Product Information Form - User Guide

Australian Food and Grocery Council

USER GUIDE FOR

PRODUCT INFORMATION FORM

PIF 5.0

MAY 2012


PREFACE

USER GUIDE AFGC PRODUCT INFORMATION FORM PAGE 2 OF 73

Produced and administered by the Australian Food and Grocery Council

All rights reserved

This document is subject to copyright. You may download, display, print and reproduce this content for your personal or non-commercial use but only in an unaltered form and with the copyright acknowledged.

This document is intended as a guide only: legal requirements are contained in the Australia New Zealand Food Standards Code and other applicable laws as relevant to the jurisdiction within which goods are traded.

The information in this document should not be relied upon as legal advice or used as a substitute for legal advice. You should exercise your own skill, care and judgement before relying on this information in any important matter.

Copyright © Australian Food and Grocery Council (AFGC) 2012


CONTENTS


INTRODUCTION 4

1. CONTACT DETAILS & DECLARATION 12

SUPPLIER LOGO 12 1.1 SUPPLIER INFORMATION 13 1.2 MANUFACTURER/S INFORMATION 14 1.3 CONTACT DETAILS FOR TECHNICAL AND ALLERGEN INFORMATION 15 1.4 SUPPLIER WARRANTY 15 1.5 CUSTOMER DETAILS 17 1.6 DEFINITIONS AND REFERENCES 18 1.7 CHECKLIST AND ATTACHMENTS 18 1.8 STATUS OF COMPLETION OF EACH SECTION 18

2. PRODUCT INFORMATION & INGREDIENTS 19

2.1 PRODUCT DESCRIPTION 19 2.2 LEGAL DESCRIPTION / SUGGESTED LABELLING DESCRIPTION 20 2.3 PRODUCT APPLICATION AND INTENDED USE 20 2.4 COUNTRY OF ORIGIN 21 2.5 COMPONENT TYPE 23 2.6 INGREDIENT DECLATATION INCLUDING PERCENTAGE LABELLING 24 2.7 PROCESSING AIDS 25

3. COMPOSITIONAL INFORMATION 26

3.1 MANDATORY ADVISORY OR WARNING STATEMENTS & DECLARATIONS 26 3.2 ALLERGEN MANAGEMENT & CONTROL 27 3.3 MANDATORY DECLARATION OF CERTAIN SUBSTANCES 28 3.4 ALLERGEN CROSS CONTACT 33 3.5 INTERNATIONAL ALLERGEN, LABELLING & INFORMATION REQUIREMENTS 38 3.6 ADDITIONAL LABELLING AND INFORMATION REQUIREMENTS 40 3.7 ANIMAL SOURCE & QUARANTINE INFORMATION REQUIREMENTS 44

4. FOODS REQUIRING PRE-MARKET CLEARANCE 46

4.1 NOVEL FOODS 46 4.2 QUARANTINE TREATMENTS 47 4.3 FOOD PRODUCED USING GENE TECHNOLOGY 48

5. NUTRIENTS & CONSUMER INFORMATION CLAIMS 52

5.1 NUTRITION INFORMATION 52 5.2 CONSUMER INFORMATION CLAIMS 57

6. DURABILITY, PACKAGING AND SUPPLY CHAIN 60

6.1 SHELF LIFE 60 6.2 POTENTIAL HAZARDS 61 6.3 TRANSPORT 62 6.4 TRADE MEASUREMENT 63 6.5 TRACEABILITY 63 6.6 PRODUCT PACKAGING 64 6.7 PALLET CONFIGURATION 66

7. SPECIFICATIONS FOR COMPLIANCE 66

8. COMMENTS / ADDITIONAL INFORMATION 68

9. ATTACHING CERTIFICATES 69

10. USEFUL REFERENCES 72


PRODUCT INFORMATION FORM USER GUIDE


INTRODUCTION

The Australian Food and Grocery Council (AFGC) developed the Product Information Form (PIF) with the assistance of industry to provide a single nationally implemented ingredient questionnaire acceptable to food companies and their suppliers in providing information necessary for regulatory and consumer information requirements. The advantage for industry in having a single standardised form is the gains in efficiency and productivity from only needing to deal with one form, rather than dealing with forms specific to a variety of customers.

The PIF is a comprehensive form designed to assist with validation and verification of allergen statements, labelling compliance, nutrition claims and claims about dietary suitability or sustainability. The PIF also collects information about relevant for quarantine risks, product durability, the presence of dangerous or hazardous substances, packaging materials etc.

This User Guide is intended to provide assistance and clarify the information to be provided in each section of the PIF. The information and examples provided in this document are not exhaustive and should be considered as a guide only.

FEEDBACK AND UPDATES

The AFGC is responsible for managing the PIF on an ongoing basis. If you have any comments or queries about the way the PIF is working, please forward your comments either to the AFGC ([email protected] ), or the Allergen Bureau ([email protected]).

The AFGC has established an email list specifically for PIF users used to announce any updates or planned developments and any issues relevant to the PIF. Joining the list if free and open to everyone, simply send an email to the AFGC ([email protected] ), and ask to be put on the list.

Version 5.0 (PIF 5.0) has been released after several years of development and upgrades through earlier versions. It is expected that PIF 5.0 will not require any further modifications for at least 12 months, and then only if legislative changes impact on information or labelling requirements.

While changes to PIF 5.0 are to be avoided, further updates to these guidelines are anticipated over time, based on user feedback and queries, and in consideration of the need for further explanations, examples or uncertainty in how to use the PIF.

DOWNLOAD FILES

The PIF is available to download from the Australian Food and Grocery Council website (http://www.afgc.org.au and the Food Allergen Bureau website http://www.allergenbureau.net/.)

The PIF5 Zip file contains the blank PIF5.0 excel template, the PrintCopy PIF 5.0 which may be used to provide information on products or ingredients. There are also files used to migrate data out of earlier versions of PIF into the current PIF5.0 as well as a tool to migrate data from the current PIF5.0 backwards to the earlier PIF4.3. The use of the data migration maps and the PIFconvert tool is described below.

The PIF UserGuide is downloaded separately as a PDF document.

GENERAL INSTRUCTIONS CONCERNING PIF 5.0

PIF 5.0 has been built to be compatible with Microsoft Office 2007 and Office 2003 versions of Excel. Optimal performance is provided when using Office 2007, and there are limitations with Office 2003 due to the limited ability to control conditional functions and limited colour palette. PIF is not backward compatible for versions of Excel in Office 2000 or earlier.

The design of the PIF is protected and must not be altered other than increasing the row height of cells to allow for printing of lengthy information. Rows must not be inserted or deleted as this will prevent

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data migration to updated form versions, and column width must not be altered as this will create page formatting problems with printing.

Use PIF 5.0 as a template and use the „save as‟ option to save completed files with document names relevant to your company documentation requirements. Add information to the PIF by navigating through the form using the tab key to move from one field to the next, or scroll through the form and use the left click on the mouse to activate an input box for data entry.

Click once into each check box for a cross to appear or begin typing to insert text into the text fields.

DO NOT COPY and PASTE from one set of field to another. For example, there are several fields that request similar information sets such as the address of the business, or the allergen information. Each cell in the form has unique properties associated with the cell which controls how other cells in the form will be have based on the information provided. Copying cells also copies their properties and may result in problems with the form function.

The form has two workpages. The front workpage has the tab Product Information Form and is to be completed by filling in the information requested for each question as appropriate. There are a number of mandatory questions in the form that can be identified using the mandatory field check box, indicated in Section 1.8; other questions are optional.

The second workpage has the tab Certificates and documents which may be used as an option for including certificates if required. A step by step guide for including certificates is provided in Section 9.

REQESTING INFORMATION ADDITIONAL TO PIF 5.0

PIF 5.0 represents the most commonly sought information, widely agreed and generally applicable across the supply chain. However, on occasion some customers may need additional information and it is recommended that customers request this in a covering letter or email to the supplier. Suppliers and customers are encouraged to manage this additional information separate to the PIF to ensure that the structure and integrity of the PIF as a single nationally applicable standardised form is maintained.

If the additional information sought is broadly relevant across the industry, then suggestions are welcome for consideration with other amendments to the form at the time of the next PIF update.

MIGRATING DATA TO VERSION 5.0

The development of PIF 5.0 has been undertaken with the intention also providing a data migration tool to move data from the previous version to the current version of PIF5.0. Once the data has been migrated into the new form, the form should be checked to make sure that the data is complete.

The conversion program is designed to identify the specific location of data is cells and relies on a file that is called “Data Migration Map.xls” to identify the location of the cells in the old and the new form.

A ZIP file can be downloaded from the website which contains the following data migration map files:

PIF 5.0 2011.xls

PrintOnly PIF 5.0.xls

PIFConvert.xls and a folder containing the following data migration maps:

Data Migration Map 50-50.xls



Data Migration Map 30Sept2010-50.xls


You must extract the files out of the ZIP file into a new folder and you must rename the appropriate data migration map you wish to use to “Data Migration Map.xls”. If you wish to migrate data from an




earlier edition of PIF5.0 to the current edition of PIF 5.0 then rename “Data Migration Map 50_50.xls” to simply “Data Migration Map.xls”. If you wish to migrate data from PIF4.3 chose the other file.

You will need to follow the following steps:

1. Download the PIF 5.0 zip file

2. Create a new folder to extract the contents of the zip file. (e.g. create new folder called PIF5)

It is suggested that you have two folders, one call “PIF43 into 5”and the other called “PIF 5 to 5”

3. Extract the contents of the zip file into both of the folder(s). This means you should have the same set of files in both folders. The screen print below is an example of a folder containing the two data migration map files, the PIFconvert file and the PIF 5.0 2011 file.

4. Rename the relevant data migration map to “Data Migration Map.xls” If you wish to migrate data from PIF4.3 to the current PIF 5.0 then rename the “Data Migration Map 43_50.xls” to be simply “Data Migration Map.xls” in the folder called “PIF43 to 5”.

To do this you need to Right Mouse Click on the file called “Data Migration Map 43_50.xls” and select rename, (or left click then select File and then rename)

The edit the name of the file and change the name to ““Data Migration Map.xls” by deleting the text “43_50”




When you have finished simply left click the mouse on the file icon, or on another file, and the new name is then displayed as shown below.

If you wish to migrate data from one version of PIF5.0 to the current edition of PIF 5.0 then rename “Data Migration Map 50-50.xls” to simply “Data Migration Map.xls” in the folder called “PIF 5 to 5” by following the same process as outlined above.

If you wish to migrate data from earlier versions of PIF3.2 then rename the Data Migration Map32-50; and if you wish to migrate data from PIF2.3 then rename the Data Migration Map 23-50.

You are now ready for Step 5.

5. Open (double click) the file called “PIF Convert.xls”

6. When the file opens make sure that you have enabled the macros and active content to run.




7. The program will then state that it cannot find the data migration map.xls file. Click OK

8. select the button “path” on the right side of the form when the top line of text states “PIF Migration Map Problem”. This occurs when the PIFconvert program does not have the correct location of the folder containing the data migration map and the PIF 5.0 2011 file.

9. Use directory navigator to find the folder with the data map you created (e.g. PIF43 into 5).




10. click on “Open” on the bottom right hand side of the form when you have selected the correct folder. You will not be able to see the files contained in the folder, but this doesn‟t matter at this stage. When you click on “Open” it will automatically take you back to the grey menu screen for the PIFconvert program.

11. click on “Save Settings” when the screen will return to the grey menu form. Notice that the “Browse PIF” is greyed out and the top line text is stating “PIF migration map problem”. Once you have selected “Save Settings”, the Browse PIF button and the top line text should change.

12. Select the files to be converted to the new edition by using the “Browse PIF” button. This will be the folders which contain your PIF4.3 files to be convert.

13. Use director navigator to find the folder and files, select the desired file and click “Open”

14. The screen will return to the grey form screen, click on “Convert”




15. The program will convert the file to PIF 5.0 using the blank template that is in the same folder as the data migration map. When it is finished it will ask you to give it a name to save the new file with a new name.

16. Open the converted file and heck that the data has migrated correctly.

If you have any difficulties in extracting the files or using the convert program, please send an email to the AFGC ([email protected] ), and provide a brief description of the problem.

MIGRATING DATA REVERSED : FROM VERSION 5.0 TO VERSION 4.3

Some companies have advised AFGC that their information technology systems are unable to be readily changed and, at least in the short term, they will need to remain with PIF4.3. This means that ingredient suppliers who have adapted their data systems to PIF5.0 have been requested to convert their forms back into the PIF4.3 version. To assist these companies, a reverse data migration tool has been developed. This has a specific tool (PIFConvertReverse) and also a specific data migration map (Data Migration Map Reverse), but otherwise work in a very similar manner to the process described above.

In order to avoid confusion, these tools are not provided on the AFGC website, but are available on request. Simply send an email to [email protected] and request the PIF5 reverse to PIF4.3 convertion tools.

MICROSOFT OFFICE VERSION AND FILLING IN HARD COPY

Product Information Form (PIF 5.0) comes in two formats: an Excel Form call “PIF 5.0 2011.xls” intended to be used with a computer and displayed on-screen; and an Excel Form which is intended to be printed and filled in manually, called “PRINTONLY PIF 5.0 2011.xls”.

The interactive Excel Form PIF 5.0 2011.xls is designed to be filled out using the Microsoft Excel form on a computer and provides prompts and guides the user in filling out the form. Options and certain questions will be affected by the answers provided in preceding questions, which also removes some of the irrelevant text. The interactive Excel Form can be printed ONCE COMPLETED, or you can save as a PDF format and email as an attachment.

It is designed to work optimally using Microsoft Office 2007. It will work on earlier versions of Microsoft Office, but there are some unavoidable formatting problems due to the lesser capability of these earlier versions. The form is designed to turn on or turn off certain questions depending on answers provided when filling out the form electronically. In Office 2003, occasionally these functions do not work properly and the text boxes do not switch off or highlight correctly.

THIS form is NOT to be used by printing the blank form and then attempting to fill in the questions in hard copy. To do this you need to use the form called "PrintOnly PIF 5.0 2011.xls".

This user guide applies in-principle to the PrintOnly version, but some of the display elements will differ.

FORMAT

Excel cells do not automatically resize to allow the content of the cells to be fully visible when the form is operating in protection mode.

If there is a lot of content in a cell and it needs to be resized, then it can be manually resized by clicking on the left hand row number and drag down to expand the row that the cell is in.






Column width cannot be changed as it will corrupt the page format for printing.

The following colour coding is applied throughout the document as a visual aid in identifying fields that require data input, whether free text, mandatory fields or limited options:

Black text with pale blue background coloured boxes require data entry values.

If questions are not relevant, but the field is mandatory, then state „not relevant‟.

