
"The luminaire should be mounted so that prolonged staring at the luminaire from a distance of less than x m is unlikely."
  • RG2 luminaires will require more warnings and special consideration for their use. However, RG2 is not normally recommended according to 60598.1
  • RG3 is not allowed.

The table shows an example of optical radiation measurement in which the limit of RG0 was exceded, hence the RG1 limit was tested and passed as RG1 unlimited.

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Baby Dummies Safety Standards

Baby Dummies Compliance Requirement

Baby Dummies Compliance Requirement


Baby Dummies Safety Standards

We’ve recently received an increasing number of inquiries about Baby Dummies compliance.

From 1 July 2019, suppliers have needed to ensure that they comply with the new standard – Consumer Goods (Babies’ Dummies and Dummy Chains) Safety Standard 2017.

The purpose of the standard is to ensure babies’ dummies and dummy chains have key safety features that address known safety hazards and reduce the risk of injury.

Babies’ dummies are required to meet certain requirements of either the Australian standard or the European soother standard. Baby dummy chains are required to meet certain requirements of the European soother holder standard.

BWES is highly experienced in the whole range of baby products compliance, including dummies, toys and bottle warmers. Please do not hesitate to contact us for more details.

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EPS Packaging

The End is Near for EPS Packaging in Australia

The End is Near for EPS Packaging in Australia


EPS Packaging

Several our clients have been asking about the future of EPS (Expanded Polystyrene) in single use packaging.

All Australian governments, federal, state, territory and local, recognise the need to reduce waste and increase our recycling rates. As outlined in the National Plastics Plan, taking responsibility for our waste in some instances will mean phasing out problematic and unnecessary single-use plastics through design, innovation or by using alternative materials.

Problematic and Unnecessary

Following consultation with government and industry, the Australian Packaging Covenant Organisation (APCO) has identified EPS in certain consumer applications as a problematic and unnecessary single-use plastic. APCO identified EPS loose fill and single use moulded EPS in packaging as problematic because they are not recyclable through kerbside collection systems, there are very limited drop-off services available to consumers, and being lightweight and fragile, EPS can have a significant impact on the environment when littered.

EPS continues to be one of the most prevalent fractions of marine debris and litter in surveyed waterways.

Dates to Remember

There is a proposed industry-led phase out to apply to EPS:

  • loose fill (by July 2022)
  • single use moulded EPS in consumer packaging (by July 2022)
  • consumer food and beverage containers (by December 2022).

Fast-tracked phase outs will not apply to:

  • EPS used for business-to-business packaging, such as fresh produce boxes specialist packaging used in medical applications, for example, organ transport or pharmaceuticals
  • EPS used in building and construction
  • business-to-consumer packaging where there is a demonstrated and effective reuse model in operation, for example bulk cold home-delivered meal services.

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New Compliance Standards For Button Battery Products

New Safety Standards for All Button Battery Products

New Safety Standards for All Button Battery Products


New Compliance Standards For Button Battery Products

In Australia, one child a month is seriously injured after swallowing or inserting a button battery. Some of them sustain serious, lifelong injuries as a result of choking or chemical burns. In Australia and globally, there is a growing record of injuries and deaths from button batteries.

To deal with this deeply concerning issue, the Australian Federal Government has created two new compliance standards governing the use and supply of button batteries.

These standards are applicable in all states and territories of Australia and affect almost all consumer products containing button/coin batteries. All businesses that supply button batteries or supply products containing button batteries in Australia must comply with these standards.

Key Points of the New Standards

  • All goods containing button/coin batteries must be secure and not release the batteries during reasonably foreseeable use or misuse conditions.
  • Consumer goods containing button/coin batteries that are intended to be replaced by the user must have a secure battery compartment that is resistant to being opened by young children.
  • Consumer goods containing button/coin batteries must provide warnings and information about the battery hazard on the product packaging and in the instructions for use.

Businesses will have 18 months to comply with the new standards.

The details of these new standards and how to comply with them are available from the BWES technical team.


