{"id":"F2015L00481","name":"Australia New Zealand Food Standards Code – Schedule 11 – Calculation of values for nutrition information panel","slug":"australia-new-zealand-food-standards-code-schedule-11-calculation-of-values-for-nutrition-informatio","collection":"legislative_instrument","jurisdiction":"commonwealth","status":"in_force","isInForce":true,"actNumber":null,"makingDate":null,"administeringDepartment":null,"currentVersion":{"id":93129,"registerId":"commonwealth-F2015L00481-current","compilationNumber":null,"startDate":"2026-04-02","status":"InForce","reasons":null,"registeredAt":null},"sections":[{"sectionNumber":"1","sectionType":"section","heading":"Australia New Zealand Food Standards Code – Schedule 11 – Calculation of values for nutrition information panel","content":"Schedule 11 Calculation of values for nutrition information panel\n\nNote 1 This instrument is a standard under the Food Standards Australia New Zealand Act 1991 (Cth). The standards together make up the Australia New Zealand Food Standards Code. See also section 1.1.1—3.\n\nStandard 1.2.8 is a standard for nutrition information requirements. This Standard:\n\n● sets out how to calculate average energy content, available carbohydrate and available carbohydrate by difference for sections 1.1.2—2 and 1.2.8—4; and\n\n● sets out how to determine dietary fibre for subsection 1.2.8—7(7) and subsection S5—6(2); and\n\n● lists substances for paragraph 1.2.8—6(9)(a) and subparagraph 1.2.8—14(1)(c)(ii).\n\nNote 2 The provisions of the Code that apply in New Zealand are incorporated in, or adopted under, the Food Act 2014 (NZ). See also section 1.1.1—3.\n\nS11—1 Name\n\nThis Standard is Australia New Zealand Food Standards Code – Schedule 11 – Calculation of values for nutrition information panel.\n\nNote Commencement:  \nThis Standard commences on 1 March 2016, being the date specified as the commencement date in notices in the Gazette and the New Zealand Gazette under section 92 of the Food Standards Australia New Zealand Act 1991 (Cth). See also section 93 of that Act.\n\nS11—2 Calculation of average energy content\n\n(1) For section 1.1.2—2, the \\*average energy content of a food means the energy content AE, in kJ/100 g, calculated using the following equation:\n\n![C:\\Users\\humphc\\Desktop\\Capture.JPG](image.001.jpeg)\n\nwhere:\n\nN is the number of \\*components in the food.\n\nWi is the ‘\\*average quantity’ of a component of the food measured in g/100 g of the food.\n\nFi is the energy factor, expressed in kJ/g:\n\n(a) for a general component listed in the table to subsection (2)—indicated in the corresponding row of that table; and\n\n(b) for a specific component listed in the table to subsection (3)—indicated in the corresponding row of that table.\n\n(2) For subsection (1), particular energy factors, in kJ/g, for certain \\*components are listed below:\n\nEnergy factors for general components\n\n| Component                                          | Energy factor |\n| -------------------------------------------------- | ------------- |\n| alcohol                                            | 29            |\n| *carbohydrate (excluding unavailable carbohydrate) | 17            |\n| unavailable carbohydrate (including dietary fibre) | 8             |\n| fat                                                | 37            |\n| protein                                            | 17            |\n\n(3) For subsection (1), and for paragraph 1.2.8—6(9)(a) and subparagraph 1.2.8—14(1)(c)(ii), particular energy factors, in kJ/g, for specific \\*components are listed below:  \n\nEnergy factors for specific components\n\n| Component     | Energy factor |\n| ------------- | ------------- |\n| D-allulose    | 2             |\n| erythritol    | 1             |\n| glycerol      | 18            |\n| isomalt       | 11            |\n| lactitol      | 11            |\n| maltitol      | 13            |\n| mannitol      | 9             |\n| organic acids | 13            |\n| polydextrose  | 5             |\n| sorbitol      | 14            |\n| D-Tagatose    | 11            |\n| Xylitol       | 14            |\n\n(4) If for Standard 1.2.8 the \\*average energy content may be expressed in kilocalories, the number of kilocalories/100g must be calculated in accordance with the following equation:\n\n![cid:image001.png@01D2337E.0463A220](image.002.png)\n\nwhere\n\nAE(C) is the average energy content in kilocalories/100 g;\n\nAE(kJ) is the average energy content in kilojoules/100 g, calculated in accordance with the equation set out in subsection (1).\n\nS11—3 Calculation of available carbohydrate and available carbohydrate by difference\n\nCalculation of available carbohydrate\n\n(1) For section 1.1.2—2(3), available carbohydrate, for a food, is calculated by summing the \\*average quantity in the food of:\n\n(a) total available sugars and starch; and\n\n(b) if quantified or added to the food—any available oligosaccharides, glycogen and maltodextrins.