Food labelling Australia: FSANZ rules for health claims on labels
CompliGUARD reviews this compliance area against TGA · AHPRA · FSANZ · ACCC frameworks for Australian health brands — here's what the regulations say.
CompliGUARD reviews food label health claims against the FSANZ Food Standards Code. Health claims on food product labels in Australia must comply with FSANZ Standard 1.2.7 — general level health claims must be from the pre-approved list or self-substantiated, high level health claims must be from the Schedule 2 approved list, and all claims must not be misleading under the Australian Consumer Law.
The rule: Australia New Zealand Food Standards Code, Standard 1.2.7; Standard 1.2.1 (labelling requirements)
FSANZ Standard 1.2.7 governs health and nutrition claims on food product labels in Australia. It applies to all food products sold in Australia and New Zealand, including functional foods, fortified foods, and health food products. The standard distinguishes between nutrition content claims (describing nutrient presence or absence), general level health claims (linking nutrients to health effects not involving disease), and high level health claims (linking nutrients to disease risk reduction). Each category has different requirements: nutrition content claims require meeting Schedule 1 thresholds; general level health claims require pre-approval or self-substantiation; high level health claims require Schedule 2 listing.
What this means in practice
- Audit all health and nutrition claims on existing labels against FSANZ Standard 1.2.7 before your next label print run — this is the lowest-cost point to identify and fix non-compliant claims.
- For every health claim on the label, document which FSANZ standard authorises it — either the pre-approved list entry or your self-substantiation assessment.
- Ensure nutrition content claims are supported by up-to-date nutrient analysis data — the product as currently manufactured must meet the Schedule 1 thresholds, not the product as originally formulated.
- Do not add health claims to a label reprint without a compliance review — label changes are a common point where claims drift outside approved territory.
- Where a product is also a Listed Medicine (AUST L), TGA Advertising Code rules apply to the label in addition to FSANZ requirements.
Common mistakes
Adding health claims to labels during a 'minor' redesign without compliance review
Label redesigns that add, amend, or reframe health claims are not minor changes from a compliance perspective — each claim change requires assessment against FSANZ Standard 1.2.7. Brands frequently add claims during redesigns without realising they have crossed into non-compliant territory.
Treat any label change that touches claim language as a compliance trigger. Review all affected claims against Standard 1.2.7 before approving the design for print.
Using imagery that implies health benefits not supported by label claims
Images on food labels can constitute implied health claims — a label image showing a person running after consuming the product may imply an energy or performance benefit even if no explicit claim is made. The ACCC assesses the overall impression created by packaging.
Review packaging imagery alongside text claims — apply the ACL misleading conduct test to the combined impression created by the full label, not individual elements in isolation.
Failing to update claims after reformulation
Where a product is reformulated and nutrient levels change, claims that were previously compliant may no longer be — the product must meet Schedule 1 thresholds as currently manufactured. Selling reformulated product with outdated compliant claims is a breach.
Trigger a label compliance review whenever a product is reformulated. Retain current nutrient analysis data for all products with active health or nutrition claims.
Compliant vs non-compliant example
❌ NON-COMPLIANT
Adding health claims to labels during a 'minor' redesign without compliance review
✅ COMPLIANT
Treat any label change that touches claim language as a compliance trigger. Review all affected claims against Standard 1.2.7 before approving the design for print.
The enforcement context
State and territory food authorities in Australia have powers to inspect food labels and take action against non-compliant claims. The ACCC can act under the Australian Consumer Law where label claims are misleading. FSANZ itself does not have direct enforcement powers but works with state authorities. Label claim compliance is audited at the point of sale, in market monitoring programmes, and in response to competitor and consumer complaints.
Before you publish, check it.
CompliGUARD reviews food product label claims against FSANZ Standard 1.2.7 and ACCC Australian Consumer Law requirements.
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Regulatory references
- Australia New Zealand Food Standards Code, Standard 1.2.7 (Nutrition, Health and Related Claims)
- Australia New Zealand Food Standards Code, Standard 1.2.1 (Requirements for labelling and other information)
- Australian Consumer Law (Competition and Consumer Act 2010, Schedule 2), s.18
- ACCC Advertising and Selling Guide, July 2021