Recent provenance research reinforces just how critical origin and documentation verification has become. As Australian Nuclear Science and Technology Organisation (ANSTO)  scientists highlight, authenticity can only be proven when traceability is backed by reliable data. Researchers rely on authentic samples to build environmental fingerprint databases — the scientific evidence needed to validate where a product truly comes from. Without trustworthy records and data, even advanced analytical tools, such as a handheld XRF (X-ray fluorescent) scanner, cannot confirm provenance. 

Despite this, many businesses remain reluctant to confront food fraud due to fears of reputational damage or potential profit loss. Consumers expect authenticity, transparency and accurate origin claims, and any breach of trust can have long-term consequences. 

With rising cases of document forgery, certificates, supplier declarations and product specifications can no longer be accepted at face value. Strengthening documentation controls is essential which includes systematic PIF reviews, cross-checking certificates against issuing-body databases, validating expiry and authenticity, and conducting audits to identify discrepancies early. Checking traceability and provenance should be a standard practice, ensuring every claim — “100% Australian,” “Organic,” “Sustainably Sourced,” “FSC Certified” — is backed by genuine, verifiable evidence. 

Independent verification is becoming a critical layer of protection. If your business needs support reviewing certificates or validating authenticity, our team MSAC Solutions can be of assistance.  

Authenticity starts with trusted documentation and trusted partners. 

The five key focus areas include: 

1. Packaging Standards & Design delivering updated and strengthened Sustainable Packaging Guidelines (SPGs) 
2. ARL continuity to uplift and strengthen the system 
3. Reporting & Packaging Data to simplify annual reporting and improve data tools
4. EPR and Soft Plastic Stewardship for supporting soft plastic stewardship through SPSA
5. Government Relations for expanded engagement with states and territories 

CEO Chris Foley’s message focuses on strengthening advocacy, seeking greater regulatory compliance, and supporting and protecting industry leadership through transitions. APCO is committing to advocate directly for practical national regulatory reform. 

Delivering a circular economy requires significant investment, better recycling infrastructure, improved data systems, and consistent cross-jurisdiction regulation. The SOI is part of the strategy to coordinate these changes. For consumers, success depends on more than industry, it will also require accessible recycling systems, consistent and clear labelling, and community uptake of reuse and recycling behaviours. 

APCO thanks their members, stakeholders and partners for their commitment towards improving Australia’s packaging system and looks forward to building a consistent, effective and circular packaging system for Australia.  

1. Energy Labelling on Alcoholic Beverages
FSANZ approved Proposal P1059 is now enforced, introducing mandatory energy labelling on most packaged alcoholic beverages sold in Australia and New Zealand. 

The pictured standardised energy statement, is to include energy content per serving, energy content per 100 mL, number of servings per package, the serving size and number of standard drinks per serving.  

2. Nutrition Panel and Health Star Rating Process Updates
FSANZ is actively reviewing the Health Star Rating (HSR) system and Nutrition Information Panel (NIP) to improve clarity, parallel integration, and support healthier food choices. The aim is to align both systems for clearer, more consistent communication. Changes are expected in early 2026 and will consider public support, regulatory costs, and supporting evidence. 

3. Soft Plastics Scheme Given Greenlight

The ACCC has officially authorised Soft Plastic Stewardship Australia (SPSA) to roll out a national, industry-led soft plastics stewardship scheme, a big step forward for Australia’s soft plastics recovery and circularity efforts. The ACCC has granted an eight-year authorisation, setting the foundation for a more reliable national approach to soft plastics stewardship. 

4. US Bans Artificial Colours 
In April 2025, the U.S. announced a ban on certain artificial food dyes due to health concerns, particularly for children. The U.S. move aligns with stricter regulations seen in the UK and EU, and a similar approach may follow in Australia. 

5. SPF Recalls
A growing number of SPF product recalls in Australia from the TGA investigations revealing that several popular sunscreens failed to meet their labelled SPF 50/50+ claims. Independent testing by CHOICE triggered the review, uncovering that multiple products, many sharing the same base formulation, were delivering significantly lower protection, with some performing as low as SPF 4. The TGA continues to assess affected products, and further regulatory action remains possible as the investigation progresses. 

6. Container Deposit Scheme Success
Container deposit schemes have been considered a success in Australia, with plans to continue growing the scheme. With all seven other states and territories in the country already offering CDSs, this launch makes Australia the first continent to be fully covered by deposit return.  

7. Greenwashing Continues
The ACCC has made misleading environmental claims a compliance & enforcement priority. The ACCC is likely to intensify enforcement in this area. As noted, greenwashing is now an active compliance priority. Businesses should keep an eye on their environmental claims and make sure their marketing and packaging are aligned.  

