Clean Label Claims Under the Microscope: Verifying “No Preservatives” Claims

A recent class action lawsuit against Costco US over its Kirkland Signature Seasoned Rotisserie Chicken highlights how critical it is to carefully assess product claims. The lawsuit alleges that Costco US advertised the product as containing “no preservatives,” while the formulation includes additives such as sodium phosphate and carrageenan, which are claimed to perform preservative functions like maintaining texture and extending shelf life.

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.

‘Milk’ Labelling for Plant-Based Products

In a recent report by the ABC, a UK court ruled that oat-based beverages cannot be marketed as “milk” following a prolonged trademark dispute. The decision reinforced that the term “milk” may only be used for products derived from animals, requiring the company involved to rethink their company strategies. The ruling clarified that trademarking a product name containing “milk” does not override established food definitions or accurately reflect the nature of the product.

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.

RSPCA Rebrand

The farm animal welfare certification scheme operated by RSPCA Australia has undergone a significant rebrand, with the long-running RSPCA Approved Farming Scheme transitioning to RSPCA Certified. The change represents the first major refresh of the program’s branding in over 17 years and is designed to strengthen consumer recognition of products produced under higher animal welfare standards.

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.

It’s time for your Annual APCO Reporting

APCO annual reporting is the tracking for all packaging for products your organisation placed on the market in Australia within the 12-month reporting period, for businesses to submit as their due diligence and requirements in the Australian packaging cycle.

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.

Momentum Builds Toward Mandatory Health Star Ratings in Australia

The national conversation around mandating Health Star Ratings (HSR) on all eligible packaged foods has taken a significant step forward. Reporting by ABC’s 7.30 program confirmed that Australian food ministers were developing a formal proposal to guide the introduction of mandatory Health Star Ratings across the country. 

Introduced as a voluntary front-of-pack labelling scheme, the Health Star Rating system was designed to support healthier consumer purchasing decisions by providing a simple, interpretive nutrition guide. However, the scheme has fallen short of its original uptake target. While the goal was for 70% of eligible packaged foods to display a Health Star Rating by November 2025, current adoption sits at approximately 37%, raising concerns about its effectiveness as a public health tool under a voluntary model. 

The Health Star Rating algorithm assesses key nutrients of concern, including sugar, sodium, and saturated fat, to generate an overall score. As Australia’s food landscape evolves, particularly with the growth of ultra-processed foods, there are increasing calls to change the system to better account for levels of processing, including additives.  

In the key outcomes announced from the Food Ministers meeting from the 13th of February, recognised that this low uptake has reduced the system’s effectiveness and undermined consumer trust. In response, the majority of ministers requested FSANZ to prepare a formal proposal to mandate the HSR in the Food Standards Code.  FSANZ will run two rounds of public consultation before reporting back with a final proposal. Ministers also agreed to publish reports on HSR uptake and consumer research to boost transparency and confidence.  

In support of the initiative, all packaged food products to display a Health Star Rating would enhance transparency and empower consumers. With limited time to interpret nutrition information during routine shopping, many Australians benefit from clear guidance rather than complex nutrition panels and ingredient lists. 

For many brands, this will involve calculating ratings and may involve in the future recalculating pending algorithm discussion, updating packaging, managing regulatory compliance, and coordinating artwork rollouts across multiple SKUs. We work closely with suppliers to navigate Health Star Rating requirements, from calculating accurate ratings and assessing reformulation opportunities through to managing label updates and implementation across product ranges.

If your business would like support in adding or updating Health Star Ratings for your products, we are available to assist through every stage of the process. 

Australian Government Moves to Strengthen Food Labelling and Clarify Plant-Based Protein Claims

The Australian federal government has announced a significant push to improve food labelling clarity, particularly around plant-based and alternative protein products, in response to industry concerns, research findings and debates over how these foods are presented to consumers. 

The government intends to strengthen existing voluntary food labelling arrangements with a reform into the development of an Industry Code of Practice for plant-based food labelling. The code is designed to go beyond current guidance by providing clearer expectations for how plant-based and alternative protein products should be labelled to support consumer choice and transparency. 

