10 Food Labelling Mistakes That Can Delay Your Product Launch
Launching a new exciting food product in Australia involves much more than developing a great recipe, attractive packaging and a strong marketing strategy. Before your product reaches supermarket shelves, online stores or consumers, its label needs to meet Australia's food regulatory requirements.
Getting that label wrong can be expensive.
A seemingly minor mistake—such as an incorrectly formatted allergen declaration, an incomplete Nutrition Information Panel or an unsupported health claim—can lead to artwork revisions, additional testing, reprinting and delays to your planned launch.
Understanding food labelling regulations Australia businesses must comply with is therefore an important part of product development.
Food Standards Australia New Zealand (FSANZ) develops the Australia New Zealand Food Standards Code, which contains general labelling requirements as well as requirements applying to particular types of foods. In Australia, these standards are enforced by state and territory authorities.
Here are 10 common food labelling mistakes that can cause problems during the final stages of bringing a product to market.
1. Missing Mandatory Information
One of the most fundamental mistakes is designing packaging before determining exactly what information must appear on it.
The Food Standards Code contains numerous labelling and information requirements. Depending on the product, these may cover areas such as food identification, ingredient statements, date marking, directions for use and storage, warning and advisory statements, nutrition information and characterising ingredients.
Additional requirements can also apply to specific categories of food.
Leaving mandatory information until late in the packaging design process can create significant problems. There may simply not be enough space to add everything while maintaining an attractive and legible design.
How to avoid it: Create a regulatory labelling checklist for the specific product before finalising the packaging layout.
2. Incorrect Allergen Declarations
Allergen labelling is one area where mistakes can have particularly serious consequences because consumers rely on this information to make safe purchasing decisions.
Australia's Plain English Allergen Labelling requirements specify how prescribed allergens must be declared.
Allergens generally need to appear using their required names in the ingredient statement, in bold type with a font size no smaller than other listed ingredients. A separate bold allergen summary statement beginning with “Contains” must also appear directly next to the ingredient statement and in the same field of view.
Prescribed allergens include substances such as wheat, milk, egg, peanut, soy, sesame, fish, crustaceans, molluscs, lupin and specified individual tree nuts. Certain cereals containing gluten must also be identified appropriately, while added sulphites require declaration at specified concentrations.
Using outdated allergen terminology or formatting can therefore result in a label requiring correction.
How to avoid it: Review every ingredient, compound ingredient, additive and processing aid for potential allergen declarations and check the final artwork against current FSANZ requirements.
3. Using an Inaccurate Ingredient List
An ingredient statement cannot simply be copied from an early product development specification.
Recipes frequently change during commercialisation. Suppliers may change, ingredients can be reformulated, and compound ingredients can introduce components or allergens that were not obvious in the original formulation.
If the final production formulation and the ingredient statement do not match, the packaging may no longer be compliant.
Ingredient declarations are governed by Standard 1.2.4 of the Food Standards Code.
How to avoid it: Conduct the final regulatory review using the actual commercial formulation and current supplier specifications—not an outdated prototype recipe.
4. Getting the Nutrition Information Panel Wrong
Most packaged foods requiring a Nutrition Information Panel (NIP) must provide specific nutrition information in a prescribed format.
Under Standard 1.2.8, a standard NIP generally includes average quantities for:
- energy
- protein
- fat
- saturated fat
- carbohydrate
- sugars
- sodium.
The information is generally presented per serving and per 100 g or 100 mL.
Errors can occur when businesses calculate nutrition information using an outdated formulation, apply incorrect serving sizes, use inappropriate data or fail to include additional nutrients triggered by claims.
For example, if a product makes a “good source of fibre” claim, dietary fibre information needs to be included in the NIP.
How to avoid it: Make sure the NIP is based on the final formulation and review whether any claims on the packaging trigger additional nutrition declarations.
5. Making Nutrition Content Claims Without Checking the Criteria
Marketing teams naturally want to highlight a product's strongest nutritional attributes.
Terms such as “low fat” or “good source of calcium”, however, aren't simply creative advertising language. Nutrition content claims are regulated.
Standard 1.2.7 establishes requirements for nutrition content and health claims. A nutrition content claim must satisfy the applicable conditions before it can be used. FSANZ notes, for example, that a product carrying a “good source of calcium” claim must contain at least the amount required by the Standard.
Problems can arise when marketing copy is approved before regulatory assessment.
How to avoid it: Treat every nutritional statement on the label as a potential regulated claim and verify the relevant conditions before artwork approval.
6. Making Unsupported Health Claims
Health claims require even greater care.