Arbutin Reduces Melanin Production

Arbutin Change Reverses Australia Product Ban

Arbutin Change Reverses Australia Product Ban


The BWES AICIS Compliance Team

Recently, the Therapeutic Goods Administration (TGA) released a very important update in the latest edition of the Standard for the Uniform Scheduling of Medicines and Poisons (SUSMP). It was released without much fanfare, but it was news that is tremendously important and exciting to the cosmetic industry, be it manufacturers, importers or distributors.

The TGA has clearly defined the parameters of use of arbutin by differentiating the different types of arbutin and their allowable concentration before mandatory SUSMP labelling must be used.

This action means that a significant number of products previously banned in Australia, can now be sold.

What is Arbutin?

Arbutin is a naturally occurring derivative of hydroquinone, used in cosmetics products for skin lightening. It works by slowly releasing hydroquinone through hydrolysis, which in turn blocks tyrosinase activity and reduces the skin’s melanin (pigmentation) production.

Whilst the TGA’s rollback is good news for the cosmetic industry, it is important to note that any supplier of the various types of arbutin used in cosmetics must be able to prove that the hydroquinone levels present in the arbutin are less than 10 mg/Kg.

BWES can assist cosmetic importers and distributors navigate their way through the new regulations.

MORE ABOUT AICIS COMPLIANCE

AICIS Cosmetics Approval & Certification

Transition from NICNAS to AICIS

Announcement: transition from NICNAS to AICIS


AICIS Cosmetics Approval & Certification

Australian Industrial Chemicals Introduction Scheme (AICIS) has replaced NICNAS as the new national regulator for the importation and manufacture (introduction) of industrial chemicals in Australia. Official start date for AICIS is 1 July 2020. NICNAS ended on 30 Jun 2020 and its website is no longer active.

Key changes:

Previous Australian Inventory of Chemical Substances (AICS) becomes Australian Inventory of Industrial Chemicals (AIIC), which only lists chemicals for industrial use.

Some exemptions under NICNAS such as low volume cosmetic introductions must be categorised to make sure it is authorised under AICIS from 31 August 2022.

Secondary notification obligations become specific information requirement in the new Inventory, where introducer may be required to submit a form to update information about the introduction so AICIS has the chance to evaluate the introduction.

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Testing of Chemicals

Comprehensive NICNAS/TGA compliance service

A more comprehensive NICNAS/TGA compliance service


NICNAS / TGA Compliance Testing

Our recently expanded service to importers, distributors and manufacturers of cosmetic products, therapeutic goods and medical devices covers all aspects of regulatory compliance.

Designed to create safety and certainty for companies, our expanded comprehensive service includes areas such as:

  • Reviews of safety or health risks
  • Regulatory early warning
  • Help with notifying relevant authorities
  • Compliance with mandatory standards
  • Reviews of packaging and marketing claims
  • Reviews of competitor claims

For a more thorough view of our NICNAS/TGA service please visit the page at our website.

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Thermomix TM31 Product Recall

4.6 million dollars. Warning to the market on the cost of misleading consumers and ignoring statutory obligations on reporting.

4.6 million dollars. Warning to the market on the cost of misleading consumers and ignoring statutory obligations on reporting.


The Federal Court has slapped Thermomix with a fine of $4.6 million dollars for a raft of offences for actively misleading and deceiving its customers with one of its products.

The case highlighted how seriously the ACCC and the Federal Courts are responding to companies who have fragrantly ignored or actively avoided their legal obligations.

The action brought by ACCC completely supports one of their 2018 Enforcement and Compliance Priorities, which is to ensure better product safety outcomes for consumers in the online marketplace.

Read the full story here…

BWES Compliance and Consulting can offer a range of services that are specifically designed to significantly reduce the risk of consumer and commercial products causing damage or harm in the marketplace. Our services include, both factory and product audits through to re-engineering of materials and electrical/electronic circuitry. As well, we can implement factory inspections of goods prior to shipment.

For any assistance simply contact us. Someone will be in touch shortly thereafter.