If there are an excess number of rows for data entry, for example Section 3.3.1 Allergens provide a block of blue coloured rows even though only one row may be need, then only fill in the relevant number of rows and leave the other rows blank.

If answers require a complex explanation, then provide a more detailed response in Section 8.0, and reference the section to which the response applies.

For large free text entry boxes, check spelling using F7 key.

Black text with yellow background coloured boxes are used to indicate column heading or to highlight a section of text.

Black text with pink background coloured boxes are drop-down lists for you to select an option. Some pink boxes have a small arrow next to the box to make it more obvious it is a list box that you need to select one of the options provided.

Yellow text with blue background in the Section 5.1 Nutritional Information Table are mandatory data fields and must be provided for additives and ingredients as well as finished retail ready products. Other fields are options. These are also the headings allergen fields that require to be completed once an allergen is selected.

Black text with green background boxes are auto-calculation boxes. These boxes are present in Section 2.4 country of origin, and Section 4.1 nutrition information. In Section 4.1 these boxes are not available for products that are purely ingredients. If appropriate, these boxes will provide an automated calculation of the %DI and RDI values for product which is a retail ready or finished product.

White text with purple background coloured boxes are indicate mandatory fields that have not been completed when the mandatory fields check box in Section 1.8 is selected. Certain questions on the form are deemed mandatory, but these will depend on the type of product and answers provided to preceding questions.

White text with red background coloured boxes indicate that there is an error with an answer that has been provided. Also, in the form status Section 1.8, this indicates sections that have not been started.




1. CONTACT DETAILS & DECLARATION

SUPPLIER LOGO

The supplier‟s company logo can be inserted into the top left-hand corner of the first page of the PIF. The supplier is the company completing the document. It is at the supplier‟s discretion if they choose to insert their logo. Inserting the company logo may be an aid to a customer in quickly and easily identifying the company that the PIF relates to. There is no allowance for the PIF to contain customer logos.

The logo image should be in gif or jpg format and should be no larger than 10-20 KB in size and not bigger than 2.5cm X 2.5 cm. Resize and reposition logo if required.

To insert a logo, RIGHT click on the graphic box "insert Logo here" at the top of the screen and use the toolbar option „Insert‟ then „Picture‟ and „File‟. Select 'Bitmap IMAGE Object - Edit', then from the top tool bar select 'Edit' and 'Paste from'. This should allow you to then select the image file from the folder on your computer to insert.

Follow the same process for inserting digital signatures if required. Digital signature images should be sized to 9.8 cm X 1.8 cm.

Immediately under the heading Contact Details and Declaration are fields relating to the description of the product and information related to identification, origin and, if relevant the import tariff code.

Supplier’s Product Name

The name or description by which the supplier refers to this specific product. This is the name or description assigned and referenced by the supplier of this specific product.

In naming or describing the product, consideration should be given to the relevance and use of terms such as „type‟ or „style‟ in association with the name as to whether this has the potential to mislead consumers. Consideration must also be given to restrictions are on terms which have received a certification trade mark in Australia, which includes amongst other things a few teas, hams and cheeses.

Geographical Indication (GI) is the legal term indicating that an item is from a specific region and thereby carries special attributes and is protected as a form of intellectual property which has specific relevance for trade with the European Union (EU), and with trading partner who trade in the EU. If the EU has a trade agreement with a country, the product name and product description may require to consider GI naming restriction. For example: the EU has agreements with countries such as Colombia, Peru, and South Korea that would prohibit the sale of oranges, or orange juice, labelled as „Valencia Oranges‟ that did not originate from Valencia in Spain.




However, for the most part, GI does not apply to products intended for sale in Australia, other than where such claims may be false or misleading.

Supplier’s Product Code

The supplier‟s internal identification code used for assigning or referencing this specific product.

Barcode – Unit GTIN

The unit global trade item number (GTIN), also known as the barcode number, is used for the unique identification of trade items worldwide. These may be 8, 12, 13 or 14 digits in length. Not all product will have a barcode number, but when present they should be specified as it will aid in traceability.

The use of the barcode on retail ready and on non-retail packaging is an aid in identifying product. There are industry guides available from GS1 about the location and style/design of the barcode.

Specify Country Imported Into / Exported from / Import Tariff Code

It is the responsibility of the customer or importer to determine relevant tariff codes for the product if they are importing it into their own market and this question may not relevant for suppliers to complete these fields. This field is specifically relevant if the IMPORTER has established arrangements with the Australian Quarantine Inspection Service (AQIS). The information may also be of assistance in making use of free trade agreements and bilateral trade agreements.

In each of the country designation boxes there are two lines to indicate up to two countries that may be relevant to indicate if the product is imported from or exported to.

1.1 SUPPLIER INFORMATION

As a general rule, the company entering into the direct supply agreement with the customer should complete this section.

Company Name The name of the company supplying this product to the customer. Business number (ABN) The ABN is a unique 11 digit identifying number that businesses use when dealing with other businesses. For example, you generally need to put your ABN on your invoices, or other documents relating to sales that you make. If you don‟t, other businesses may withhold 46.5% from any payment to you.




It is not compulsory for an Australian company to registering for an ABN is not, but it be required to register for the GST.

Trading Name A business name is the name or title under which a person, or other legal entity, trades. It is sometimes referred to as your trading name.

If the business structure you have chosen is as a sole trader, a partnership or a trust, and not as a company, then you are required to register your business name in the state or territory in which you will operate. But you don‟t need to register a business name if you plan to conduct your business under your, or your partner‟s, first name and surname.

Registration of a business name does not in itself give you any proprietary rights - only a trade mark can give you that kind of protection.

Business Address This information may be required as part of product labelling where the product is a packaged retail-ready finished product. The full street address of the head office or the manufacturing site as applicable. Ensure the street number & name, city, state, country, and postcode (or zip code) is included.

Postal Address The full postal address details for postal mail delivery. Include only if different to the street address, otherwise use text “as above”.

Key Contact Person for Queries The full name, position and contact details (email and phone number) of the authorised contact person dealing with the product on behalf of the supplier. This person should have access to technical specifications, supply and availability, and other relevant information that may be required by customers.

Phone number / Fax number The phone and facsimile numbers to reach the key contact. Use mobile phone number of landline is not relevant. Normal conventions for local numbers, such as (02) 6273 1466 apply. If international suppliers then option to use international number convention requires that you use a quotation mark symbol in front of the addition symbol ( „+ ), or else do not include the addition symbol.

Date Form Completed The date when the form was completed by the relevant technical personnel on behalf of the supplier, as distinct from the date of authorisation in section 1.4. Date format to use is day-month-year where the month is the three letter abbreviation dd-mmm-yyyy, for example 01-Apr-2011.

Document Number: The supplier‟s document reference number. The number under which the supplier references this document.

Issue Number: The supplier‟s document issue number. The supplier‟s issue or revision number for the completed PIF.

Issue Date: The suppliers document issue date. The date on which the completed PIF was issued or last updated by the supplier. Use the format dd-mmm-yyyy, for example 01-Apr-2011.

1.2 MANUFACTURER/S INFORMATION




This section should be completed ONLY when the manufacturer is different to the supplier.

DO NOT copy and paste cells as this will transfer cell conditions and formatting.

Company Name The full name of the company manufacturing this product for the supplier.

Site of Manufacture The name of the city and country where this product is manufactured. Where there are multiple sites where the product is manufactured, and where the product supplied may be provided from these alternate site, list the additional sites in order of priority or volume of production.

1.3 CONTACT DETAILS FOR TECHNICAL AND ALLERGEN INFORMATION

This section should provide the full name including first name and last name of the authorised technical contact person who is able to provide relevant detailed technical and allergen information about the product and the conditions in which is it handled, including all relevant details about potential sources of cross contact allergens. This person may be different from the Key Contact Person in Section 1.2, for example they may be the senior Production Manager or QA Person for the manufacturing site.

Use the same format for phone numbers as with the company contact. If international dialling, provide the relevant country and area code or use the internationally accepted code format.

1.4 SUPPLIER WARRANTY

The supplier declaration and warranty is an acknowledgement of the obligations in providing correct and accurate information, and an undertaking that any changes to the information provided will notified to the customer in an appropriate and timely manner to minimise the flow-on impacts on the customer.

Clause 3 of the warranty acknowledges that the accuracy of the information that is provided is limited to the degree that the supplier relies on third party information, and that the supplier has undertaken reasonable verification checks in place.

In the event that there is an omission of information, if the information provided is in error, then the customer must be immediately informed and the corrected PIF re-issued as soon as possible.




Clause 8 sets out the limitations for use by the customer of the data provided by the supplier. The PIF is considered commercial-in-confidence and the supplier retains the further disclosure of information is restricted without prior written agreement of the supplier.

Clause 6 sets out requires that if and when the supplier becomes aware of changes that will occur to the product, either due to a change in production or a change in ingredients, the supplier should advise their customer in advance of such changes coming into effect. Such changes can impact further down the supply chain and introducing requirements to change product labelling. Advance warning is essential to ensure that changes to labelling will be able to be accommodated by the customer.

When to re-issue a PIF The PIF will need to be re-issued periodically as agreed with the customer and supplier as part of validation and verification requirements of relevant food safety plans. As a guide, this should be at least every two years, but may be annually for products that are likely to have changes to nutritional content due to seasonal variations. Otherwise, the PIF should be re-issued when there are substantial changes to specifications.

Products or ingredients that are subject to due to seasonal variations, such as increased availability of feed, may need to be revised and reissued if there are significant nutritional variations on a yearly




basis. Products or ingredients that required to be sourced from different suppliers due to environment impacts such as droughts or floods, may be subject to a change in allergen risks from different suppliers and need re-evaluation.

Changes that DO NOT substantially alter the nature, substance or quality of the product, such as a more recent food safety audit or updated compliance certificates, do not warrant re-issuing the PIF unless there are specific requirements to do so in supplier contracts.

Company Details and signature The company entering into the direct supply agreement with the customer should complete this section and should have regard to the conditions laid out in the warranty.

Complete the company name, authorise person‟s details and signature and the date on which this PIF is authorised or provided to the customer.

Authorised Signature The signature of the person authorised to sign declaration on behalf of the company. This can be inserted as a digital signature, or if the completed PIF is to be printed it can be physically signed. Follow the same process for inserting a digital signature as with the Logo. Digital signature images should be sized to 9.8 cm X 1.8 cm.

The graphical image present in the template can be deleted and replaced with another digital signature image as a gif or jpg, and use the toolbar option „Insert‟ then „Picture‟ and „File‟ Alternatively edit and the graphic and insert a signature by RIGHT clicking on the graphic box "insert signature here”. Select 'Bitmap IMAGE Object - Edit', then from the top tool bar select 'Edit' and 'Paste from'. This should allow you to then select the image file from the folder on your computer to insert, then save and close edit mode. Date of Authorisation The date of signing this declaration and provided to their customer. Use the format dd-mmm-yyyy.

1.5 CUSTOMER DETAILS

The company and customer details to whom the PIF is being provided. If the Customer‟s Product Name and the Customer‟s Product Code are known these should also be provided for easy reference.

Customer Internal Use Only The purpose of this section is to assist customers with document management. It is recognized that many companies have their own internal systems. Completing this section is optional.

The supplier should leave this section blank.




1.6 DEFINITIONS AND REFERENCES

Any reference to the “Code” in either the PIF or this User Guide refers to the Australia New Zealand Food Standards Code.

Any reference to “Standards” or “Standard” in either the PIF or this User Guide refers to a food standard contained within the Australia New Zealand Food Standards Code.

Additional related documents including the AFGC Allergen Management Guide and VITAL (Voluntary Incidental Trace Allergen Labelling) documents can be viewed at http://www.allergenbureau.net/allergen-guide/

1.7 CHECKLIST AND ATTACHMENTS

The checklist is designed to ensure that the form has been completed correctly, in full and in accordance with the customer‟s request.

Complete the checklist by checking each of the boxes (by clicking once in the box) as applicable to indicate:

- the form has been completed in full - the document has been signed and dated - attachments have been supplied where applicable or as requested The customer may request additional associated documents be supplied at the time of completing the product information form. Any request for additional information should be outlined in the customer‟s covering letter or request to the supplier. Common associated documents may include Material Safety Data Sheets (MSDS), HACCP certification, Food Safety Certification and Product Specifications.

1.8 STATUS OF COMPLETION OF EACH SECTION

Certain questions on the form are deemed mandatory, but these will depend on the type of product and answers provided to preceding questions. The status of completion for each section depends on whether the mandatory questions relevant to the product have been responded. If all the mandatory questions have been completed within the Section, then the “status” will be displayed as

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“COMPLETED” and colour coded as green, otherwise if some questions within the Section have been responded to, but the Section has not been completed it will display as “PARTIAL” and colour coded yellow. If none of the questions in the Section have been responded to it will be indicated as “NOT DONE” and colour coded red.

Mandatory field checkbox An aid to assist in finding mandatory questions that may have been missed is provided at the bottom of the section. By selecting the check box, those questions that essential to be answered in this form (i.e. mandatory) but have not been completed will be highlighted with a purple background and white text. These fields will revert to their normal colour (blue or pink) when a response is provided.

2. PRODUCT INFORMATION & INGREDIENTS

References:

FSC Standard 1.2.4 Labelling of Ingredients

FSC Standard 1.3.1 Food Additives;

User Guides on Ingredient Labelling and Food Additives

Intellectual Property Australian http://www.ipaustralia.gov.au/.

2.1 PRODUCT DESCRIPTION

Insert a description of the product, which may include description of the physical nature, technological function or characterising attributes of the product.

Examples:

A natural chicken flavour consisting of natural extracts on a maltodextrin and salt base.

Crunchy peanut butter produced from clean, shelled peanuts which are roasted to a uniform medium brown colour.

An aqueous, clear solution of food grade acetic acid 75% w/w

Ground cloves are the ground dried unopened flower bud from the plant Eugenia Carophyllata. A dark brown powder with strong a aromatic flavour.

http://www.ipaustralia.gov.au/




2.2 LEGAL DESCRIPTION / SUGGESTED LABELLING DESCRIPTION

The legal description or name of the product, which can be used for ingredient labelling purposes in accordance with Standard 1.2.4 and Standard 1.3.1 of the Code. Where one or more alternatives exist, include all alternatives including any generic names, class names and food additive names and / or numbers. The product description and the legal description may differ to the extent that the legal description often contain less detail and reflects the name of the product used in labelling. Examples:

Colour (160a), Carotenes, Colour (Carotenes)

Vegetable Gum (407), Carrageenan Gum, Vegetable Gum (Carrageenan),

Acetic Acid, Food Acid (260), Acidity Regulator (260), Food Acid (Acetic Acid)

2.3 PRODUCT APPLICATION AND INTENDED USE

These are drop-list fields and only certain options are available. These are mandatory fields and an option MUST be specified. The response to these requirements will have an impact on questions and options available further on in the form.

