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Mandatory energy labelling on alcoholic beverages was implemented through Amendment No. 241 in August 2025. See what changed →

FSANZ consulting, one Code, two countries, ongoing change

Every food sold in Australia or New Zealand has to meet the Food Standards Code. We review composition, labelling and, where it applies, food safety standards against the current Code, including recent amendments.

What is FSANZ?

Food Standards Australia New Zealand, FSANZ, is a bi-national government agency responsible for developing the Australia New Zealand Food Standards Code, the set of standards that regulate food sold in Australia and New Zealand. FSANZ assesses applications and proposals to change the Code, and the FSANZ Board decides whether to approve changes, which are then notified to the Australian and New Zealand ministers responsible for food.

Food standards themselves are enforced by Australian state and territory food regulatory agencies, the Department of Agriculture, Fisheries and Forestry for imported food, and the New Zealand government. FSANZ also coordinates food surveillance and food recalls in Australia, alongside its core role developing the Code.

The Code is currently made up of 80 Standards and 29 Schedules, organised into parts with different territorial scope. Some standards apply across both countries, while others apply to Australia only, reflecting New Zealand's separate arrangements for primary production and processing food safety through its Ministry for Primary Industries.

The Code changes regularly. FSANZ maintains a consolidated PDF of all Standards and Schedules for reference, but the authoritative version is always the Federal Register of Legislation, since the consolidated document is updated only when a change is gazetted through an application or proposal.

FSANZ at a glance

Governs
Australia & New Zealand
Document
Food Standards Code
Structure
80 Standards, 29 Schedules
Parts 1 & 2
Both countries (ingredients, labelling)
Parts 3 & 4
Australia only (food safety, MRLs)
NZ food safety
Ministry for Primary Industries
Recent amendment
No. 241 (Aug 2025)
Latest microbiological guidance
Seafood & cell-cultured (2025)

How the Food Standards Code is organised

The Code's parts have different territorial scope, which matters for any business operating across both countries.

1

Parts 1 & 2: Composition & labelling

Apply in both Australia and New Zealand. Regulate ingredients, processing aids, colourings, additives, vitamins and minerals, composition of certain foods, genetically modified foods, and the labelling of packaged and unpackaged food.

2

Parts 3 & 4: Food safety standards (Australia)

Apply to Australia only. Cover food safety standards, primary production and processing standards, and maximum residue limits for agricultural and veterinary chemicals.

3

New Zealand food safety (separate)

In New Zealand, the activities covered by Parts 3 and 4 are undertaken separately by the New Zealand Ministry for Primary Industries, outside the Code itself.

For a business operating in both countries, this means Parts 1 and 2 give a shared baseline for product composition and labelling, but food safety system requirements diverge: Australian operations work to Code Parts 3 and 4, while New Zealand operations work to Ministry for Primary Industries requirements. A label that's correct for both countries doesn't mean the underlying food safety system is automatically compliant in both.

Energy labelling on alcoholic beverages

A significant 2025 amendment changed labelling requirements for an entire product category that previously sat apart from general Code labelling rules.

What changed, and when

On 25 July 2025, Australian Food Ministers endorsed FSANZ Board decisions on Proposal P1059, Energy Labelling on Alcoholic Beverages, and Proposal P1049, Carbohydrate and Sugar Claims on Alcoholic Beverages. These were implemented through Amendment No. 241 to the Food Standards Code, announced on 13 August 2025.

P1059

Alcoholic beverage manufacturers must clearly display energy, kilojoule, content labels on each drink, bringing alcoholic beverages closer to the labelling standard applied to other packaged foods.

P1049

New rules govern how carbohydrate and sugar claims can be made on alcoholic beverages, affecting marketing claims such as "low carb" or "no added sugar" on these products.

13 Aug 2025

Amendment No. 241 formally implements both proposals into the Code.

For alcoholic beverage producers, this means any product label that does not currently display kilojoule energy content needs review, and any carbohydrate or sugar-related claims need checking against the new P1049 requirements. Producers planning new product launches or label refreshes should build these requirements in from the outset instead of treating them as a retrofit.

Alongside this amendment, FSANZ also updated the Compendium of Microbiological Criteria for Food in 2025, adding new chapters with targeted guidance for the seafood and cell-cultured food sectors, reflecting the Code's ongoing responsiveness to emerging product categories such as cell-cultured foods.

How the Code changes over time

The Code is not static. Understanding how changes happen helps explain why ongoing monitoring matters as much as an initial compliance review.

