Under the Australian Consumer Law, claims businesses make about products need to be truthful and capable of substantiation. Under the ACCC, claims must not make false or misleading impressions. A common product claim is “100% Natural”. Would you expect clean, organic ingredients? An investigation by the ABC earlier this year found that products claiming this were misleading, finding that ingredients such as emulsifiers and additives were present.

For food businesses, the Food Standards Code also needs to be considered. FSANZ advises that food labelling is subject to specific requirements within the Code prohibiting false, misleading or deceptive representations. In Australia, truth in labelling is governed by the Australian Consumer Law (ACL) contained in the Competition and Consumer Act 2010, and state and territory Fair Trading Acts and Food Acts.  

Before adding a “100%” claim, businesses should consider whether the evidence supports the whole impression created by the claim.

For example, consider:

1. What exactly does the “100%” refer to?
2. Does the entire formulation support that interpretation?
3. Are there ingredients, additives or processing considerations that could change the consumer’s understanding?
4. If the claim relates to Australian origin, does the applicable country-of-origin framework support it?
5. Is there reliable supplier and traceability documentation available to substantiate the claim?

A supplier declaration alone may not always give a business the level of assurance it needs. Recent investigations in Australia showed the importance of internal compliance material. This highlighted the importance of checking traceability, certificates and supporting documentation behind claims of 100% origin.  

A practical takeaway is that the stronger and more absolute the claim, the stronger the substantiation should be. Before placing “100%” prominently on a food label, make sure you can clearly define what the claim means and demonstrate that the product, its formulation and the supporting evidence match the impression consumers are likely to take from it.

Looking for help or have a question? Our services assist in your handling of product documentation, compliance checks, and build confidence in your brand reputation, taking the hard work out of it. Get in touch to review your products today.

MSAC celebrated National Nutrition Week within our own community, reminding us of the connection food has to culture, community and wellbeing. It brings people together, sparks conversations and helps create healthier workplaces and communities. During the week, we encouraged our community to share a simple recipe, host a team morning tea, or start a conversation about food, culture and connection. A question asked: What’s one meal, recipe or food tradition that brings your team, family or community together?

The National Nutrition Foundation centred its 2026 campaign on “Love What You Eat”, encouraging Australians to consider how food connects people with culture, community and place, supports wellbeing and brings people together. Helpful resources were shared throughout the week, specifically for workplaces, schools and early childhood settings for improving nutrition in these environments.  

Nutrition Australia also highlighted four key areas of positive food experiences for children and young people: food and nutrition security, mental wellbeing and food and environmental sustainability and food waste, including sustainable eating and reducing waste in households and community settings.

World Food Day on the 16^th of October also fell within National Nutrition Week, providing an additional opportunity to reflect on food and the future of food systems. The FAO (Food and Agriculture Organisation) is a specialised agency of the United Nations, that celebrates the day to remind us that the future of food depends on the choices we make today. Innovation is the tool that turns challenges into opportunities.

For food regulatory professionals, National Nutrition Week is a useful reminder that nutrition communication increasingly extends beyond traditional nutrient messages. Food security, sustainability, wellbeing, waste reduction and positive relationships with food featured prominently in the 2026 campaign.

For the industry, this makes accurate and supportable nutrition and wellbeing communications particularly important. Businesses chose to use the week as an opportunity to promote their products, regulatory requirements around nutrition content claims, health claims and potentially misleading representations continue to apply. This is particularly relevant when linking products with health or wellbeing outcomes.

Europe’s Greenwashing Ban: What Could It Mean for Australian Packaging?

Europe is continuing to take a stronger approach to environmental and sustainability claims, with new rules aimed at tackling greenwashing and giving consumers clearer information about the environmental impact of products.

While these European requirements do not directly apply to products sold in Australia, this could set a future precedent. International regulation combined with increasing consumer focus on sustainability could influence how environmental claims are made and substantiated in the Australian industry.

In Australia, businesses are already required to ensure environmental claims are truthful, accurate and supported by reasonable grounds under the Australian Consumer Law. The ACCC has also identified greenwashing as an ongoing compliance and enforcement priority for 2026–27.

Packaging is an area where environmental claims can easily create a misleading overall impression. Statements such as “recyclable”, “sustainable”, “eco-friendly”, “environmentally friendly” or “made from recycled materials” need to be considered carefully and supported by appropriate evidence.

The ACCC considers the overall impression on packaging, including wording, graphics, colours and environmental symbols. As packaging continues to evolve, businesses are looking at recycled content, alternative materials, recyclability and reduced packaging as ways to improve environmental outcomes. With the ACCC continuing to prioritise greenwashing, and international regulation moving towards greater transparency, reviewing sustainability claims early in the packaging development process can help reduce regulatory risk and avoid costly artwork changes later.

The European approach is another indication that environmental claims are likely to face increasing global scrutiny. Although Australia has its own regulatory framework, businesses should continue to take an active approach to greenwashing, particularly as packaging innovation and sustainability claims become more common.

MSAC can play an important role in the product development and artwork process. Packaging claims, particularly linked with the environment, should be reviewed alongside packaging materials, components and circular pathways. This allows your claims, packaging specifications and supporting evidence to align, mitigating your risk of any potential risks.

New Zealand’s soft plastics recycling scheme has achieved impressive milestones. Since launching with just 70 stores in 2015, the program now operates through 200 members and over 350 collection points, displaying the leverage to continue a powerful endorsement that consumer demand exists when convenient options are available.

Australia has built the processing capacity for a soft plastic’s circular environment, but it is operating far below its potential. An insight into manufacturing factories found the facilities are currently running just two days per week at single shift, a vast difference to previous years of a full 24-hour functioning site.

The constraints have been found to be from insufficient material supply, driven by low industry membership in Australia’s Soft Plastics Stewardship Scheme (SPSA). With only 37 members representing just 10-15% of the industry, recyclers lack the feedstock to justify running at full capacity.

An insightful example shared was Australia Post’s Smart Circular Satchel. Developed in just 10 weeks using 100% post-consumer recycled LDPE and manufactured entirely onshore, the satchel performed flawlessly through Australia Post’s network without any special handling. This proof point removes the perception that recycled plastics are inferior; they can deliver premium performance in demanding applications.

The webinar made clear that the industry stands at a crossroads. The infrastructure exists, with working technology and driving consumer demand. What’s needed now is:

1. Industry Support: Brand owners to join SPSA and commit to using recycled content.
2. Policy Clarity: Government commitment to EPR regulation and minimum recycled content mandates for investment confidence needed to scale operations.
3. Data Transparency: Tracking of soft plastics placed on the market sets an important precedent for supply chain visibility
4. Procurement Leadership: Governments and large corporations must adopt recycled-first policies, creating the demand that drives the circular economy.

Australia and New Zealand have built the foundation for a successful soft plastics recycling industry. The question now is whether brand owners and government will provide the support needed to sustain it. As one panellist noted: it’s pointless making packaging recyclable if recyclers don’t survive.