Unlike traditional 1D barcodes that primarily identify a product, GS1-compliant 2D barcodes can store substantially more information within a single code. This enables manufacturers to encode details such as batch numbers and expiry dates while also linking consumers to digital product information including ingredients, allergen declarations, nutrition information, sustainability credentials and recycling guidance.

GS1 2D barcodes offer retailers and manufacturers a multifunctional point-of-sale solution, enabling the delivery of enhanced product information and additional data attributes through a single code. It is important to recognise that mandatory declarations remain, including allergens, ingredient lists, nutrition information panels and date marking, which must continue to appear on the food label unless specific exemptions apply. Digital content should be viewed as complementary rather than a substitute for regulatory labelling requirements.

For businesses considering implementation, it is also important to note that GS1’s 2027 target is an industry ambition rather than a legislative deadline. Current guidance recommends that 2D barcodes be used alongside existing linear barcodes until point-of-sale systems are universally capable of scanning the new formats. Adoption is considered to grow progressively across the Australian retail sector.

As consumer demand for transparency continues to grow, the next-generation barcodes provide an opportunity for food businesses to strengthen product traceability, improve access to information and support transparency. While implementation is not yet mandatory, manufacturers should begin considering how their labelling, packaging and data management systems can support this emerging standard.

While 2D barcodes provide an effective way to deliver additional product information to consumers, businesses should ensure that any information accessed through a digital link is accurate, substantiated and consistent with on-pack labelling. The Australia New Zealand Food Standards Code continues to require mandatory information to appear on the food label.

Contact us today to see how your digital content can serve as a complementary source of information to boost your brand and products.

A company’s supply chain emissions often account for the largest proportion of a food business’s carbon footprint and are becoming increasingly important under Australia’s evolving sustainability reporting requirements. The industry continues to invest in renewable energy, food waste reduction, sustainable packaging and supply chain collaboration to support national emissions reduction targets.

For grocery retailers, climate-related disruptions present challenges across the entire supply chain. Delays in transportation, reduced access to seasonal produce and changing growing conditions require businesses to strengthen supplier relationships, diversify sourcing strategies and improve contingency planning to maintain consistent supply for consumers.

In response, many organisations are investing in more resilient supply chains through supplier diversification, improved forecasting, renewable energy adoption, sustainable packaging initiatives and food waste reduction programs. Digital traceability systems and enhanced data collection are also supporting businesses in managing regulatory obligations while improving visibility across increasingly complex supply networks.

Europe has experienced a record-breaking heatwave, impacting the supply chain, population health, and government pressure. These recent events continue to lead the conversation globally in integrating climate objectives into food regulation. Through sustainable food system agendas, the EU is embedding environmental sustainability alongside food safety, consumer protection and agricultural policy.

These developments are influencing global supply chains, with many multinational food manufacturers aligning sustainability programs across all markets, including Australia. Food businesses should continue preparing for increasing climate-related reporting obligations, enhanced supplier engagement and emissions data collection, stronger expectations around sustainable sourcing and packaging, and greater scrutiny of environmental claims and sustainability credentials.

Businesses that actively strengthen environmental efforts, improve supply chain visibility and invest in credible reporting will be better positioned to meet future regulatory requirements while responding to growing customer and stakeholder expectations. Start a conversation with us today to see how you can lead the way in sustainability for your brand.

While the term “free-range” is widely recognised, businesses must ensure that claims made on-pack, online and through advertising are supported by evidence and do not create a misleading overall impression for consumers.

For eggs, the Free-Range labelling requirements that producers must meet include: Hens must have meaningful and regular access to an outdoor range during daylight hours, outdoor stocking densities must not exceed 10,000 hens per hectare, and the outdoor stocking density must be clearly declared on the packaging. This is particularly relevant given recent bird flu outbreaks in Australia, which have increased attention on free-range farming practices and compliance.

These requirements operate alongside the Australian Consumer Law, which prohibits businesses from making false or misleading representations about goods. Importantly, compliance is assessed on the overall impression conveyed to consumers, not simply whether the words “free-range” appear on the label.

