{"id":"F2013L00054","name":"Australia New Zealand Food Standards Code - Standard 1.2.7 - Nutrition, Health and Related Claims","slug":"f2013l00054","collection":"legislative_instrument","jurisdiction":"commonwealth","status":"repealed","isInForce":false,"actNumber":null,"makingDate":null,"administeringDepartment":null,"currentVersion":{"id":351561,"registerId":"commonwealth-F2013L00054-current","compilationNumber":null,"startDate":"2026-04-09","status":"Repealed","reasons":null,"registeredAt":null},"sections":[{"sectionNumber":"Part 1","sectionType":"division","heading":"Purpose and interpretation","content":"### Part 1 – Purpose and interpretation\n\nEditorial Note:\n\nStandard 1.1A.8 is a transitional Standard that applies to claims about the presence or absence of dietary fibre in a food and operates concurrently with Standard 1.2.7. The transitional arrangement permitted by Standard 1.1A.8 allows a supplier making a claim about the presence or absence of dietary fibre in a food to either comply with clause 11 of Standard 1.2.7 or clause 2 of Standard 1.1A.8, but not both. This transitional arrangement under Standard 1.1A.8 commenced on 18 January 2016 and will cease on 1 March 2016 when the revised Code takes effect and that Standard is revoked. The revised Code will provide a similar transitional arrangement until and including 17 January 2017.\n\n1 Purpose\n\nThis Standard –\n\n (a) sets out the claims that can be made on labels or in advertisements about the nutritional content of food (described as nutrition content claims) and the claims that can be made on labels or in advertisements about the relationship between a food or a property of a food, and a health effect (described as health claims); and\n (b) describes the conditions under which such claims can be made, and\n (c) describes the circumstances in which endorsements can be provided on labels or in advertisements.\n\n> Note: Editorial note:\n\n> Note: Standard 1.2.8 may prescribe additional labelling requirements for claims regulated in Standard 1.2.7.\n\n2 Interpretation\n\nIn this Standard –\n\n> average energy content is as defined in Standard 1.2.8.\n\n> biologically active substance is as defined in Standard 1.2.8.\n\n> biomarker means a measurable biological parameter that is predictive of the risk of a serious disease when present at an abnormal level in the human body.\n\n> carbohydrate is as defined in Standard 1.2.8.\n\n> dietary fibre is as defined in Standard 1.2.8.\n\n> endorsement means a nutrition content claim or a health claim that is made with the permission of an endorsing body.\n\n> endorsing body is a not-for-profit entity which has a nutrition- or health-related purpose or function that permits a supplier to make an endorsement.\n\n> fat is as defined in Standard 1.2.8.\n\n> food group means any of the following groups –\n\n (a) bread (both leavened or unleavened), grains, rice, pasta and noodles;\n (b) fruit, vegetables, herbs, spices and fungi;\n (c) milk and milk products as standardised in Part 2.5 and analogues derived from legumes and cereals mentioned in Column 1 of the Table to clause 3 in Standard 1.3.2;\n (d) meat, fish, eggs, nuts, seeds and dried legumes;\n (e) fats including butter, edible oils and edible oil spreads.\n\n> fruit means the edible portion of a plant or constituents of the edible portion that are present in the typical proportion of the whole fruit (with or without the peel or water), but does not include nuts, spices, herbs, fungi, legumes and seeds.\n\n> fvnl is as defined in item 4 of Schedule 5 for the purpose of calculating V points.\n\n> general level health claim means a health claim that is not a high level health claim.\n\n> gluten means the main protein in wheat, rye, oats, barley, triticale and spelt relevant to the medical conditions coeliac disease and dermatitis herpetiformis.\n\n> glycaemic index (GI) means a measure of the blood glucose raising ability of the digestible carbohydrates in a given food as determined by a recognised scientific method.\n\nEditorial note:\n\n> Note: A method for determining glycaemic index of carbohydrates in foods is described in the Standards Australia Australian Standard Glycemic index of foods (AS 4694 – 2007). In particular, glycaemic index testing is carried out by the determination of glycaemic (blood glucose) responses in human volunteers (in–vivo testing).\n\n> Note: The objective of AS 4694 - 2007 is to establish the recognised scientific method as the standard method for the determination of glycaemic index (GI) in foods.