Country of Origin Labelling definitions

Need help with some Country of Origin Labelling (CoOL) terms? Browse our list of definitions below:

Definition of CoOL terms

Fresh fruit and vegetables in transparent packaging

Fresh fruit and vegetables in transparent packaging can include any unprocessed fruit, vegetables, nuts, spices, herbs, fungi, legumes and seeds. These can be whole or sliced and packed and displayed for sale in a package that does not obscure the nature or quality of the product.

Grown in

A food or ingredient was grown in a country if it was:

  • materially increased in size or materially altered in substance in that country by natural development; or
  • harvested, extracted or otherwise derived from an organism that has been materially increased in size, or materially altered in substance, in that country by natural development.

A food consisting of more than one ingredient is also grown in a country if: 

  • each of its significant ingredients was grown in that country; and
  • all, or virtually all of the processing occurred in that country.

Made in

A food or ingredient was made in a country if it underwent its last substantial transformation in that country.

Substantial transformation

According to Australian Consumer Law (Schedule 2 of the Competition and Consumer Act 2010), a food was substantially transformed in a country if:

  • each significant ingredient of the product was grown in that country; and if all, or virtually all, processes involved in the production or manufacture of the product happened in that country; OR
  • as a result of one or more processes undertaken in that country, the product is fundamentally different in identity, nature or essential character from all of its ingredients or components that were imported into that country.

Substantial transformation examples:

Products with Australian and imported ingredients WITH substantial transformation:

Product Australian ingredient/ component Imported ingredient/ component Substantially transformative or material process/change Primary reason why it is considered to be substantial transformation
Cake Sugar, eggs, flour Spices Mixing and baking The imported ingredients (spices) are fundamentally different from, and do not have the identity, nature or essential character of the finished product (cake)
Apple pies Pastry, sugar Apples, spices Forming a pie and baking The imported ingredients (apples, spices) are fundamentally different from, and do not have the identity, nature or essential character of the finished product (apple pie)
Frozen crumbed prawns Prawns, egg Crumbs, spices Cultivating and shelling prawns and raising chickens (from which eggs are, gathered) before crumbing The imported ingredients (crumb, spices) are fundamentally different from, and do not have the identity, nature or essential character of the finished product (frozen crumbed prawns)
Frozen battered seafood snack Flour, eggs, water (to form batter) Prawns, squid, seasoning Mincing, mixing, forming and battering The imported ingredients (seafood) are fundamentally different from, and do not have the identity, nature or essential character of the finished product (frozen battered seafood snack)

Products with Australian and imported ingredients WITHOUT substantial transformation:

Product Australian ingredient/ component Imported ingredient/ component Material process/change that is not substantially transformative Primary reason why it is NOT considered to be substantial transformation
Canned apricots Syrup Apricots Peeling, cooking and canning The imported ingredients (fresh apricots) are not fundamentally different from, retain their identity and nature, and have the essential character of the finished product (canned apricots)
Orange juice Water, sugar, preservatives Orange juice concentrate Reconstitution The imported ingredient (orange juice concentrate) is not fundamentally different from, retains its identity and nature, and has the essential character of the finished product (orange juice)
Frozen crumbed prawns Crumb, egg Prawns, spices Crumbing, packing, freezing The imported ingredients (prawns) are not fundamentally different from, retain their identity and nature, and have the essential character of the finished product (frozen crumbed prawns)
Mashed peas   Peas Mashing and packing The imported ingredients (peas) are not fundamentally different from, retain their identity and nature, and have the essential character of the finished product (mashed peas)

Packet or Package

Packet or package includes:

  • any container or wrapper in, or by which food for sale is wholly or partly encased, covered, enclosed, contained or packaged
  • if food is carried or sold or intended to be carried and sold in more than one package—includes each package.

Packet or package does not include:

  • a bulk cargo container; or
  • a pallet overwrap; or
  • a crate and packages which do not obscure labels on the food; or
  • a transportation vehicle; or
  • a vending machine; or
  • a hamper; or
  • a container or wrapper (including a covered plate, cup, tray or other food container) in which food is served in a prison, hospital or medical institution.

Produced in

A food or ingredient was produced in a country if:

  • each of its significant ingredients were grown or otherwise wholly obtained in that country; and
  • all, or virtually all, of the processing occurred in that country.

Proportion of Australian ingredients

In order to work out the percentage of Australian-produced or grown content in a food, businesses must break down a food into its individual ingredients or components and determine each item’s weight. This is calculated according to the product’s recipe (that is, the ingoing weight) and not the final weight of the ingredients in the food after cooking or processing.

The percentage declared on the label must be a whole number that is no higher than the minimum proportion of Australian content.

Example: Tomato sauce

Australian content: 1 kg of tomatoes, 170g of olive oil, 20g of sugar, 10g of basil and 150g of water

Imported content: 130g of onion and 20g of garlic cloves

The proportion of Australian ingredients by ingoing weight is 1350g. The total ingoing weight of all ingredients is 1500g. Expressed as a percentage, the Australian content is 90 per cent (1350 ÷ 1500 x 100).

