Category Archives: Food Labelling Review – Australia

Label Review Guide Australia – Food Category Sauce – Pete Evans 330g Butter Chicken – 10th December 2018

Label Review Guide Australia
Pete Evans 330g Butter Chicken

Pete Evans 330g Simmer Sauce Jamaican, Butter Chicken Front
Pete Evans 330g Simmer Sauce Jamaican, Butter Chicken Front
Pete Evans 330g Simmer Sauce Jamaican, Butter Chicken Side 2
Pete Evans 330g Simmer Sauce Jamaican, Butter Chicken Side 2
Pete Evans 330g Simmer Sauce Jamaican, Butter Chicken Side 1
Pete Evans 330g Simmer Sauce Jamaican, Butter Chicken Side 1
  1. Prescribed Name, Name or Description of Food – This product Pete Evans does not have a prescribed name as perStandard 1.2.2-2 (1)(a) Information requirements – food identification.  Otherwise it requires a name or descriptionto be sufficient to indicate the true nature of the food.  In this case ‘Simmer Sauce’ is the name andthe description ‘Healthy meal base for curries and stir-frys’.   The type of simmer sauce is ButterChicken. 
  2. Company Name and Address – Clearlystated on the label Ozganics Australia and full address given.
  3. Weights and Measures Declarations – Thissection falls under the National Trade Measurement Regulations 2009.  In relation to food, this regulation sets outwhat unit of measure to use (mass, volume etc) and the marking of themeasurement.  For this product themeasurement marking is 330g and needs to comply to division 4.4 which outlinesthe requirements, position, set-out (how many mm from the package limits) andcharacter size.
  4. (Production) Lot Identification – Batchidentification given below the best before date.  Given as 15018674/2
  5. (Shelf Life) Date Marking – As this isa best before food item and is more than 3 months from the date the month andyear to be applied.  In this case it isprinted on the jar ‘BEST BEFORE: 30/05/2020’. Standard 1.2.5-5 (4)(b)
  6. Directions of Use and Storage – Due tohealth or safety reasons storage conditions are given as instructionsrefrigerate after opening.  Use within 5days.  Although not required to have adirection of use as it is not a health or safety issue to open the jar andconsume right away.  However a servingsuggestion is given for Pete’s butter chicken recipe. 
  7. Country of Origin – Correct as per the‘Country of Origin Food Labelling Information Standard 2016’.  It has on the jar ‘Made in Australia from atleast 70% Australian ingredients’.  Itfollows the style guide and in the correct format. 
  8. Nutrition, Health and Related Claims –This product has a claims on the front and back of the label.  On the front of the label and the tamperproof tag from the lid to jar base has the words ‘No Added Sugar’.  Under standard 1.2.7 – 12 Nutrition, healthand related claims in S4-3 the food property is listed in column 1 whichrequires a specific descriptor column 3 ‘No Added’ and the conditions that mustbe met column 4.  The conditions for ‘NoAdded Sugar’ are the food contains no added sugars (in the standard meansmonosaccharides and disaccharides), honey, malt or malt extracts andconcentrated fruit juice.  Reviewing theingredient listing this product meets the requirements for a ‘No Added Sugar’claim.  On the side of the label is theclaim ‘Gluten & Dairy Free’.  Looking at ‘Gluten Free’ claim using the samestandard list as above S4-3 to be ‘free’ the food must not contain detectablegluten, oats or cereals.  As per FoodStandards Code 1.2.8 Nutrition information requirements 1.2.8-6 (iv) What mustbe on the nutrition information panel must be the name and average quantity ofany other nutrient in respect of which a claim requiring nutrition informationis made.  To provide clarity on this1.28-4 definitions claim requiring nutrition information (a)(i) a nutritioncontent claim.  Reviewing the labelnutrition information panel gluten values is absent which will be covered inpoint 9 below.  The next claim on theproduct is ‘dairy free’.  This claim doesnot fall under a nutrition content claim as per section 1.1.2-9definition.  This claim falls under theACCC as the statement needs to be accurate and not mislead consumers.   
  9. Nutrition Information Requirements –The nutrition information is clear andconforms to the food standards code 1.2.8 on the back of the label.  The per serve value for Carbohydrate andsugar should have been rounded up to 4.8g and 2.5g as the serving size is82.5g.  Due to the use of the nutritioncontent claim ‘gluten free’ this needs to be included in the nutritioninformation panel as per S12 -2.  What isnot clear if the words ‘not detected’ in the nutrition information panel isacceptable  or should you follow theexample 1.2.8-6 (6) and use the symbol ‘0’ which is required for the absence ofdietary fibre.  Given the amount of‘gluten free’ foods on the market this needs to clear in the foodstandards. 
  10. Characterising Ingredients and Componentsof Food – On front of label is ‘with turmeric, coconut & spices’ as perstandard 1.2.10 these characterising ingredients are emphasised on the label ofthe food in words.  The declaration ofthe characterising ingredients must be declared as a percentage 1.2.10-8 whichcan be found in the ingredient list (turmeric 0.1%, coconut 5.2% & Herbs& Spices 2.7%).  Grouping ‘herbs’with the spices for the declaration of characterising ingredients is not clearand should be listed separately.   
  11. List ofIngredients – Following standard 1.2.4 information requirements statementof ingredients Pete Evans Butter Chicken Simmer Sauce complies.  The ingredients are listed by common,descriptive or generic names and appear to be in descending order of ingoingweight.  This product contains foodadditives which have followed S7-2 food additive class names ‘thickener’ andoptional class names ‘vegetable gum’ with the name followed in brackets.   
  12. Warning and Advisory Statement – Doesnot apply to this product.
  13. LegibilityRequirements – The characters size 4.12 section in relation to the PeteEvans Butter Chicken Simmer Sauce conforms to the standard as 330g is printedin a colour that provides a distinct contrast with the background colour andover 4.8mm in height.
  14. MarketingClaim – This product has a few marketing claims that fall under the ACCCTrade Practices act.  The Non GMOCompliance Australia logo on the side of the jar is a food type assurance claimwere a specific system or process has been put in place to provide assurance tospecific consumer groups.  From thewebsite this group is a not for profit organisation and business have to meettheir standards (and pay!) to be able to use the logo on the packaging. On thefront label is the branding Pete Evans ‘Healthy Everyday’ and the copy ‘Healthymeal base for curries and stir-frys’ the word ‘healthy’ for consumers must notbe mislead, deceive or be false.  Howwould you know if this was a ‘healthy’ meal base?  On the back of the label has a similarstatement ‘My sauces are full of flavour and healthy wholefood ingredients’ theuse of the word wholefood ingredients could be misleading as it is statementsaying all ingredients are ‘wholefoods’ or that it contains ‘wholefoods’.  As the process for tapioca starch and xanthanare far from ‘wholefoods’.       
Pete Evans 330g Simmer Sauce Jamaican, Butter Chicken
Pete Evans 330g Simmer Sauce Jamaican, Butter Chicken