A health claim connects a food, nutrient or substance with a health effect. Under Australia's framework, health claims must be supported by scientific evidence and comply with Standard 1.2.7.
There are two main categories: general level health claims and high level health claims.
General level health claims may rely on pre-approved food-health relationships or, subject to the Code's requirements, a relationship self-substantiated by the food business. High level health claims must be based on pre-approved food-health relationships. Foods carrying health claims must also satisfy applicable requirements, including the Nutrient Profiling Scoring Criterion (NPSC).
A marketing phrase that sounds harmless can therefore create significant regulatory implications.
How to avoid it: Have proposed health-related marketing language reviewed before incorporating it into packaging, advertising or launch materials.
7. Forgetting That Claims Can Change the Rest of the Label
Another common mistake is reviewing each part of a label independently.
Food labelling requirements are interconnected.
Adding a claim to the front of the package can trigger additional requirements elsewhere. For example, certain nutrition claims require the relevant nutrient or substance to be declared in the Nutrition Information Panel.
This means a last-minute marketing change may require more than simply adding a badge or sentence to the front panel.
It could affect the NIP, supporting documentation and potentially whether the claim can legally be made at all.
How to avoid it: Whenever marketing copy changes, conduct another regulatory review of the entire label rather than reviewing only the amended wording.
8. Overlooking Warning and Advisory Statement Requirements
Allergens aren't the only substances that may trigger mandatory declarations.
Standard 1.2.3 deals with warning statements, advisory statements and declarations. Depending on a product's ingredients and composition, additional statements may be required.
The exact requirements vary considerably according to the food and its ingredients, which makes generic label templates risky.
A label used successfully for one product should not automatically be copied across an entire range without checking whether the formulation introduces different regulatory obligations.
How to avoid it: Assess each SKU individually against the relevant requirements of the Food Standards Code.
9. Treating Label Design as Only a Graphic Design Exercise
A beautiful label isn't necessarily a compliant label.
Branding agencies and graphic designers are experts at creating visually appealing packaging, but regulatory information has its own requirements regarding wording, placement, format and presentation.
Allergen declarations demonstrate this clearly: prescribed allergens must be presented using particular terminology and formatting, including bold declarations and a separate “Contains” summary statement in the required location.
Changing the layout for aesthetic reasons can unintentionally create a compliance problem.
How to avoid it: Build regulatory review into the artwork process. Ideally, review the text before design begins and then conduct a final artwork review before files are released for printing.
10. Waiting Until the Final Week to Check FSANZ Compliance
Perhaps the most expensive food labelling mistake is simply leaving compliance too late.
Imagine that packaging has been designed, thousands of labels are ready for printing, retailers have been given a launch date and a marketing campaign is scheduled.
Then someone discovers that the allergen statement is incorrect or a front-of-pack claim doesn't meet the necessary criteria.
Suddenly the business may need revised artwork, additional calculations, new approvals and potentially reprinted packaging.
The better approach is to incorporate food labelling regulations Australia compliance into the product development process from the beginning.
FSANZ's Code covers general requirements applying broadly across foods as well as specific requirements for certain food categories.
Early regulatory review allows potential issues to be identified while they are still relatively easy—and inexpensive—to fix.
Why Pre-Launch Food Label Reviews Matter
Food labels sit at the intersection of product development, regulatory compliance and marketing.
The formulation determines the ingredient and allergen information. Nutrition data affects the Nutrition Information Panel. Marketing statements can trigger additional nutrition requirements. Health claims can introduce further substantiation and eligibility criteria.
That interconnectedness is why reviewing only the finished artwork can be risky.
A thorough pre-launch assessment should consider the final formulation, supplier specifications, ingredient declarations, allergens, mandatory statements, nutrition information, marketing claims and any category-specific FSANZ requirements.
It should also consider whether the final presentation accurately represents the product. FSANZ notes that food representations are also subject to applicable food and fair-trading laws prohibiting false, misleading or deceptive representations.
Get Your Food Label Right Before You Launch
Launching a food product requires substantial investment in formulation, manufacturing, packaging, marketing and distribution. A preventable labelling problem should not be the reason all that work is delayed.
Understanding food labelling regulations Australia requirements early can help businesses identify compliance issues before packaging goes to print and before launch deadlines become difficult to change.
Regulatory Matters can assist food businesses with regulatory and labelling considerations during product development and commercialisation.
Whether you're developing a new food product, reformulating an existing range or preparing new packaging, obtaining regulatory advice before artwork approval can help reduce costly last-minute changes.
