Country of origin: Who labels export beef diverted to retail?

James Nason, 03/07/2018

When beef processed in an export-accredited abattoir is sold onto Australia’s domestic market, who is responsible for adding the now-required Country of Origin labelling to that product – the processor or the retailer?

Three component label

The Country of Origin Food Labelling Information Standard which took effect from Sunday, July 1, now requires red meat sold at retail in Australia to be labelled with a “three-component standard mark” ( pictured below right).

The majority of cattle slaughtered in Australia are processed in the country’s 90 or so export-accredited abattoirs, but it isn’t unusual for beef processed in an export abattoir to not be exported but sold domestically.

This scenario has raised questions as to who bears the responsibility for ensuring sure that diverted beef is labelled appropriately for the domestic market, and whether it is up to the processor or the retailer (i.e. butcher or supermarket) to add the correct Country of Origin labels to the product before it goes on shelves.

Two component label

An Australian Competition and Consumer Commission response to Beef Central this week indicates the answer will depend on the particular circumstance.

An ACCC spokesperson said it is clear that if a food intended for export is redirected into the domestic market, it must be labelled according to the requirements of the Country of Origin Food Labelling Information Standard.

The ACCC said the business supplying the redirected food will need to make an assessment about labelling requirements.

Country of Origin statement

A redirected packaged food must bear the appropriate country of origin label if it:

(1) is ‘suitable for retail sale’ without any further processing, packaging or labelling, and

(2) is required to ‘bear a label’ under the Food Standards Code.

For example, if the redirected export meat is packaged in the processor’s packaging and can be placed directly on the retail shelf in that packaging by the retailer, then the processor will need to ensure the packaging has appropriate labelling.

A redirected food that is not (ACCC’s emphasis) suitable for retail sale will need to have country of origin labelling displayed when it is offered for retail sale.

This means that if the redirected export meat needs to be cut up or otherwise needs further labelling or packaging to be retail-ready, then Country of Origin labelling will need to be applied to the packaging or displayed on the retail shelf by the retailer.

‘Country of Origin’ or ‘Extent of Australian origin’?

While the new laws have been called ‘Country of Origin’ labelling, some have taken to social media this week challenging that description.

They point out that the new laws do not require the identification of any other country involved in the production of food sold at retail in Australia.

The labelling requires the identification of the amount of the product that was grown, produced, made or packed in Australia, but does not indicate which other countries were involved, just that the non-Australian content was produced/manufactured ‘overseas’.


What about sausages made with Aussie beef and imported sausage meal?

There are three types of country of origin labels included in the Standard – the three-component standard mark, the two-component standard mark and the country of origin (as pictured above – also more information on each on the ACCC website here)

As a ‘priority food’ under the Standard, red meat must be labelled with the “three-component standard mark”, unless an exemption applies.

The ACCC advises that a ‘Grown in Australia’ or ‘Product of Australia’ three-component standard mark can only be used for foods that contain exclusively Australian ingredients.

For example, these labels could be used on Australian-grown beef (i.e. 100pc beef with no other ingredients).

A food with imported ingredients can only claim to have been ‘Made in’ a country if processing in that country has resulted in an end product that is fundamentally different from those imported ingredients.

A sausage made in Australia using Australian beef and a sausage meal (containing Australian and imported ingredients) would be labelled with a ‘Made in Australia’ three component mark with the proportion of Australian content clearly indicated in the bar chart and text.

The proportion of Australian ingredients in a food is worked out according to the weight of the ingredients and must be rounded down to the nearest whole number (i.e. 99.9% becomes 99%).

The ACCC has been providing education to business and consumers in relation to the new country of origin labelling laws since 2016 and through 2017.

The ACCC said in recent months it had engaged and presented to members of the Australian Meat Industry Council and others in the meat industry to educate butchers and wholesalers about the new Country of Origin Labelling requirements.


Your email address will not be published. Required fields are marked *

Your comment will not appear until it has been moderated.
Contributions that contravene our Comments Policy will not be published.


  1. Ron Legge, 03/07/2018

    I agree with Kristy Hayward 100%

  2. Bert Mann, 03/07/2018

    this is the biggest load of rubbish forced onto businesses in a long time. shame on the government

Get Beef Central's news headlines emailed to you -