Reference

Australian Flavour Regulations

A clause-by-clause reference

Instruments retrieved 12 September 2026, each Code instrument as the authorised compilation current on that date. Covers Australia and New Zealand, with the New Zealand carve-out in section 9.

The Australia New Zealand Food Standards Code does not define a natural flavour. It defines a flavouring substance and a permitted flavouring substance, permits flavourings through a single line in Schedule 16, and leaves the word natural to the Australian Consumer Law.

This page sets out each governing clause in turn: a plain-English sentence, the wording of the instrument itself, and the citation. Nothing here is paraphrased into a quotation, and nothing is stated that the named instrument does not say.

Section 01

Flavouring substance and permitted flavouring substance

The Code defines a flavouring substance purely by function, and defines a permitted flavouring substance by reference to four overseas lists plus two origin limbs.

flavouring substance means a substance that is used as a food additive to perform the technological purpose of a flavouring in accordance with this Code.

Standard 1.1.2, s 1.1.2—10

permitted flavouring substance means any of the following: (a) 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);

Standard 1.1.2, s 1.1.2—10, paragraph (a)(i)

(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;

Standard 1.1.2, s 1.1.2—10, paragraphs (a)(ii) to (a)(iv)

(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).

Standard 1.1.2, s 1.1.2—10, paragraphs (b) and (c)

Limbs (b) and (c) describe what other jurisdictions call natural and nature identical, without using either word. They are limbs of a permission concept, so quoting limb (b) as though it were a definition of natural flavouring invents a legal category the Code does not have. Note also that no JECFA list appears in paragraph (a): JECFA is the Codex route, not an Australian permission route.

Section 02

The Code does not define natural flavour

A case-insensitive search for the phrase natural flavour returns nothing in any of the fourteen Code instruments retrieved for this page, including the two that carry every general definition and every ingredient-declaration rule.

Subject to subsection (2), a term used in this Code that is also used in the *FSANZ Act has the same meaning as in the FSANZ Act, unless the contrary intention appears.

Standard 1.1.2, s 1.1.2—2(1)

That interpretation rule imports meanings only from the FSANZ Act or an application Act, and the definitions that do apply are the closed list in s 1.1.2—2(3). Because the Code is silent on the word, natural on an Australian food label takes its ordinary meaning and is policed by the Australian Consumer Law rather than by FSANZ. Section 7 below sets out the provisions that do the policing. Nature identical is absent on the same basis: the phrase appears nowhere in the Code.

Instrument	Subject
Standard 1.1.1	Structure of the Code and general provisions
Standard 1.1.2	Definitions used throughout the Code
Standard 1.2.3	Warning statements, advisory statements and declarations
Standard 1.2.4	Statement of ingredients
Standard 1.2.10	Characterising ingredients and components
Standard 1.3.1	Food additives
Standard 1.4.1	Contaminants and natural toxicants
Standard 3.2.2	Food safety practices and general requirements
Schedule 7	Food additive class names
Schedule 10	Generic names of ingredients
Schedule 15	Substances that may be used as food additives
Schedule 16	Types of substances that may be used as food additives
Schedule 19	Maximum levels of contaminants and natural toxicants
Schedule 24	Restricted plants and fungi

Instruments searched, all returning zero occurrences of the phrase natural flavour

Section 03

How flavourings are permitted

One line in Schedule 16 carries the entire flavouring permission for Australia and New Zealand, and it reaches the general additive gate in Standard 1.3.1 through the definition of an additive permitted at GMP.

*Permitted flavouring substances, excluding quinine and caffeine

Schedule 16, s S16—2

additive permitted at GMP means a substance that is listed in section S16—2.

Standard 1.1.2, s 1.1.2—11(3)

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;

Standard 1.3.1, s 1.3.1—3(1)(a) and (b)

a reference to 'GMP' is a reference to the maximum level necessary to achieve 1 or more technological purposes under conditions of GMP.

Schedule 15, s S15—4(1)(b)

The chain runs in one direction: a listing on one of the four publications in section 1, or an origin under limb (b) or (c), makes a substance a permitted flavouring substance; s S16—2 makes that an additive permitted at GMP, with quinine and caffeine excluded by name; and Schedule 15's food-class headings decide where an additive permitted at GMP may go. GMP is a ceiling, not a licence, so a listing on FEMA GRAS is the first of four tests rather than an Australian approval.