Compound ingredients

It is not uncommon for foods to contain ‘compound ingredients’; that is, ingredients that are themselves made up of sub-ingredients.

Examples of compound ingredients include:

  • pasta in a ready meal
  • yoghurt balls in a trail mix.

If a compound ingredient contains both Australian and imported sub-ingredients, the ingoing weight of the sub-ingredients must also be broken down in order to work out the overall percentage of Australian content. This is because only the Australian proportion of a compound ingredient may be counted as Australian content.

Example: Beef Bolognese pasta meal

Ingredients: 80g tomato sauce (90 per cent Australian content), 120g beef and vegetables (Australian) and 175g pasta (36 per cent Australian content).

The ingoing weight of Australian ingredients is 255g (72g for the sauce, 120g for the meat and vegetables and 63g for the pasta). The total ingoing weight of all ingredients is 375g. Expressed as a percentage, the Australian content is 68 per cent (255 ÷ 375 x 100).

This product would have a statement indicating that it contained ‘at least 68% Australian ingredients’.

Processing aids

For the purposes of calculating the proportion of Australian content, processing aids are not regarded as ‘ingredients’. The definition of ‘processing aid’ in the Information Standard is the same as that used in the Australia New Zealand Food Standards Code, namely a substance that is used in the processing of raw materials, foods or ingredients, to fulfil a technological purpose in the processing, but which does not perform a technological purpose in the final food.

Example: Cheese

Australian content: Dairy and salt (98 per cent)

Imported content: Rennet (2 per cent)

Rennet is used in the making of cheese to separate curds and whey and would be considered a processing aid. Therefore, the proportion by weight of the Australian ingredients in the cheese would be 100 per cent as the Rennet is not included in the calculation.

Water as an ingredient

In general, water is to be counted as an ingredient when determining the proportion of Australian content in a food. The only exception to this is where water is used, alone or with other ingredients, as a ‘liquid packing medium’ (e.g. the brine in a can of tuna, or, the fruit syrup in a can of peaches). In this instance, the water in the medium is only to be counted when determining the weight of ingredients if the medium is generally consumed as part of the food.

Examples:

  • The liquid in a can of chickpeas (Aquafaba) is generally not consumed, so the water in the liquid would be excluded from the calculation of the weight of ingredients.
  • The fruit syrup solution in a can of peaches can be consumed as part of the food so the water in the syrup would be included in the calculation of the weight of ingredients.

Where water is counted as an ingredient, its origin will be taken to be the country in which it was collected or harvested. The exception to this is where water is used to reconstitute dehydrated or concentrated ingredients or other components of food (including food additives). In this instance, the water will have the country of origin of that ingredient or component.

Example:

A fruit juice drink is manufactured in Australia by combining a Brazilian fruit juice concentrate and water from Australia (plus other ingredients). If the water added is only to the extent necessary to reconstitute the concentrate, the water will be considered to be Brazilian water. Any additional water (i.e. more than is the amount necessary to reconstitute the concentrate) would be taken to be Australian.

Average proportion of Australian ingredients

An average Australian content claim can only be used for food items made or packed in Australia. It is determined by averaging the ingoing weight of the Australian ingredients over a continuous one, two or three-year period before the date that the label is affixed to the package.

An average proportion claim may be preferable for a business that manufactures or supplies foods where the level of Australian content varies widely over time. This may be due to a variety of reasons such as reduced availability, seasonal changes or regular changes in supplier.

Example:

An apple pie is made in Australia using fresh apples (the apples make up 50 per cent of the ingoing weight of all ingredients). For nine months of the year, the pie is made from 100 per cent Australian ingredients.

Due to seasonal availability, imported apples are used for the remaining three months (Australian content by ingoing weight becomes 50 per cent). Based on a one-year average, 87.5 per cent of the food, by ingoing weight, is Australian content.

Additional information requirements

The use of an average content claim for a food item means that there will be times where the actual percentage of Australian content in a food is less than what is represented on the label. The Information Standard provides optional standard marks for situations where the average percentage of Australian ingredients is used.

To ensure that consumers are not misled, country of origin labels for foods that contain varying Australian content must direct consumers to a telephone number, website, smartphone application or program where they can access more information about the product. The Information Standard sets out the methods businesses may use to do this.

Method Required identifying phrase in mark
A barcode or similar device for consumers to scan using a smartphone app or other software. '- Scan barcode for details'
A contact telephone number for consumers to call during business hours. ‘- Call [phone number] for details’
A website address for consumers to visit. ‘- Visit [website] for details’

Example:

For convenience, the apple pie manufacturer decides to use the average percentage of Australian content on its labels and sets up a hotline where consumers can get more details.

The manufacturer could use a label along the lines of: ‘Made in Australia—ingredient sources vary—average 87% Australian ingredients—call (01) 2345 6789 for details’.