For Question 2.3.1 the available options in the drop-list are:

Raw material chemical, OR food additive OR processing aid used in food manufacturing

Food supplied as an ingredient for use in further manufacturing or processing

Food may be used as an ingredient, or may be retail-ready finished product

Food which is a retail-ready finished product The first and second option (raw material … and an ingredient) will limit the selections and information presented in Section 4 on the nutritional information. This is because it is not appropriate to specify a serve size for products that are raw materials, food additives, processing aides or ingredients; and without a serve size you cannot determine the percent daily intake. For Question 2.3.2 the available options in the drop-list are:

Liquid, single strength ready for use

Liquid, concentrate

Solid, dehydrated substance

Solid substance, suspended in liquid

Solid, semi-solid or powder substance, intended for use in further preparation

Solid, semi-solid or powder substance, ready for consumption The state of the product, being liquid or solid, will determine the units of measure (millilitres or grams), while the use of a liquid concentrate or dehydration also generates questions about reconstitution, and both questions about liquids require a response as to the specific gravity. For a product which is suspended in a liquid it is assumed that this is intended to be drained before use, and the nutritional information panel specified the nutrients are reported on this basis.




2.4 COUNTRY OF ORIGIN

References:

FSC Standard 1.2.11 Country of Origin Requirements

Australian Consumer Law 2011, Schedule 1, Part 5-3 – Country of origin representations

Fair Trading Act 1986 (New Zealand) Part 1, 13(j) Country of Origin (COO) Statements on foods are regulated in Australia within Standard 1.2.11 Country of Origin Requirements and the provisions of the Australian Consumer Law (ACL), Part 5 - 3. In New Zealand COO statements are not a mandatory food labelling requirement. However if a voluntary COO representation is made then the claim must not be misleading or deceptive. The provisions of the ACL provide specific requirements for claims about the country of origin of a product, and in particular claims relating to a representation that the goods are the produce of a country, the use of a logo, or that the goods where grown in a particular country. The provisions allow for substantial transformation, content and production cost including the cost of packaging. For further Country of origin information go to www.accc.gov.au and search for “Country of origin”. Some food businesses operate on a trans-Tasman basis and sell their products in both Australia and New Zealand. COO information may be requested by food companies on New Zealand products in order to meet their legislative requirements when these products are sold into other countries. In addition, the COO information provided on food ingredients is used by the manufacturer to help determine the COO statement to be declared on the final food product.

2.4.1 Overarching country of origin declaration Provision is made for a declaration that covers 2 countries. If more countries, then use the "Other" statement or provide additional information under Section 8 comments.

The overarching country of origin statement has a limited range of options, such as Product of… or Made in… If none of these are appropriate, there is an “Other” option. If you select the “Other” option, please specify what the other statement is by inserting text in the pale blue box that appears underneath when this option is selected.

http://www.accc.gov.au/




Product of: Where each significant ingredient of the food is locally sourced and all/virtually all the manufacturing / processing of the goods have happened in that country.

It is possible that there will be a small % imported ingredients, depending on circumstances and the relevance of the imported ingredients in the overall representation of the product. Question 2.4.2 seeks to confirm that the average local content exceeds 95%. This of itself may not be sufficient to meet ACCC requirements for product of claims, depending on the circumstances and additional factors. The information should be used as a guide and whether further information is required.

Made in: Requires that ingredients are mostly locally sourced, or have been substantially transformed in the country claimed to be the origin, and at least 50% of the costs of production have been carried out in that country. In the case of „Made in Australia‟ using a mixture of local and imported ingredients, the labelling may be qualified to state “Made in Australia from local and imported ingredients” where there is more than 50% local content, or “Made in Australia from imported and local ingredients” where the imported content exceeds 50% of the product. Where these conditions are not met the following qualifying statements may be used:

Made from local and imported ingredients:

means that the local ingredients must be at least 50% of content. Made from imported and local ingredients:

means that the imported ingredients are at least 50% of content. Grown in: Requires that ingredients are substantially locally sourced, or have been substantially transformed in the country claimed to be the origin, and 50% or more of the total weight of the goods is comprised of ingredients or components that were grown and processed only in that country.

Other statements: Other statements as appropriated, for example, Packed in... , Blended in..., Brewed in..., etc. For products or raw materials that may be sourced from multiple countries, please use the 'other' category to nominate as appropriate. Question 2.4.2: Note that you can only complete either the question about greater than 95% local content or greater than 50% local content. Selecting an answer for either question automatically removes the other. Question 2.4.3 - source of primary ingredients. This is useful for traceability and confirming the origin of the ingredients. Traceability may also be important for food safety reasons, and to only be able to trace back to a source when an incident arises. Traceability may also to evaluate the potential risk that may be associated with an ingredient from a particular region and may help in identifying potential food safety hazards and contaminants that must be controlled.

Traceability is important in establishing the providence of the product, especially when there are essential characteristics associated with the local production or the region, for example to establish that a type of extra-hard cheese that comes from Parma.

While it is ideal to be able to have the names of the countries where the primary ingredients are sourced, in some cases the information may not be able to be provided when the ingredient is sourced from multiple countries and there is a high level of intermingling of ingredients and batches or limited traceability documentation from suppliers




Provision has therefore been made to permit country regions and preceded with an asterisk, such as *European Union or *Asia, as a last resort and to retain some element of traceability.

Question 2.4.4 – substantial transformation and production costs: The determination about whether an ingredient may be considered to be imported or local depends on whether the ingredient has undergone a substantial transformation process. This generally involved changing the nature or form of the ingredient into something that is recognisably different, for example changing using curing salts and brine to transform raw pork into bacon, or changing a whole orange into orange juice. Substantial transformation is not considered to have occurred when ingredients are simply blended or concentrates simply have water added.

2.5 COMPONENT TYPE

Three options are provided to specify the types of components present in the product:

Product is a single component substance: A substance which if used in further manufacturing would only require to be declared on a label as a single ingredient, examples - milk, honey, salt, tea, coffee.

Ingredients which may include compound substances: Compound substances may be made from two or more ingredients, e.g. spaghetti, which is made from wheat flour, egg and water.

When present at 5% or more in a food, a compound ingredient MUST declare all the food additives present in the compound ingredient.

When a compound substance is present at less than 5% as an ingredient in a food, only those food additives that are still performing a technological function in the food must be declared. If there is an allergen present, or substances derived from an allergenic source, then it must be declared irrespective of whether it performs a technological function.

Products that consist of ingredients that are not compound substances: products that are a mixture of various foods or food additives that are a single component substance, such as a mixture of wholegrain wheat flour, salt, sugar, canola oil, yeast, milk powder and water.

EXAMPLE SCENARIO: Pectin used in making jam

Pectin: The pectin is manufactured in Malaysia from an extract of citrus peel. The citrus peel undergoes substantial transformation in the manufacturing process. Citrus peel is sourced from several countries across South-East Asia and the Middle-East, and varies considerably from season and year to year.

Is “Made in Malaysia” the overarching country of origin declaration for the pectin?

How do you declare the countries where the ingredients come from to make the pectin?

The usage of pectin in manufactured product is about 2% of jam in Australia. Will this have an impact in declaring the country of origin of the retail product if the fruit content is all sourced in Australia?




2.6 INGREDIENT DECLATATION INCLUDING PERCENTAGE LABELLING

References:

FSC Standard 1.2.4 Labelling of Ingredients

FSC Standard 1.2.10 Characterising Ingredients and Components of Food;

User Guides on Ingredient Labelling, Percentage Labelling and Food Additives

Provide a full list of ingredients including food additives in descending order as prescribed in Standard 1.2.4 of the Code, including a full breakdown of compound ingredients, percentage of each ingredient, and percentage of characterising components / ingredients (if applicable).

Full breakdown of ingredients and percentages is requested:

to assist customers compile their own product ingredient lists (which may require consolidation of similar components across different ingredients from different suppliers).

to provide a cross check to the allergens sections and information on hidden ingredients

It is up to the supplier and customer to negotiate an acceptable outcome if a concern arises regarding the provision of this information.

Component Name

List each ingredient in descending order by weight. Ingredients should be described based on the principles for labelling in Standard 1.2.4.

Percentage

The percentage of each ingredient must be specified. Ranges or maximum/minimum values may be acceptable alternatives if agreed to with the customer, provided that the exact percentage of any characterising ingredient or component is always provided.

Compound Substance Ingredients

This section should be used to break down any compound ingredients into their components. If the ingredient is a single ingredient, this field can be left blank.

Characterising Component

The characterising components column should be used to record the percentage of any characterising ingredient within a compound ingredient in the product. If any of the components of compound ingredients are classed as characterising, their exact percentage should be provided in the last column.

For single ingredients, this percentage will be the same as the percentage listed in the previous percentage column.




Example 1 : Confectionary

COMPONENT NAME

PERCENT OF TOTAL

COMPOUND SUBSTANCE INGREDIENTS

Full breakdown list of components in compound ingredient including additive code numbers

Characterising component

% %

Sugar 55 - 60%

Vegetable Fat 15 - 20% Vegetable Fat (Emulsifiers [492, Soy Lecithin])

97.30%

Cocoa 15 - 20%

Citrus peel 2 - 3%

Whey Powder 0 - 5%

Example 2 : Satay Sauce

COMPONENT NAME

PERCENT OF TOTAL

COMPOUND SUBSTANCE INGREDIENTS

Full breakdown list of components in compound ingredient including additive code numbers

Characterising component

% %

Water 55.00%

Peanut Butter 30.00%

[Roasted Peanuts, vegetable oil,

80% salt, antioxidant (306) ]

Desiccated Coconut 5.00% Coconut, Preservative 220

Food Acid (260) 4.00%

Salt 3.00%

Spices 2.00%

Emulsifier (Lecithin) 0.50%

Vegetable Gum (415) 0.50%

2.7 PROCESSING AIDS

Reference:

FSC Standard 1.3.3 Processing Aids

Enzyme Commission number (EC number) Provide a full list of processing aids used in the manufacture of this product and not declared in the ingredient listing.

Processing aids may be a source of undeclared allergens. The information provided in this section is cross-checked against Section 3. It is also used to respond to consumer and customer requests regarding the composition or production of the product.

FSC Additive Number - the numbers specified in the food standards code in Standard 1.3.3, or Enzyme Commission (EC) Number.




3. COMPOSITIONAL INFORMATION

3.1 MANDATORY ADVISORY OR WARNING STATEMENTS & DECLARATIONS

References:

FSC Standard 1.2.3 Mandatory Warning and Advisory Statements and Declarations;

User Guide on Mandatory and Advisory Declarations;

FSC Standard 1.5.1 Novel Foods The presence of foods or substances in foods listed in this section triggers either an advisory or mandatory warning statement to be placed on the label of the food. The customer will need to know this information to be able to ensure labelling compliance of their products with this section of the Code.

Select either “yes” or “no” response in the pink column to indicate the presence of the food or component in this product. In the case of polyols, isomalts and polydextrose the type and level must also be specified.

To assist in filling out this section, the following advice is provided for the components:

Bee Pollen The pollen collected from the legs of bees. This does not include bee pollen that is naturally present in honey.

Propolis The reddish resinous cement collected by bees from the buds of trees, which is used to stop up crevices in hives and strengthen the cells.

Quinine An alkaloid derived principally from the bark of the cinchona tree.

Aspartame An intense sweetener that replaces the sweetness normally provided by sugars in foods without contributing significantly to the available energy.

Guarana Derived from a vine (Paullina cupana H.B.K.), it consists of a crystallisable principle, called guaranine, which is identical to caffeine.

Phytosterol esters Phytosterol esters are prepared by the reaction of phytosterols with fatty acid methyl esters or free fatty acids. The free phytosterols are structurally related to cholesterol and occur naturally at low levels (up to 0.9%) in common vegetable oils.

Phytosterol esters are considered to be novel food ingredients because they do not have a history of significant human consumption by the broad community in Australia and New Zealand at the proposed levels of dietary exposure.




Tall oil phytosterols Tall oil phytosterols are predominantly a mixture of four phytosterols: sitosterol, sitostanol, campesterol and campestanol, extracted from tall oil soap which is a bi-product of the pulping process used for coniferous trees in North America and Europe.

They are then purified in a three-step process. The free phytosterols are structurally related to cholesterol and occur naturally at low levels (up to 0.9%) in common vegetables. Tall oil phytosterols are considered to be novel foods because they are non-traditional foods for which there is insufficient knowledge in the broad community to enable safe use of this food in the form or context in which it is presented.

Royal Jelly A milky white viscous secretion from the salivary glands of honeybees.

Polyols, Isomalts and Polydextrose Modified carbohydrates including lactitol, maltitol, maltitol syrup, xylitol, sorbitol, erythritol, isomalt and

polydextrose. Special consideration should be given where these substances may be used as a carrier in foods. Their presence at particular levels triggers an additional advisory statement to be included on the label of the food.

3.2 ALLERGEN MANAGEMENT & CONTROL

This section seeks information about the processes in place to manage food safety risks and whether allergen management is part of the food safety plan.

If the business has a food safety program then information is requested about whether this has been independently audited and to provide the details of the certification body responsible for the audit.

The date of the most recent audit or inspection is relevant only at the time that this PIF is prepared. If the PIF is subsequently updated and re-issued to a customer then the date of the most recent audit may also be updated, but a PIF should not be re-issued simply because an audit has been undertaken.




Question 3.2.4 – minimising allergen cross contact Allergen cross contact control measures should be monitored for effectiveness and should be part of the overall food safety program. In Question 3.2.4, tick only those control measures, which are applied and are regularly assessed in their effectiveness to reduce or prevent of cross contact in your manufacturing premises.

If particulate cross contact allergens are present these measures will need to be evaluated in response to question 3.4.4.

3.3 MANDATORY DECLARATION OF CERTAIN SUBSTANCES

References:

FSC Standard 1.2.3 Mandatory Warning and Advisory Statements and Declarations;

User Guide on Mandatory and Advisory Declarations

The Code requires the presence of specified foods that may cause adverse allergic reactions to be declared on food labels. These substances are commonly referred to as allergens.

The list of foods that may cause severe adverse reactions and must always be declared on food labels is contained in Standard 1.2.3 Clause 4 and includes:

Cereals containing gluten and their products, namely wheat, rye, barley, oats and spelt and their hybridised strains including triticale.

crustacea and crustacea products, egg and egg products, fish and fish products, milk and milk products, tree nuts and sesame seeds, and their products, peanuts and soybeans, and their products, added sulphites in concentrations of 10mg/kg (ppm) or more

If the option for Cereals containing gluten and their products is selected, two further questions will be asked as to whether processing has rendered the product gluten free, and if processing has rendered the product from of wheat proteins. This requires the either gluten or wheat protein must not be detected. The Codex level of 20mg/kg for gluten free is not acceptable.