Section 04

Restricted substances

Three separate schedules constrain what may be inside a flavouring: Schedule 15 fixes what carriers and preservatives a flavouring preparation may contain, Schedule 19 caps the classic flavouring-derived toxicants in the finished food, and Schedule 24 names the source botanicals.

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.

Standard 1.4.1, s 1.4.1—3(1)

If a substance may be *used as a food additive under the table to section S15—5: (a) the substance may be added in the form of a preparation of the substance; and (b) other substances may be used as food additives in the preparation in accordance with the permissions under category 0 of the table (preparations of food additives).

Schedule 15, s S15—3

The Schedule 19 limits apply to the buyer's finished food, not to the flavouring in the drum, which is why a certificate of analysis covering the relevant toxicants has to be read against the dose rate rather than accepted on its own. Levels are in mg/kg unless the Schedule says otherwise.

Substance	Maximum level
Colourings permitted at GMP	GMP
Colourings permitted to a maximum level	as listed
Benzyl alcohol	500 (in the final food)
Ethanol	GMP
Ethyl acetate	GMP
Glycerol diacetate	GMP
Glyceryl monoacetate	GMP
Isopropyl alcohol	1 000 (in the final food)
Butylated hydroxyanisole (INS 320)	1 000
Triethyl citrate (INS 1505)	GMP

Schedule 15, table to s S15—5, category 0.3 Flavourings: what a flavouring preparation may contain

Substance	Food	Maximum level
Coumarin	Alcoholic beverages	10
Safrole	Food containing mace and nutmeg	15
Safrole	Meat products	10
Safrole	Alcoholic beverages	5
Thujones (alpha and beta)	Sage stuffing	250
Thujones (alpha and beta)	Bitters	35
Thujones (alpha and beta)	Sage flavoured foods	25
Thujones (alpha and beta)	Alcoholic beverages	10
Pulegone	Confectionery	350
Pulegone	Beverages	250
Quinine	Mixed alcoholic drinks n.e.c.	300
Quinine	Tonic, bitter and quinine drinks	100
Quinine	Wine based drinks and reduced alcohol wines	300

Schedule 19, table to s S19—6(1): maximum levels in mg/kg for the toxicants a flavouring most often carries

Species	Common name	Toxicant
Artemisia absinthium	Common wormwood	Thujone, santonin
Cinchona spp.	Cinchona	Quinine
Cinnamomum camphora	Camphor tree oil	Safrole, coumarin
Mentha pulegium oil	European pennyroyal oil	Pulegone
Hypericum perforatum	St John's wort	Hypericine
Sassafras albidum	American sassafras oil	Safrole

Schedule 24, table to s S24—2: restricted plants that carry those toxicants

Section 05

Declaration in the statement of ingredients

A flavouring is declared by the word flavouring or flavour, or by a more specific name, and its own ingredients need not be listed, with three named exceptions that always break out.

If a *flavouring substance is an ingredient, it must be listed in the statement of ingredients by using: (a) the word 'flavouring' or 'flavour'; or (b) a more specific name or description of the flavouring substance.

Standard 1.2.4, s 1.2.4—7(4)

A statement of ingredients need not list: (a) an ingredient of a *flavouring substance;

Standard 1.2.4, s 1.2.4—3(2)(a)

whether as a *flavouring substance or otherwise

Standard 1.2.4, s 1.2.4—7(6), on the declaration of added caffeine

The Code's own Note to s 1.2.4—3(2)(a) flags the carve-outs, and they sit in subsections 1.2.4—7(5) and (6). Section 1.2.4—7(5) requires nine substances to be declared specifically, by class name plus the Schedule 8 name or code, whenever 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. Section 1.2.4—7(6) does the same for caffeine. Two further points are worth stating because both are commonly got wrong: the authority for the word flavouring is s 1.2.4—7(4) itself and not a Schedule 10 generic name, because Schedule 10 has no flavouring entry at all; and the only flavour-adjacent class name in Schedule 7 is flavour enhancer, which is a different thing.

Section 06

Allergens

Allergen declaration reaches inside a flavouring, because the obligation bites however the allergenic food is present, and the Plain English Allergen Labelling form is now the only compliant form.

(a) an ingredient or as an ingredient of a *compound ingredient; or (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.

Standard 1.2.3, s 1.2.3—4(5)

A summary statement 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.