James joins MSAC from Boparan Manufacturing Group, a leading UK food manufacturer, where he served as Technical Director, partnering with major UK retailers on fresh food technical initiatives. His career includes roles at Sainsbury’s Supermarkets as Director of Technical for Fresh Foods, leading fresh food strategies during Brexit and COVID-19; Coles Group as Head of Quality and Responsible Sourcing, driving quality and ethical sourcing programs; and Tesco US’s Fresh & Easy, overseeing technical and innovation. With a Master of Science in Food Science from the University of Bristol, and extensive global experience, James excels in quality assurance, brand management, ESG, and strategic innovation.

“We are thrilled to welcome James Whittaker as our new COO,” said Andy McKie, Managing Director of MSAC. “After ten years of consistent growth and building loyal customers, MSAC is excited for this next season of international expansion. James’s expertise and leadership experience will be instrumental in advancing MSAC’s legacy of excellence with renewed energy, expanded services and a deeper commitment to innovative solutions and mission to being the best global innovation led technical and systems service provider.”

James added “I am excited to join MSAC, and I look forward to driving operational excellence and innovation for our global clients.”

Please join us in welcoming James Whittaker to MSAC as he steps into this pivotal role.

Higher cocoa prices are driving cost-saving measures resulting in product formula’s containing less cocoa, inferior substitutes, and lower solid content. In turn this brings brands to relabel their products away from the legal definition of “chocolate” in the market.

Consumers may be misled if the label uses the term “chocolate” or a similar term when the composition no longer meets the legal standard, opening the risk of regulatory enforcement, product recall, and reputational damage. Under the Food Standards Australia New Zealand (FSANZ), a product labelled as “chocolate” must meet certain compositional criteria. Similarly, in the UK, a product described as “milk chocolate” must meet minimum cocoa solids and minimum milk solids thresholds.

When those changes push the composition below the legal threshold for “chocolate”, brands sometimes adopt terms like “chocolate-flavoured”, “choc-coated”, “choc variety” or even “choc” in their branding/packaging. While from a marketing vantage this may be tempting, there are regulatory risks.

Given the current cocoa cost pressure, labelling teams and compliance functions should analyse recipes, cocoa measurement content, ingredient substitutions and ensure that the product names and descriptors are legally supported.

The rising cocoa prices and tight regulatory definitions of what may be labelled “chocolate” mean that food businesses are facing an evolving risk landscape.

When cocoa prices spike, recipe change becomes tempting. But if you reduce cocoa solids below the legal threshold for “chocolate”, you must change the name or descriptor on the pack and review your export packaging. The cost of ignoring this may greatly exceed the short-term savings from the cheaper recipe.

Brands reformulating products due to rising cocoa costs should work closely with regulatory and labelling teams to verify that the product name, composition, and market claims remain compliant. Failure to do so can expose brands to enforcement action, recalls, and reputational damage, often far costlier than the savings gained from reducing cocoa content. Contact us today to enquire.

As the online food market continues to grow, ensuring that consumers have access to clear, accurate and consistent product information has become a key regulatory focus. The policy paper, titled “Information for Food Sold Online: Understanding and Defining the Problem” examines the current state of online food labelling and the challenges faced by both businesses and regulators.

The paper highlights inconsistencies in how mandatory information, such as ingredient lists, allergen declarations, nutrition information and country of origin is presented across different online retail platforms. In some cases, key details may be missing or difficult for consumers to find before purchase, raising concerns about compliance, consumer protection, and fair competition.

It also identifies that many of the existing food information regulations were developed for physical packaging and may not fully address the complexities of digital retail environments. This creates uncertainty around who is responsible for ensuring accurate information, either the brand, the retailer, or the platform listing the product.

The findings examine the growing need for clearer guidance and consistent enforcement to align online practices with in-store requirements. As online grocery retailers continue to expand, businesses should review their online listings to ensure all mandatory information is accurate, visible and up to date.

Businesses are encouraged to review their digital listings to ensure all required information is clear, accurate, and accessible before purchase, supporting both regulatory compliance and consumer protection in an increasingly digital retail environment. If you require guidance and system guidance, our team is equipped with all the resources you need.

The review seeks to ensure that NIPs continue to provide clear, useful, and accurate information to support consumer understanding and informed food choices. FSANZ is inviting stakeholder feedback on the preliminary position paper, including any additional data, evidence, or perspectives that could inform the final recommendations to food ministers, expected in early 2026. Submissions can be made through the FSANZ Consultation Hub, with the consultation period closing 30^th of November 2025.

This consultation represents an important opportunity for industry, regulators, and other stakeholders to contribute to the future direction of nutrition labelling in Australia and New Zealand.

To recap, FSANZ have agreed to conduct a review of the Nutrition Information Panel (NIP) in parallel with the Health Star Rating. The HSR and the NIP are closely linked in helping consumers make informed food choices.

Any changes arising from the NIP review may result in amendments to the Australia New Zealand Food Standards Code, meaning that industry may need to adjust labelling practices.