Suitable for retail sale

A packaged food is ‘suitable for retail sale’ if it could be sold by a business without any further processing, packaging or labelling. Determining whether a food is suitable for retail sale should be considered objectively, based on fact.

If a food is suitable for retail sale, it must comply with the Information Standard (unless an exemption applies) even if it is being sold at wholesale. Food that is sold in large quantities or labelled ‘not for retail sale’ may still be considered suitable for retail sale, as will foods sold to restaurants or cafes that can be sold without any further processing, packaging or labelling.

Definitions of particular food products

Alcoholic beverages

Alcoholic beverages include any beverage with more than 0.5% by weight/volume of alcohol, however described.

Biscuits and snack foods

Biscuits and snack foods include:

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

Biscuits and snack foods do not include:

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

Bottled water

Bottled water includes natural mineral water, non-carbonated water, mineral and source waters, soda water, and carbonated mineral water

Confectionery

Confectionery includes the following:

  • chewing gum
  • cocoa and chocolate products
  • 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, honey, marmalades or other spreads apart from cocoa or chocolate spreads.

Fish

Fish means a cold-blooded aquatic vertebrate or aquatic invertebrate including shellfish, but not including amphibians or reptiles.

Food

According to section 5 of the Food Standards Australia New Zealand Act 1991, food includes:

  • any live, raw, prepared or partly prepared substance or thing that is or can be used for human consumption (may include live animals and plants)
  • chewing gum or an ingredient or additive in chewing gum, or any substance used in preparing chewing gum.

It does not matter whether the substance, thing or chewing gum is in a condition fit for human consumption.

According to the Food Standards Australia New Zealand Act 1991, food does not include the meaning of therapeutic goods as stated on the Therapeutic Goods Act 1989.

If you need further help in deciding if your product is a food or a therapeutic good, please visit the Food-Medicine Interface Guidance Tool.

Fruit and vegetables

Fruit and vegetables means any of fruit, vegetables, nuts, spices, herbs, fungi, legumes and seeds.

Fruit and vegetable juices and drinks

Fruit and vegetable juices and drinks mean drinks consisting of one or more of the following:

  • fruit juice or vegetable juice, including liquid elements of a fruit or vegetable, such as coconut water
  • fruit or vegetable purée
  • concentrated fruit juice or vegetable juice
  • concentrated fruit or vegetable purée
  • comminuted fruit or vegetables
  • orange peel extract; and one or more of the following:
    • water
    • mineralised water
    • sugars
    • milk-like drinks made from cereals, nuts and legumes (including soy) that are sold as dairy analogues.

Honey

Honey means the natural sweet substance produced by honey bees from the nectar of blossoms or from secretions of living parts of plants or excretions of plant sucking insects on the living parts of plants, which honey bees collect, transform and combine with specific substances of their own, store and leave in the honey comb to ripen and mature.

Jam

Jam means a product prepared by processing one or more of the following:

  • fruit
  • concentrated fruit juice
  • fruit juice
  • water extracts of fruit; or such a product processed with sugars or honey (includes conserve).

Jam does not include marmalade.

Milk

Milk means:

  • the mammary secretion of milking animals, obtained from one or more milkings for consumption as liquid milk or for further processing, but excluding colostrums; or
  • such a product with phytosterols, phytostanols and their esters added.

Seasoning

Seasoning includes the following:

  • salt and salt substitutes, pepper, dried herbs and spices
  • blends of spices and other seasonings or flavourings in powder or paste forms
  • dry cures or rubs that are applied to external surfaces of meat or fish
  • meat tenderisers.

Seasoning does not include the following:

  • mustards
  • sauces, chutneys or relishes.

Soft drinks and sports drink

Soft drinks and sports drinks include:

  • water based carbonated and non-carbonated flavoured drinks
  • drinks sold as ‘sport’, ‘energy’ and ‘electrolyte’ drinks     
  • carbonated fruit or vegetable drinks
  • powder, syrup, liquid and frozen concentrates for the preparation of carbonated or non-carbonated water-based non-alcoholic beverages by addition of water or carbonated water, such as fountain syrups, fruit syrups for soft drinks, and 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 drinks sold as milk substitutes.

Sugar and Sugars

Sugar includes the following:

  • white sugar
  • caster sugar
  • icing sugar
  • loaf sugar
  • coffee sugar
  • raw sugar.

Sugars include the following:

  • hexose monosaccharides and disaccharides, including dextrose, fructose, sucrose and lactose; or
  • starch hydrolysate; or
  • glucose syrups, maltodextrin and similar products; or
  • products derived at a sugar refinery, including brown sugar and molasses; or
  • icing sugar; or
  • invert sugar; or
  • fruit sugar syrup derived from any source, but does not include:
    • malt or malt extracts; or
    • sorbitol, mannitol, glycerol, xylitol, polydextrose, isomalt, maltitol, maltitol syrup or lactitol.

Tea and coffee

Tea and coffee, whether in dry form or in a ready to drink form, means the following:

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

Queries in relation to interpretation of the requirements should be directed to the Australian Competition and Consumer Commission.

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