What FSANZ Rules Require for Flavour Labelling and Natural Claims

The Australia New Zealand Food Standards Code defines "flavouring substance" in Standard 1.1.2, s 1.1.2—10, as "a substance that is used as a food additive to perform the technological purpose of a flavouring in accordance with this Code", and it does not define "natural flavour" or "natural flavouring" anywhere. The flavouring itself is declared on your label under Standard 1.2.4, s 1.2.4—7(4), which allows "the word 'flavouring' or 'flavour'; or (b) a more specific name or description of the flavouring substance". Because the Code is silent on the word "natural", that claim is governed instead by the Australian Consumer Law, which at s 18(1) provides that "A person must not, in trade or commerce, engage in conduct that is misleading or deceptive or is likely to mislead or deceive."

The Permission Chain, Clause by Clause

Permission for a flavouring is a chain of four instruments, and it begins with a definition rather than an approved-products list. Standard 1.1.2, s 1.1.2—10 defines a permitted flavouring substance to include "a substance that is listed in at least one of the following publications: (i) Generally Recognised as Safe (GRAS) lists of flavouring substances published by the Flavour and Extract Manufacturers' Association of the United States from 1960 to 2024 (edition 31);". The same paragraph names the other three lists: "(ii) Chemically-defined flavouring substances, Council of Europe, November 2000; (iii) Annex I of Council Regulation (EU) No 872/2012 of 1 October 2012 adopting the list of flavouring substances [2012] OJ L267/1; (iv) 21 CFR § 172.515;". Those four are the whole list. A JECFA reference on a supplier specification is not one of them, so it does not by itself establish an Australian permission.

The Two Origin Limbs Inside the Definition

The definition has two further limbs that describe, without ever naming them, what other markets call natural and nature identical. Standard 1.1.2, s 1.1.2—10 continues: "(b) a *flavouring substance obtained by physical, microbiological, enzymatic or chemical processes from material of vegetable or animal origin either in its raw state or after processing by traditional preparation process including drying, roasting and fermentation; (c) a flavouring substance that is obtained by synthetic means and which is identical to one of the substances described in paragraph (b)." The asterisk in the Code's own text marks a defined term. Read the limbs for what they are: alternative routes into a permission, not a compositional standard a label claim can be built on.

Schedule 16, Schedule 15 and the Meaning of GMP

From there the chain closes quickly. Schedule 16, s S16—2 lists as an additive permitted at GMP "*Permitted flavouring substances, excluding quinine and caffeine", and Standard 1.1.2, s 1.1.2—11(3) states that "additive permitted at GMP means a substance that is listed in section S16—2." Standard 1.3.1, s 1.3.1—3(1) then supplies the gate every additive passes: "A substance may be *used as a food additive in relation to food if: (a) the substance is permitted to be used as a food additive for that food by Schedule 15; and (b) any restrictions on the use of that substance as a food additive set out in this Standard or in Schedule 15 are complied with;". GMP is a ceiling, not an absence of one. Schedule 15, s S15—4(1)(b) defines it: "a reference to 'GMP' is a reference to the maximum level necessary to achieve 1 or more technological purposes under conditions of GMP."

Quinine, Caffeine and the Toxicant Ceilings

Two named substances sit outside the flavouring permission, and a short list of natural toxicants is capped whatever the flavouring is called. Quinine and caffeine are excluded from s S16—2 by name, and caffeine carries its own declaration rule under s 1.2.4—7(6) whenever it is added, whether as a flavouring substance or otherwise. Standard 1.4.1, s 1.4.1—3(1) provides that "The level of a contaminant or natural toxicant listed in section S19—4, S19—5 or S19—6 in a food listed in relation to that contaminant or toxicant must not be greater than the corresponding amount listed in that Schedule." The Schedule 19 table sets, among others, coumarin at 10 mg/kg in alcoholic beverages, safrole at 15 mg/kg in food containing mace and nutmeg, 10 mg/kg in meat products and 5 mg/kg in alcoholic beverages, and thujones at 25 mg/kg in sage flavoured foods. Schedule 24 names the source species behind those limits, including common wormwood, cinchona, European pennyroyal oil, St John's wort and American sassafras oil, which is where to look first when a brief calls for a botanical extract.

How the Flavouring Is Declared

The declaration rule itself is short and it offers only the forms set out in s 1.2.4—7(4). What the Code then removes is the need to open the flavouring up: s 1.2.4—3(2)(a) provides that "A statement of ingredients need not list: (a) an ingredient of a *flavouring substance". That exemption has named carve-outs. Section 1.2.4—7(5) requires nine substances to be specifically declared when they are added as a flavouring substance or as an ingredient of one: L-glutamic acid, monosodium glutamate, monopotassium L-glutamate, calcium di-L-glutamate, monoammonium L-glutamate, magnesium di-L-glutamate, disodium guanylate, disodium inosinate and disodium-5′-ribonucleotides. Caffeine is the tenth, under s 1.2.4—7(6). Telling a customer that everything declares as flavour is wrong the moment a system carries any of them.

Flavour and the Percentage Declaration

A flavouring also does not drag a percentage declaration onto your label, but a named or pictured ingredient does. The Note to s 1.2.10—2 reproduces s 1.1.2—4(2): "Despite subsection (1), any of the following is not a characterising ingredient: (a) an ingredient or category of ingredients that is used in small amounts to flavour the food;". A characterising ingredient is one mentioned in the name of the food, usually associated with that name by a consumer, or emphasised on the label in words, pictures or graphics, and its proportion must be declared under s 1.2.10—3(1). So the flavour is exempt while the strawberry on the front of the pack is not.