Sulphite values: Care must therefore be taken in the method used for testing as some test methods, such as the use of test strips have a lower limit of quantification of 10mg/kg. This is not sufficiently accurate to ensure the reliability to results as it is important that the method used have a lower limit of sensitivity well below 10 mg/kg so that there is quantification of sulphite in the range of 1 – 10 mg/kg.

Input fields will allow numerical and text fields, but only numerical fields will be counted for total sulphite value and text fields are assumed to be equivalent to nil value. For example, you could have less than 1 mg/kg naturally present, less than 0.1 mg/kg in carry over material and 10 mg/kg added as an ingredient and the total sulphite calculated will be 10mg/kg.

If appropriate, use the text "less than" rather than the "<" symbol for values. e.g. less than 10

Naturally occurring in ingredients This is the level of sulphites present as a natural constituent of the food ingredient or produced as a by-product of processing.

Residual from processing aid, or carry-over in compound in ingredient This is the level of sulphites added to the food via compound ingredients and/or the residual sulphite present from the use of a processing aids, and which is not naturally occurring in the ingredients, nor is it sulphite added as a preservative.

Sulphite added as an ingredient This is the level of added sulphites only. It excludes any naturally occurring sulphites, or added to the food via ingredients, food additives and/or processing aids as a compound ingredient.

Added sulphur dioxide or sulphites are widely used as preservatives. Special consideration should be given to the treatment of processed fruits, vegetables and herbs.




Examples of common sulphite-containing preservatives are sulphur dioxide (220), potassium bisulphite (228), potassium metabisulphite (224), sodium sulphite (221), sodium metabisulphite (222), and sulphurous acid.

The source of the added sulphites (including additive numbers where relevant) should be included on the form in the box provided.

Total Sulphite This value is automatically calculated based on numerical values. Where the value is stated a „less than‟ a value, this should be relevant to the limit of detection for the method used, for example „less than 10‟ in each of the three fields will result in a total sulphite value of „less than 10‟.

Total sulphite present in product is important as it is a mandatory requirement to declare the presence of sulphite when present at 10mg/kg or more.

Allergens

When completing this section, note that:

Expressions such as „egg and egg products‟ or „crustacea and crustacea products‟ include all products derived from these substances. This is irrespective of whether the food is still present in its original form or whether protein is present or not. It incorporates even the most highly processed derivatives of these foods. Currently no thresholds apply for highly processed or refined derivatives.

Ingredients should be reviewed for hidden sources of allergens. Ingredients may contain less known sources of allergens, which may be overlooked. (Refer to Useful Information below)

Every box must be marked with a YES or NO response as appropriate.

Where a “Yes” response is used, additional information must be inserted.

Additional information includes

o The name and type of allergen derivative o The percentage (%) of the allergenic derivative in the product o The percentage (%) of protein (or gluten, in the case of cereals containing gluten)

present in the allergenic derivative in the product. This can be determined by food analysis or taken from food composition tables.

o Confirm (Yes / No) that the allergenic protein has been removed from the derivative during processing

To convert from ppm to %, divide by 10000; e.g 100mg/kg = 0.01%;

To assist in filling out this section, some of the components have been defined to provide clarification.




3.3.1 Table for Allergens present as ingredients

The allergens which are selected in list under Section 3.3 will cause the Allergenic Substance in the Table to 3.3.1 to be highlighted and at least one row of information will be required.

Source name: The allergen names can be very specific to a product, such as egg or milk, or they can be very broad, such as crustacea, fish or tree nuts. The source name is the name of the allergenic substance/food from which the ingredient, additive or processing aid is derived. For example, the source substance name could be wheat for cereals containing gluten, almonds for tree nuts, cows milk for milk, etc.

The source name IS NOT the name of the food in which the allergen is found. For example, soy sauce is NOT the source name for the presence of soybean products, but rather it is soybean.

Derivative name: The derivative name is the name of the substance which has been derived from the source material and is used in the product. This may be an ingredient, a compound ingredient, an additive or a processing aid. For example, maltodextrin may be derived from wheat, casein is a derivative from milk.

Process: Has the ALL of the allergenic protein been removed during the process of manufacturing the derivative material. For example, if during the process of distilling grain alcohol could remove all wheat derived allergenic protein, then answer "Yes".

Cereals containing gluten & their products This includes wheat, rye, oats, barley, spelt, triticale or their hybridised strains.

Special consideration should be given to the origin and content of flours, starches, thickeners, hydrolysed vegetable proteins, corn flours, breadcrumbs, gluten powder, baking powders, curry powders, carriers used for flavour bases, malt vinegar, couscous, semolina, malt, icing sugar, whiteners, wheat starch, glucose syrups, dextrose, maltodextrin, amylases, free flow agents and caramel colour. These may have been derived from gluten-containing cereals.

Ingredients derived from gluten-containing cereals must be declared regardless of whether the product contains gluten. For example: Dextrose can be derived from sucrose, maize, potato or wheat and in its final form, dextrose produced from each of these sources is chemically indistinguishable and has no detectable presence of gluten. However, the declaration required by clause 4 of Standard 1.2.3 is for cereals containing gluten and their products, therefore, if dextrose derived from wheat is present in the final food, you must declare this as a statement on the label (e.g. „contains products from wheat‟ or ‟ wheat dextrose‟).

Crustacea and crustacean products

Crustaceans include various species of aquatic animals, wild and cultivated, which have an inedible chitinous outer shell, but which may be used as a source of other ingredients such as glucosamine. Special consideration should be given to Asian sauces, flavours and extracts of crustacea. Examples include prawns, shrimp, crab, lobster, etc.

Egg and egg products

This includes both white (albumen) and yolk in fresh, dried and frozen forms. Examples include eggs, egg pulp, egg protein, egg albumin, egg lecithin, lysozyme, dried egg powder, emulsifiers and clarifying agents used in wine, juice and stock production. Special consideration should be given to the content of binders and coating substances.

For example: lysosyme enzyme is used in cheese manufacturing. The lysosyme may be extracted from egg white, or sourced from a nonmammalian, nonavian source such as a bacterial culture. If the lysozyme is derived from egg white, it should be stated in Section 3.3.1 under egg and egg products, and in Section 3.7 that there or Animal and Bird products in their product.




Fish and fish products (including mollusc)

The Food Standards Code Standard 2.2.3 defines “fish” is very broadly as:

“any of the cold-blooded aquatic vertebrates and aquatic invertebrates including shellfish, but does not include amphibians and reptiles.”

In addition to aquatic animals with a skull and in most cases a backbone, that have gills throughout life and whose limbs, if any, are in the shape of fins, this definition of „fish‟ also encompasses mollusc and shellfish (such as oysters, clams, mussels, scallops), squid, cuttlefish, octopus, shark fin, fish roe, bêche-de-mer, and jellyfish. These broadly represent a wide variety of different and distinct allergenic groups.

Crustaceans are a subset of “fish” under this definition, but for the purpose of the PIF if crustacean are present and indicated as an allergen, they do not also need to be indicated under “fish”.

VITAL users please note: the definition applied when using VITAL to consider inadvertent presence of cross contact allergens only considers cartilaginous fin fish rather than “seafood”. This definition may be applied for the purpose of precautionary labelling, but MUST NOT be applied for ingredients.

Special consideration should be given to the origin and content of fish flavours, sauces including Worcestershire sauce, and extracts, gelatine, hydrolysed animal proteins, encapsulated beta-carotene, and clarifying agents such as isinglass.

The FSC provides an exemption declaring isinglass derived from swim bladders and used as a clarifying agent in beer and wine as an allergen under „fish and fish products‟.

Lupin and lupin products Lupin is included as a non-mandatory declaration on the basis that there are reports of lupin allergic responses and a degree of cross-reaction with people who are allergic to wheat. FSANZ is undertaking a risk evaluation of lupin and may propose including lupin as a mandatory declaration. Milk and milk products Milk is defined in Standard 2.5.1 as milk obtained from milking animals. Refer to Standard 2.5.1 for a complete definition. Milk products include milk, cream, cheese, yoghurt, ice cream, milk powders, cheese powders, lactose, milk proteins, whey, milk sugars, milk fats, caseinates, and casein. Special consideration should be given to the origin and content of flavours, whiteners, hydrolysed animal proteins and clarifying agents.

Tree nuts & their products Tree nuts are the seeds of a variety of trees and shrubs, which are characterized by a hard inedible shell enclosing an oily seed. Commodities: Almonds; Beech nuts; Brazil nut; Cashew nut; Chestnuts; Coconut; Hazelnuts; Hickory nuts; Japanese horse-chestnut; Macadamia nuts; Pecan; Pine nuts; Pili nuts; Pistachio nuts; Sapucaia nut; Walnuts.

Please note that within the Code, coconut is not considered a tree nut and therefore should not be listed in this section. Nut products include any nut oil, and any paste, flour or butter made from nuts.

VITAL users please note: the definition applied when using VITAL to consider inadvertent presence of cross contact allergens considers a much more limited range of nuts than that specified in the food and these definitions MUST NOT be applied for ingredients in Section 3.3. Sesame seeds & their products This includes sesame seeds and products such as sesame seed oil and tahini.




Peanut and peanut products This includes whole/ground/crushed peanuts, peanut oil, peanut meal, peanut butter, peanut flour and peanut paste. Special consideration should be given to pastes and pesto products.

Soybeans & their products Products include soy lecithin, soy protein, soy sauce, soy flour, soybean oil, soya yoghurt, soya milk, tofu, and bean curd. Special consideration should also be given to the origin and content of hydrolysed and texturised vegetable proteins, vegetable oils, anti-dusting agents, tocopherols, protein isolates, antioxidants, emulsifiers, lecithin and flavours which may contain soy or soybean oil.

3.3.2 allergens as a substrate Where the PIF is for a raw material (declared in 2.3.1) the allergen declaration exempts allergenic substrates/feedstock that has been used in a metabolic process for the production of the ingredient and where the allergenic proteins have been fully removed or metabolised. For example, the use of soybean for the production of xanthine gum.

If the PIF is not for a raw material, then question 3.3.2 will not be available.

3.3.3 Summary of allergens to be declared

The summary of allergens present as ingredients should be declared consistent with the AFGC recommendations on allergen labelling, declaring the common name of the group or class of allergen and if tree nuts are present, declaring the name of the specific tree nut.

If there are no allergens present, the use of an allergen-free statement for product labelling must have regard to ACCC restrictions on the use of the term „free‟ and provisions for „false, misleading and deceptive‟ under Australian Consumer Law.

Standard 1.2.8 clause 16, requires in the use of the term „gluten free‟ there must be no detectable gluten present in the product.

Use of such terms need to be supported by an Allergen Management Plan which includes validation and verification programs for allergen testing of ingredients/finished produces, cleaning validation, a VITAL plan and other evidence to demonstrate the allergen is no present. An allergen-free statement must not be used when:

1) The product contains a compound ingredient, processing aid or additive derived from a source containing the relevant allergen, regardless of amount added or degree of refining or;

2) a VITAL assessment identifies cross contact allergens from any source and at any level.

3.4 ALLERGEN CROSS CONTACT

References:

AFGC Food Industry Guide to Allergen Management and Labelling (2007) and

VITAL (Voluntary Incidental Trace Allergen Labelling) system [VITAL 2.0 recommended]




Cross contact allergen: Cross contact allergens are those allergens that may be inadvertently incorporated into a product through various routes and where the occurrence of the allergen is sporadic, intermittent and uncontrollable.

Where an allergen is consistently present (i.e. not sporadic) but the occurrence is unintended, highly variable and uncontrollable, it may also be considered to be a cross contact allergen and reported in Section 3.4 of the PIF.

NOTE: cross contact allergens are not to include the potential risks of production errors or other known failures to adhere to good manufacturing practices.

If the allergen is consistently present at significant levels that exceed VITAL Action Level 1, consideration should be given to declare the allergen as an ingredient in Section 3.3, rather than as a cross contact allergen. However, this may have implications for both ingredient labelling and compliance with consumer law.

The declaration provided in the PIF is intended to cover all possible routes and sources of the cross contact allergen, such as inclusion from growing environments, harvesting, transport and storage of the raw materials through to considering the cross contact sources in a manufacturing facility, such as through the use of shared equipment or from aerosols or dust in a processing environment.

This section requests information on cross contact allergens that the supplier has assessed as likely to occur and the level of allergen that may be present, or whether the cross contact allergen occurs as a particulate material. This will enable customers to assess whether a precautionary cross contact statement is required on their product.

If an assessment of the „worst case‟ or maximum level protein from the cross contact allergen is provided using the VITAL method, the manufacturer or supplier can determine that a precautionary statement is not required if the level is present is within Action Level 1.

The declaration of carry-over cross contact allergens present in ingredients, where those allergens are not directly attributable to their presence in the facility or on the production lines is problematic for the PIF. It is recommended that where such carry-over of cross contact allergens that “Present in same facility” I is identified as “YES”, but “Present on same production line” is “NO”, and under derivative name specify “carry-over of allergen from ingredients”.

Example scenario:

Example 1: A ground spice producer advises that due to growing, harvesting, storage and / or transportation conditions that cross contact with wheat grains and pollen occurs and there is high likelihood gluten will always “detectable” in the final ground spice and on occasion may be present at more than 20mg/kg. As the gluten protein is consistently present with no way of controlling it, the supplier chose to declare that it was an allergen present in the product in Section 3.3.1.

Declaring it in this section means that packaging the ground spice for direct sale requires a declaration that the product “Contains wheat” and include wheat in the ingredient list. Manufacturers using this ground spice as part of their product, even when present in small amounts, will also need to declare the presence of wheat.

Example 2: A chocolate manufacturer producing 75% dark chocolate on a production that also hazel nut chocolate and where there is the possibility of sporadic, intermittent small particulate pieces of hazel nut may be present in the 75% dark chocolate. The chocolate manufacturer declares the




presence of hazel praline on the same production line and provides relevant advice at question 3.4.4, such as “traces of hazel nut may be present”.

Due to the complexity of this area, customers may need to enter into further discussions with suppliers where more specific information or clarification is required.

Question 3.4.1 Are there any other allergens onsite other than those indicated in the previous section.

Where an allergen is identified as an ingredient in the previous Section 3.3, and where the allergenic protein have not been removed and an allergen declaration will be required, there is no need to also nominate the presence of the same allergen as a cross contact allergen. For example, it is not appropriate to declare in the ingredient list that a product contains peanuts and then also declare that it peanuts may be present.

With the exception of Cereals containing gluten and also Tree nuts, where an allergen is present in Section 3.3.1 the corresponding allergens will be blanked out in Section 3.4.2 unless the allergen identified in 3.3.1 has had the allergenic protein removed. If the allergenic protein is identified as being removed then it may be possible that the same class of allergen may be present as a cross contact allergen and it should be identified as a cross contact.

