1. Country of Origin Labelling
This information is for Metcash’s retailer customers; not for public distribution.
The information provided is for general guidance only. It does not exhaustively summarise the Country of Origin Labelling requirements, and should not be taken as legal advice. While we have made every attempt to ensure that the information is correct and current, laws can be changed and updated, and their application can vary based on specific products and circumstances. Retailers should obtain their own independent legal advice in respect of the application of the Country of Origin Legislation in their own store(s).
27 November 2018
As presented at the 2016 and 2017 Metcash Supermarkets & Convenience Expos and regional meetings in February 2018, the Australian Government’s new Country of Origin Food Labelling Information Standard 2016 has been in place since 1 July 2016, requiring most food for retail sale in Australia to carry country of origin information. A transition period of two years was granted, and we are now approaching the deadline of 1 July 2018 for all businesses to become compliant.
The Country of Origin Food Labelling Information Standard places two key regulatory obligations on to anyone who sells food at a retail level:
That the product is labelled in accordance with the requirements of the Standard; and
That whoever makes the sale holds records of the materials relied upon in making the label declaration.
Businesses that fail to comply with the legislation from 1 July 2018 face a maximum penalty of $1.1 million, and individuals face a maximum penalty of $220,000. This includes making false or misleading representations about the origin of goods.
What does it look like?
Country of origin information can be a text statement or an image called the ‘standard mark’ (the kangaroo in a triangle and bar graph showing percentage of Australian product). The type of label required is dependent on the product, so if you are producing anything in store, you need to check via the online tool to ensure your in-store products or direct lines are compliant.
CoOL p1

2. Country of Origin Labelling
This information is for Metcash’s retailer customers; not for public distribution.
The information provided is for general guidance only. It does not exhaustively summarise the Country of Origin Labelling requirements, and should not be taken as legal advice. While we have made every attempt to ensure that the information is correct and current, laws can be changed and updated, and their application can vary based on specific products and circumstances. Retailers should obtain their own independent legal advice in respect of the application of the Country of Origin Legislation in their own store(s).
27 November 2018
Direct purchased products
Any products you stock that are purchased direct from a supplier (i.e. without any involvement by Metcash) will need to be checked by you for compliance. It is up to the supplier to ensure they are complying with the legislation, but as the seller of this stock to the public, you can also be held liable for selling products that do not comply – so it is important you check all of your directs products upon receipt and talk to your suppliers about what is required.
If a supplier’s country of origin statement changes, you will need to contact your supplier for product verification information, as you could be liable for the product your are selling. Generally, a good supplier will advise you in advance. Each change in country of origin for a product should be identified as a separate product/item by the supplier.
You may decide to conduct your own review of a certain product if you suspect supplier information is questionable. If a supplier cannot provide you with a documented specification for each product, then this is a sign for alert. The specification should be less than 12 months old.
Packed and labelled exemption
The ACCC will provide an exemption to stock that has been packaged and labelled prior to 1 July This means that stocked labelled in compliance with the old laws can still be sold on the market after 1 July 2018, so long as suppliers can prove the label was applied prior to that date. Suppliers will need to run down stock that has been packaged prior to this date, so you may receive some longer shelf life items with an ‘old’ label for a period of time.
CoOL p2

3. Country of Origin Labelling
This information is for Metcash’s retailer customers; not for public distribution.
The information provided is for general guidance only. It does not exhaustively summarise the Country of Origin Labelling requirements, and should not be taken as legal advice. While we have made every attempt to ensure that the information is correct and current, laws can be changed and updated, and their application can vary based on specific products and circumstances. Retailers should obtain their own independent legal advice in respect of the application of the Country of Origin Legislation in their own store(s).
27 November 2018
Record keeping
Records of country of origin claims must be kept for 12 months from the sale of the item.
If a retailer is asked to substantiate a country of origin claim for products supplied through the Metcash DC, Metcash Customer Service will support these requests in a timely manner.
For direct items, or items packaged in your store, it is the responsibility of the retailer to ensure that these records are available.
Packaging your own products
If you are packaging your own products, there are a number of rules around this, so you need to make sure you refer to the ACCC documentation. Some of the considerations:
Underestimate rather than overestimate the Australian content
Labels must be clearly legible and in English
Use the online tool to help with creating your own labels
Packaging your own products to sell to other businesses:
If you package food products for retail sale to another business (such as selling fresh meat packs to other IGA stores), then you MUST:
Label these packages according to the CoOL Standard, regardless of where they were made AND packaged in-store
Be able to provide evidence of the country of origin, upon request by the other business, to enable them to comply with their own CoOL requirements
Keep record of such evidence for 12 months after the sale, for each product you sell to another business
CoOL p3

4. Country of Origin Labelling
This information is for Metcash’s retailer customers; not for public distribution.
The information provided is for general guidance only. It does not exhaustively summarise the Country of Origin Labelling requirements, and should not be taken as legal advice. While we have made every attempt to ensure that the information is correct and current, laws can be changed and updated, and their application can vary based on specific products and circumstances. Retailers should obtain their own independent legal advice in respect of the application of the Country of Origin Legislation in their own store(s).
27 November 2018
For more information
General questions should be answered by the links below. Business or Metcash-specific questions can be directed to
Links and government information
The Country of Origin Labelling Information Standard 2016:
ACCC’s guidelines:
County of Origin Labelling Tool: goods/Country-of-origin-food-labelling/Country-of-Origin-Labelling-online-tool
Country of Origin Style Guide Video: goods/country-of-origin-food-labelling
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