Label Review Guide Australia – Food Category Confectionery – M&M’s 130g Caramel – 22nd August 2018

M&M's 130g Caramel

M&M’s 130g Caramel

M&M's 130g Caramel Bottom

M&M’s 130g Caramel Bottom






M&M's 130g Caramel Back

M&M’s 130g Caramel Back

M&M's 130g Caramel Front

M&M’s 130g Caramel Front










  1. Prescribed Name, Name or Description of Food – Front of pack is the product is M&M’s with the flavour being caramel. Back of pack has the word ‘Confectionery’ which is clear with a description of the product – Bite size pieces of milk chocolate with a caramel centre coated with a thin crisp shell.
  2. Company Name and Address – This information is found on the bottom of the pouch and the imported by details being Mars Chocolate Australia. It also has the Mars New Zealand address which is extra information as Australia and New Zealand share the same Food Standards Code and can list just Australia or New Zealand company details.
  3. Weights and Measures Declarations – Clear and is printed in a colour that provides a distinct contrast with the colour of the blue background. Due to pack size the minimum height of the characters is 2.5mm which is ~5mm.  As per National Trade Measurement Regulations 2009.
  4. (Production) Lot Identification – Provided in the Best Before white box 816CBTOP23. The date can also be used as lot identification.
  5. (Shelf Life) Date Marking – As this is a best before food item and is more than 3 months from the date the month and year to be applied. As per the Australia New Zealand Food Standards Code – Standard 1.2.5 – Information requirements – date marking 1.2.5-5(4)(b) the examples given don’t include the dash ‘/’ which is printed on the pack 04/2019.  Update required to match code can include Apr 2019 or 04 2019.
  6. Directions of Use and Storage – Not needed as the requirements are if specific storage conditions are required to ensure that the food will keep until the best before date. Also for health and safety reasons.  Mars can include this information if it likes for quality reasons given this is a chocolate product in the Australian climate such as ‘store in cool dry place’.
  7. Country of Origin – As this item is a non-priority food being confectionery it only requires to carry a country of origin text statement. In this case ‘Made in the USA’ complies the Country of Origin Food Labelling Information Standard 2016 but not sure why the word ‘the’ is added.
  8. Nutrition, Health and Related Claims – No claims made as it is confectionery.
  9. Nutrition Information Requirements – Meets Australian regulation. However some notes can be made; the panel clearly indicates the average quantities as per the standard.  In this case it is indicated twice in the header ‘Average Quantities’ and at the bottom ‘All nutrition values are averages’.  The line ‘Your daily intakes may be higher or lower depending on your energy needs’ is not required but extra information for the consumer.
  10. Characterising Ingredients and Components of Food – As this is a caramel product and the characterising ingredient the percentage is given at 26%. Milk chocolate is also used in the product and needs to meet standard 2.10.4-2 miscellaneous standards for other foods for chocolate.  At 29% cocoa solids stated on pack meets the minimum of 20% (200 g/kg) cocoa bean derivatives.  The percentage of milk solids is also listed at 23% because it is ‘milk’ chocolate.
  11. List of Ingredients – Meets requirements. Food additives were used and as per schedule 7 Food additive class names were followed being thickener, emulsifier, colours, flavour and glazing agent.  Some of the class names also included the e number in brackets after.  The colours used in this product might raise some eyebrows; (171) Titanium dioxide, (129) Allura Red AC, (110) Sunset Yellow FCF, (102) Tartrazine, (133) Brilliant Blue FCF.
  12. Warning and Advisory Statement – Not required for this product.
  13. Legibility Requirements – No issues.
  1. Other Information (Open) – Daily intake guide thumbnails which are voluntary and managed by Australian Food & Grocery Council.  It is used to assist consumers to make inform choices as the values are preserving and daily intake percentage given.  The thumbnails used on pack show the correct information but don’t follow the ‘code’ for placement and design specifications.


Conclusions: Update require to best before format ‘04/2019’ replace the dash with a space ’04 2019’.  The layout of the daily intake thumbnails can be adjusted.