\n\nCalculation of available carbohydrate by difference\n\n(2) For section 1.1.2—2(3), available carbohydrate by difference, for a food, is calculated by subtracting from 100 the \\*average quantity in the food, expressed as a percentage, of the following substances:\n\n(a) water;\n\n(b) protein;\n\n(c) fat;\n\n(d) dietary fibre;\n\n(e) ash;\n\n(f) alcohol;\n\n(g) if quantified or added to the food—any other unavailable carbohydrate;\n\n(h) a substance listed in subsection S11—2(3).\n\n  \n\nS11—4 Methods of analysis for dietary fibre and other fibre content\n\n(1) This section applies for the purposes of subsection 1.2.8—7(7) and section S5—6(2).\n\n(2) The total \\*dietary fibre, and amount of any specifically named fibre, in a food must be determined in accordance with any one or more of the methods contained in following sections of the AOAC:\n\n(a) for dietary fibre—sections 985.29 or 991.43, or 2017.16;\n\n(b) for dietary fibre (including all resistant maltodextrins)—section 2001.03;\n\n(c) for inulin and fructooligosaccharide—section 997.08;\n\n(d) for inulin—section 999.03;\n\n(e) for polydextrose—section 2000.11;\n\n(f) for resistant starch—section 2002.02.\n\n(3) If the dietary fibre content of a food has been determined by more than 1 method of analysis, the total dietary fibre content is calculated by:\n\n(a) adding together the results from each method of analysis; and\n\n(b) subtracting any portion of dietary fibre which has been included in the results of more than one method of analysis.\n\n(4) In this section:\n\nAOAC means the Official Methods of Analysis of AOAC International, twenty first edition, 2019, published by AOAC International, Maryland USA.\n\n\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_  \n\nAmendment History\n\nThe Amendment History provides information about each amendment to the Schedule. The information includes commencement or cessation information for relevant amendments.\n\nThese amendments are made under section 92 of the Food Standards Australia New Zealand Act 1991 unless otherwise indicated. Amendments do not have a specific date for cessation unless indicated as such.\n\nAbout this compilation\n\nThis is compilation No. 6 of Schedule 11 as in force on 29 October 2024 (up to Amendment No. 233). It includes any commenced amendment affecting the compilation to that date.\n\nPrepared by Food Standards Australia New Zealand on 29 October 2024.\n\nUncommenced amendments or provisions ceasing to have effect\n\nTo assist stakeholders, the effect of any uncommenced amendments or provisions which will cease to have effect, may be reflected in the Schedule as shaded boxed text with the relevant commencement or cessation date. These amendments will be reflected in a compilation registered on the Federal Register of Legislation including or omitting those amendments and provided in the Amendment History once the date is passed.\n\nThe following abbreviations may be used in the table below:\n\nad = added or inserted am = amended\n\nexp = expired or ceased to have effect rep = repealed\n\nrs = repealed and substituted\n\nSchedule 11 was published in the Food Standards Gazette No. FSC96 on 10 April 2015 as part of Amendment 154 (F2015L00481 –- 2 April 2015) and has since been amended as follows:\n\n| Section affected | A’ment No. | FRL registrationGazette                         | Commencement(Cessation) | How affected | Description of amendment                     |\n| ---------------- | ---------- | ----------------------------------------------- | ----------------------- | ------------ | -------------------------------------------- |\n| S11—2(4)         | 168        | F2017L0041411 April 2017FSC11013 April 2017     | 13 April 2017           | rs           | Correction to structure of subsection.       |\n| S11—4(2)(e)      | 179        | F2018L0065524 May 2018FSC120                    | 24 May 2018             | am           | Omitted and substituted S11-4(2) (e) and (f) |\n| S11—4            | 182        | F2018L0159423 Nov 2018FSC12329 Nov 2018         | 29 Nov 2018             | am           | Omitted and substituted S11-4 (2) and (3)    |\n| S11—2(1)         | 200        | F2021L006842 June 2021FSC1413 June 2021         | 3 June 2021             | am           | Omitted and substituted S11—2(1)             |\n| S11—4(2)(a)      | 205        | F2022L0002714 Jan 2022FSC14620 Jan 2022         | 20 Jan 2022             | am           | Omitted and substituted section reference    |\n| S11—4(4)         | 205        | F2022L0002714 Jan 2022FSC14620 Jan 2022         | 20 Jan 2022             | am           | Omitted and substituted AOAC details         |\n| S11—2(3)         | 233        | F2024L0137728 October 2024FSC17329 October 2024 | 29 October 2024         | ad           | Insert D-allulose in S11—2(3)table.          |","sortOrder":0}],"analysis":{"flash_summary":{"complexity_score":5,"scope_assessment":{"changed":false,"description":"The Schedule remains a narrowly technical instrument that defines how to calculate nutrition panel values. Amendments recorded in the history are technical updates and corrections (for example, changes to AOAC method references, structural corrections and the insertion of a specific energy factor for D‑allulose). Those updates adjust the set of recognised components and methods but do not enlarge the Schedule's purpose beyond providing calculation rules and acceptable analytical methods."