For cereals containing gluten and also for tree nuts, it is a requirement that the different food types within the class are nominated. For example, it is possible that the allergen could be declared for the presence of wheat, while there is a cross contact for barely; or there may be Almonds present as ingredients while there is also a risk of cashew nuts present as cross contact.

This does NOT apply for the other allergen groups.

Present in same facility A facility refers to enclosed vicinity in which a product is manufactured. Separate, fully enclosed areas within the one site may be considered separate facilities. It is possible to have the allergen on a site,




but still answer NO to allergen present in same facility if the allergen is strictly controlled and prevented from entering into the designated area of the facility.

Enter Yes or No based on whether the allergenic food type is present in the same manufacturing facility as the product.

Present on same line Enter Yes or No based on whether the allergenic substance is present in other products that share common equipment (including batching, mixing, filling and packing equipment), irrespective of the scheduling for production or whether this equipment is stripped and cleaned between use. This specifically refers to the equipment used within the aforementioned facility.

Notice that the blue background highlighted box on the left hand side only become activated when „Yes‟ option is indicated for „present in same facility‟. If there is no allergenic substance present in the same facility then it cannot be „present on same line‟, and therefore the option for the second question is blanked out.

Specify name and type of derivative The name and type of derivative that is present in the same facility and/or on the same line should be listed here and follows the same intent as in Section 3.3.1; i.e that the source of the allergen is the name of the source food, such as prawns for the Crustacea group; prawn meat and prawn shell may be the derivatives from which there is a potential for cross contact on the same production lines used to manufacture breaded crumbed fish products.

Total protein from allergens estimated using the VITAL2.0 procedure VITAL is a process of evaluating the presence of unintended cross contact allergen, those that inadvertently become incorporated due to shared processing equipment and/or facilities and determining whether it is necessary to label for cross contact allergens . AFGC recommends the use of VITAL 2.0 where possible.

VITAL is a tool to assess cross contact allergen and determine if the use of a precautionary statement is appropriate. All cross contact allergens, present due to unintentional presence in ingredients and due to unintentional incorporation during manufacture, should be identified. If cross contact allergens are identified as particulate allergens (refer to the VITAL documentation for the definition of particulate), then VITAL directs that a precautionary statement (May be present: xxx) is required.

An indication of whether the cross contact is in particulate form should be provided for each allergen in the table for 3.4.2. If the allergen is readily dispersed and a concentration can be determined then the VITAL estimated value should be provided, otherwise use the term unavailable.




Text may be included with the number, but not symbols. Acceptable text that may be used is: - less than - or less - unavailable - particulate The VITAL procedure has recently been updated to VITAL 2.0, which estimates the amount of protein present in mg/kg. There is no need to separately estimate the amount of gluten present, for the purpose of using VITAL or determining the Action Level.

The VITAL Action Level 1 MUST NOT be used as a justification not to declare the presence of allergens or the ingredients derived from allergens in Section 3.3; nor can it be used to justify a „Gluten free‟ claim. The VITAL Action Level 1 and 2 relate solely to the declaration of the precautionary statement: “MAY BE PRESENT:”

Particulates VITAL defines particulate as a separate and distinct particle of material (eg sesame seeds, slithered nuts, grated cheese). For the purpose of VITAL, a particulate refers to an entity of food which either

1. Does not mix homogenously with other parts of the food; or 2. May consist of, or are likely to aggregate into an entity which contains equal to or greater than

the relevant Reference Dose.

Where the VITAL risk assessments identifies that particulate cross contact allergens may be present in the final product, then answer yes to 3.4.3 and 3.4.4.

Questions 3.4.3 is about the presence of cross contact allergens that may be present in particulate forms, such a small pieces of nut or seeds, or may be flakes of material that has been trapped in machinery. If the potential for particulate cross contact allergens exits, then 3.4.4 asks if the range allergen management functions have been implemented to control the particulate material or if, despite all these measures, the particulate cross contact allergen is still present.

If the particulate is identified as still being potentially present in the product, the provide information at 3.4.4 with regard to an appropriate statement or advice – eg “sesame seed cross contact via baking tins”.

Particulate cross contacts are treated differently to non-particulates as non-particulates are more likely to be more homogenously distributed through a product. If particulates are present, then a VITAL calculation is not appropriate and therefore consideration needs to be given to an alternative form of precautionary statement.

If the particulate cross contact allergen is not present, or has been managed and is not likely to be present, then 3.4.5 asks if the cross contact allergen levels have been assessed using the VITAL




procedure. If they have been assessed using VITAL, then the question further asks if these have been assessed against VITAL action level 2 and what is an appropriate precautionary statement.

VITAL recommends using the term “May be present:” followed by the allergens that are at Action Level 2. Cross contact allergens present at a level indicated by Action Level 1 are not labelled in precautionary statements.

If the particulate cross contact allergen is likely to present despite undertaking the allergen control actions, then questions at 3.4.5 are not relevant and neither is it appropriate to consider VITAL assessment and VITAL cross contact statements. However, it is necessary to provide an appropriate precautionary statement, such as “May contain pieces of peanut”.

Although some foods or ingredients mentioned in the following Sections 3.5, 3.6 and 3.7 may be allergenic, and the reason to provide the information is to enable customers to be aware if these ingredients are present in the event of consumer enquiries, these foods or ingredients are NOT to be included in the requirements for the declaration of cross-contact ingredients in questions related to Section 3.4

It may be relevant to evaluate the potential of some of the ingredients in Sections 3.5, 3.6 and 3.7 if certain claims or warranties are made about the product. For example, if the product is claimed to be suitable for Vegans but there is a potential cross contact with animal products. While there is no requirement to cross-contact for these sections, the obligation remains with the supplier that if such claims are made they must be true and correct.

3.5 INTERNATIONAL ALLERGEN, LABELLING & INFORMATION REQUIREMENTS

Section 3.5 collects information that is additional to the requirements of Standard 1.2.3 Mandatory Warning and Advisory Statements and Declarations.

The information is required to enable the customer to:

meet the needs of export markets

ensure that additional labelling requirements are met

answer consumer enquiries related to ingredients they may prefer to avoid or may be sensitive to review possible claims that may be made on the customers finished product.

Every box must be marked with a YES or NO response as appropriate. Where a YES response is used, additional information must be inserted. Use of the term “Added” does not include the naturally occurring presence of the component in the food. For example, added sugar does not include sugar/s naturally present in the food.

Gelatine Beef gelatine will naturally disqualify a product from making a vegan/vegetarian claim, and care must be exercised as to whether it would be suitable for kosher/halal. Beef gelatine is also an issue for imported products due to rules on potential BSE risk. Gelatine can be sourced from other materials, such as fish (still not acceptable for vegan/vegetarian) or the use of substitutes such as agar or




carrageen. Gelatine will therefore automatically disqualify a product from all vegan claims, but not halal or kosher. Seafood products Fish and crustacean are identified in Section 3.3 and 3.4 as required in the Food Standards Code. Shellfish allergies are also commonly seen in adults, particularly those living in regions where they are often eaten. Researchers have estimated that 75% of individuals who are allergic to one type of crustacean (shrimp, lobster, crawfish or crab) are also allergic to shellfish, but not allergic to fish. As crustaceans and molluscs (oysters, squid, scallops and snails) contain the same type of proteins some people may react to both groups of foods. Shellfish (molluscs) are soft-bodied marine invertebrates with protective shells, including oysters, clams, mussels, abalone or scallops. Importantly, the group also includes snails (a French cuisine called escargot).

Fungi Some kinds of mushroom spores are known as inhalation allergens and contact allergens that cause allergic reactions like bronchial asthma, and contact dermatitis. There has to date only been a small number of reports describing food anaphylaxis reaction caused by mushrooms. There are several reported cases of allergic reactions to matsutake mushroom. In addition, the use of wild mushroom or field mushrooms requires careful identification.

Fruits The fruits section is divided into four classes of fruits plus avocado and banana. The classes of Pome fruit, Stone fruit, Berry fruit and Citrus fruit have accompanying examples for the name of a fruit in this class, but the list is not intended to be exhaustive and there may be other fruits in these classes that would also be appropriate to list within the specified class. This information is important for companies to be able to provide advice more broadly about the presence of potential allergens other than those listed in Section 3.3. In France it is reported that the most commonly identified allergens of plant origin in adults are: fruits from the latex group (bananas, avocados, chestnuts, kiwis, etc.) at up to 14% of cases, followed by rosaceous fruits (apricots, cherries, strawberries, raspberries, hazelnuts, peaches, pears, apples, plums) which account for 13% of allergy cases. Tree nuts and Umbelliferae (dill, carrots, celery, fennel, parsley, etc.) each represent 9.5% of cases.




Vegetables Similar to the section on fruits, the section on vegetables attempt to group some of the vegetables under a class and provides examples of vegetables within the class, and also separately lists tomato and yam. Vegetables in the Umbelliferae are a very large group with over 300 genera, and in the EU it is mandatory requirement to declare the presence of celery as an allergen. Yeast & Yeast Products Includes baker‟s yeast, brewer‟s yeast and yeast extracts.

Herbs Herbs are the leaves of aromatic plants used for flavouring foods. Include any herb or herb extracts. Spices Spices are obtained from the bark, buds, roots, fruits or seeds of plants. Some plants such as coriander can be classed as either a herb or spice, depending on what part of the plant is used. Chilli should be included here as a spice (even if not dried). For the purpose of the PIF, where the product is previously listed in this Section, such as celery with Umbelliferae in Vegetables or Mustard listed in „grains, seeds nuts and spices‟, then it should not also be listed under Spice. The substance should only be listed once, even though it could also be a spice.

3.6 ADDITIONAL LABELLING AND INFORMATION REQUIREMENTS






Every box must be marked with a YES or NO response as appropriate. Where a YES response is used, additional information must be inserted. Use of the term “Added” does not include the naturally occurring presence of the component in the food. For example, added sugar does not include sugar/s naturally present in the food.




To assist in filling out this section, some of the components have been defined to provide clarification. Answer „Yes‟ any of these components have been added to the product, or it the product is itself one of these substances. i.e., if the product is salt, answer „Yes‟ to added salt.

Added Fats & Oils The types of added fats and oils are separated into animal and vegetable origin. Fats and oils of animal origin will invalidate Vegan and vegetarian claims. If fats and oils are of vegetable origin, then if these include palm oil you are requested to advise if this is RSPO (Roundtable on Sustainable Palm Oil) certified. Hydrolysed Vegetable Protein Hydrolysed Vegetable Protein (HVP) is made by chemically degrading vegetable proteins (commonly from soy, maize or wheat sources) into smaller compounds and in the case of full hydrolysis to amino acids. The type of protein and degree of hydrolysis should be specified to assist with allergen inquiries. Intense Sweeteners Substances used to replace the sweetness normally provided by sugar, without contributing significantly to the energy content of the food. Common examples are aspartame (951) and saccharin (954). Intense sweeteners are usually in the additive number range of 950 – 968. Note that some food additives can have multiple functions and therefore it is important to review the additives within and outside this range for their function in the food.




Preservatives Substances used to prolong the shelf life of a food. Although food acids and antioxidants can have a preserving effect, include here only those additives that are classed in the preservative group. Common examples include potassium sorbate (202), sodium benzoate (211), sulphur dioxide (220) and sodium metabisulphite (223). Note that there is a separate section for antioxidants, and food acids can be listed at the end of the table under „other food/component‟ if required. Flavour Enhancers Substances added to enhance the existing taste and/or odour of a food, such as monosodium glutamate (621) and others usually in the additive number range of 620 – 641. Note that some food additives can have multiple functions and therefore it is important to review the additives within and outside this range for their function in the food.

Added Colours Colours add, enhance or restore colour to food. The additive number and type of colour should be specified to assist with product claims. Colours are broadly divided into three groups: natural, artificial and not defined. Use the „not defined‟ category if the ingredient is highly coloured and added to a food for the purpose of providing colour, and is a permitted food ingredient, but does not have Colours specified in Schedule 4 of Standard 1.3.1 may only be added to the maximum level specified in the standard.




Added Flavours Flavourings are substances used to impart taste and/or smell to food. Flavourings have a long history of safe use in a wide variety of foods, from confectionery and soft drinks to cereals, cakes and yoghurts. They are used in comparatively small amounts so that consumer exposure is relatively low. The International Organisation of the Flavour Industry (IOFI) has implemented several changes within the flavours industry to comply with Regulation (EC) N° 1334. This details labelling requirements for natural flavours and the reclassification of nature identical and artificial flavours as „flavouring substances‟. The definitions are taken from the current Codex Guidelines on the Use of Flavourings (CAC/GL 66-2008). Following advice provided by the Flavour and Fragrance Association of Australia and New Zealand (FFAANZ), PIF 5.0 requires information concerning flavours consistent with the IOFI changes and separates an overall designation of „flavouring‟ or „natural flavouring‟. The terms „artificial‟ or „nature identical‟ flavouring are not supported. The FFAANZ provides the following definitions: Natural flavouring substances (CAC/GL 66-2008 item 2.2.1.1) Flavouring substances obtained by physical processes that may result in unavoidable but unintentional changes in the chemical structure of the components of the flavouring (e.g. distillation and solvent extraction), or by enzymatic or microbiological processes, from material of plant or animal origin. Such material may be unprocessed, or processed for human consumption by traditional food-preparation processes (e.g. drying, torrefaction (roasting) and fermentation). This means substances that have been identified / detected in a natural material of animal or vegetable origin. Synthetic flavouring substances (CAC/GL 66-2008 item 2.2.1.2) Flavouring substances formed by chemical synthesis. Natural flavouring complexes (CAC/GL 66-2008 item 2.2.2) Preparations that contain flavouring substances obtained by physical processes that may result in unavoidable but unintentional changes in the chemical structure of the flavouring (e.g. distillation and solvent extraction), or by enzymatic or microbiological processes, from material of plant or animal origin. Such material may be unprocessed, or processed for human consumption by traditional food-preparation processes (e.g. drying, torrefaction (roasting) and fermentation). Natural flavouring complexes include the essential oil, essence, or extractive, protein hydrolysate, distillate, or any product of roasting, heating, or enzymolysis. A thermal process flavouring (IOFI Guideline chapter 14.3) Product prepared for its flavouring properties by heating raw materials that are foodstuffs or constituents of foodstuffs. This process is analogous to the traditional home cooking of ingredients of plant and animal origin. Smoke flavourings (CAC/GL 66-2008 item 2.2.3) Complex mixtures of components of smoke obtained by subjecting untreated wood to pyrolisys in a limited and controlled amount of air, dry distillation, or superheated steam, then subjecting the wood smoke to an aqueous extraction system or to distillation, condensation, and separation for collection of the aqueous phase. The major flavouring principles of smoke flavourings are carboxylic acids, compounds with carbonyl groups and phenolic compounds. Added Salt Any salt (sodium chloride) added to the product. This does not include salt that is naturally present in ingredients or in a product, EXCEPT if the product is salt in which case answer Yes.