Food businesses should consider all elements of product presentation when assessing compliance. Images of hens roaming freely through expansive green paddocks, statements suggesting unrestricted outdoor access, or marketing that overstates animal welfare practices may all contribute to a misleading representation if they do not accurately reflect how the product is produced.

The Australian Competition and Consumer Commission (ACCC) has consistently reinforced that businesses must be able to substantiate not only explicit claims but also any implied messages conveyed through packaging, branding and advertising.

These cases reinforce an important compliance principle for businesses, with documentation and substantiation being essential. Businesses should maintain evidence demonstrating that production practices align with both regulatory requirements and consumer expectations created by marketing claims.

Regular reviews of claims on your pack, marketing materials and substantiation records can help minimise regulatory risk and ensure products remain accurate, transparent and compliant with both food regulatory requirements and Australian Consumer Law. MSAC is facilitated to ensure your claims and documentation are compliant in one place.

As with previous cell-cultured food applications, FSANZ has undertaken a comprehensive pre-market safety assessment, evaluating production methods and manufacturing controls, microbiological and chemical safety, nutritional composition, potential risks and dietary impact.

FSANZ’s preliminary assessment has concluded that, when produced in accordance with the proposed specifications, the ingredient does not raise public health or safety concerns and is suitable for inclusion in the Food Standards Code. The application is now open for public consultation before a final decision is made.

The commercial availability of cell-cultured foods in Australia remains limited, with the regulatory pathway becoming increasingly established. Food businesses developing, importing or considering future use of cultivated ingredients should monitor these applications closely, as each approval helps define the regulatory expectations for this emerging category.

Compliance considerations by businesses should ensure they are prepared to demonstrate robust evidence. This is achieved by supporting the safety of the ingredient through comprehensive documentation of manufacturing processes and quality controls, appropriate traceability throughout the production chain, compositional specifications and conditions of use.  

A key regulatory principle is that food labels must not be false, misleading or deceptive. This means businesses will need to ensure that product names and descriptions accurately reflect the nature and production method of cell-cultured foods, enabling consumers to make informed purchasing decisions. This ensures consumers have accurate product descriptions and labelling that meet all applicable regulatory requirements.

FSANZ has included their application and provisions that must be applied. Division 2 of Standard 1.5.4 sets out the following general labelling requirements for cell-cultured foods: Section 1.5.4-5 applies to food for sale that has a cell-cultured food as an ingredient and requires that, for the labelling provisions in Standard 1.2.1, ‘information relating to cell-cultured food’ requires the use of either ‘cell-cultured’ or ‘cell-cultivated’ in conjunction with the name of the ingredient that is a cell-cultured food.

Interest in cultivated proteins continues to grow internationally, with regulators balancing innovation alongside consumer confidence and food safety. As additional applications are assessed, businesses should expect further guidance around regulatory expectations, product naming, labelling and market authorisation processes.

Get in touch with our regulatory team to see what this could mean for your brand and future production.

1. FSANZ Extends HSR Submission Deadline

FSANZ has extended the deadline for stakeholder responses and survey submissions for the proposed mandatory implementation of Health Star Rating (HSR). The extension aims to encourage greater industry participation and gather further evidence to inform the assessment of moving from the current voluntary approach.

Public consultation is now underway on the proposal to require HSR labelling on packaged foods and beverages sold in Australia. While many public health and medical organisations support a consistent and mandatory labelling framework as an important measure to improve consumer understanding and support healthier food choices, manufacturers have highlighted the significant implementation costs and operational impacts that mandatory HSR labelling may present.

The consultation process will play a critical role in determining the future direction of front-of-pack nutrition labelling and its implications for food manufacturers, retailers and consumers. MSAC is actively submitting a survey response to have our say on the front-of-pack labelling scheme and encourage our community to submit their opinions. 

2. Caffeine Ingredient Amendments Gazetted

On May 1st 2026, Food Ministers agreed not to request a review of FSANZ’s proposed amendments arising from Proposal P1056 Caffeine Review. As a result, Amendment 250 to the Australia New Zealand Food Standards Code was gazetted in the Commonwealth of Australia Gazette No. FSC 190 on June 9th 2026.

