>>Dr Schaper: Now, let's say he has to make a
country of origin claim. Tania,
I know your burning question was about this.
>>Ms Chapman: That's right.
From the growers I've spoken to and as one
myself, one of the fundamental issues that we
face is when does this new Standard apply to me?
There are many different ways farmers can sell
their produce, so I'm looking for some clarity
around that.
>>Dr Schaper: Now, in terms of who has to
display or attach the label,
it's worth noting that the new Standard imposes the
labelling requirements on the foods,
not on the trader.
This means that, depending on the circumstances,
the obligation to provide labelling can apply to
growers or to distributers or importers or
manufacturers or retailers.
A good starting point is if you previously had to
provide country of origin labelling under the old
Food Code, then the new Standard is going to apply
to you.
Put simply, food must have country of origin
labelling if it fits into one of the following
categories; firstly, if it's in a package,
it doesn't matter whether it's for wholesale or
retail sale in this case.
Secondly, if it's certain unpackaged seafood, meats,
fruits, vegetables, nuts, seed and fungi and it's
being offered for retail sale or, thirdly,
if it's fresh fruit or vegetables in transparent
packaging and it's being offered for retail sale.
>>Ms Chapman: Okay, so we'll need to label fruit
and vegies for retail sale,
but what about wholesale?
If I sell my produce to the central markets,
do I have to provide country of origin
labelling?
>>Dr Schaper: No, the Standard doesn't require
labelling at the wholesale level for fresh fruit and
vegetables, although some buyers may still ask you
to provide this information in some form.
A manufacturer or retailer who needs origin
information to do their labelling can also require
their suppliers to provide this information,
so that's worth bearing in mind.
>>Mr Preston: Yeah, but this doesn't mean that all
retail sales of food are covered.
Like under the old Food Code,
there's a number of exceptions where food
wouldn't require country of origin labelling.
These include food that is sold at a restaurant,
canteen or by a catering business for immediate
consumption or delivered at the customer's request,
packaged and ready to eat, for example,
a takeaway pizza.
Or food that's made and packaged on the same
premises where it's sold, like cake made from
scratch in a bakery.
>>Ms Chapman: Another example of this one,
the last one, could be a dairy processor who makes,
packages and sells cheese from the farm shop on
their property.
>>Mr Preston: Yeah, that's absolutely right, Tania.
In that instance, a country of origin label
would only be required if the cheese was sold at
another location off the property.
>>Dr Schaper: So, we know which food has to be
labelled, but who is responsible for actually
doing the labelling?
Tania, we've got a few different scenarios,
so why don't you run us through these?
>>Ms Chapman: Sure.
First, let's look at when a grower has to label
their produce.
We've already said that the new Standard applies
to the retail sale of loose fruit and veg,
and fresh fruit and veg in transparent packaging.
So, if you're a grower and you're selling your
produce directly to consumers,
such as at a market, you'll need to comply with
the Standard, otherwise you'll just have to
provide the origin information upon request
if a wholesale buyer needs it to do their labelling.
Next, if you're a manufacturer or processor
of packaged food products, it's generally safe to
assume you have to provide labelling unless an
exemption applies.
Finally, if you're a retailer,
you'll need to make sure that the packaged food you
supply is labelled.
You'll also need to make sure that those labels are
displayed on or near fresh fruit and veg in
transparent packaging, as well as the required
unpackaged foods.
>>Mr Preston: What happens if I import products from
an overseas manufacturer who doesn't want to add
the new labels to their packaging just for the
Australian market?
>>Dr Schaper: Well, Chris, if the food's going to be
sold in Australia, it must be labelled according to
the Standard as from 1 July 2018.
If not, it simply won't be allowed into the country.
This is because customs regulations will require
imported foods to be labelled according to the
Standard at the border.
>>Mr Preston: Michael, can a business that's exempt
from the Standard choose to use the new picture
labels on their products?
For example, a fast food delivery business that
wants to use the "Made in Australia" kangaroo in
triangle on their packaging?
>>Dr Schaper: Yes, but there's a "but".
If your business isn't required to use the
picture labels, but you choose to do so,
then you must comply to the rules in the Standard
that apply around the use of those labels.
Now, this principle also applies to businesses that
choose to label non-priority foods as if
they were priority items.
And for those who do have to comply with the
Standard, there are some key dates you need to be
aware of.
From now until 30 June 2018 you have two options.
You can either, one, continue to comply with
the country of origin requirements of the old
Food Code or, two, you can adopt the new labelling
requirements under the Standard.
If you have to use the new picture labels,
you have until 1 July 2018 to make the transition.
The existing requirements for country of origin
labelling in the Food Code are going to remain in
place up until the day before then.
Chris, I bet manufacturers and processors want to
know what happens to stock that's already been
labelled under the old Food Code?
>>Mr Preston: Absolutely.
Manufacturers have asked me things like,
"What happens if I make a product that has a
ten-year shelf life and it's on shelves after
1 July 2018, still with the old labelling?"
Well, that's okay under the new Standard.
Basically, if you attach the code compliant label
to the food on or before 30 June 2018,
that food can see out its shelf life.
You won't have to relabel it in order to comply with
the new Standard.
>>Dr Schaper: That's right.
Now, bear in mind this principle will apply
differently depending on the packaging scenario.
The way we see it, there are two basic types of
packaging.
The first is where you attach the label to the
package, for example, you stick it on,
and the second is where it's part of the packaging
itself.
Let's use tinned soup as an example.
Here the country of origin label is going to appear
somewhere on the paper wrapper that you actually
stick to the tin.
If the wrapper with a food code compliant label is
stuck on or before 30 June 2018, well,
it can still be sold after this date.
However, from the next day on only the new labels can
be attached and this could be done by either printing
new paper wrappers or sticking over the old
country of origin label on the wrapper with a new one.
On the other hand, a cereal box would be an
example where the country of origin label is likely
to already be part of the packaging.
That is it's already part of the box.
In this case, the cereal couldn't be added to the
box on or after 1 July 2018 without either, one,
printing new boxes or, two,
covering the old label with a new one.
So, to sum up, one of our key takeaways,
so to speak, from this segment,
our tips and traps.
>>Ms Chapman: Well, for me,
I'd say you really need to figure out now whether you
need to use the new labels and if you leave things
too late you may not be ready come 1 July next year.
That could be a costly mistake for a business
that has to stop production because they
don't have their new packaging ready to go.
>>Mr Preston: Thanks, Tania.
My tip is actually very, very similar.
I think it's crucial that businesses manage their
packaging stock.
Don't make the mistake of being caught out with
heaps of costly packaging that you just can't use.
>>Dr Schaper: Some excellent tips, there.
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