Standard 1.2.3, s 1.2.3—7(3)

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.

Standard 1.2.3, application, saving and transitional provisions table, Proposal P1044 Variation F2021L00145

A flavouring is a substance used as a food additive, so paragraph (b) of s 1.2.3—4(5) catches its allergenic components even though the rest of its ingredients need not be listed. Both Plain English Allergen Labelling windows closed on 26 February 2026, before the retrieval date of this page, so there is no transitional position left to rely on. The required name must appear in bold in the statement of ingredients under s 1.2.3—7(1), separately for each ingredient that is or contains the relevant food under s 1.2.3—7(2)(a).

Section 07

Natural claims under the Australian Consumer Law

Because the Code says nothing about the word, a natural claim is governed by the general misleading-conduct prohibition and by the specific prohibition on misrepresenting the composition of goods.

A person must not, in trade or commerce, engage in conduct that is misleading or deceptive or is likely to mislead or deceive.

Competition and Consumer Act 2010, Schedule 2 (Australian Consumer Law), s 18(1)

make 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

Australian Consumer Law, s 29(1)(a)

Standard/style/select claims are those claims implying a relationship with a particular standard, style or product selection. For example, claims such as: 'Pure', 'Fresh', 'Natural', 'Trim/Lean', 'Original', 'Genuine', 'True', 'Real'.

ACCC, Misleading claims and the Trade Practices Act, Commissioner John Martin, 23 November 2006, p 9

The classification matters: the same ACCC document treats Farmhouse, Country Style, Grandma's Recipe and World's Best as likely puffery, and does not put natural in that group. Unlike s 18, s 29 carries pecuniary penalties. On a neighbouring undefined term the ACCC's published position is that all organic claims, whether they reference a standard or not, should be able to be proved, and the same logic applies to a natural claim: there is no standard, so the claim has to be substantiated on its own terms.

Section 08

Country of origin

The substantial transformation test that decides an Australian made claim sits in the Consumer Law, and the labelling rules in the Information Standard reach only retail or retail-ready sales.

Goods were substantially transformed in a country if: (a) the goods met, in relation to that country, the requirements of item 1 or 2 in the second column of the table in subsection (1); or (b) 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;

Australian Consumer Law, s 255(2)(a) and (b)

Under the ACL, a good may safely represent that it was made in a particular country if the business can demonstrate that it underwent its last substantial transformation in the country claimed.

ACCC, Country of origin claims and the Australian Consumer Law, guide for business, p 8

This Part applies in relation to a sale of food in Australia if: (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.

Country of Origin Food Labelling Information Standard 2016, s 14(1)

For a business-to-business flavour sale the consequence is specific. A bulk flavour sold to a manufacturer for further processing is outside Part 2 of the Information Standard, so the standard mark, the kangaroo logo and the bar chart are not required on the drum. The origin claim itself is still fully governed by ACL ss 18, 29 and 255, and the ACCC warns that identity, nature and essential character are undefined and take their ordinary meaning, with mere assembly or repackaging generally not enough.

Section 09

New Zealand scope

The Code applies on both sides of the Tasman, but a listed set of provisions is not incorporated into New Zealand law, and the food safety standards are among them.

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.

Standard 1.1.1, s 1.1.1—3(1)

(viii) Chapter 3 (food safety standards); (vix) Chapter 4 (primary production and processing standards).

Standard 1.1.1, Note 1 to s 1.1.1—3

So Standard 3.2.2, the source of the food-safety, traceability and recall obligations an Australian buyer relies on, does not govern a New Zealand business. A New Zealand buyer's food-safety expectations run through the Food Act 2014 and its risk-based measures instead. The flavouring provisions themselves are unaffected: the permission in s S16—2 and the declaration rule in s 1.2.4—7(4) apply identically in both countries.

Section 10

How to cite this page

Suggested citation, with the retrieval date that applies to every clause quoted above:

VKA Australia, “Australian Flavour Regulations: a clause-by-clause reference”, vka.au, retrieved 12 September 2026. https://vka.au/reference/australian-flavour-regulations

This page is a reading of the instruments named in it, not legal advice. Every clause quoted was retrieved on the date above from the publisher listed in Sources, each Code instrument as the authorised compilation current on that date. Where a proposition rests on the absence of a term rather than its presence, section 2 names every instrument searched so the negative can be rechecked.