This case highlights an important consideration for food manufacturers and retailers: it’s not just the ingredients present in a product, but the role they play in the formulation that determines whether a claim can be made and substantiated. Many food additives can serve multiple functions depending on how they are used in a formulation. When claims such as “No Preservatives” or “No Added Preservatives” or “Preservative Free” are made, businesses must ensure that none of the ingredients perform a preservative function within the final product.

With consumers increasingly seeking clean-label products—commonly understood as products made with simpler, fewer and easily recognisable ingredients, with minimal additives and greater transparency—front-of-pack claims such as “No Preservatives” play a significant role in purchasing decisions. As a result, inaccurate or unsupported claims can expose businesses to regulatory scrutiny, legal action and reputational damage.

To mitigate these risks, businesses should conduct thorough formulation assessments, ingredient function reviews – accurately declaring any additives as required under Food Standard Code – and carry out documentation checks supported by credible PIFs and technical substantiation.

Our team at MSAC Solutions can assist with documentation reviews, ingredient functionality assessments and claims verification to help ensure product claims are properly substantiated and compliant.

As the plant-based category continues to grow, the Australian dairy industry is calling for stronger adherence to the Food Standards Code and, potentially, further amendments to tighten naming and labelling provisions. The industry argues that clearer definitions would support agricultural integrity and ensure transparency for consumers.

While proponents of plant-based beverages maintain that consumers understand the difference between dairy and non-dairy alternatives, others believe confusion persists, particularly in relation to nutrition and product origin. This has prompted ongoing discussion about whether restrictions should extend beyond “milk” to other dairy-derived terms such as cream, butter, cheese and yoghurt.

Consideration is also being given to the use of animal imagery, traditional dairy terminology and associated claims on plant-based packaging. Ultimately, the discussion should reflect a broader push for a level playing field across both plant-based and animal agricultural sectors, with consumer clarity and informed choice remaining central to the outcome. With debate intensifying month by month, regulatory and legal frameworks may soon evolve.

As regulations on alternative animal labelling spark movement, a proactive label review is becoming essential rather than optional. Businesses operating in both dairy and plant-based categories should ensure their product names, claims, imagery and composition align with current requirements and are future-proofed against potential code amendments. 

Our food regulatory labelling services provide comprehensive compliance reviews, risk assessments and strategic guidance to help brands navigate evolving standards with confidence, protect market access and maintain consumer trust.

The scheme, which has operated in Australia for more than two decades, certifies farms and supply chains that meet the organisation’s animal welfare standards for species including poultry, pork and farmed salmon. These standards are intended to go beyond minimum legal requirements and cover areas such as housing conditions, stock density, environmental situations and handling practices.

Under the rebrand, the term “Certified” replaces “Approved” to better communicate that participating farms and supply chains are subject to ongoing auditing and verification. The updated RSPCA logo also introduces a unified visual identity across all animal protein categories, designed to improve recognition on packaging and food settings.

From a labelling perspective, the transition will occur progressively. During the rollout period, both the existing RSPCA Approved and the new RSPCA Certified marks may appear on product packaging and menus. Businesses participating in the scheme will gradually update artwork and marketing materials until eventually phased out. The updated branding emphasises the verification aspect of the scheme and aims to provide consumers with clearer signals at point-of-purchase in the food labelling landscape.

For food businesses using the certification, the rebrand primarily affects on-pack claims and logo usage. Companies will need to ensure that updated artwork aligns with the new branding guidelines and that any references to the scheme accurately reflect the new terminology. As with the previous mark, use of the logo remains restricted to licensed participants whose products can be traced through certified supply chains.

As the new RSPCA Certified identity rolls out, our MSAC regulatory services can review labelling, sustainability and animal welfare requirements, and brand guidelines to ensure a smooth transition while maintaining compliance with certification requirements.

At the start of your APCO Annual Report, you will need to provide your Baseline Metric, the number of stock keeping units (SKUs), or the total tonnes of packaging that your organisation have placed on the Australian market during your 12-month reporting period.

The reporting requires 7 criterions to complete: Governance and Strategy, Design and Procurement, Recycled Content, Recoverability, Disposal Labelling, On-site Waste and Problematic Materials, with additional information your organisation wishes to include in your APCO Annual Report.

The 44 questions completed for your packaging metrics create an overall performance metric for your business:

1 Getting Started: You are at the start of your packaging sustainability journey.

2 Good Progress: You have made some first steps on your packaging sustainability journey.

3 Advanced: You have taken tangible action on your packaging sustainability journey.

4 Leading: You have made significant progress on your packaging sustainability journey.

5 Beyond Best Practice: You have received the highest performance level and have made significant progress on your packaging sustainability journey

MSAC are here for your needs to regularly complete your APCO reporting to assist in tracking and reporting your data. To avoid relying on the compilation of data and manual reporting, at MSAC, we have created Addis®, an all-in-one solution to solve all your packaging challenges, to capture all your data in one safe place. 

Addis® automatically manages your claims and certificates, enables automatic volumetric calculation with all associated dashboards and reports, enables easy APCO reporting and tracks your progress towards your sustainability targets. 

Let us handle all of it with our team of specialised packaging technologists. Contact regulatory@msacsolutions.com to enquire further.