The reform aims to ensure that consumers should be able to clearly identify their protein source, emphasising the importance of clear and informative food labelling. The key objectives to include in the reform include discouraging animal imagery on packaging that may confuse consumers, limiting the use of meat-specific terminology without clear qualifiers, and improving the prominence of plant-based protein labelling terminology (“legume protein”). 

Food Standards Australia New Zealand (FSANZ) has undertaken consumer and market research examining how Australian shoppers interpret plant-based labelling. The research did find that most consumers can accurately identify plant-based products and understand their composition, and are confident about how these products are intended to be used.  

Despite the results, the meat and livestock sectors want a compulsory regulatory framework. The industry voices that voluntary codes lack enforcement power, and stronger, mandated rules are needed to prevent misleading practices and protect consumers and primary producers.  

For businesses developing or marketing plant-based foods, navigating labelling requirements can be complex, particularly around ingredient declarations and product naming.

Our team offers specialist support in helping ensure labels align with regulations while remaining clear, accurate and consumer-friendly. From label reviews to claims and terminology assessments, we partner with you to reduce regulatory risk and support confident market entry. 

FSANZ Releases Alcohol Energy Content Calculator

On 13 August 2025, changes to the Australia New Zealand Food Standards Code were officially gazetted, introducing mandatory energy labelling for packaged alcoholic beverages. 

This reform stems from Proposal P1059 – Energy labelling on alcoholic beverages to require packaged alcoholic beverages to display an energy statement.  

To help businesses respond, FSANZ has developed the Average Energy Content Calculator for alcoholic beverages. The calculator assists manufacturers in calculating the average energy content of packaged alcoholic beverages to prepare a compliant energy statement.  

The calculator allows you to determine average energy content by entering the core values required to develop your compliant energy statement. For each product, you will require the core information of:  

  • Average alcohol content  
  • Specific gravity  
  • Serving size  
  • Number of standard drinks per package 
  • Number of servings per package 

Composition data (if applicable), expressed in g per 100 g: 

  • Sugar alcohols (e.g. sorbitol, xylitol, erythritol, maltitol, mannitol, lactitol, isomalt, glycerol) 
  • Carbohydrate 
  • Fat 
  • Protein 
  • Fibre  
  • Organic acids 

For many alcohol producers, particularly those with flavoured beverages, RTDs, liqueurs, or with added carbohydrate ingredients, this step may require an analytical laboratory analysis. 

We are already working with alcohol manufacturers and importers to prepare for these changes. Our services include: 

  • Determining an energy statement on pack 
  • Assisting in calculating compliant average energy values 
  • Preparing labels and specifications to comply with the updated legislation  
  • Conducting full label compliance reviews against the Code 
  • Liaising where analytical verification is needed 
  • Advising on artwork layout and regulatory positioning 

Don’t leave compliance till the last minute with early action allowing you to integrate changes to be a leading brand in the industry, avoid non-compliant stock and reduce regulatory risk. Contact us to today to assist you efficiently with the required changes today.

Questioning The Integrity of Sustainable Timber Certification Systems in Australia

Recent reporting in ABC News has raised questions about the integrity of sustainable timber certification systems in Australia. According to conservation advocates and new research, auditing processes have revealed shortcomings in voluntary certification schemes. The areas logged as “sustainably managed” may not always adequately protect native forests, with building evidence suggesting the scheme could be leading to damage to the environment in Australia and failing to protect forests.

Industry services that monitor compliance of accredited schemes highlighted deficiencies in how sensitive ecosystems were identified at a major plantation site. Local landholders and researchers warn that endangered species habitat has potentially been compromised where certification audits failed to recognise key ecological features.

Industry bodies are defending the strength of the certification frameworks, such as the Forestry Stewardship Council (FSC) and emphasising ongoing improvements in impact assessment and compliance processes. However, academic commentary argues that systemic reform is needed to ensure that certifications align with conservation outcomes and regulatory expectations across the sector.