Added Sugar This includes a broad range of hexose monosaccharides and disaccharides as defined in Standard 2.8.1, that is added to the product. This does not include sugar that is naturally present in ingredients or in a product, EXCEPT if the product is a sugar in which case answer Yes.

Note that sugar does NOT include sorbitol, mannitol, glycerol, xylitol, polydextrose, isomalt, maltitol, maltitol syrup, lactitol or malt and malt extracts.

3.7 ANIMAL SOURCE & QUARANTINE INFORMATION REQUIREMENTS

Ref:

Standards Australia AS SSA 5300 - Australian Fish Names Standard

FSC Standard 2.2.1 – Meat and Meat Products

FSC Standard 2.2.3 – Fish and Fish Products






The questions in this section provide information that may be of interest for quarantine purposes if the product or its ingredients are imported. In the case of honey, there are also State quarantine restrictions within Australia on the movement of honey into Western Australia. Animal & Animal Products This question has been separated out from meat products in order to cross check against vegetarian suitability.

Animal products include any animal derivatives. Key examples are animal (including poultry & seafood) flesh, organs, stock, fat or bone, gelatine, milk/dairy, eggs and honey and including the substances derived from these products. It is important that less obvious ingredients of animal origin are also considered, such as cochineal and shellac which are products derived from insects.

This section excludes yeast, plankton and other free living micro-organisms.

Meat & Meat Products meat means the whole or part of the carcass of any buffalo, camel, cattle, deer, goat, hare, pig, poultry, rabbit or sheep, slaughtered other than in a wild state, but does not include –

(a) the whole or part of the carcass of any other animal unless permitted for human consumption under a law of a State, Territory or New Zealand; or

(b) avian eggs, or foetuses or part of foetuses.

This question is designed to collect specific information on meat to address BSE and other similar requirements. This information may be of relevance with Halal enquiries, and will automatically disqualify vegan, ovo-vegan and ovo-lacto-vegan claims.

Meat products refer to the animals specified in the food standards code, which excludes poultry and seafood (which are covered separately in this section). Four commonly sourced domestic animals (beef, sheep, goat, pork) are nominated on the form, along with an „other‟ to specify any meat animal




not covered by these four options. Products include meat flesh, organs and meat extracts that may be derived from fat, skin, bones; but excludes milk and milk products.

If this question is answered Yes, then the Animal & Animal Products question must also be answered as Yes.

Bird & Bird Products This question is designed to provide information to assist quarantine risk assessment of imported products for bird flu and other biosecurity issues.

Selecting this option will invalidate claims for suitability of the product for vegans or lacto-vegetarians, but claims may still be permitted for ovo-lacto-vegetarians provided meat and seafood are not also selected elsewhere in Section 3.

Bird products include any derivative (eg meat, eggs, stock, fat, feather, bone etc) from birds (eg chicken, duck, quail, turkey, and others which may include goose, guinea fowl, spitchcock, emu). Four common types of poultry (chicken, quail, duck, turkey) are provided on the form to identify using a check box, otherwise please use the „other‟ checkbox and specify the type.

If this question is answered Yes, then the Animal & Animal Products question must also be answered as Yes, and Meat & Meat Products may need to be answered as Yes (depending on the type of product).




Fish & Fish Products This question is designed to provide information to assist with the correct identification and importation of fish products. This should be consistent with the allergen declaration in Section 3.3.

If this question is answered Yes, then the Animal & Animal Products question must also be answered as Yes. Selecting this option will invalidate claims for vegan, lacto-vegetarian, and ovo-lacto-vegetarians.

Honey & Honey Products This question is designed to provide information to assist with the movement of honey products to protect the industry from European Foul Brood disease and other economically important exotic bee diseases and mites that can adversely affect the bee and horticulture industries. This will include, bee propolis, bee pollen or royal jelly identified in Section 3.1

4. FOODS REQUIRING PRE-MARKET CLEARANCE

4.1 NOVEL FOODS

Reference:

FSC Standard 1.5.1 Novel Foods

novel food means a non-traditional food and the food requires an assessment of the public health and safety consideration. A non-traditional food means:

a) a food that does not have a history of human consumption in Australia or New Zealand; or b) a substance derived from a food, where that substance does not have a history of human

consumption in Australia or New Zealand other than as a component of that food; or c) any other substance, where that substance, or the source from which it is derived, does not

have a history of human consumption as a food in Australia or New Zealand.




Novel foods must not be used unless the food is listed in the table to clause 2 of Standard 1.5.1, and it is used in accordance with the conditions of use. This section introduces a question on the use of engineered nanoparticles on the basis that this is a developing area of technological innovation, and there are significant concerns raised by consumer advocacy organisations for information about whether nano-engineering is used in the food industry.

Complete the box to indicate if the product contains any novel foods. For a “Yes” response specify the novel food components and any specific conditions for use outlined in Standard 1.5.1.

4.2 QUARANTINE TREATMENTS

Reference: FSC Standard 1.5.3 Irradiation of Food

Irradiation means the processing of food by subjecting it to the action of ionising radiation, but does not include ionising radiation imparted to food by measuring or inspection instruments. Only foods included in the table to Standard 1.5.3 of the Code are permitted to be irradiated. The use of irradiation triggers the need for additional labelling requirements on foods.

Complete the boxes to indicate if any irradiation, sterilisation or chemical processes have been used on the food or its ingredients. All “Yes” responses trigger the need for additional information to be inserted. The use of certain processes or chemicals may also require additional labelling requirements on the finished product/s in which the material is used, therefore additional information regarding the ingredients or sterilants is required.

The use of Ethylene Oxide (ETO) for sterilisation treatment is now prohibited in Australia and New Zealand. ETO treatment may still be used in some overseas countries and therefore attention should focus on ensuring imported at risk ingredients have not been ETO treated. While the use of Ethylene Oxide in Australia and New Zealand is no longer permitted, this is not the case in all countries and therefore this question remains relevant.




4.3 FOOD PRODUCED USING GENE TECHNOLOGY

References: FSC Standard 1.5.2 Foods Produced Using Gene Technology User Guide on Food Produced Using Gene Technology Regulation (EC) No 1829/2003 of the European Parliament on genetically modified food and

feed1

Important definitions from Standard 1.5.2 are:

genetically modified food means food that is, or contains as an ingredient, including a processing aid, a food produced using gene technology which – (a) contains novel DNA and/or novel protein; or (b) has altered characteristics;

but does not include – (c) highly refined food, other than that with altered characteristics, where the effect of the

refining process is to remove novel DNA and/or novel protein; (d) a processing aid or food additive, except where novel DNA and/or novel protein from the

processing aid or food additive remains present in the food to which it has been added; (e) flavours present in the food in a concentration no more than 1g/kg; or (f) a food, ingredient, or processing aid in which genetically modified food is unintentionally

present in a quantity of no more than 10g/kg per ingredient.

a food produced using gene technology means a food which has been derived or developed from an organism which has been modified by gene technology.

gene technology means recombinant DNA techniques that alter the heritable genetic material of living cells or organisms.

altered characteristics means (a) the genetic modification has resulted in one or more significant composition or nutritional

parameters having values outside the normal range of values for existing counterpart food not produced using gene technology;

(b) the level of anti-nutritional factors or natural toxicants are significantly different in comparison to the existing counterpart food not produced using gene technology;

(c) the food produced using gene technology contains a new factor known to cause an allergic response in particular sections of the population;

(d) the intended use of the food produced using gene technology is different to the existing counterpart food not produced using gene technology; or

novel DNA and/or novel protein means DNA or a protein which, as a result of the use of gene technology, is different in chemical sequence or structure from DNA or protein present in counterpart food which has not been produced using gene technology.

GM Labelling Decision Tree: The following diagram describes the decision process used to determine if GM labelling is required or not, or if the ingredient is not permitted under the FSC.

1 http://eur-lex.europa.eu/LexUriServ/LexUriServ.do?uri=CELEX:32003R1829:EN:HTML




Question 4.3.1 This question is an absolute question inclusive of all ingredients, food additives, processing aids and elements of the product. Any genetically modified components that are exempt under the labelling requirements for genetically modified foods must not be excluded when responding to this question. If there are several GM ingredients present, and where they have different properties or characteristics then give preference to indicating the presence of novel DNA or novel protein, altered characteristics and any additional labelling requirements of any single GM ingredient.

If No, ensure that the rest of this question is completed, which confirms the basis on which the product is non-GM, then go to question 4.3.7. Questions 4.3.2 to 4.3.6 will are not relevant and will be invisible.

Is the food of itself, or does it contain an ingredient, including a processing aid, that is produced using gene technology?

Any GM substance present with altered characteristics?

Does the product contain any novel DNA or novel protein?

Is the product made with gene technology a processing aid or food additive?

GM labelling required

Yes

Yes No

Yes No

GM flavour used at 1g/kg or less ?

Listed in one of following: * Schedule to Std 1.5.2 * Std 1.3.3 - processing aids * Std 1.3.1 – food additives

What evidence that the product is NOT GM?

Additional labelling requirements?

Is GM cross contamination possible?

Verify GM NOT present?

Adventitious GM is 10 g/kg or less

NO GM Label required

Exemption not proven – GM labelling required

Yes No

Yes

No

No

Yes

Yes

Yes No

Yes

No

Yes

INGREDIENT NOT ALLOWED

GM LABELLING DECISION TREE

No

.

No

No

If there are several GM-derived ingredients, the questions should be read in the context that affirmative answers to questions concerning the presence of GM material from one GM ingredient take precedence over claims that GM material is not present in other ingredients.

Also, adventitious GM material may include a variety of different sources of GM ingredients. The presence of adventitious GM material at less than 10mg/kg should be read as the aggregate total amount of adventitious material and not the individual amounts of different types of adventitious GM material present in an ingredient.




If Yes, go to question 4.3.2.

Question 4.3.2 This question about whether the ingredient or additive or processing aid has altered characteristics as this may require special conditions or labelling requirements.

Question 4.3.3 This question provides a cross-check against other questions relating to labelling. In most cases ingredients which contain novel DNA or protein must be labelled, whereas there an exemption to labelling may apply if novel DNA or novel protein is not present.

The answer YES or No will determine which options are required to be answered in Question 4.3.4

Substrate used by micro-organisms in the synthesis of new products do not need to be declared provided there is no novel DNA and no novel protein from the feed stock which is present in the final synthesised product.

E.g if microbially fermented xanthine gum is derived from a GM-soy substrate and there is no novel DNA or novel protein present in the purified xanthine gum, then no declaration is required.

Question 4.3.4 This question provides further information on the nature of any genetically modified components or ingredients if the answer to 4.3.4 was yes; whereas it will also determine the basis on which novel DNA or novel protein is absent if the answer to 4.3.4 was No.

Standard 1.5.2 of the Code clearly identifies the labelling requirements and exemptions. This question asks for confirmation on whether labelling is required.




If exempt, the reason must be based on standard 1.5.2 and must be clearly documented in the space provided. (eg “non-GM”; “GM food additive where no novel DNA/protein in final product”; “flavour present in a concentration of less than 1g/kg)

Question 4.3.5 This question asks whether there are additional labelling requirements. This is intended to mean in addition to a declaration that it is a GM food or ingredient. This is likely if it has altered characteristics, or if there is a requirement stipulated in the table to the Standard 1.5.2.

Question 4.3.6 If the GM component which is present with novel DNA or novel protein and is listed in Standard 1.5.2, or if this is a processing aid which is permitted in Standard 1.3.3, then answer YES.

GM foods must be approved for sale. If the GM component in question 4.3.3 is a GM food, the specific type of approved GM food must be provided.

If the GM component is a processing aid, such as a GM derived enzyme, then it must be listed in Standard 1.3.3.

The table to clause 2 of standard 1.5.2 of the Code lists approved GM foods. Foods should be listed by the description in this table (eg “Food derived from glufosinate ammonium-tolerant corn line T25”).

If the answer to 4.3.6 was No, then is this a GM food additive permitted in Standard 1.3.1. If the answer to this is No, or if the GM food is not listed in the Table to Clause 2 of Standard 1.5.2 then it is not permitted to be used or sold in Australia or New Zealand

Questions 4.3.7 to 4.3.11 – GM cross contamination in foods and ingredients These require information about the potential that there could be inadvertent GM material present in the product and whether there has been verification and testing of product to determine if GM material is present to determine if exemptions to labelling may be appropriate.

Question 4.3.7 This question assesses the potential for cross contamination of a non-GM food item with GM material through transport as a bulk commodity.




Question 4.3.8 This question is designed to obtain information on whether the product may come into contact with any other foods containing GM proteins or DNA during manufacture and storage at the manufacturer‟s premises. It is not intended to cover the entire distribution cycle.

Question 4.3.9 Identity preservation (IP) systems can be used to control purity of ingredients though the entire supply chain, ensuring that non-GM crops and ingredients are not contaminated with GM material.

Do not tick Yes unless a formal, audited and recognised IP system is in place.

Question 4.3.10 If there is verifiable documentation to show that the materials you have used are not GM, particularly in relation to source and transport of material, then PCR testing may not be necessary. However, where the verifiable documentation is not available, or where there is the potential for unintentional GM material to be present, then PCR testing is recommended.

Question 4.3.11 It is permissible to have low levels of GM ingredients unintentionally present due to cross contamination without requiring to label the product as GM, provided the level of adventitious GM material is no more 10g/kg (equivalent to 1% by weight of the ingredient).

Question 4.3.12 The requirements of the FSC are limited to food or ingredients for human consumption and produced using gene technology which is mandatory information. Question 4.3.12 is concerned with whether animals have been fed using stock feed which uses a GMO as source material for production of food or feed and products for food and/or feed use which contain, consist of or are produced from a GMO, including nutritional supplements, additives, processing aids and flavours.

This is option information unless the products may be exported to the European Union where it is a mandatory requirement of Regulation (EC) No 1829/2003 of the European Parliament on genetically modified food and feed.

5. NUTRIENTS & CONSUMER INFORMATION CLAIMS

5.1 NUTRITION INFORMATION

References: Standard 1.1.1 Preliminary Provisions Standard 1.2.8 Nutrition Information User Guide Nutrition Information Labelling AFGC Style Guide for Daily Intake Guide

This section collects nutrition information on the material to enable the customer to appropriately label the product and/or products in which that the material is used as an ingredient.

For flavours or additives used in very small quantities, the nutrition information may or may not be significant depending on the application. It is up to the supplier to negotiate what information is acceptable to the customer.

Nutrition Data Questions in the section 5.1 will depend on answers provided earlier in the form at Question 2.3.1 and 2.3.2.