\n\n> health claim means a claim which states, suggests or implies that a food or a property of food has, or may have, a health effect.\n\n> Note: Editorial note:\n\n> Note: For the definition of claim, see clause 2 of Standard 1.1.1.\n\n> health effect means an effect on the human body, including an effect on one or more of the following –\n\n (a) a biochemical process or outcome;\n (b) a physiological process or outcome;\n (c) a functional process or outcome;\n (d) growth and development;\n (e) physical performance;\n (f) mental performance;\n (g) a disease, disorder or condition.\n\n> high level health claim means a health claim that refers to a serious disease or a biomarker of a serious disease.\n\n> maximum claimable amount means the maximum claimable amount as prescribed by clause 4 or clause 5 of Standard 1.3.2.\n\n> meets the NPSC means that the nutrient profiling score of a food described in Column 1 of Schedule 4 is less than the number specified for that food in Column 2 of that Schedule.\n\n> monounsaturated fatty acids is as defined in Standard 1.2.8.\n\n> NPSC means the nutrient profiling scoring criterion.\n\n> nutrient profiling score means the final score calculated pursuant to the method described in Schedule 5.\n\n> nutrition content claim means a claim about –\n\n (a) the presence or absence of –\n\n (i) a biologically active substance; or\n (ii) dietary fibre; or\n (iii) energy; or\n (iv) minerals; or\n (v) potassium; or\n (vi) protein; or\n (vii) carbohydrate; or\n (viii) fat; or\n (ix) the components of any one of protein, carbohydrate or fat; or\n (x) salt; or\n (xi) sodium; or\n (xii) vitamins; or\n\n (b) glycaemic index or glycaemic load;\n\n> that does not refer to the presence or absence of alcohol, and is not a health claim.\n\n> Note: Editorial note:\n\n> Note: For the definition of claim, see clause 2 of Standard 1.1.1.\n\n> polyunsaturated fatty acids is as defined in Standard 1.2.8.\n\n> property of food means a component, ingredient, constituent or other feature of food.\n\n> reference food means a food that is –\n\n(a) of the same type as the food for which a claim is made and that has not been further processed, formulated, reformulated or modified to increase or decrease the energy value or the amount of the nutrient for which the claim is made; or\n\n(b) a dietary substitute for the food in the same food group as the food for which a claim is made.\n\n> Note: Editorial note:\n\nAn example for paragraph (a) is reduced fat milk compared to whole milk (the reference food).\n\nAn example for paragraph (b) is milk alternatives compared to milk products (the reference food).\n\n> reference quantity means the reference quantity specified for the food in Column 2 of the Table to clause 3 of Standard 1.3.2.\n\n> salt is as defined in Standard 2.10.2.\n\n> saturated fatty acids is as defined in Standard 1.2.8.\n\n> serious disease means a disease, disorder or condition which is generally diagnosed, treated or managed in consultation with or with supervision by a health care professional.\n\n> small package is as defined in Standard 1.2.1.\n\n> sugars is as defined in Standard 1.2.8.\n\n> trans fatty acids is as defined in Standard 1.2.8.\n\n> vegetable means the edible portion of a plant or constituents of the edible portion that are present in the typical proportion of the whole vegetable (with or without the peel or water) but does not include nuts, spices, herbs, fungi, dried legumes (including dried legumes that have been cooked or rehydrated) and seeds.","sortOrder":0},{"sectionNumber":"Part 2","sectionType":"division","heading":"Claims framework and general principles","content":"### Part 2 – Claims framework and general principles\n\n3 Nutrition content claims or health claims not to be made about certain foods\n\nA nutrition content claim or health claim must not be made about –\n\n (a) kava; or\n\n(b) a food that contains more than 1.15% alcohol by volume, other than a nutrition content claim about –\n\n (i) energy content, carbohydrate content or gluten content; or\n (ii) salt or sodium content about a food that is not a beverage; or\n\n (c) an infant formula product.\n\n> Note: Editorial note:\n\n> Note: Kava is standardised in Standard 2.6.3.\n\n> Note: Infant formula product is standardised in Standard 2.9.1.\n\n4 Standard does not apply to certain foods\n\nThis Standard does not apply to food that is –\n\n (a) intended for further processing, packaging or labelling prior to retail sale; or\n (b) delivered to a vulnerable person by a delivered meal organisation; or\n (c) provided to a patient in a hospital or other similar institution, other than food in a package.