FSANZ food label checklist for small brands

This outline is for small food brands, importers, and home or hospitality founders who are about to print or stick a label on packaged food sold in Australia. It is a working review order, not a substitute for the Food Standards Code and not legal advice.

FSANZ publishes the Food Standards Code that food businesses use as the reference for what a label must say. State and territory food authorities enforce the rules, and the ACCC cares about claims that could mislead a buyer. A small brand usually meets all three of those audiences with one piece of packaging, so the checklist follows the label from top to bottom rather than by regulator.

If you already have a draft PDF or a photo of a sticker, the useful next step is a structured pass that marks each item as present, missing, or needing a closer look. That is the shape of the food label mini review on this site. Use the checklist below to prepare the file, then send the draft if you want a second pair of eyes.

A buyer and an inspector both need to know what the food is, how much is in the pack, and who is responsible for it. Before debating marketing lines, confirm the prescribed name or an accurate name, the net quantity, and the name and street address of the supplier in Australia. A website or a social handle is not a substitute for a business address.

Lot identification and date marking come next. Packaged food generally needs a use-by or a best-before date, and the storage conditions that make that date meaningful. If the product is frozen, chilled, or shelf-stable only under a specific instruction, that instruction has to sit where a person packing a carton and a person opening the pack can both follow it.

Imported food often arrives with a home-country label plus an English sticker. Check that the sticker does not cover the original date, lot, or allergen information unless those details are fully repeated on the sticker. A sticker that hides the original warning and does not replace it is a common reason a first shipment gets held up.

The statement of ingredients should list components in the order required by the Code, with compound ingredients broken down where the rules say so. Additives need the class name and the number or name a reader can recognise. This is also where allergen declarations live. Plain English allergen labelling (PEAL) asks for required names in the ingredient list and in a summary statement. The companion note on PEAL walks through that pattern.

The nutrition information panel is next. Most packaged foods need energy, protein, fat, saturated fat, carbohydrate, sugars, and sodium, in the format the Code describes, per serving and per 100 g or 100 mL. A panel copied from an overseas label often uses different nutrients, different units, or a serving size that does not match the Australian pack. Treat a foreign panel as a draft, not as finished artwork.

Characterising ingredients and percentage labelling matter when the name of the food points at a particular ingredient, such as a fruit content in a drink or a meat content in a pie. If the name makes a promise, the panel and the ingredient list have to be able to support it.

Country of origin labelling has its own rules for food sold in Australia, including the standard mark for priority foods and the statements used for non-priority foods and imports. Do not invent a kangaroo mark, a “Product of Australia” line, or a “Made in” claim because it looks familiar. Match the claim to where the food was grown, processed, and packed, and to the category of the product.

Then read every claim on the front: natural, organic, no added sugar, high protein, gluten free, source of, healthy, fresh, or immunity. Each of those words can be a nutrition content claim, a health claim, or an ordinary marketing line that still must not mislead. If you cannot point at a calculation, a certificate, or a Code permission, soften the wording before you print.

A practical order for a small brand is: name and supplier, net quantity, dates and storage, ingredients, allergens, nutrition panel, origin, then claims and pictures. Pictures count. A photo of fresh fruit on a drink with little fruit is still a claim. When that pass is done, decide what you can correct yourself and what needs a food technologist, a laboratory, or a compliance adviser before launch.

Keep the marked-up label with the version of the recipe it belongs to. When the recipe, the supplier, or the pack size changes, the label review starts again at the items that changed. Small brands get into trouble when the artwork file and the kitchen formula drift apart.

The mini review I offer is a preliminary risk pass over one or two draft labels. It is priced as an early check — AUD 79, 149, or 199 depending on depth — and it will not certify the product or promise that a retailer or a regulator will accept it. If you want that pass, use the form on the food label review page and attach the draft.