If the product is a liquid, or a liquid concentrate there will be preliminary questions in Section 5.1 concerning the specific gravity, and relevant dilution rates. Similarly if the products is dehydrated and is required to be reconstituted, there are preliminary questions about how the product is reconstituted, or if the product is suspended in liquid and required to be drained.

Question 5.1.1 For products that are raw material chemicals, or food additives or processing aids, there is no recommended serve as these are not finished goods for retail sale. Without a serve size, there can be no %DI or average quantity per serve column in the nutrition information table, and only the average quantity of the nutrient per 100 units (gram or ml).

Question 5.1.1 requires the serve size to be specified, but only if the product is, or may be, a “retail-ready finished product”, in which case the nutrition inform will display average quantity per 100 units, and the % Daily Intake per serve, as well as the average quantity per server. Otherwise, if the food is an ingredient for further processing or a raw material then the table will only display the average quantity per 100 units as there is no relevant serve size.

In determining the appropriate serve size for the product, the guiding serve size principles are:

Single serve items should be appropriate sizes for the target market.

The serving portion should be realistic (at both the lower and upper levels).

If a product is packed such that it can be reasonably expected to be consumed by the target consumer in one serving then the pack should be the ‗serving size„, and the energy and nutrient content of the whole pack should be clearly indicated.

Multiple serve items should consist of appropriate serving sizes in relation to single serve packs.

Serving sizes must not be used inappropriately to manipulate energy or nutrient content per serving.




Question 5.1.2 Check the relevant box to indicate if the information in the table if provided based on per 100g weight or 100mL volume.

Nutrient Information Table Certain text is specified which may be used. In the case of gluten, the text “not detected” may be used and means that gluten is below the limit of detection of the method of analysis. In all other cases, the value used should be stated as “less than” the limit of quantification of the method. The text should be in lowercase and not in capitals to ensure it fits in the field. For example, transfat would be reported as “less than 0.01” rather than not detected.

The text “less than” is prescribed in the food standards code, and the symbol “<” is not permitted.

Where a value is unknown for mandatory field, the text “unavailable” must be inserted. It is not permitted to leave a mandatory field blank.

Raw material chemicals, food additives or processing aids For products such as sodium metabisulphite, sodium citrate, potassium nitrate etc, which are permitted food additives, enter "unavailable" for nutrition data fields that are not relevant. The sodium value may still need to be considered. The %Ash and % Moisture figures are not relevant.

Raw materials nutritional information: Where analytical values are not possible then please provide "typical" values provided for energy, protein, total fat, carbohydrate, sugars, sodium, ash and moisture as a minimum. Please reference the source used for the typical values in 4.1.4.

Questions in the section 5.1 will depend on answers provided earlier in the form at Question 2.3.1 and 2.3.2. If the product is liquid or a liquid concentrate then there will be questions as to the specific gravity, and the temperature at which the specific gravity is measured. If the product is a liquid




concentrate, of if it is a dehydrated solid, then there will be questions concerning reconstitution. If the product requires to be drained before use, the

Where the information is inserted per 100mL, the specific gravity must also be included.

Complete the table by inserting the quantity of each nutrient listed. The cells requesting information on energy, protein, total fat, saturated fat, trans fat, polyunsaturated fat, monounsaturated fat, cholesterol, carbohydrate, sugars, dietary fibre, sodium and potassium are bolded, which indicates they are mandatory and must be completed.

Note that the nutrients in blue highlight with bold yellow correspond to the minimum mandatory requirements for the nutrition information table outlined in Clause 5 (1) of Standard 1.2.8. These also correspond to the recommendation for the front of pack daily intake guide (DIG). These values are requested to enable companies calculate the nutrient information in the final food and determine if the product is eligible to make nutrient claims. Where information is not available, then enter the statement “not available”. Do not leave the cell blank or insert a “0” value where information is not known.

Any vitamin, mineral or biologically active substance can be inserted into the cells at the bottom of the nutrition information table. For example, omega 3 fatty acids can be listed as here.

Ensure that all data is entered in accordance with the units of measurement specified.

Specific nutrient values are preferred but tight value ranges may be accepted via discussion and agreement with by the customer. For example 50mg or 50-55mg is acceptable, however broad range figures such as 100+ or <100mg are unacceptable. These are of little assistance in being able to use this information to perform additional calculations.

Nutrient Table Formats and Calculations:

Please refer to the requirements of the AFGC DIG style guide and also the Food Standards Code.

The units of measure are automatically set as per the requirements of the FSC.

The DIG requirements only allow one decimal place when the %value is less than 1 or if the value is less than 0.1% then it will be reported as ~0%.

For gluten, the alternative text "not detected" may be used, consistent with the reporting requirement in the Food Standards Code.

The FSC requires the use of the text 'less than' rather than the symbol < and only permits values up to three significant figures. The table calculation for average quantity per serve will therefore round values to three significant figures or if the value is less than 0.001 the value will be returned as 0.

Where the average energy content of a serving or unit quantity of the food is less than 40 kJ, that average energy content may be expressed in the panel as „less than 40 kJ‟.

Where the average quantity of protein, fat, classes of fatty acids, carbohydrate, sugars or dietary fibre in a serving or unit quantity of the food is less than 1 gram, that average quantity may be expressed in the panel as „less than 1 g‟.

The calculation used to determine if the total fat level is reasonably close to the sum of the levels in the fat components allows for a small discrepancy when a stated value of „less than‟ is used. Whereas if actual numerical values are used then the sum of the components must fall within 0.02g of the stated total value.

Where the average quantity of sodium or potassium in a serving of the food, or unit quantity of the food is less than 5 milligrams, that average quantity may be expressed in the panel as „less than 5 mg‟




To the right of the table there will appear limited additional hints. One of these is advice to “Confirm fat subgroup levels correct”. This is based on the aggregate values of fatty acids components compared to the stated total fat content. For the purpose of error checking, the program will assume that 'Less than' values are equivalent to nil (zero) level, although for the purpose of the %DI and NIP the value is stated as < (less than) the value.

Question 5.1.3 There are three check boxes to select the appropriate reference values for vitamins and minerals the product is intended to be supplied to. The pick-list provides a list of vitamins or minerals that may be referenced, subject to the requirements of Standard 1.3.2, and selecting the vitamin or mineral will also select the appropriate units of measure and reference values against which the percentage of the RDI per serve will be automatically calculated for retail-ready finished product.

A claim to the effect that a food is a good source of a vitamin or mineral may be made if a reference quantity of the food contains no less than 25% of the RDI or Estimated Safe and Adequate Daily Dietary Intake (ESADDI) for that vitamin or mineral.

The vitamin “folate@women” is specifically for the use of folate/folic acid when the target population is women of child-bearing age. This RDI differs to other adult values as it is established for women in order to reduce the risk of neural tube disease. It is a mandatory requirement to fortify bread making with folic acid.

Question 5.1.4 Estimation of content is a calculation based on the addition of the quantity of protein, fat, carbohydrate, dietary fibre, ash and moisture to give an estimate of quantity. This may be useful as a guide for foods and derivatives of foods that consist of a mixture of proteins, fats, carbohydrates, fibre and moisture, in which case the calculated value made be reasonably close to „100‟..

Estimate of content calculation is not suitable for ingredients such as vitamin premixes, or additives and processing aids, as the number calculated is unlikely to be very close to 100.

Where values in the NIP are stated as either unavailable or not detected, the calculation will assume these to be a zero value and may underestimate the calculation. Where the value is stated as a less than value, the calculation will be based on the value and may over-estimate the calculation.




Question 5.1.5 Standard 1.2.8 provides that carbohydrate values can be determined by:

(a) „carbohydrate by difference‟, calculated by subtracting from 100, the average quantity expressed as a percentage of water, protein, fat, dietary fibre, ash, alcohol, and if quantified or added to the food, any other unavailable carbohydrate and the substances listed in column 1 of Table 2 to subclause 2(2); or

(b) „available carbohydrate‟, calculated by summing the average quantity of total available sugars and starch, and if quantified or added to the food, any available oligosaccharides, glycogen and maltodextrins.

This question requires that the method used to determine the carbohydrate content is specified is using either of these two methods, or if by another method then to specify what this is.

Question 5.1.6 „Average quantity‟ is determined in accordance with the definition set out in clause 2 of Standard 1.1.1:

(a) the manufacturer‟s analysis of the food; or (b) calculation from the actual or average quantity of nutrients in the ingredients used; or (c) calculation from generally accepted data (or nutrition tables);

which best represents the quantity of the substance that the food contains, allowing for seasonal variability and other known factors that could cause actual values to vary. This questions requires the source of the information for the nutrients to be declared as the basis on which to determine the reliability, accuracy and validation of nutrient values and claims.

5.2 CONSUMER INFORMATION CLAIMS

Information on the dietary suitability is required for consumer and export market purposes.

Note that the definitions below have been provided as a guide to the food industry in order to ensure consistency in the information collected. Individuals may vary in their own choice or preference in regards to each of these areas.




Halal Suitable The term Halal refers to the type of food that is permitted for consumption by people of the Islam faith. Halal Foods must be certified, however information on whether the product would be suitable for Halal certification is also useful.

When Halal certified a copy of the current valid certificate must be attached. Copies of renewed certificates are to be supplied to the customer as they become available over time. For more information, see http://www.afic.com.au/Halal.htm

Kosher Suitable Kosher foods are selected and prepared to meet traditional Jewish ritual and dietary laws. Kosher foods must be certified, however information on whether the product would be suitable for Kosher certification is also useful. When Kosher certified a copy of the current valid certificate must be attached. Copies of renewed certificates are to be supplied to the customer as they become available over time. For more information, see http://www.kosher.org.au/

Vegetarian suitable: a food or ingredient product contains no meat, poultry or seafood ingredients, but can include milk and milk products (excluding cheeses made with rennet), honey and egg. There are two terms identified in the PIF:

Ovo-Lacto-Vegetarian: food that does NOT include beef, lamb, pork, poultry, fish, shellfish or animal flesh of any kind, but may contain milk and milk products and egg products, EXCLUDING cheeses made with rennet.

Lacto-Vegetarian i food that does NOT include beef, lamb, pork, poultry, fish, shellfish or animal flesh of any kind, may contain milk and milk products, but NOT cheeses made with rennet.

http://www.afic.com.au/Halal.htm

http://www.kosher.org.au/




Vegan suitable: a food or ingredient product that does not originate from animals and does not contain any animal products or by-products such as meat, fish, eggs, dairy, animal fats, gelatine, honey, cochineal, leather, wool and silk.

These claims are NOT suitable where certain cross contact allergens are present, such as meat/dairy.

"Free" claims: commonly used in reference to the absence of a substance such as gluten free, or free from artificial colours, fat-free, sugar-free etc. Care needs to be taken in meeting substantiation requirements and take into account the ACCC / NZ Trade Commission about detectable/trace levels of a substance in a product where there is a „free from‟ claim.

Sustainability claims: claims to be 'environmentally safe', renewable or sustainable.

e.g.. Sustainable Palm Oil, Forrest Alliance, Carbon neutral, etc.

Humane treatment claims: claims based on the use of humane treatment which may include the method of animal husbandry e.g., Free range or Barn Laid eggs, Dolphin safe, Fair Trade, etc.

Other claims: anything that doesn't fit above. For example, Low Glyceamic Index

Organic Organic foods are produced without the use of synthetic fertilisers/pesticides/herbicides or other chemicals, antibiotics or genetically modified organisms and with emphasis on sustainability and responsible land & environment management. Claims should be certified against Australian Standard 6000-2009 Organic and biodynamic products. When certified organic, a copy of the current valid certificate must be attached. Copies of renewed certificates are to be supplied to the customer as they become available over time.




6. DURABILITY, PACKAGING AND SUPPLY CHAIN

6.1 SHELF LIFE

References: FSC Standard 1.2.5 - Date Marking of Food User Guide Date Marking - July 2001 AFGC Guide for Date Marking - 2009

This section collects information on the shelf life of the product, temperature requirements to maintain shelf life, and the useability of the product once the packaging is opened.

Date marking is an indication by the manufacturer of the length of time that an ingredient or a food can be kept under specified storage condition before it starts to noticeably deteriorate, i.e. when it is in “best condition”. Date marking is also used to indicate when food will deteriorate to a point when it is unfit for consumption and may present a safety risk, and therefore should be discarded.

Standard 1.2.5 requires that packaged foods with a shelf life of less than two years must be labelled with either a „Use-by‟ or „best before‟ date. The „Use-by‟ date signifies the estimated maximum storage in accordance with any stated conditions, after which the intact package of food should be discarded due to health and safety concerns. The „best before‟ date is applied to foods that will not present a health and safety concern after that date, and is the maximum period within which the foods remains marketable and retains any specific qualities for which express or implied claims have been made.

While Standard 1.2.5 applies to packaged foods for retail sale, similar principles apply to ingredients used in further processing and the manufacture of foods.

No single factor can be relied on to determine shelf life, whether microbial, chemical or organoleptic. Shelf life determination requires an evaluation of all of these parameters, and cannot be determined by guess work or by copying the shelf life of a similar product from another source.

Product - once in use: shelf life and storage Secondary Storage of products is dependent on handling and storage post–opening and where relevant the manufacturer/supplier should provide appropriate advice on the storage conditions to achieve the intended in-use once opened shelf life. For products which do not have resealable package guarantees are not provided for expected shelf life as this is outside the manufacturer‟s control.




6.2 POTENTIAL HAZARDS

References: Occupational Health and Safety Regulations (as relevant) Environmental Protection Legislation (as relevant)

Dangerous goods are substances or articles that present an immediate hazard to people, property or the environment. They are often highly concentrated substances like acids or contain large amounts of embodied energy such as flammable liquids.

Some dangerous goods can react and burn violently, explode and/or emit toxic fumes and gasses if mixed together, spilt or involved in fire. For this reason they are labelled with a relevant dangerous goods diamond. The classes of dangerous goods are:

Class 2 Flammable gas

Class 2 non-flammable gases

Class 3 Flammable liquids

Class 3 Combustible liquid

Class 4 Flammable solids

Class 4 Combustible solids

Class 4 Dangerous when wet

Class 5.1 Oxidizing agent

Class 5.2 Organic peroxide

Class 6 Toxic

Class 8 Corrosive

Class 9 Miscellaneous dangerous goods While it is unlikely that a food ingredient will fall into some of these categories, the full list is provided for the sake of completeness rather than any expectation that there will be a need to declare a Class 6 Toxic ingredient.

Hazardous chemicals used in the workplace can cause immediate and/or long-term impacts on your health if not used safely. There are known carcinogenic or cancer causing substances that are listed as notifiable or prohibited and relevant regulators must be notified before use.

