Coding and labelling: decoding the rules for fresh produce, Part 1

In the first of this two-part series, we focus on demystifying the labelling rules for fresh produce. What’s mandatory? What’s not? What do retailers want?

It’s tough keeping up with food labelling and coding regulations. And it’s tougher still trying to work out which of these regulations applies to the fresh produce industry.

Several things add to the confusion:

  • new laws are introduced to protect consumers
  • industry standards are constantly evolving
  • at the same time, the customers of fruit and vegetable producers — the major supermarkets, processors and distributors — are insisting that suppliers implement their own specific labelling and coding rules for products

Producers are left asking: how exactly do we need to label and code our products?

Granted, there are some labelling and coding standards that fresh produce suppliers are not legally obliged to follow. However, often it’s in their best interests to do so anyway — whether it strengthens relationships with trading partners or improves their product’s traceability and efficiency through the supply chain. The important thing is to identify what works best for your particular product and supply chain.

Why fresh produce labels?

Consumers are increasingly looking to food labels for answers. Use-by dates, ingredients, allergen information, instructions for storage and preparation, advisory and warning statements, country of origin… the list goes on. And it’s getting longer. People want to know what’s in their food and where it comes from — and that includes fresh produce.

But it’s not only the consumers who need this information; retailers and wholesalers need answers too. Labelling and coding keeps the whole supply chain moving efficiently.

In Australia, it’s estimated that between 50-60% of supermarket sales are perishable items, with a loss of 5-7% as a result of poor inventory management (Planet Retail – Food Waste report). The right labelling helps better and faster turnaround of stock, improved stock accuracy and improved tracking of product recalls and withdrawals. So for any fresh produce suppliers who value longer-term relationships with their customers — and that’s probably every producer in Australia — labelling and coding compliance is a must.

Who makes the rules?

Food Standards Australia and New Zealand (FSANZ) sets the standards for what information must be on food labels in the Food Standards Code. Local state and territory agencies (such as the NSW Food Authority) enforce the rules.

Know the rules for fresh produce. The good news is that fresh produce is mostly exempt from the full labelling requirements, so long as it is:

  • not in packaging
  • whole or cut fresh fruit and vegetables in packaging that does not obscure the nature or quality

However, there may still be certain information that needs to be displayed in connection with the food or provided to the purchaser on request. The rules that do apply to fresh produce are:

Rule 1: country of origin

Country-of-origin labelling describes the country or countries where the food was grown, manufactured or packaged. Under the Food Standards Code, fresh produce must be labelled with its country of origin, including fruit, vegetables, nuts, spices, herbs, fungi, legumes and seeds. As Australian consumers display more and more interest in the origin of their food and its ingredients, country-of-origin labelling is becoming ever more important.

There are very specific rules about how this information must be displayed, the size and legibility of the labels and signs. You or your trading partners can face significant fines if these are not followed to the letter. Both Coles and Woolworths were fined in 2011 when stores were found by the NSW Food Authority to be selling fruit that was mislabelled under the country-of-origin labelling legislation.

According to the legislation, produce can be labelled in two ways, depending on how it is packaged:

  •  all fresh or packed fruit and vegetables must have a label identifying the country or countries where the food was grown or packaged, or;
  • there must be a sign connected to the display that identifies the country of origin

Here’s a quick guide to the definitions for country-of-origin labelling:

  • Product of” means the country of origin claimed must be the source of each significant ingredient of the food, plus all or virtually all the production and manufacturing processes must have happened in that country. For example, “Product of Australia” or “Produced in Australia” means that all significant ingredients used in the food originated in Australia and that the food is also manufactured in Australia.
  • Made in” means the goods have been substantially transformed in that country, with 50% of the production cost carried out in that country. For example, “Made in Australia” and “Manufactured in Australia” can only be used if the food has been significantly changed or processed in Australia.

If the produce comes from several places, there must be a statement to the effect that the foods are a mix of local and/or imported foods. A common example is “Made in Australia from imported ingredients”. For more details, check the Food Standards website.

Rule 2: Nutritional information

While the Food Standards Code requires all manufactured foods to have a nutrition information panel, fresh produce is exempt from this rule when sold unpackaged. However, if a nutrition claim is made, the retailer must have the nutrition information displayed close to where the food is displayed or available on request. And the company responsible for providing the nutritional information is also responsible for its accuracy.

What about ‘Australian Grown’?

Introduced in 2007, Australian Grown is a labelling scheme for fresh and packaged goods. Australian Grown is not a mandatory labelling requirement, but rather, companies have to earn the right to use it. The “Australian Made, Australian Grown” logo — the green and gold kangaroo symbol — can only be used on produce that is registered with the campaign and meets its criteria. You can find out how to register on their website.

What do retailers want?

In addition to meeting the Food Standards Code, fresh produce suppliers need to adhere to their customers’ labelling requirements. Retailers such as Coles, Woolworths, Metcash and Costco have strict labelling regulations to keep their warehouse and supply chain working efficiently, as well as helping them ensure they’re ticking all the boxes they need to from a regulatory view point. Mostly, this comes down to labelling at a carton or crate level.

Coles, for example, asks its fresh produce suppliers to follow specific carton/crate labelling requirements in which each “pickable entity” (crate, carton, bag, tray, bin) is individually labelled with product description, SKU code, unit of measure, vendor details and batch numbers. All labels must be colour-coded according to its Fresh Produce Product Label requirements — white for 14 degrees Celsius and pink for 3 deg C. And, of course, suppliers are reminded that each label must contain the mandatory country-of-origin information.

Many retailers request that GS1 logistics labels are assigned to cartons and pallets. Even if they don’t, these labels are a worthwhile method of providing information about the unit in a way that can be easily understood by both machines and humans. GS1 Australia provides detailed information on the types of logistic label for the fresh produce industry on its website.

How to get the right labels

Matthews can help you with your product labelcarton label and compliant pallet label for fresh produce. Combining the latest label applicator and printer technologies with expertise, Matthews ensures your fresh produce always has the right information in the right place to comply with your trading partners and the legislation.

In Fresh produce: decoding labelling and coding, Part 2, we will delve into coding rules for fresh produce.

For more information on labelling and coding for fresh produce, speak to the experts at Matthews. We also recommend you visit www.foodstandards.gov.au to stay up to date with the latest changes to the Food Standards Code, and see how optimising your packaging can optimise your supply chain.

Mark Dingley
Mark Dingley is Chairman of the Australian Packaging and Processing Machinery Association (APPMA) and is the CEO at Matthews Australasia. With 25 years of experience in the product identification industry and the wealth of knowledge gained from working closely with industry associations in developing and implementing standards & best practice, Mark is able to assist manufacturers with a range of issues from getting real-time visibility of their production line, improving automation, establishing quality assurance using machine vision to selecting the best fit technology for coding and labelling applications. Mark Dingley's LinkedIn Profile
Mark Dingley

by Mark Dingley

Mark Dingley is Chairman of the Australian Packaging and Processing Machinery Association (APPMA) and is the CEO at Matthews Australasia. With 25 years of experience in the product identification industry and the wealth of knowledge gained from working closely with industry associations in developing and implementing standards & best practice, Mark is able to assist manufacturers with a range of issues from getting real-time visibility of their production line, improving automation, establishing quality assurance using machine vision to selecting the best fit technology for coding and labelling applications. Mark Dingley's LinkedIn Profile

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