A shelf-ready pack can taste right and still be wrong on origin. "Made in", "product of" and "packed in" have set meanings. Match them to where the food was grown, produced, made or packed, and lock the choice before artwork is approved and before the first warehouse drop.
Written for supermarket category managers, private-label and controlled-brand managers, and QSR or foodservice buyers. Shiiv Imports Pty Ltd trades as Shiiv Imports. We are a sourcing agent, importer and private-label builder, not a manufacturer. The partner plant makes the food. We collect the origin evidence and check it against the pack. It sits beside the buyer checks and the spec pack.
What the Standard covers
Country of origin for food sold in Australia is set by the Country of Origin Food Labelling Information Standard 2016, made under the Australian Consumer Law. The ACCC explains the rules and can ask a business to substantiate a claim. FSANZ does not run this standard. From 1 July 2018 the Food Standards Code no longer sets country of origin labelling. The Code still sets ingredient lists, allergen declarations and nutrition information. Settle origin in that same step.
Most food offered for retail sale must state where it was grown, produced or made. Packaged food in a supermarket, store, market, online shop or vending machine needs a country of origin label. Some unpackaged retail foods need the information beside the product, on a sign: fruit, vegetables, nuts, spices, herbs, fungi, legumes, seeds, fish and most meat, or a mix of those.
Food bought from a restaurant, cafe, take-away shop, school or caterer does not need that label. If origin is stated anyway, the kangaroo and the bar chart have to follow the Standard, and the claim has to be true. A compliant label can support a safe-harbour defence. Maps, flags and other cues can still mislead.
Since 1 July 2026, a 2025 information standard requires a restaurant, cafe or other hospitality business selling seafood for immediate consumption to show whether it is Australian, imported, or a mix. A retail pack of the same seafood still follows the 2016 Standard.
Priority foods and the mark
Food that needs a label is priority food unless it is non-priority. The ACCC and business.gov.au list seasonings, confectionery, biscuits and snack foods, soft drinks and sports drinks, alcoholic drinks, tea and coffee, and bottled water. Non-priority food needs a text statement of where it was grown, produced, made or packed. The standard mark is not mandatory. Every other food that needs a label is priority. ACCC examples include fruit and vegetables, meat, seafood, bread, milk, juice, sauces, honey, nuts and cereal.
Chips, crackers and sweet biscuits are non-priority snack foods. Cakes, muesli bars and coated nuts are outside that category. Salt, dried herbs, spices and dry rubs are seasonings. Mustards, sauces, chutneys and relishes are priority foods.
Priority food grown, produced or made in Australia carries a three-component mark: the kangaroo in a triangle, a bar chart of the minimum Australian ingredients by ingoing weight, and a statement. A "made in" claim includes that percentage. Most priority food packed in Australia carries a two-component mark, bar chart and percentage, with no kangaroo. Packing here does not earn the kangaroo unless the food was grown, produced or made in Australia. Imported food may use that two-component mark to show Australian ingredients. Imported priority food needs a country of origin statement in a box. Unpackaged food does not.
Grown, made and packed
"Product of" and "produced in" mean the main ingredients come from the stated country and almost all processing happened there. "Grown in" works the same way, and a grown-in or produced-in Australia claim needs every ingredient to be Australian. "Made in" means the last substantial transformation was in that country: the food is fundamentally different in identity, nature or essential character from its imported ingredients. "Packed in" covers food packaged where it was not grown, produced or made. business.gov.au lists "packed in Australia from imported ingredients" as one phrase a label may use. In its examples, canning imported fruit or reconstituting imported juice falls short of substantial transformation. A process meets the test when the finished food is fundamentally different from every imported ingredient.
The evidence, then the artwork
Before artwork is signed, take the factory's points in writing: the site and process for the last substantial transformation, ingredient origin and ingoing weight if a percentage will be printed, the packing country if it differs, and which format those facts support. A head-office country is not a "made in" line, and a recipe with no Australian ingredient has nothing to put on the bar chart. A change of plant, major ingredient or packing country means a new check and usually new artwork.
Plant certificates stay on the quality file. HACCP, and a GFSI-benchmarked scheme such as BRCGS, SQF or FSSC 22000 where a partner holds one, apply to a named site and scope. Partners hold those certifications. Shiiv Imports holds ISO 9001 for how we source, select suppliers, watch production and handle recalls. It is not a plant food-safety certificate, and it is not an origin declaration.
On a private-label pack, recipe, artwork and labels are signed together. The pack follows the Food Standards Code for ingredient order, allergens (including cross-contact) and nutrition information. Origin is added under the Information Standard. An unsupported claim stays off the pack. The plant owns the origin facts. We check them against the specification and the artwork. We do not name major-chain private-label clients. An export carton still needs a compliant origin line before the sailing is counted on.
New Zealand, briefly
New Zealand does not use the kangaroo or the bar chart. The Consumer Information Standards (Origin of Food) Regulations 2021 are administered by the Ministry of Business, Innovation and Employment under the Fair Trading Act 1986. At retail, including online, they cover one type of fresh, frozen or thawed fruit, vegetable, meat, finfish or shellfish that is no more than minimally processed, plus cured pork. Disclose where the produce was grown, the animals were raised, or the fish were caught or the shellfish harvested, in clear English or Māori. Food for immediate consumption at a restaurant, cafeteria, takeaway, canteen or caterer is excluded. Eggs, dairy, sauces, biscuits and snacks are outside that list. The regulations commenced on 12 February 2022, with frozen food from 12 May 2023.
Before the first warehouse drop
Record the channel, priority or non-priority, the statement, the country and the format. Attach the factory declaration, ingredient origins and packing country, and note that the Code panel and the origin line were approved together. If New Zealand is in scope, say whether the line is a regulated food item.
Send product, pack, channel and the origin facts you hold with a sourcing brief, or a private-label brief for an own-brand pack. We reply the same business day on how the label file is shared under NDA. Email sales@shiv-impex.com.
Shiiv Imports Insights. Shiiv Imports Pty Ltd (ABN 15 158 243 442 / ACN 158 243 442). Trading name Shiiv Imports. Public email sales@shiv-impex.com. Cities: Sydney, Auckland, Singapore, Ahmedabad.