Any workplace that produces or uses a chemical must assess the risks of potential exposure to workers by the chemicals produced in the workplace. Potential hazards identified in the health effects review must be recorded by manufacturers and suppliers on the product labels and MSDS using prescribed risk phrases. The Material Safety Data Sheet and the product label are the primary sources of health hazard communication from the manufacturer/supplier to employees in the workplace.

Occupational health and safety legislation also contains provision on the storage and handling of dangerous goods in classes 2, 3, 4, 5, 6.1, 8 and 9. This legislation also covers combustible liquids known as C1 (eg diesel) and a group of chemicals which are too dangerous to be transported.

Occupation health and safety legislation has specific requirements governing the notification of the relevant agencies before undertaking any work involving notifiable quantities of dangerous goods.

The transport of dangerous goods by land is regulated by the relevant State or Territory department of environment or environmental protection legislation.




A Material Safety Data Sheet (MSDS) is designed to provide both workers and emergency personnel with the proper procedures for handling or working with a particular substance. MSDS's include information such as physical data (melting point, boiling point, flash point etc.), toxicity, health effects, first aid, reactivity, storage, disposal, protective equipment, and spill/leak procedures. These are of particular use if a spill or other accident occurs and are necessary in managing occupational health and safety responsibilities for employees.

There are large collections of MSDS available on the internet and from a variety of sources, such as government agencies, manufacturers, universities, international non-government organisations, etc.

Where the information is publicly available on the internet for the relevant hazardous substance then the internet website address should be provided for ease of access to the information. Otherwise, a an copy of the MSDS should be provided as an attachment with the PIF when provided to customers, either in electronic or printed format depending on how the PIF is provided to customers.

6.3 TRANSPORT

This section collects information on transport and packaging with four options provided:

Freight or tanker transport of unpackaged product

Bulk/wholesale package, not individually packaged

Packaged for catering/manufacturing supply

Packaged in retail-ready packs

Where the product is provided via freight or tanker transport as an unpackaged product, the remaining questions about trade measurement and traceability and packaging are not relevant and are blanked out.




6.4 TRADE MEASUREMENT

References: National Trade Measurement Regulations 2009

Under the national trade measurement legislation, manufacturers, packers and importers can choose either of two methods for determining the measurement of pre-packed articles with common measurements or „constant nominal content‟.

The first method is Net Quantity based on the Uniform Trade Measurement Legislation (UTML) where:

the average content in a sample of pre-packed articles of the same kind and measurement can‟t be less than the stated quantity marked on the packages

no pre-packed article can have a shortfall greater than 5% of the stated quantity the permissible average deficiency in a sample of 12 or more articles is nil (see exceptions

below) – an inspector will generally check 12 articles, but can choose a number of packages greater than 12 for this sampling process, depending on the circumstances

a small number of „desiccating‟ goods that lose moisture after packing are allowed a greater permissible maximum deficiency and an average deficiency after the day of packing to reflect this moisture loss.

The second system for determining the measurement of pre-packed goods with a constant nominal content is the Average Quantity System (AQS). This is an internationally agreed method that was adopted in Australia in July 2010 as part of the new national trade measurement system. Under the AQS, manufacturers, packers and importers must comply with three important rules:

the average net content in a sample from the production run of pre-packed articles can‟t be less than the stated quantity marked on the packages

allowance is made for a small number of articles to exceed a „tolerable deficiency‟, and none of the articles in the sample can have more than twice the prescribed tolerable deficiency.

In Australia, manufacturers using the Average Quantity System, are required to include on product labelling an 'e' mark in association with the statement value on finished or retail-ready goods. It need NOT be applied to goods that are not retail ready.

In New Zealand the requirement of use of the 'e' mark differs to that of Australia. Product imported from New Zealand does not require to be labelled with the 'e' mark provided country of origin states New Zealand.

Trade measurement may alternatively be specified in terms of trade as a quantity averaged across all commercial units supplied, and are not intended to be sold for retail sale. If average quantity is selected to indicate such arrangements, it is not be necessary to provide AQS statistical variance data.

6.5 TRACEABILITY

References: FSC Standard 1.2.5 - Date Marking of Food FSC Standard 1.2.2 - Food Identification Requirements

This section collects information on the type of information used to identify the product. It is a requirement of the Food Standards Code that retail ready product should have a lot or batch code, or where the product contains a date mark.




Type of Primary Code In general this may be date code, lot code, batch code, production code. Please specify what is the primary code type used for the purpose of traceability to assist in identifying specific stock in the event of having to undertake a product recall/withdrawal.

Method of Coding How has the code been applied to the package? Sticker, embossed, inject, stamped, etc?

Example of Coding Format There is no single specific requirement as to how the information can be provided, with a variety of industry formats for batch or lot codes and also a variety of formats for date codes. It is therefore necessary to provide an example of what the coding format means as an example. Insert an example of the coding format applied to the product for both the unit package and the shipper, if applicable. Such as:

Example of coding format: 09/11/2001 09:59 Coding Translation: Day:11; Month: September; Year: 2001; Hour: 09; Minute: 59

6.6 PRODUCT PACKAGING

References: Standard 1.4.3 Articles and Materials in contact with food http://www.packagingcovenant.org.au http://www.packaging.org.nz/packaging_stewardship/packaging_stewardship.php

This section collects information on the use of packaging and the design to protect consumers from malicious tampering, the type of material used and whether the company is a signatory to relevant industry packaging stewardship schemes in Australia or in New Zealand.

6.6.1 Tamper Evidence Insert a description of any tamper evidence or protection measures on the packaging that protect against product tampering. For example: induction seal, safety button cap, plastic fuji seal.

http://www.packagingcovenant.org.au/

http://www.packaging.org.nz/packaging_stewardship/packaging_stewardship.php




6.6.2 Migration of substance into food Certain types of components in some plastics are able to migrate out of the plastic packaging into foods. The Standard 1.4.3 sets out certain requirements. In addition, question 6.6.3 asks if engineered nanoparticles are used in the packaging materials.

6.6.4 Australian or NZ Packaging Covenant The Australian Packaging Covenant („Covenant‟) is an agreement between companies in the supply chain and all levels of government to reduce the environmental impacts of consumer packaging. While participation in the Covenant is voluntary, brand owners who choose not to become signatories or who fail to comply with the Covenant requirements will be regulated under the National Environmental Protection (Used Packaging Materials) Measure (NEPM) in each of the states and territories within which the company sells its products. The NEPM is enforced by the relevant regulatory authorities in each of the states and territories. For more information see http://www.packagingcovenant.org.au;

The New Zealand equivlant on packaging see NZ Packaging Product Stewardship Scheme (http://www.packaging.org.nz/packaging_stewardship/packaging_stewardship.php)

General description of pack: Insert a description of the packaging materials for both the unit and the shipper. For example: tin can, PET bottle, laminated polypropylene bag, glass jar, corrugated board carton.

Packaging material

Metals - includes all types of metals used in packaging such as aluminium, tin, steel

Packing materials - includes materials used to protect product within package from damage, such as styrofoam, shredded paper, etc.

Plastics - includes PET, PVC, LDPE, bioplastic, etc.

Plastic coding symbol number - the number designation for the type of plastic polymer (1 - 7) which is often found inside the mobius recycling symbol on plastic packaging.

http://www.packagingcovenant.org.au/

http://www.packaging.org.nz/packaging_stewardship/packaging_stewardship.php




Sealing Method Insert a description of the methods used to seal the product packaging, such as heat or vacuum seal.

Dimensions Enter the height, width and depth of the product unit, including appropriate units of measurement.

6.7 PALLET CONFIGURATION

This section collects information on the configuration of the pallet for transport.

Gross weight per pallet Enter the total weight of a pallet of product, includes product, packaging and pallet.

Stack height of loaded pallet Means the stack height of the pallet when loaded with the packaged product.

Pallet configuration Enter the number of shippers per layer and the number of layers on the pallet.

7. SPECIFICATIONS FOR COMPLIANCE

This section allows the supplier to include specific specification requirements in relation to the physical, organoleptic, chemical and microbiological specifications.

Certified laboratory testing The AFGC recommends that companies use laboratories that are certified for the test methods being employed and that the laboratory participates in regular proficiency testing to assess their performance in using the specified test method. In Australia, certification of laboratories is undertaken by NATA, Australia and laboratory reports should be issued carrying the official NATA certification stamp to demonstrate the laboratory is accredited for the method and results reported.

Test / Parameter Refers to a description of the test or parameter. Examples include viscosity, pH, salt, soluble solids, particle size, colour, appearance, yeasts & moulds.

Specification Refers to an acceptable result for the test / parameter, which usually consists of ranges of values or upper and lower limits. Ensure that the unit of measure (eg %, mg, cfu/g) is included here where appropriate.




Test Method Refer to AOAC methods and / or recognised Australian or International standards. Where a supplier quotes an internal test method a copy must be attached.

Readily Available for Inclusion on C of A This column is designed to provide the customer with information on what sort of data can readily be provided on a C of A. Customers will use this information to discuss and agree on specific C of A requirements with the supplier via their normal business processes.

Physical specification This is a mandatory field as it is relevant for every ingredient, additive, processing aid and finished product to at least have a basic description of the physical parameters of the product.

Microbiological specification Testing parameters for Microbial Specifications shall, as a minimum, include the relevant microbiological requirements specified in the ANZFSC, and must ensure goods are safe and suitable as defined within relevant state and territory food acts.

Microbiological testing for the presence of pathogens or indicator organisms should be consistent with the risks of contamination associated with the product, and the management of those risks through the use of a documented Hazard Analysis Critical Control Program (HACCP). Appropriate microbiological testing may be used to validate the effectiveness of the HACCP system.

Additional microbiological testing may also be provided to demonstrate the nature and substance of the product, or where appropriate in respect of product specification. For example, it may be appropriate to provide a yeast & mould count for fermented goods.

An example of how the table could be completed is provided below. This shows under the heading test/parameter the type of microbiological tests that might be required, the specifications for these tests in the product and the methods that are used by the analyst. If the Cof A or the C of C is available, this can be provided as a separate document or as an attachment to the PIF.




Chemical specification This section should be used to cover a variety of testing and compliance requirements for the Food Standards Code where appropriate. For example, pesticide residue screening may be required on certain ingredients of animal and vegetable origin, but not on ingredients that are mineral or chemical origin.

Chemical testing for purity and specificity of chemical or mineral substances may be undertaken where there are appropriate reference methods, and may be set out as requirements of the terms of trade rather than a requirement of the Food Standards Code.

Chemical testing may also be appropriate where nutrition content and health claims are made and verification of the claim depends on analytical testing.

8. COMMENTS / ADDITIONAL INFORMATION

This section is designed to capture any specific additional information requested by the customer. This information may be specific to the individual food or contained within the Standards outlined in Part 2 of the Code. This section can also be used by the supplier to insert and provide further comments on the product. If applicable, record the section of the form to which the information relates.




9. ATTACHING CERTIFICATES

It is possible to attach the certificates related to the particular PIF which may be more convenient for some companies and their customers than sending the certificates as a separate document. First you need to package all the certificates and documents into a single ZIP file for ease of attaching them to the Excel form. Create a new zip file and name it appropriately.

The certificates you might wish to include in the ZIP files as examples:

Allergen declaration

Certificate of Compliance

Food safety plan audit certificate (e.g. BRC, SQF2000, ISO, WQA etc)

Halal Certificate

Irradiation and GMO certificate

Kosher Certificate

Laboratory Analysis Report

MSDS data

Organic Certificate

Once you have created the ZIP file with the documents then you need to go open the relevant PIF excel form, scroll down to the bottom of the workpage were there are two tabs, and click on „Certificates and documents‟. The instructions on the workpage are to click on the „Insert‟ tab on your Excel form and then select „Object‟. This will then open a dialogue box in the form to enable you to select the ZIP file to be added.




Once you have located the ZIP file and clicked „Open‟ this will then be added to the workspage and will display as follows:

To view or extract the contents of the ZIP file, left mouse click on icon showing the ZIP file and then select „Package Object‟ and then „Activate Contents‟. This will allow you to extract the contents of the zip file.

A TIP ON ATTACHING FILES:

Always check the zip of the PDF or JPEG image to be inserted into the ZIP file and make sure that it is less than 1Mb in size. The total size of the ZIP file MUST be less than 5Mb in size as if the file is too big it may prevent the Excel file from being emailed.


REFERENCES



REFERENCES


10. USEFUL REFERENCES

1. Australian Consumer Law 2010 (Commonwealth) Australia (http://www.comlaw.gov.au/Details/C2011C00774 )

2. Fair Trading Act 1986 (New Zealand)

(http://www.legislation.govt.nz/act/public/1986/0121/latest/DLM96439.html )

3. Codex Alimentarius Official Standards

(http://www.codexalimentarius.net/web/standard_list.do?lang=en )

4. Australia New Zealand Food Standards Code

(http://www.foodstandards.gov.au/foodstandardscode/)

5. FSANZ User Guides

(http://www.foodstandards.gov.au/foodstandards/userguides/)

a) Overview of Food Labelling

b) Legibility Requirements for Food Labels

c) Information Requirements for Foods Exempt from Bearing a Label

d) Warning and Advisory Declarations

e) Ingredient Labelling

f) Date Marking

g) Nutrition Information Labelling

h) Percentage Labelling

i) Food Additives

j) Labelling Genetically Modified Foods

k) User Guide to representations about food

6. AFGC Food Industry Guide to Allergen Management and Labelling (2007)

(www.afgc.org.au )

7. AFGC VITAL (Voluntary Incidental Trace Allergen Labelling) system (http://www.allergenbureau.net/allergen-guide/vital/)

8. Frequently Asked Questions about the Materials Safety Data Sheet (http://www.ilpi.com/msds/faq/parta.html#whatis/)

9. Internet Resources for MSDS (http://www.ilpi.com/msds/index.html)

10. GS1 industry numbering and barcoding guidelines (http://www.gs1au.org/information_library/technical_fact_sheets.asp )

11. International Organization of the Flavour Industry (IOFI)

(http://www.iofi.org/ )

12. Flavour and Fragrance Association of Australia and New Zealand (FFAANZ)

(contact: [email protected] )

http://www.comlaw.gov.au/Details/C2011C00774

http://www.legislation.govt.nz/act/public/1986/0121/latest/DLM96439.html

http://www.codexalimentarius.net/web/standard_list.do?lang=en

http://www.foodstandards.gov.au/foodstandardscode/

http://www.foodstandards.gov.au/foodstandards/userguides/


http://www.allergenbureau.net/allergen-guide/vital/

http://www.ilpi.com/msds/index.html

http://www.gs1au.org/information_library/technical_fact_sheets.asp

http://www.iofi.org/



Level 2, Salvation Army House

2–4 Brisbane Avenue

Barton ACT 2600

Locked Bag 1

Kingston ACT 2604

T: (02) 6273 1466

F: (02) 6273 1477

[email protected]

www.afgc.org.au



Documents

Product Information Form - User Guide