\n\nEditorial Note:\n\nThe facilities that are ‘other similar institutions’ are described in the table to clause 8 of Standard 1.2.1.\n\n5 Standard does not apply to certain claims or declarations\n\nThis Standard does not apply to –\n\n (a) a claim that is expressly permitted by another Standard in this Code; or\n (b) a claim about the risks or dangers of alcohol consumption or about moderating alcohol intake; or\n (c) a declaration that is required by the Act; or\n (d) a Permitted Health Star Rating symbol.\n\n6 Form of food to which provisions of this Standard apply\n\nIf this Standard imposes a prerequisite, condition, qualification or any other requirement on the making of a claim, that prerequisite, condition, qualification or requirement applies to the form of the food as determined in accordance with the Table.\n\n \n\nTable to clause 6\n\n| Form of the food |\n| ----------------------------------------------------------------------------------------------------------------------- |\n| The food as sold if the food can be either prepared with other food or consumed as sold. |\n| The food as prepared if the food is required to be prepared and consumed according to directions. |\n| The food after it is reconstituted with water and ready for consumption if the food requires reconstituting with water. |\n| The food after it is drained and ready for consumption if the food requires draining before consuming. |\n\n> Note: Editorial note:\n\n> Note: Clause 11A of Standard 1.2.8 provides additional nutrition information panel (NIP) requirements where a claim is based on food as prepared.\n\n7 Claims not to be therapeutic in nature\n\nA claim must not –\n\n (a) refer to the prevention, diagnosis, cure or alleviation of a disease, disorder or condition; or\n (b) compare a food with a good that is –\n\n (i) represented in any way to be for therapeutic use; or\n (ii) likely to be taken to be for therapeutic use, whether because of the way in which the good is presented or for any other reason.\n\n8 Claims not to compare vitamin or mineral content\n\nA claim that directly or indirectly compares the vitamin or mineral content of a food with that of another food must not be made unless the claim is permitted by another Standard in this Code.\n\n9 Standard does not prescribe words\n\n(1) Nothing in this Standard is to be taken to prescribe the words that must be used when making a claim.\n\n(2) Any statement or information required by this Standard may be modified if the modification does not alter or contradict the effect of the required statement or information.","sortOrder":1},{"sectionNumber":"Part 3","sectionType":"division","heading":"Requirements for nutrition content claims and health claims","content":"### Part 3 – Requirements for nutrition content claims and health claims","sortOrder":2},{"sectionNumber":"Division 1","sectionType":"division","heading":"Nutrition content claims","content":"### Division 1 – Nutrition content claims\n\n10 Presentation of nutrition content claims\n\nA nutrition content claim must be stated together with a statement about the form of the food to which the claim relates, unless the form of the food to which the claim relates is the food as sold.\n\n11 Nutrition content claims about properties of food in Schedule 1\n\n(1) If a property of food is mentioned in Column 1 of Schedule 1 a nutrition content claim may only be made about that property of food in accordance with this clause.\n\n(2) If a claim is made in relation to a food about a property of food mentioned in Column 1 of Schedule 1 the food must meet the corresponding general claim conditions, if any, in Column 2 of that Schedule.\n\n \n\n(3) If a claim made in relation to a food about a property of food mentioned in Column 1 of Schedule 1 uses a descriptor mentioned in Column 3 of that Schedule or a synonym of that descriptor the food must meet –\n\n (a) the general claim conditions for the relevant property of food in Column 2 of that Schedule; and\n (b) the specific claim conditions in Column 4 of that Schedule for the relevant descriptor.\n\n(4) If, in relation to a claim mentioned in subclause (3), there is an inconsistency between a general claim condition in Column 2 of Schedule 1 and a specific claim condition in Column 4 of that Schedule, the specific claim condition prevails.