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Grown, produced, made and packed

A country of origin label says where a food was grown, produced, made or packed. For example:

  • Australian grown
  • product of Australia
  • made in Australia
  • packed in Australia from imported ingredients.

Here’s what those terms mean.

A food product is grown in a country when both:

  • all of its significant ingredients were grown in that country. An ingredient is significant if it is important to the nature or function of the food, even if it only makes up a small proportion of the product.
  • all (or nearly all) of its processing occurred in that country.

You can only claim a food is grown in Australia when all its ingredients are Australian.

A food product is produced in a country when both:

  • all of its significant ingredients were grown or otherwise wholly obtained in that country. ‘Wholly obtained’ refers to foods or ingredients that are from that country but are not ‘grown’, such as salt or water.
  • all (or nearly all) of its processing occurred in that country.

You can only claim a food is produced in Australia when all its ingredients are Australian.

The meaning of ‘produced’ is similar to ‘grown’. Products that are grown in a country can usually claim to be produced in that country as well. 

A food product is made in a country if it underwent its last substantial transformation in that country. Substantial transformation means any process where the end product is fundamentally different from its ingredients.

A ‘made in’ claim is about processing rather than ingredients. That means a product can be made in Australia even if all its ingredients are imported.

A food is packed in a country if was packaged in that country, but it wasn’t entirely grown, produced or made there.

This claim is often used for products that contain ingredients from multiple countries.

Packet or package

A packet or package is a container or wrapper in which food for sale is fully or partly encased, covered, enclosed, contained or packaged.

Some examples of packets or packages:

  • bag
  • bottle
  • can
  • jar
  • box
  • wrapper.

The following are not packets or packages:

  • bulk cargo containers
  • pallet overwraps
  • crates and packages which don’t obscure labels on the food
  • transport vehicles
  • vending machines
  • hampers
  • containers or wrappers used to serve food in a prison, hospital or medical institution.

Substantial transformation

A food is substantially transformed in a country if either:

  • it was grown or produced in that country
  • as a result of processes in that country, it is fundamentally different to all of its imported ingredients or components.

Examples of substantial transformation

Product

Local ingredients

Imported ingredients

Process or change

Why this is substantial transformation

Cakes

Sugar, eggs, flour

Spices

Mixing and baking

The finished product (cake) is fundamentally different to the imported ingredients (spices).

Apple pie

Pastry, sugar

Apples, spices

Forming a pie and baking

The finished product (apple pie) is fundamentally different to the imported ingredients (apples, spices).

Frozen crumbed prawns

Prawns, egg

Crumbs, spices

Cultivating and shelling prawns and raising chickens (from which eggs are gathered) before crumbing

The finished product (frozen crumbed prawns) is fundamentally different to the imported ingredients (crumbs, spices).

Frozen battered seafood snack

Flour, eggs, water

Prawns, squid, seasoning

Mincing, mixing, forming and battering

The imported ingredients (seafood) are fundamentally different to the finished product (frozen battered seafood snack).

Examples of changes that aren’t substantial transformation

Product

Local ingredients

Imported ingredients

Process or change

Why this is not substantial transformation

Canned apricots

Syrup

Apricots

Peeling, cooking and canning

The imported ingredients (fresh apricots) are not fundamentally different to the finished product (canned apricots).

Orange juice

Water, sugar, preservatives

Orange juice concentrate

Reconstitution

The imported ingredient (orange juice concentrate) is not fundamentally different to the finished product (orange juice).

Frozen crumbed prawns

Crumb, egg

Prawns, spices

Crumbing, packing, freezing

The imported ingredients (prawns) are not fundamentally different to the finished product (frozen crumbed prawns)

Mashed peas

None

Peas

Mashing and packing

The imported ingredients (peas) are not fundamentally different to the finished product (mashed peas).

The Australian Competition and Consumer Commission’s guide to country of origin food labelling has more examples of substantial transformation.

Food

For country of origin labelling, food means anything that is or can be consumed by humans. This can include live animals and plants.

It also includes chewing gum and any ingredients, additives and substances used to prepare chewing gum.

It does not matter whether the food is in a condition fit for human consumption.

Food does not include:

  • products not for human consumption, such as pet food
  • therapeutic goods.

If you need help deciding whether your product is food or a therapeutic good, use the Therapeutic Goods Administration’s Food-Medicine Interface Guidance Tool.

Priority and non-priority foods

There are different labelling requirements for priority and non-priority foods.

Non-priority foods are foods for which Australians are least concerned about origin information. They are:

  • seasonings
  • confectionery
  • biscuits and snack foods
  • soft drinks and sports drinks
  • alcoholic drinks
  • tea and coffee
  • bottled water.

If your product doesn’t belong to any of these non-priority food categories, it is a priority food for country of origin labelling.

Types of food

An alcoholic beverage is any beverage with more than 0.5% alcohol by weight or volume.

 

Some examples of biscuits and snack foods:

  • potato and other vegetable chips, crisps, sticks or straws
  • crackers
  • rice cakes
  • sweet biscuits and cookies
  • crackers
  • pretzels
  • cones or wafers
  • other ready-to-eat savoury snacks such as pork crackling or prawn chips.

Biscuits and snack foods do not include:

  • cakes
  • muesli bars
  • processed nuts, including coated nuts and nut mixtures (for example, nuts mixed with dried fruit).

Bottled water includes:

  • natural mineral water
  • carbonated mineral water
  • non-carbonated water
  • mineral and source waters
  • soda water.

Some examples of confectionery:

  • cocoa and chocolate products
  • chewing gum
  • lollies and jellies
  • ice-cream, edible ices (including sherbet and sorbet), flavoured ice blocks and other frozen confectionery
  • popcorn
  • crystallised fruit, glacé fruit and edible cake decorations.

Confectionery does not include:

  • sugar, icing sugar or icing sugar mixes
  • jams or marmalades
  • honey
  • other spreads, apart from cocoa or chocolate spreads.

This means unprocessed fruit or vegetables that are packed and displayed for sale in a package that does not obscure the nature or quality of the product. The fruit or vegetables can be whole or sliced.

Fruit and vegetables includes nuts, spices, herbs, fungi, legumes and seeds.

Some examples of seasonings:

  • pepper, salt and salt substitutes
  • dried herbs and spices
  • spice blends and other seasonings or flavourings in powder or paste form
  • dry cures or rubs for meat or fish
  • meat tenderisers.

Seasonings do not include:

  • mustards
  • sauces
  • chutneys
  • relishes. 

Soft drinks and sports drinks include:

  • water-based flavoured drinks (carbonated and non-carbonated)
  • sport, energy and electrolyte drinks
  • carbonated fruit or vegetable drinks
  • powder, syrup, liquid and frozen concentrates used to make water-based non-alcoholic drinks. For example, fountain syrups, fruit syrups for soft drinks, or frozen or powdered concentrate for lemonade and iced tea.

Soft drinks and sports drinks do not include the following:

  • non-carbonated fruit or vegetable drinks
  • milk
  • cereal, nut or legume-based milk substitutes.

This includes:

  • coffee and coffee substitutes, including instant and decaffeinated coffee
  • tea and herbal infusions, including instant tea
  • other similar cereal and grain beverages, except cocoa.

It doesn’t matter whether the product is in a dry form or ready to drink.

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