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.  

The NPC is a free online tool used by food manufacturers to estimate the average nutrient content of products and prepare compliant nutrition information panels. The latest dataset draws primarily on FSANZ’s most recent food composition databases, including the Australian Food Composition Database (AFCD) and AUSNUT 2023. It also incorporates new data for a range of food additives and ingredients that have been approved under the Food Standards Code since the previous update.

For businesses that use the NPC to generate nutrition information, the update may result in changes to nutrient values for some ingredients and finished products. FSANZ notes that as food composition data is updated over time, nutrient calculations generated by the NPC may vary from previous results. Businesses should therefore consider reviewing any nutrition information panels that rely on NPC data, particularly when undertaking label updates, product reformulations or compliance reviews.

While the update improves access to nutrition data, it also serves as a reminder that food businesses remain responsible for ensuring the accuracy of nutrition information presented on labels and compliance with the Food Standards Code.

If you need assistance with your nutrition labelling and specification development and management, our services offer support for product development projects and guide food labelling compliance requirements.

The plan identifies three key areas of activity:

1. Developing food standards based on the best available scientific evidence.
2. Coordinating regulatory activities across the food regulation system, including food incident responses and recalls.
3. Providing advice to regulators and food standards information to industry and consumers.

A key focus of the corporate plan is to provide greater transparency around upcoming proposals and projects, helping stakeholders better understand what is on the horizon and when changes may occur. By taking a planned and coordinated approach, FSANZ can focus its resources on what will have the greatest impact on public health, food safety and the broader food regulatory system.

FSANZ recognises the changing food landscape, including innovation in food production, evolving consumer expectations, international regulatory developments, and emerging food safety risks. The continued emphasis on risk management, regulatory coordination, and evidence-based decision-making means food businesses can expect ongoing attention to compliance, traceability, product safety, and consumer information requirements.

A corporate plan outlines strategic direction to inform the industry and deliver tangible outcomes efficiently. With a focus on collaboration, FSANZ works with a reflection on stakeholder feedback across developing standards in line with governments, regulators and the food industry workforce.

To deliver these outcomes, FSANZ invests in five essential areas: workforce, regulatory science, digital transformation, communication, and governance, to strengthen the required capabilities. Altogether, this improves system performance to maintain ongoing trust and be better positioned to evolve and produce highly reputable resources.

MSAC supports this ongoing and future-focused approach to strengthen integration across the industry and deliver outcomes that contribute to a safe and reliable food environment. By continuing to monitor the strategies and future changes expected, we will support and guide in achieving positive outcomes with FSANZ and wider stakeholders in the food regulatory system.

Recent developments have raised further questions about the future of packaging reform in Australia, following the Federal Government’s decision not to introduce proposed mandatory packaging standards during its current term.

The proposed reforms were intended to establish national packaging requirements, including minimum recycled-content targets and measures to reduce problematic materials and chemicals in packaging. The reforms followed an agreement between Australian governments in 2023, intended to move away from voluntary approaches and toward more consistent national standards.

For food manufacturers, retailers and packaging suppliers, consistency is particularly important. A broader question is also in discussion on the development of Australia’s domestic recycling industry. Australian recycling facilities are reportedly operating below capacity, while recycled materials can face competition from lower-cost imported plastics.

This creates a difficult cycle, without sufficient demand for recycled materials, investment in recycling infrastructure can become challenging, while without reliable domestic recycling capacity, businesses may find it more difficult to source recycled content.

The Government has cited cost-of-living pressures as a key consideration in its decision not to proceed with the proposed national scheme at this time. However, questions remain around the actual cost impact of mandatory recycled-content requirements.

Industry modelling referenced by the ABC estimated that mandatory recycling standards could add approximately 0.3 cents per packaging item. This discussion extends beyond the immediate cost of packaging. It also includes the longer-term costs associated with waste management, recycling infrastructure, resource recovery and environmental impacts.

