TGA · AHPRA · FSANZ · ACCC

    What nutrition content claims are permitted for food products in Australia?

    CompliGUARD reviews this compliance area against TGA · AHPRA · FSANZ · ACCC frameworks for Australian health brands — here's what the regulations say.

    CompliGUARD reviews nutrition content claims against FSANZ Standard 1.2.7 of the Food Standards Code. Nutrition content claims for food products in Australia are permitted under FSANZ Standard 1.2.7 where the product meets the prescribed nutrient thresholds — for example, a product can claim 'high in protein' only if it meets the minimum protein content specified in Schedule 1 of Standard 1.2.7.

    The rule: Australia New Zealand Food Standards Code, Standard 1.2.7, Schedule 1

    Standard 1.2.7 of the Australia New Zealand Food Standards Code divides nutrition claims into two categories: nutrition content claims (describing the presence or absence of a nutrient) and health claims (linking nutrients to health outcomes). Nutrition content claims are permitted where the product meets the prescribed thresholds in Schedule 1. These thresholds specify the minimum or maximum amount of a nutrient per serve or per 100g/100ml required to support each claim. A brand cannot use 'good source of calcium' unless the product meets the calcium threshold in Schedule 1 — regardless of how much calcium the product actually contains.

    What this means in practice

    • For every nutrition content claim you intend to make, look up the relevant nutrient threshold in Schedule 1 of Standard 1.2.7 and confirm your product meets it.
    • Calculate nutrient content per serve and per 100g/100ml — Schedule 1 thresholds are expressed in both formats and the product must meet the applicable measure.
    • Do not use claim language that implies a higher nutrient level than the threshold requires — 'excellent source' and 'good source' have different thresholds and cannot be used interchangeably.
    • Comparative claims (e.g. 'more protein than X') require both products to meet the relevant conditions and the difference to be nutritionally significant — check Standard 1.2.7 s.8 for comparative claim rules.
    • Retain the nutrient analysis data that supports each claim — if the claim is challenged, you will need to demonstrate the product met the threshold at the time of advertising.

    Common mistakes

    Mistake

    Using 'high in protein' without meeting the Schedule 1 threshold

    Problem

    The claim 'high in protein' requires the product to contain at least 10g of protein per serve and that protein contributes at least 25% of the energy content of the product — both conditions must be met. Brands frequently use 'high in protein' based on absolute protein content alone.

    Fix

    Calculate both the absolute protein per serve and the percentage of energy from protein. Confirm both thresholds are met before using 'high in protein.' If only one is met, use 'source of protein' instead — which has a lower threshold.

    Mistake

    Making 'low sugar' claims on products that use sugar alcohols

    Problem

    Sugar alcohols (sorbitol, xylitol, erythritol) are not classified as sugars under the Food Standards Code — but they do contribute to carbohydrate content and energy. Products using sugar alcohols to achieve a 'low sugar' claim must still meet the Schedule 1 threshold for sugars.

    Fix

    Check the Schedule 1 definition of sugars before making low sugar claims on products containing sugar alcohols. The claim applies to sugars as defined in the Code — not total sweeteners.

    Mistake

    Using 'source of' and 'good source of' interchangeably

    Problem

    'Source of' and 'good source of' are distinct claim levels with different Schedule 1 thresholds. Using 'good source of' when the product only meets the 'source of' threshold is a direct breach of Standard 1.2.7.

    Fix

    Always check which threshold the product meets and use the corresponding claim level. When in doubt, use the lower claim — 'source of' rather than 'good source of.'

    Compliant vs non-compliant example

    ❌ NON-COMPLIANT

    Using 'high in protein' without meeting the Schedule 1 threshold

    ✅ COMPLIANT

    Calculate both the absolute protein per serve and the percentage of energy from protein. Confirm both thresholds are met before using 'high in protein.' If only one is met, use 'source of protein' instead — which has a lower threshold.

    The enforcement context

    The ACCC has taken action against food businesses for misleading nutrition content claims under the Australian Consumer Law, separate from FSANZ enforcement. Where a nutrition claim implies a benefit that the product's nutrient content does not support, both the ACL's misleading conduct prohibition and Standard 1.2.7 may be engaged simultaneously.

    Before you publish, check it.

    CompliGUARD reviews food product nutrition content claims against FSANZ Standard 1.2.7 Schedule 1 thresholds automatically.

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    Related questions

    Regulatory references

    • Australia New Zealand Food Standards Code, Standard 1.2.7, s.5 (nutrition content claims)
    • Australia New Zealand Food Standards Code, Standard 1.2.7, Schedule 1 (nutrient thresholds)
    • Australia New Zealand Food Standards Code, Standard 1.2.7, s.8 (comparative claims)
    • Australian Consumer Law (Competition and Consumer Act 2010, Schedule 2), s.18