Changes to the Code happen through two routes: applications, submitted by individuals or organisations requesting a specific change, such as approval of a new ingredient or processing aid, and proposals, which FSANZ initiates itself to address broader food standards issues or respond to emerging food safety concerns. Each goes through assessment, public consultation, and a final decision by the FSANZ Board, with approved changes notified to ministers and then gazetted into the Code.

Recent examples illustrate the range of changes: alongside the alcoholic beverage labelling amendments, the FSANZ Board approved a December 2025 change permitting a new processing aid, aminopeptidase Y from a genetically modified strain of Trichoderma reesei, for use in protein and yeast processing and flavour production. A February 2026 Board decision corrected an omission in compositional fat requirements for Special Medical Purpose Products for infants that had been approved in an earlier proposal but inadvertently left out of the Code text.

Separately, biosecurity-driven import condition changes happen on their own schedule, addressing specific risks for particular products and countries of origin. Recent examples include updated import conditions for retorted salmon roe, Canadian bivalves, and finfish, each reflecting biosecurity considerations and not general Code composition or labelling requirements. A business importing into Australia needs to track both the Code itself and these biosecurity import conditions, since they can change independently of each other.

Who needs FSANZ consulting?

Code compliance is a legal requirement for any food sold in Australia or New Zealand, whether produced locally or imported.

Manufacturers launching new products

Businesses needing a full Code compliance review for composition, additives and labelling before a product goes to market.

Alcoholic beverage producers

Operations needing to implement energy labelling under P1059 and review claims against P1049 following Amendment No. 241.

Importers into Australia or New Zealand

Businesses needing Code compliance for composition and labelling, plus current biosecurity import conditions for their product category.

Seafood and cell-cultured food businesses

Operations needing to apply the updated Compendium of Microbiological Criteria guidance for their sector.

Businesses operating across both countries

Operations needing to track shared Parts 1 and 2 requirements alongside diverging Australian Code Parts 3/4 and New Zealand Ministry for Primary Industries food safety frameworks.

Businesses using new ingredients or processing aids

Operations needing to confirm a new ingredient, additive, or processing aid is currently permitted under the Code before using it.

FSANZ consulting services

We cover the full scope of Food Standards Code compliance, from a single label review to ongoing regulatory monitoring.

Food Standards Code gap assessment

A review of products and labels against the Code, covering composition, additives, processing aids and labelling under Parts 1 and 2, and food safety standards under Parts 3 and 4 for Australian operations.

Labelling compliance review

Review of product labels against Code labelling requirements, including mandatory warnings, allergen declarations, and category-specific rules.

Alcoholic beverage energy labelling (P1059/P1049)

Implementation of kilojoule energy labelling and review of carbohydrate and sugar claims following Amendment No. 241.

Food safety standards implementation (Australia)

Implementation of food safety standards under Parts 3 and 4 of the Code for Australian food businesses, including primary production and processing.

New ingredient and processing aid checks

Confirmation of whether a new ingredient, additive, or processing aid is currently permitted under the Code, and what conditions apply.

Import compliance support

Review of Code compliance for imported products plus current biosecurity import conditions for the relevant product category and country of origin.

Seafood and cell-cultured food guidance

Application of the updated Compendium of Microbiological Criteria for Food guidance to seafood and cell-cultured product operations.

Dual-market compliance mapping

Mapping of shared Code requirements against diverging Australian Parts 3/4 and New Zealand Ministry for Primary Industries food safety frameworks for businesses operating in both countries.

Ongoing Code monitoring

Ongoing monitoring of Code amendments, applications and proposals relevant to your product range, with practical guidance issued as changes are gazetted.

We also recommend training alongside consulting

The Code changes regularly, and a label that was correct last year can fall out of compliance through an amendment nobody on the team noticed. Building team understanding of how the Code is structured, and how to spot when a recipe or claim change might trigger a compliance check, through training reduces this risk. We recommend pairing this consulting programme with relevant training delivered through Confi Food, and can advise on the right approach during the initial consultation.

The FSANZ compliance process

Compliance work follows a defined sequence. Our part of the process typically takes a few days to a couple of weeks depending on scope.