The amendment introduces new regulatory requirements for caffeine-containing foods and establishes a transitional period commencing on June 9th 2026, and ending 24 months later, on June 9th 2028. During this period, businesses will be required to review products and implement any necessary changes to ensure compliance with the updated requirements.

FSANZ undertook a comprehensive assessment of caffeine safety, including hazard assessments, dietary intake modelling, social science literature reviews, and evaluations of caffeine’s effects on sports performance. These assessments identified several regulatory gaps where the existing Food Standards Code did not align with current evidence.

In particular, the review found that formulated supplementary sports foods may contain excessive levels of caffeine due to the absence of specific regulatory limits. Inconsistent caffeine declarations on labels were also identified as a concern, increasing the risk of consumers unknowingly exceeding recommended intake levels.

The new requirements are intended to strengthen consumer protections, improve transparency, and provide greater regulatory clarity regarding the use and declaration of caffeine in the food supply.

Businesses should closely monitor the new caffeine requirements, as each has the potential to result in significant compliance, packaging and product reformulation considerations. Early assessment of affected product ranges and implementation planning will help ensure a smooth transition ahead of future regulatory deadlines.

The campaign is designed to address the significant gap between the recommended fibre intake. While adults are advised to consume around 30 grams of fibre each day, average consumption remains just over half this amount. To encourage healthier eating habits, Sainsburys has also developed product inspiration across breakfast, lunch, dinner and snacks, highlighting simple swaps and additions that can help boost fibre intake throughout the day.

The initiative reflects a broader shift towards making nutrition information more accessible and actionable for consumers. By simplifying product identification and providing practical solutions, Sainsburys is positioning fibre as a key nutrient of focus, much like the protein trend that has dominated retail recently.

The conversation around fibre is equally relevant in Australia. According to the 2022–23 National Health Survey, fewer than 20 per cent of Australian adults meet the recommended daily fibre intake. This is due to increasing consumption of ultra-processed and convenience foods, which tend to contain lower levels of naturally occurring fibre. As a result, fibre-rich foods such as wholegrains, legumes, fruits and vegetables have become less prominent in many Australians’ diets. With fibre intake remaining a challenge for many Australians, similar approaches could play an important role in supporting public health outcomes and improving dietary quality nationwide.

Initiatives such as Sainsburys Full on Fibre campaign demonstrate how clear front-of-pack messaging can help guide healthier choices and encourage nutrient-rich purchasing behaviours. Our food compliance services support businesses substantiating nutrition content claims and ensuring labels align with current legislation and industry standards. Whether launching a new product, updating packaging, or responding to emerging nutrition trends, our team can help minimise compliance risks while enabling confident and effective communication of product benefits to consumers.

Data reported by APCO members in 2023 and 2024 indicate that while the use of PFAS in food contact packaging has declined, a complete phase-out has not yet been achieved. Under the 2022 PFAS Action Plan, APCO established a framework to support industry transition, to eliminate intentionally added PFAS and a threshold of 100 ppm total fluorine in packaging materials.

APCO’s voluntary, industry-led approach aligns with broader regulatory developments in Australia and internationally. In July 2025, the Australian Government prohibited the import, manufacture and export of three PFAS chemicals (PFOA, PFOS and PFHxS) through the Industrial Chemicals Environmental Management Standard (IChEMS). Further regulatory action may also arise with a recent Senate Inquiry recommending accelerating the phase-out of PFAS across all food contact packaging applications.

Following consultation, APCO will review current thresholds, claims guidance, reporting requirements and program settings to support the ongoing transition away from PFAS in fibre-based food contact packaging, with the longer-term objective of eliminating PFAS from all packaging formats in Australia. Industry engagement will play a critical role in shaping the next phase of the Action Plan and ensuring practical pathways for implementation.

As regulatory expectations continue to evolve, businesses involved in food packaging should monitor developments closely and participate in APCO’s consultation process to help shape a practical and effective pathway towards a PFAS-free packaging future.