The nutrition panel is a primary way that consumers receive nutrition information on packaged foods. Revisions could affect how nutrients are displayed, what nutrients are included, formatting, and how the panel supports consumer choice.

An implementation to consider is one announced by the Canadian government of a new mandatory front-of-pack nutrition symbol to be required on pre-packaged foods in Canada that are high in one or more of saturated fat, sugars or sodium. The aim is to help consumers make quicker, more informed choices, and to support health professionals in warning about health risks associated with frequent consumption of these high-level nutrients. The easy-to-understand and mandated principal display panel in a legislative consistency is a quick and informed tool for consumers when shopping for groceries.

The alignment with the HSR preparatory work means that labelling changes could have broader implications, especially if the HSR becomes mandated.

With final recommendations expected early 2026, build in labelling review to update time into your product-labelling roadmap, so you’re not caught off-guard by regulatory shifts.

Business are encouraged to plan for potential label reviews and factor in update timelines within their product labelling strategies to remain compliant with upcoming regulatory changes.

The ACCC has found that the Scheme is likely to result in environmental benefits by: diverting batteries from landfill, reducing fire risks during collection, transport, sorting and processing of end-of-life batteries.

The authorisation is conditional on key conditions, including addressing ingestion risks in children, publishing an annual report on key scheme outcomes and targets and an independent review of performance, governance and finances must be undertaken in three years. If the scheme changes during the authorisation period, the BSC must implement a consultation protocol with participants.

The ACCC notes that participation to date has been relatively low due to the voluntary nature of the Scheme; higher participation would yield greater public benefit. The ACCC emphasised that it is not the body to make mandatory product-stewardship regulation but instead assesses competition and liability consequences of proposed schemes.

The focus of the scheme translates to reducing risk, with batteries if disposed of improperly (including fire hazards), and packaging materials raising disposal and recycling challenges. The authorisation underscores industry-led stewardship as a means to drive improved circularity, which is increasingly relevant for packaging compliance.
By proactively aligning with stewardship frameworks, embedding governance and reporting practices, and designing packaging with disposal solutions, with end-of-life in mind, businesses can both manage regulatory risk and seize the opportunity of the circular-economy shift.

For businesses involved in food and packaging, this decision highlights the growing regulatory emphasis on product stewardship and end-of-life management. Aligning packaging design and circular-economy principles not only supports compliance but also positions businesses to meet future sustainability expectations, a highly reputable value of brands for consumers.

An initial investigation has revealed that all challenged products were tested at the same UK-based laboratory conducting the SPF testing. The TGA’s review identified unreliable testing practices at this facility, prompting further investigation.

Former employees have since raised concerns about questionable manufacturing and testing standards within the facility, citing unethical practices, equipment, and safety requirements. These revelations have deepened scrutiny into the broader sunscreen supply chain.

While the TGA does not directly regulate third-party laboratories, it does oversee sunscreens as therapeutic goods to ensure they provide effective sun protection. The administration has confirmed that investigations are ongoing, particularly as Australia approaches the high UV exposure months of summer.

This situation underscores the critical importance of trust, transparency, and regulatory compliance in the sunscreen market. The TGA has invited affected companies to propose regulatory responses and is considering further laboratory testing, noting persistent challenges in the current SPF testing methodologies.

Australians are encouraged to continue using sunscreen correctly, reapplying as directed, and choosing products with verified SPF claims.

For companies, this serves as a strong reminder of the need for validated testing and accurate product claims. Our regulatory consultants can help ensure your formulations and test results meet compliance standards, giving your business and your customers peace of mind. 

Stay informed as discussions continue around potential reforms to how sunscreens are regulated and tested in Australia.

Consumers are becoming increasingly mindful of their drinking habits, embracing moderation and exploring reduced or zero-alcohol options for health and lifestyle benefits. The global market performance of no and low alcohol wines continues to show strong momentum, reflecting a sustained change in consumer preferences.

As the market evolves, producers need to understand and comply with the regulatory requirements that govern claims such as “low,” “light,” or “zero.” These descriptors must meet the relevant definitions under the Australia New Zealand Food Standards Code.

Under Standard 1.2.7, “light” or “low” is considered a comparative claim and must clearly identify the reference product on which the comparison is based and accurately represent the difference. The Code restricts certain claims and uses defined limits, advising that producers avoid using certain expressions that may not comply with requirements.

If choosing to use your true product name of Wine, it must also comply with the standards definition of a ‘wine product’.  As well, to consider the use of additives or processing aids that are not approved under the Wine Production Standard (4.5.1) may also impact your labelling.

There are tight controls around the labelling and identification of alcoholic products in Australia, with the vast compliance and definitions that manufacturers are required to follow.

Don’t get caught up in the mix up and partner with MSAC on the labelling of products to meet all legal standards of your beverages, avoiding costly errors and ensuring your brand builds trust with consumers.