STAY CoOL &
TIDY UP YOUR PACK

What do the new rules on Country of Origin Labelling mean and why is it worth brand managers using this opportunity to make their packaging work as hard as it can for them?

Here’s the basic background from Gwen Blake, Managing Director of Boxer & Co.

Recent years have seen several high-profile cases of overseas food being contaminated, such as the Hepatitis A outbreak that was linked to the consumption of imported frozen berries from China. On top of that, with some people keen to support Australian farmers, keep manufacturing jobs onshore or reduce their food miles, consumer interest in product origins has increased dramatically.

It was felt that the old guidelines didn’t do a good enough job of making it easy for consumers to know where their food came from, so the federal government has responded with a new set of rules.

Under the new system, Country of Origin Labelling (CoOL) requirements are part of Australian Consumer Law. Businesses have to change their food labels to comply with the new law before it becomes mandatory on July 1, 2018. Non-compliance with the correct labelling can result in a fine of up to $1.1 million per offence. The leading supermarkets have made a commitment to ensuring their suppliers adhere to the labels and will therefore withdraw from sale any products that don’t comply. These laws are intended to be taken seriously!

The reforms commenced on July 1, 2016, but businesses were given two years to change labels to the new format. Any products already in market are fine to sell until their best before date, but anything packaged after June 30, 2018, MUST comply with the new laws.

Some companies have already updated their packaging to the new standards, so consumers are starting to see and recognise the new labels in market.

So, what does this mean in practical terms?

A comprehensive guide can be found at www.business.gov.au/foodlabels

You can either use the label in the green and gold pantones PMS341 and PMS137 or the guidelines also state that it’s OK to use the logo in monochrome. Boxer & Co. has spoken with the Australian Competition and Consumer Commission but they were unable to confirm if their definition of ‘monochrome’ means just black or if we are able to use any single dark colour. We were advised to speak to a lawyer to interpret the guidelines. We think a single dark colour should be fine, but that’s just our interpretation!

So, regarding printing. If space is available on your existing packaging, a single black or dark colour plate change COULD get you over the line if you use the monochrome version.

However, given that the labelling needs to be at minimum legible size and most brands already have a hard time squeezing everything on their packaging, it’s most likely that complying with CoOL is going to involve moving a few elements around on your pack and will therefore impact on most of your print plates. If you’re going to the cost and trouble of doing this, it would also be a great time to consider a redesign or at least a tidy-up of your pack as the incremental cost is going to be really low versus doing it any other time.

One of Boxer & Co.’s clients, Brownes Dairy, is already doing exactly that:

“Space on our packaging is always limited, so adhering to the new CoOL guidelines has meant a bit of a re-shuffle and re-prioritisation of information. Knowing we had to do that anyway, we’ve made the most of the opportunity by addressing a few other design elements, so that all of our packs are fully up to date and work as hard as they can for us.”
Nicole Ohm, Marketing Manager, Brownes Dairy

So, before you simply add the CoOL to your packaging, ask yourself if you can make a few small tweaks to your packaging design to maximise sales:

• What new trends have come to light since I last redesigned my packaging that might affect the way people shop my category?
• What claims could be updated on my pack in line with current health concerns and diets?
• Does the hierarchy of information on my packaging work as hard as it possibly can for me?
• Can my back of pack be more engaging and encourage cross-sells?
• Whose budget does CoOL come from and can I piggy-back some design changes onto that with less impact on my own budget?