Stage What happens Our role Duration
1. Scope confirmation The applicable parts of the Code, and any New Zealand Ministry for Primary Industries requirements, are confirmed for your product range and markets. We confirm scope based on your products and target markets. 1 day
2. Composition and ingredient review Ingredients, additives and processing aids are checked against Parts 1 and 2 of the Code. We review formulations against current permitted substances. 2 to 3 days
3. Labelling review Labels are checked against mandatory particulars, warnings, allergen declarations, and category-specific rules such as P1059/P1049. We conduct the review and produce a findings report. 2 to 3 days
4. Food safety standards review (Australia) For Australian operations, food safety standards under Parts 3 and 4 are reviewed. We assess against the relevant Part 3/4 standards for your sector. 3 to 5 days
5. Corrected specification A corrected label and compliance specification is produced, ready for handover to design or production. We produce the specification covering all identified gaps. 2 to 3 days
6. Import condition check (if applicable) For imported products, current biosecurity import conditions are checked separately from Code compliance. We review current import conditions for your product category. 1 to 2 days
7. Implementation Label and formulation changes are implemented according to your production and packaging schedule. We remain available to answer questions during implementation. 1 to 2 weeks
8. Ongoing monitoring Code amendments relevant to your product range are monitored on an ongoing basis. We flag relevant changes as they are gazetted. Ongoing

FSANZ gap assessment

Our gap assessment checks current products against the current Code, since both sides of that comparison can change.

The assessment covers composition, additives, processing aids and labelling under Parts 1 and 2, and, for Australian operations, food safety standards under Parts 3 and 4. It identifies any category-specific requirements that may apply to your products, such as the alcoholic beverage energy labelling introduced through Amendment No. 241, or sector-specific guidance such as the updated microbiological criteria for seafood and cell-cultured foods.

For businesses operating across both Australia and New Zealand, the assessment maps which requirements are shared under Parts 1 and 2, and which diverge, Australian Parts 3/4 versus New Zealand Ministry for Primary Industries food safety frameworks.

  • 1

    Scope and market confirmation

    We confirm which parts of the Code, and which country-specific food safety framework, apply to your products and markets.

  • 2

    Composition and labelling review

    We review ingredients, additives, processing aids and labels against current Code requirements.

  • 3

    Category-specific requirements check

    We check for category-specific rules, such as alcoholic beverage labelling or seafood microbiological guidance.

  • 4

    Written report and action plan

    We produce a written gap assessment with a prioritised action plan.

What you receive

  • Composition and ingredient compliance check against Parts 1/2
  • Labelling review including mandatory warnings and allergens
  • Category-specific requirement check (e.g. alcoholic beverages)
  • Food safety standards review for Australian operations (Parts 3/4)
  • New Zealand Ministry for Primary Industries cross-check, where relevant
  • Import condition review, for imported products
  • Prioritised written action plan
  • Code amendment monitoring notes relevant to your range

For multi-product ranges, we can run this review across the full range in a single engagement, prioritising products affected by recent amendments such as P1059/P1049 first.

Request a free consultation →

The most common Food Standards Code issues

The same issues appear across Code compliance reviews regardless of product category. Knowing where these gaps cluster is the most effective preparation.

FSANZ vs Codex Alimentarius vs EU food law

For businesses trading internationally, understanding how the Food Standards Code relates to international frameworks clarifies where alignment exists and where it doesn't.

FSANZ Code Codex Alimentarius EU food law
Status Legally binding (AU/NZ) International reference standards Legally binding (EU)
Scope Composition, labelling, food safety (AU) Principles and guidelines, not directly enforceable Hygiene, labelling, traceability
Relationship Often references Codex principles in development Reference point for many national frameworks, including FSANZ and SFCR Separate legally binding framework, also Codex-aligned
Our consulting FSANZ Codex Alimentarius EU Food Law

FSANZ cost and timeline

What drives the timeline and cost of an FSANZ compliance project. We provide a written proposal with a fixed fee after the initial consultation.

Timeline

How long our consulting work takes

Cost factors

What drives the consulting fee

Single product label review

A label compliance review for one product against current Code requirements. Our consulting work typically takes 2 to 3 days.

New product full review

A full composition, additive and labelling review for a new product before launch. Our consulting work typically takes 1 to 2 weeks.

Alcoholic beverage range retrofit

Implementation of P1059 energy labelling and P1049 claims review across a beverage range, scoped to the number of SKUs affected.

Dual-market compliance mapping

Mapping shared Code requirements against diverging Australian Parts 3/4 and New Zealand Ministry for Primary Industries frameworks for businesses operating in both countries.

Import condition review

Review of biosecurity import conditions alongside Code compliance for imported product categories with recent condition changes.

Number of products and categories

A single-product, single-category business requires less review than a multi-category range spanning, for example, beverages and seafood.

Scope of engagement

A single label review, a full range review, or an ongoing monitoring retainer each carry different fees. All scopes are defined in writing before work begins.

Design and print costs

Design and printing costs for updated packaging are separate from our consulting fees and managed directly between you and your designer or printer.

Get a quote for your project →

FSANZ questions

Answers to the questions we hear most often from businesses selling into Australia and New Zealand.