},"complexity_factors":["Formulaic calculation requiring summation across N components (S11—2(1))","Two energy‑factor tables: general components (5 rows) and specific components (12 rows including D‑allulose) (S11—2(2)–(3))","Cross‑references to multiple other Code provisions (e.g. 1.1.2—2, 1.2.8—4, 1.2.8—6, 1.2.8—14, S5—6(2), 1.2.8—7(7))","Dual calculation routes for available carbohydrate (direct summation vs. by difference) with a list of items to subtract (S11—3(1)–(2))","Prescriptive list of laboratory methods (AOAC methods with edition) and an overlap‑adjustment rule when multiple methods are used (S11—4(2)–(4))","Conditional logic where the presence or quantification of certain components changes which factors or routes are applied (e.g. quantified or added oligosaccharides; substances listed in S11—2(3))","Recent amendment activity (multiple technical amendments, most recently adding D‑allulose) requiring users to track updates (Amendment History, Amendment No. 233)","Defined technical terms used throughout (e.g. \"average quantity\", \"component\", \"dietary fibre\", \"AOAC\") and required unit consistency (g/100 g, kJ/g, kJ/100 g)"],"plain_english_summary":"**What this instrument does (mechanics)\n\n- Sets the exact maths that food businesses and regulators must use to calculate the numbers that appear in the Nutrition Information Panel (NIP) for packaged foods. (Schedule 11 is a technical part of the Australia New Zealand Food Standards Code.)\n\n- Average energy content (kJ per 100 g): calculated by summing, for every component of the food, the component's average quantity (g per 100 g of food) multiplied by a prescribed energy factor (kJ per g). The Schedule gives the energy factors for broad component classes (fat, protein, carbohydrate, alcohol, unavailable carbohydrate/dietary fibre) and for a list of specific sweeteners and sugar‑substitutes (for example, erythritol, glycerol, polydextrose and D‑allulose). See S11—2(1)–(3).\n\n- Kilocalories (kcal) conversion: if kcal are used on the label the Schedule prescribes converting the kJ figure into kcal using the stated conversion. See S11—2(4).\n\n- Available carbohydrate: defined either by summing quantified available sugars and starch (plus, if quantified or added, certain oligosaccharides/glycogen/maltodextrins) or by calculating \"available carbohydrate by difference\". The \"by difference\" route means subtracting the measured percentages of water, protein, fat, dietary fibre, ash, alcohol, other unavailable carbohydrate and any substances listed in S11—2(3) from 100. See S11—3(1)–(2).\n\n- Dietary fibre testing: the Schedule lists the AOAC laboratory methods (Official Methods of Analysis of AOAC International) that are acceptable to determine total dietary fibre and named fibres (for example, resistant starch, polydextrose, inulin). If more than one method is used, the rules require adding results and subtracting any overlap so the fibre total is not double counted. See S11—4(2)–(3) and S11—4(4).\n\nWho this affects and why it matters\n\n- Who is required to use these rules: food manufacturers, importers and packers who prepare or supply packaged foods bearing a Nutrition Information Panel, and testing laboratories that provide compositional analysis used to prepare NIPs. (The Schedule operates as part of the Food Standards Code.)\n\n- Why it matters: the Schedule fixes the technical inputs used to calculate energy and carbohydrate numbers on labels. These numbers affect how products are presented to consumers and can influence product formulation, product positioning and comparative claims. The Schedule also constrains which laboratory methods are acceptable for dietary fibre figures.\n\nPractical consequences, incentives and implementation mechanics (source‑based observations)\n\n- Compliance costs: businesses must measure or obtain laboratory data for component quantities (Wi in S11—2(1)) and apply the prescribed energy factors (S11—2(2)–(3)). Where specific components (such as erythritol or D‑allulose) are present, businesses can use the listed lower energy factors for those ingredients rather than generic carbohydrate factors (S11—2(3)). This creates an incentive for manufacturers to quantify and disclose the presence of those specific low‑energy substances so they can be reflected in the NIP.\n\n- Testing burden and choices: the Schedule limits acceptable fibre analysis to particular AOAC methods (S11—4(2)). Businesses that want to rely on fibre values must instruct laboratories to use those methods and to apply the overlap adjustment rule if multiple methods are used (S11—4(3)). That produces direct laboratory costs and requires record‑keeping of method details.\n\n- Behavioural effects on formulation and labelling: because certain sugar‑replacers and polyols have lower prescribed energy factors (S11—2(3)), manufacturers may favour ingredients that produce lower declared energy on the label. The \"by difference\" method for available carbohydrate (S11—3(2)) may also lead businesses to choose whether to quantify particular components (so they are included or excluded) depending on which calculation yields a more favourable label value.