Historically, packaging disposal instructions have varied significantly between EU Member States, resulting in a complex mix of colours, icons, codes and local requirements. This fragmented approach has often led to consumer confusion and incorrect waste separation, reducing the effectiveness of recycling systems. The new PPWR pictograms aim to provide clear and consistent disposal guidance.

The regulation establishes a legally binding framework across all 27 EU Member States, creating a common standard for environmental compliance. The symbols will be used across different packaging materials and formats, making it easier for consumers to identify the correct disposal pathway and supporting a higher-quality recycling scheme.

In addition to the new labelling requirements, manufacturers must complete a range of compliance checks before packaging can be placed on the market. These include conformity assessments, adherence to material restrictions and concentration limits, and compliance with calculating and reporting recycled content. Packaging must also meet the relevant sustainability and waste management requirements set out under the regulation.

To support industry implementation, a transition period has been proposed. The mandatory application of the new symbols is expected from August 12th 2028, or 24 months following the adoption of the legislation. Existing packaging and labels may continue to be sold during a transitional period extending to 2029, after which the use of previous labelling systems will no longer be permitted.

The introduction of harmonised recycling symbols represents a significant step towards improving packaging circularity across Europe. By providing clear and consistent disposal instructions, the PPWR aims to increase consumer participation in recycling, reduce contamination in waste streams, and support the EU’s broader environmental and waste recovery objectives.

Here’s what changed:  

Before Addis, certifications were buried inside audit records. There was no direct link between a raw material and the certificate proving it was sustainably sourced. Teams were manually chasing paperwork, spec techs were reviewing hundreds of legacy documents by hand, and critical gaps, like a supplier certified for segregated RSPO but a spec that said mass balance, were completely invisible.  

Now? Every certificate is digitally linked to the raw material spec it covers. Validation rules fire in real time. Discrepancies surface at the moment of specification build, not months later in an audit.  

The business impact:  

• 1000’s of certificates digitally linked, live and auto-renewing  

• Global certifications now actively verified and traceable   

• Legacy spec errors that had gone undetected for years — found and fixed   

• The RFA licence requirement eliminated entirely as a process by-product   

• Supplier onboarding described as “seamless” by teams across the business – supply chain change management another of our USPs.  

But here’s what we’re most proud of:  

This isn’t just an efficiency story. Every time a shopper picks up a product with an RSPO, Rainforest Alliance, or sustainability certification on the label, there’s now a verified, digital chain of evidence behind that claim. Not a filing cabinet. Not a manual check. A system that proves it.  

That’s what assurance at scale actually looks like. And that’s what we build.  

We’re now scaling this across other commodities like seafood because if it works for eggs, palm oil and cocoa at this scale, it works everywhere.  

To every supplier, specification technology, sustainability lead, and procurement professional who was part of this journey, thank you. You proved that when the right technology meets the right team, you don’t just manage compliance. You transform it.  

All imbedded with AI and in production – not just a demo.  

“It’s been really positive. We’ve never had the opportunity to scrutinise and validate at this level before, it’s been an awesome exercise.”   

Interested in what this could look like for your supply chain? Let’s talk.  

The call provides a voice for industry stakeholders to have their say on improving the front-of-pack interpretive labelling tool. The proposal seeks to review and strengthen aspects of the current voluntary framework, which has now been in the market for more than a decade.  

The latest submission proposal will have several areas for potential refinement, including whether the HSR system should remain voluntary or move toward mandatory implementation in future, clearer calculation and algorithm guidance, consistent requirements across product categories, and an enforcement governance.  

The proposal may also trigger renewed discussions about consumer perceptions of the balance between simplified front-of-pack messaging and the understanding of healthier food choices.  

Submissions are due by the 21st of June, with FSANZ expected to consult with industry stakeholders, public health groups and government bodies as the proposal progresses. Food businesses should monitor updates closely and begin reviewing current HSR usage across product portfolios to identify any potential future compliance impacts. MSAC will be involved in the submission proposal process and encourages our community to have its say.