Food Standards Australia New Zealand, FSANZ, is a bi-national government agency responsible for developing the Australia New Zealand Food Standards Code, the set of standards that regulate food sold in Australia and New Zealand. FSANZ assesses applications and proposals to change the Code, and the FSANZ Board decides whether to approve changes, which are then notified to the Australian and New Zealand ministers responsible for food. Food standards are enforced by Australian state and territory food regulatory agencies, the Department of Agriculture, Fisheries and Forestry for imported food, and the New Zealand government.

The Code is organised into parts with different scopes. Parts 1 and 2 apply in both Australia and New Zealand, covering the use of ingredients, processing aids, colourings, additives, vitamins and minerals, the composition of certain foods, genetically modified foods, and the labelling of packaged and unpackaged food, including mandatory warnings and advisory labels. Parts 3 and 4 apply only in Australia, covering food safety standards, primary production and processing standards, and maximum residue limits for agricultural and veterinary chemicals. In New Zealand, equivalent food safety functions are carried out by the New Zealand Ministry for Primary Industries. The Code currently comprises 80 Standards and 29 Schedules.

Proposal P1059, Energy Labelling on Alcoholic Beverages, requires alcoholic beverage manufacturers to clearly display energy, kilojoule, content labels on each drink. Alongside P1049, covering carbohydrate and sugar claims on alcoholic beverages, these changes were endorsed by Australian Food Ministers on 25 July 2025 and implemented through Amendment No. 241 to the Food Standards Code, announced on 13 August 2025. This represents a significant change for alcoholic beverage producers, who previously had different labelling obligations to other packaged foods under the Code.

The Code changes through applications, submitted by individuals or organisations requesting specific changes, and proposals, which FSANZ initiates itself to address broader food standards issues or respond to important food safety concerns. Each application or proposal is assessed, with an initial assessment, public consultation, and a final decision by the FSANZ Board. Board decisions are notified to Australian and New Zealand ministers responsible for food, and changes are gazetted into the Code. FSANZ also maintains the Compendium of Microbiological Criteria for Food, which was updated in 2025 with new chapters providing targeted guidance for the seafood and cell-cultured food sectors.

Food imported into Australia must comply with the Food Standards Code in the same way as domestically produced food, and is enforced by the Department of Agriculture, Fisheries and Forestry. Separately, biosecurity import conditions, covering matters like permitted species, refrigeration evidence, and country-of-origin restrictions, are managed under Australia's biosecurity framework and can change independently of the Code itself. Examples of recent biosecurity-driven changes include updated import conditions for retorted salmon roe, Canadian bivalves, and finfish, each addressing specific biosecurity risks and not general food composition or labelling.

An FSANZ gap assessment reviews products and labels against the relevant parts of the Australia New Zealand Food Standards Code: composition, additives, processing aids and labelling under Parts 1 and 2, and, for Australian food businesses, food safety standards under Parts 3 and 4. It identifies any category-specific requirements that may apply, such as the alcoholic beverage energy labelling introduced through Amendment No. 241, and produces a written action plan.

The most common issues are: labels that have not been updated following Code amendments, such as the 2025 alcoholic beverage energy labelling requirements. Products using additives, processing aids, or ingredients not currently permitted under Parts 1 and 2, particularly where a recipe change introduces something new without checking it against the Code. Mandatory warning statements or advisory labels missing or incorrectly presented. For Australian food businesses, food safety standards under Parts 3 and 4 not being met at the primary production or processing stage. Imported products meeting Code labelling and composition requirements but not current biosecurity import conditions, which can change independently.

Yes. While Parts 1 and 2 of the Code, covering composition, additives and labelling, apply in both countries, Parts 3 and 4, covering food safety standards, primary production and processing standards, and maximum residue limits, apply only in Australia. In New Zealand, equivalent food safety functions for primary production and processing are carried out separately by the New Zealand Ministry for Primary Industries, meaning a business operating in both countries needs to track two distinct food safety frameworks alongside the shared Parts 1 and 2 requirements.

Our consulting work moves fast. A label compliance review against the Code typically takes a few days, while a full product range review across composition, additives and labelling typically takes 1 to 2 weeks. Where a Code amendment introduces new category-specific requirements, such as alcoholic beverage energy labelling, the timeline depends on how many products in your range are affected.

Yes. Gap assessments, labelling reviews, and Code compliance checks are all available remotely. We work with businesses based in Australia, New Zealand, and international businesses exporting to either market.

Single pieces of work on this subject

You can commission any of these on their own, with an agreed scope and a written quote, without taking on ongoing consulting. See all food safety services.

Compliant across the Tasman

Tell us about your products, your markets and your current labels. We will tell you exactly what the Food Standards Code requires.