\n\n- Who decides in practice: the Schedule prescribes the technical rules; manufacturers decide which calculation route and which laboratory method to use (subject to the allowed list). Regulators enforce use of these rules and whether provided analyses and labels comply with the Code.\n\n- Implementation risks and compliance complexities: small errors in component measurement, inconsistent laboratory choice, or incorrect application of the summation/subtraction rules can produce incorrect NIP numbers. The overlap subtraction rule for multiple fibre methods (S11—4(3)) adds calculation complexity which can cause inconsistent results between laboratories unless documented carefully.\n\n- Market effects: the Schedule is mechanistic rather than prescriptive of ingredients. However, by assigning lower energy factors to particular substances the Schedule creates a measurable drafting incentive for manufacturers to use those substances and to ensure analytical evidence is on file. That benefit is concentrated (manufacturers of products using those ingredients can show lower energy on labels) while the compliance costs (testing, record‑keeping) are borne by all businesses that must produce NIPs.\n\nRelevant sections to check when implementing\n\n- S11—2(1)–(4): formula for average energy content, tables of energy factors and kJ→kcal conversion.\n- S11—3(1)–(2): definitions and calculation routes for available carbohydrate.\n- S11—4(2)–(4): acceptable AOAC methods for dietary fibre and rules where multiple methods are used.\n\nSource limits: this Schedule is a technical annex to the Food Standards Code and should be read together with the referenced Code provisions (for example, Standard 1.2.8 and section 1.1.2—2) when deciding which calculation path and lab methods apply to a particular product.\n"},"kimi_summary":{"content_quality":"ok","complexity_score":5,"scope_assessment":{"changed":false,"description":"The legislation remains tightly focused on its original purpose: providing technical calculation methodologies for nutrition information panels. While it has been amended six times since 2015 (adding new sugar substitutes like D-allulose, updating AOAC method references, and correcting structural errors), these amendments represent technical updates and refinements rather than scope creep. The core function—mathematical rules for energy, carbohydrate, and fibre calculations—has remained consistent."},"complexity_factors":["Mathematical formulas with variables and equations requiring substitution (subsections S11-2(1) and S11-2(4))","Cross-references to other standards (Standard 1.2.8, sections 1.1.2-2, 1.2.8-4, 1.2.8-7, S5-6) and external methodology (AOAC International standards)","Multiple calculation methods for the same concept (available carbohydrate vs available carbohydrate by difference in S11-3)","Conditional logic for specific components (subsection S11-2(3) listing 12 specific substances with unique energy factors, separate from general components)","Technical scientific terminology requiring external reference (AOAC methods with specific section numbers like 985.29, 991.43, 2017.16)","Nested definitions (terms like 'average quantity' and 'components' are asterisked, indicating they are defined terms in the broader Code)","Dual jurisdiction application (Australia and New Zealand with different enabling legislation)"],"plain_english_summary":"This is a technical rulebook for how food businesses in Australia and New Zealand must calculate the numbers on Nutrition Information Panels. It sets exact formulas and energy factors for calories/kilojoules, methods for available carbohydrate (direct or by-difference) and mandated laboratory methods for dietary fibre, with rules to avoid double-counting.  \n\nIt ensures manufacturers, importers and labs produce consistent, comparable nutrition figures so consumers can trust product comparisons."},"flash_summary_failed":{"failed":true,"reason":"A positive credit balance is required for all requests, including BYOK, so fallback providers remain available. Add credits at https://vercel.com/d?to=%2F%5Bteam%5D%2F%7E%2Fai%3Fmodal%3Dtop-up to continue.","source":"analysis-cron"}},"importantCases":[],"_links":{"self":"/api/acts/australia-new-zealand-food-standards-code-schedule-11-calculation-of-values-for-nutrition-informatio","history":"/api/acts/australia-new-zealand-food-standards-code-schedule-11-calculation-of-values-for-nutrition-informatio/history","analysis":"/api/acts/australia-new-zealand-food-standards-code-schedule-11-calculation-of-values-for-nutrition-informatio/analysis","conflicts":"/api/acts/australia-new-zealand-food-standards-code-schedule-11-calculation-of-values-for-nutrition-informatio/conflicts","importantCases":"/api/acts/australia-new-zealand-food-standards-code-schedule-11-calculation-of-values-for-nutrition-informatio/important-cases","documents":"/api/acts/australia-new-zealand-food-standards-code-schedule-11-calculation-of-values-for-nutrition-informatio/documents"}}