To combat this threat to biodiversity, an urgent reform is being requested for Australia’s certification scheme to protect the areas. High standards are required to protect threatened species and align this with certification bodies through strengthening assessments following a strong and ethical supply chain.

Prospects for forest biodiversity conservation in Australia are expected to develop over the next decade. In the meantime, we will keep you updated on any reforms. Our services provide FSC certification checking to support businesses in managing claims and strengthening environmental credibility.  By assessing alignment between FSC requirements, we assist organisations in verifying due diligence and corrective actions to meet high environmental and governance standards.

How GLP-1 Medications Are Shaping the Food Industry

Retail and food industry responses to the rapid rise in GLP-1 weight-loss medications, such as Ozempic, are now influencing product development and consumer behaviour.

Australian adults are nearing nearly half a million people using Ozempic-like drugs for weight management. Appetite suppression associated with GLP-1 use is expected to influence how Australians eat, with experts forecasting higher demand for nutrient-dense, protein-rich and fresh food, shifting away from energy-dense discretionary products. This could reshape consumer preferences and product portfolios across food manufacturers and retailers.

In the UK, convenience retailer Co-op has launched a new own-brand range of “GLP-1 friendly” ready meals, marking a retail first in the convenience sector. The meals are designed for smaller appetites but higher nutrient density, providing protein, fibre and at least two portions of fruit and vegetables per serving. These products reflect the changing eating patterns of individuals using appetite-suppressing medications, and price promotions aim to support accessibility for a broad customer base.

For regulators and industry stakeholders in Australia, these developments point to a transforming food landscape driven by pharmacologically altered appetite patterns.  There may be opportunities for innovation in meal solutions and functional foods that align with these emerging consumer needs, without compromising nutritional quality. As consumer demand evolves, standards around nutritional labelling, health claims and “GLP-1 friendly” marketing may require closer scrutiny to ensure clarity and compliance.

As GLP-1 weight-loss medications influence consumer eating patterns, food businesses may need to begin researching entering this emerging market. 

Our food regulatory services help manufacturers and retailers navigate these changes, ensuring labels and health claims remain compliant while supporting innovation in supporting nutrient and portion-appropriate foods.

Soft Plastics Recycling Reboot Meets Urgent Calls for Packaging Reform

Australia’s soft plastics recycling system is showing signs of revival, but industry and environmental groups warn that broader regulatory reform is urgently needed to secure a trusted circular packaging economy.

After several years of disruption following the collapse of the REDcycle collection program in 2022, soft plastics recycling is returning. Collected soft plastics from supermarket and council collection trials are shredded, sorted and sent to manufacturers for reuse in new products, a key step toward rebuilding infrastructure that was long missing from Australia’s waste system.

A renewed industry-led effort is underway through Soft Plastic Stewardship Australia (SPSA), backed by major retailers and brands. The Australian Competition and Consumer Commission (ACCC) has granted authorisation for a nationwide voluntary recycling scheme that aims to coordinate collection, processing and end-market development for soft plastic packaging.

Despite these developments, significant concerns persist about the viability and scale of current recycling pathways and the broader packaging ecosystem The Australian Council of Recycling (ACOR) and the Australian Packaging Covenant Organisation (APCO) have called for urgent federal action to introduce stronger regulatory measures on packaging design, recycled content and extended producer responsibility (EPR).

Industry modelling suggests that ensuring all packaging is recyclable, made with recycled material and supported by a fee-based EPR framework would boost local economic activity, create jobs, and significantly reduce plastic waste and emissions, all with minimal impact on product costs.

Only a small fraction of Australia’s 1.3 million tonnes of annual plastic packaging currently contains recycled content, and without mandated standards, cheap virgin imports continue to dominate the market, weakening demand for recycled material.

For operations in Australia, remaining updated with these developments is signalling a transition point for improvements and collection with clear and consistent regulatory frameworks for recyclable-ready design, recycled content uptake and genuine circular outcomes.

Our packaging regulatory services support businesses to navigate this transition, guiding packaging compliance, sustainability claims, recycled content obligations and upcoming reform to prepare for a tightly regulated circular economy.