Allergens Reach Inside the Flavouring

Allergen labelling reaches inside the flavouring, and this is the line that never moves. Standard 1.2.3, s 1.2.3—4(5) makes the obligation bite however the allergenic food arrives, including where it is "(b) a substance *used as a food additive, or an ingredient or component of such a substance; or (c) a substance *used as a processing aid, or an ingredient or component of such a substance." A flavouring is a substance used as a food additive, so its allergenic components are declared even though its other ingredients need not be. The form is Plain English Allergen Labelling: the required name in bold in the statement of ingredients, plus a summary statement which under s 1.2.3—7(3) "must: (a) commence with the word 'Contains' and then list the *required name of each food to be declared; and (b) contain no other words." The transition is finished, not pending. Standard 1.2.3's transitional table records that "The transition period is the period of time that commences on 25 February 2021 and ends on 25 February 2024. The post-transition period is the period of time that commences 26 February 2024 and ends on 26 February 2026." Both windows have closed, so PEAL form is the only compliant form.

Where the Word Natural Is Actually Governed

None of the above touches the word natural, because the Code never uses it of a flavouring. The constraint is the Australian Consumer Law. Section 18(1) prohibits misleading or deceptive conduct, and s 29(1)(a) separately prohibits a person from making "a false or misleading representation that goods are of a particular standard, quality, value, grade, composition, style or model or have had a particular history or particular previous use", which is the limb a composition claim such as natural falls under. Unlike s 18, s 29 carries pecuniary penalties. The ACCC's stated expectation of the word, from its 2006 food and beverage media release, is that "The ACCC believes that consumers would have a reasonable expectation that a food describing itself to be natural or pure should not contain food additives or artificial preservatives." In the accompanying presentation the ACCC classed "Natural" among "Standard/style/select claims", which it defined as "those claims implying a relationship with a particular standard, style or product selection", listing "'Pure', 'Fresh', 'Natural', 'Trim/Lean', 'Original', 'Genuine', 'True', 'Real'". Its puffery examples were different words entirely, so natural is not treated as puffery. On the neighbouring undefined term of organic the ACCC states the transferable principle plainly: "All organic claims, whether they reference a standard or not, should be able to be proved".

Country of Origin for a Bulk Flavour

Country of origin is the other panel buyers raise, and for a bulk flavour the answer is narrower than most expect. The Country of Origin Food Labelling Information Standard 2016, s 14(1), applies its labelling Part only where "(a) the sale is a retail sale; or (b) the sale is not a retail sale, but the food is sold as suitable for retail sale without any further processing, packaging or labelling." A flavour sold in bulk to a manufacturer for further processing sits outside that Part, so the standard mark and its bar chart are not required on the drum. The claim itself is still governed by the Australian Consumer Law. Section 255(2) sets the substantial transformation test, under which goods were substantially transformed in a country if "as a result of one or more processes undertaken in that country, the goods are fundamentally different in identity, nature or essential character from all of their ingredients or components that were imported into that country", and the ACCC's guide adds that "the source of a product's individual ingredients or components is not relevant to a 'made in' claim." The ACCC also warns that the bar is real, because "The ACL does not define what 'identity', 'nature' or 'essential character' mean." Where the Information Standard does apply, the kangaroo logo is reserved for fully Australian product: "If all of the food in a display or package was grown, produced or made in Australia, the mark will also include a kangaroo logo."

What Changes in New Zealand

New Zealand is inside the same Code but not the same whole of it. Standard 1.1.1, s 1.1.1—3(1) provides that "Unless this Code provides otherwise, this Code applies to food that is: (a) sold, processed or handled for sale in Australia or New Zealand; or (b) imported into Australia or New Zealand." Note 1 to that section then lists provisions not incorporated into New Zealand law under the Food Act 2014, including "(viii) Chapter 3 (food safety standards)". Standard 3.2.2 therefore does not govern a New Zealand buyer, whose food safety obligations run through the Food Act 2014 and its risk-based measures instead. The flavouring permission in s S16—2 and the declaration rule in s 1.2.4—7(4) do apply identically on both sides of the Tasman.

The Documentation Pack, Tied to Clauses

That leaves a documentation pack, and each item in it maps to a clause rather than to a preference. A full specification naming every flavouring component, because you build your own statement of ingredients from it and have to break out the s 1.2.4—7(5) substances and s 1.2.4—7(6) caffeine. An allergen statement covering carriers and processing aids, because s 1.2.3—4(5) reaches them and the label is yours, not the flavour house's. A written confirmation that each component is a permitted flavouring substance, naming which of the four publications it appears on, and addressing the quinine and caffeine exclusion explicitly. A certificate of analysis for the Schedule 19 toxicants relevant to the botanicals used, because it is your finished food that must comply. For an Australian supplier, Standard 3.2.2 already requires the rest: cl 5(2) obliges a food business to produce on request "the name and business address in Australia of the vendor, manufacturer or packer", cl 12 requires a wholesale supplier, manufacturer or importer to "have in place a system to ensure the recall of unsafe food" and to "set out this system in a written document", and cl 3(1) requires that food handlers have "skills in food safety and food hygiene matters". Ask for the written recall procedure and the last mock recall record; a supplier already holds both.

How VKA Australia Handles Claim Targets

VKA® Australia formulates from Southport, Queensland, with claim targets in the brief from day one: tell us the markets the product sells into and the words you want on the pack, natural included, and the flavour is built to support them rather than audited against them afterwards. Browse what we supply and how custom development works, or talk to a flavourist directly about a labelling question you are carrying right now. Every clause cited above, with the Schedule 15, Schedule 19 and Schedule 24 tables in full and a retrieval date against each source, is set out in our clause-by-clause reference to the Australian flavour regulations.