Businesses should continue to consider packaging design, recycled content and recyclability outcomes as part of their broader product development and sustainability strategies, rather than waiting for mandatory requirements to be introduced. Our packaging regulatory services can assist businesses with reviewing packaging requirements; obtaining regulatory advice early can help reduce compliance risks and avoid costly packaging changes later.

This recognition is a wonderful acknowledgement of the professionalism, expertise and hard work of our dedicated team, who provide specialist support to clients across Australia and around the world.

MSAC Solutions began on the Surf Coast, and our local heritage continues to be an important part of who we are. Even our Addis Integrity Intelligence platform takes its name from Point Addis, reflecting the connection between our business and the region where it all began.

While our work now supports global clients, we remain proud of our Surf Coast roots and the community that has been part of our journey.

Receiving this award is a great recognition of what our team has built together and the commitment we bring to everything we do. We would like to thank the Torquay Business Awards for recognising MSAC Solutions, and our incredible team and clients for being part of our continued growth.

A very proud moment for MSAC Solutions and an exciting milestone as we look towards the future.

Legislative labelling changes introduced by FSANZ can occur multiple times in a year, prompting businesses to redesign labels and possible reformulations. Once consolidated, the date is intended to limit label design costs and operational disruptions, allowing a reduction in the burden of labelling changes. FSANZ is proposing the 30th of May to be the least disruptive to the food supply chain.  

Protecting health and safety is FSANZ’s priority, with this approach to be rigorously reviewed to assess public health risk and benefits. FSANZ called for submissions from stakeholders to provide information on an appropriate date and approach, potential benefits and concerns, and offer alternative approaches or solutions. Submissions were encouraged to submit evidence, examples and data to facilitate responses. Submissions opened 21st of July 2026 and closed 18th of August 2026.   

From a regulatory perspective, an annual common commencement date for food labelling changes would provide greater regulatory certainty, allowing industry, regulators and enforcement agencies to better plan for implementation while reducing compliance costs. It could also improve consistency across the food supply chain, reduce packaging waste and streamline enforcement.  

However, a fixed commencement date could delay the introduction of important consumer information, such as food safety or allergen labelling changes, and create a large implementation workload for small businesses.  

To be effective, the approach should retain flexibility for urgent public health and safety changes and provide clear guidance on which regulatory amendments are covered, while providing complex transition management support and education across the supply chain to coordinate implementations efficiently. 

MSAC will be keeping a close eye on the outcomes of the submissions and proposals going forward. Following the consultation, a summary report will be published by FSANZ presenting the information and evidence submitted to consider the potential risks and benefits of adopting the change. 

The findings have raised concerns about the strength of traceability and supplier documentation, particularly around claims made on pack. From a food regulatory compliance perspective, the investigation reinforces the importance of maintaining traceability, supply-chain verification and documentation throughout the supply chain.  

While our labelling system in Australia is regulated by legislation and reputable standards, businesses remain responsible for ensuring that any claims are accurate, substantiated and not misleading. The investigation also highlights the increasing use of scientific authentication techniques as a complementary verification tool alongside documentation and audit processes.

The investigation demonstrates the growing expectation from regulators, retailers and consumers for greater transparency across global food supply chains. Four Corners found the food system is built to protect consumers from unsafe food, checking for contamination rather than fraud. In an increasingly complex global food supply chain, Australia is showing to be falling behind on testing for authenticity on our products on shelves. With limited routine testing to detect substitution, false origin claims and other forms of food fraud can act as a public health risk.

While our borders are working hard to ensure robust testing is compliant with import requirements, with authorities detecting hundreds of non-compliant food products each year, Australia’s regulatory system could be strengthened by requiring routine authenticity testing.

The case serves as a reminder that food integrity extends beyond food safety to include transparency and consumer trust. For food manufacturers, importers and retailers, regular supplier assurance activities, effective traceability systems and periodic verification of high-risk ingredients can help mitigate regulatory and reputational risks. 

MSAC Solutions provides you with services through our data-driven solutions and expert teams to build and optimise your brand’s trust and reputation.