SIAA POLICY on Extending Country of Origin Labelling (CoOL) to Foodservice


  1. SIAA supports the conclusions reached by the Review of Food Labelling Law and Policy (20091); the Productivity Commission (2016)2, the Dept. of Industry, Innovation and Science (2017)3 and the Australia and New Zealand Ministerial Forum on Food Regulation (2018)4 - all of which, based on independent inquiry and research, did NOT support the extension of seafood CoOL to the foodservices sector.


  1. SIAA notes that foodservice outlets are already required, under consumer law, to provide country of origin information on request.


  1. SIAA supports and encourages voluntary CoOL where business owners determine that they can provide sufficient information on labels to allow consumers to make properly informed choices.


  1. Conversely, SIAA does not support a system that relies on one or two words (origin) on a menu to define a product; and which can mislead consumers by omitting valuable provenance and abetting popular misconceptions.


  1. SIAA notes that country of origin should not be used as a surrogate indicator of food safety5, as this is comprehensively covered by dedicated systems approved and robustly enforced by mandatory physical inspection and laboratory testing by the Australian Government (over 24,000 inspections annually) at our border.


  1. SIAA notes that country of origin is not a reliable indicator of sustainability, worker welfare or other social issues, as these are complex issues that can vary within supplier nations and are best indicated by specific certifications.


  1. SIAA recognises the complexity and cost to Australian businesses, and thus to consumers, of providing origin information at point of sale - estimated by Restaurant & Catering Australia6 at over $300 million annually.


  1. SIAA recognises that almost 30,000 people are employed in the sale of seafood of various origins thru foodservice outlets, and seeks to protect those Australian jobs.


  1. SIAA questions the usefulness of country of origin to provenance, given that Australian products are frequently processed and packed overseas and re-imported as Product of that country; and that many Australian producers rely on, and significantly benefit, from this.


  1. SIAA recommends product branding and certifications as more reliable indicators of provenance than CoOL, to assist consumers.






1) Review of Food Labelling Law and Policy - Australia and New Zealand Food Regulation Ministerial Council 2009.

6.38 …. Some submissions (especially from the seafood industry-186) go further in suggesting that CoOL be extended to foods sold in restaurants. While arguments were presented in the case of seafood,

this would constitute an exception to the general exemption of restaurants from mandatory labelling requirements and the Panel does not accept the arguments as sufficient to justify modifying the exemption.



2) Productivity Commission  

Some industry participants asked that the Commission recommend that mandatory country-of-original labelling be extended to seafood sold for immediate consumption. This is unnecessary for public policy (food safety and consumer protection) reasons, which are adequately dealt with under existing law.


3) Seafood Origin Information Working Group - Department of Industry, Innovation and Science (2017). 

No final report has been published but the chair indicated to the working group that the department’s research did not warrant extension of the current legislation.


4) Australia and New Zealand Ministerial Forum on Food Regulation (2018) Seafood Labelling

Australian Forum Ministers considered advice prepared by the Food Regulation Standing Committee concerning seafood labelling in the food service sector.

The Forum was advised of the current Australian provisions that enable consumers to request country of origin information for seafood directly from the foodservice business and that based on extensive consumer research, there is insufficient evidence to warrant extension of the current Australian Country of Origin Labelling legislation to seafood in the foodservices sector.


5) Labelling Logic - Review of Food Labelling Law and Policy (2011)

6.36 It is clear from the submissions that CoOL is used by some people as a surrogate for health information; however the Panel accepts that prescriptive requirements for CoOL cannot be sustained on public health grounds. Australia has a robust quarantine inspection regime with a rigorous monitoring system administered by AQIS, whose protocols for inspection assure the safety of imported foods. Indeed, a 2003 Communiqué of the Ministerial Council states that in relation to the ‘policy direction on mandatory country of origin labelling of food, Ministers emphasised that this is not a public health and safety issue, as the safety of the food supply is assured through other means’.185


6) Restaurant & Catering Australia – ‘Extending Mandatory Country of Origin Labelling to the Foodservice Sector’ (2017)

The introduction of mandatory CoOL is reminiscent of component pricing legislation that was introduced in 2009. The legislation, which required a single price to be displayed for goods and services, resulted in cafes, restaurants, and bistro operators having to print separate menus when displaying weekend and public holiday surcharges.

Work completed by Restaurant & Catering Australia (R&CA) revealed the cost of such measure ranged from $8,000-$10,000 per business. Not only was there an administrative cost to operators, it also led to considerable confusion among consumers when two prices were displayed on the menu (surcharge and non-surcharge rates).

As a result, cafes, restaurants, and bistros were exempted from the requirement in 2012.