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.  

According to the newly released data, FSANZ coordinated 92 food recalls in 2025, above the 10-year average of 87. Undeclared allergens remained the leading cause of food recalls, accounting for 38% of all food recalls in 2025.  

Undeclared allergens are continuing to dominate as the leading cause of recalls, accounting for 35 recalls in 2025. Milk, Wheat/Gluten, and Tree Nuts were the most commonly reported allergens, with many incidents linked to labelling and packaging errors. FSANZ reported that undeclared allergens have remained the primary recall driver for the past five years, with 197 allergen-related recalls recorded between 2021 and 2025.  

Microbial contamination and foreign matter were also major contributors to recalls, while mixed and processed foods remained the most frequently recalled product category.  

The data also provides insight into corrective actions being implemented by the industry. Between 2021 and 2025, the most common responses following recalls included staff training, amended handling procedures and updates to product labels and artwork.  

FSANZ noted that while rising recall numbers can indicate emerging supply chain or manufacturing issues, they also reflect stronger detection systems, improved internal testing and increased regulatory oversight. Many recalls are initiated proactively by businesses following internal monitoring, retailer feedback or consumer complaints.  

For manufacturers, importers and retailers, the latest figures reinforce the need for vigorous artwork review processes, allergen verification controls and ongoing supplier management. FSANZ continues to remind businesses that recall plans are mandatory and should be regularly reviewed to ensure rapid response capability if an issue arises.  

The latest recall statistics also come amid broader regulatory activity within the Australian food sector, including ongoing reviews of labelling requirements, nutrition information and food regulation systems, exactly what MSAC is here for! 

The renewed scheme, which initially launched as a pilot across five Victorian stores in early 2024, now allows customers to return clean and dry household soft plastics, including bread bags, chip packets, frozen food packaging and cereal liners, through dedicated collection bins located at participating stores.  

According to Woolworths, approximately 40 million pieces of soft plastic packaging, equivalent to more than 310,000 kilograms, have already been collected and processed through the program. The retailer says collected materials are being converted into products, including in-store wall panelling, building materials and selected Woolworths own-brand bread bags containing 30 per cent recycled plastic.  

The program is being supported by Australian recycling partners with Woolworths also collaborating through Soft Plastics Stewardship Australia (SPSA), alongside major brands such as Mars and Nestlé to help rebuild Australia’s soft plastics recycling infrastructure.  

The relaunch follows significant scrutiny of Australia’s soft plastics recycling system after the collapse of REDcycle left thousands of tonnes of material stockpiled nationally. Since then, regulators and industry have worked to restore consumer confidence while expanding local processing capacity and improving transparency across the recycling supply chain.  

For food and packaging businesses, the expanded collection network signals increasing industry momentum towards circular packaging systems and recycled-content packaging outcomes. It also reinforces the growing importance of Australasian Recycling Label (ARL) guidance, stewardship participation and design-for-recyclability considerations as retailers continue investing in packaging recovery initiatives.