\n\n(5) A descriptor must not be used in a nutrition content claim about lactose or trans fatty acids unless the descriptor –\n\n (a) is mentioned in Column 3 of Schedule 1 and corresponds with that property of food, or\n (b) is a synonym of the descriptor mentioned in paragraph (a).\n\n(6) A descriptor must not be used in a nutrition content claim about glycaemic load unless that descriptor is expressed as a number or in numeric form.\n\n(7) A nutrition content claim in relation to gluten may only –\n\n (a) use a descriptor that is mentioned in Column 3 of Schedule 1 in conjunction with gluten, or a synonym of such a descriptor; or\n (b) state that a food contains gluten or is high in gluten.\n\n(8) Subject to this clause and clause 14 (Nutrition content claims must not imply slimming effects) any descriptor that is not mentioned in Column 3 of Schedule 1, including a descriptor expressed as a number or in numeric form, may be used in conjunction with a property of food that is mentioned in Column 1 of that Schedule.\n\n12 Nutrition content claims about properties of food not in Schedule 1\n\n(1) A nutrition content claim about a property of food that is not mentioned in Schedule 1 may only state –\n\n (a) that the food contains or does not contain the property of food, or\n (b) that the food contains a specified amount of the property of food in a specified amount of that food, or\n (c) a combination of (a) and (b).\n\n(2) A statement made for the purposes of paragraph (1)(a) must not use a descriptor listed in Column 3 of Schedule 1 or any other descriptor except a descriptor that indicates that the food does not contain the property of food.\n\n13 Nutrition content claims about choline, fluoride or folic acid\n\n(1) A nutrition content claim about choline, fluoride or folic acid may only state –\n\n (a) that the food contains choline, fluoride or folic acid, or\n (b) that the food contains a specified amount of choline, fluoride or folic acid in a specified amount of that food, or\n (c) a combination of (a) and (b).\n\n(2) A statement made for the purposes of paragraph (1)(a) must not use a descriptor listed in Column 3 of Schedule 1 or any other descriptor.\n\n \n\n(3) A nutrition content claim about choline, fluoride or folic acid may be made only if a health claim about that substance is made in relation to the same food.\n\n14 Nutrition content claims must not imply slimming effects\n\nA nutrition content claim that meets the conditions to use the descriptor diet must not use another descriptor that directly or indirectly refers to slimming or a synonym for slimming.\n\n15 Comparative claims\n\n(1) In this clause, a comparative claim means a nutrition content claim that directly or indirectly compares the nutrition content of one food or brand of food with another, and includes claims using the following descriptors –\n\n (a) light or lite;\n (b) increased;\n (c) reduced;\n\nor words of similar import.\n\n(2) A nutrition content claim using the descriptor diet is a comparative claim if it meets the conditions for making that claim by having at least 40% less energy than the same quantity of reference food.\n\n(3) A comparative claim about a food (the claimed food) must include together with the claim –\n\n (a) the identity of the reference food; and\n (b) the difference between the amount of the property of food in the claimed food and the reference food.","sortOrder":3},{"sectionNumber":"Division 2","sectionType":"division","heading":"Health claims","content":"### Division 2 – Health claims\n\n16 Application or proposal to vary Schedule 3 taken to be a high level health claims variation\n\nAn application or a proposal to add a general level health claim to Schedule 3 is taken to be an application or proposal for a high level health claims variation.\n\n> Note: Editorial Note:\n\n> Note: High level health claims variation is defined in section 4 of the Food Standards Australia New Zealand Act 1991 (FSANZ Act).\n\n> Note: The effect of this provision is that an application or a proposal to add a general level health claim to Schedule 3 will be assessed under the provisions in Subdivision G of each of Divisions 1 and 2 of Part 3 of the FSANZ Act, as appropriate.\n\n17 Conditions for making health claims\n\n(1) A health claim must not be made unless it complies with subclause (2) and either subclause (3) or (4), whichever applies.\n\n(2) The food to which the health claim relates meets the NPSC.\n\n(3) If the health claim is a high level health claim –\n\n (a) the food or the property of food is mentioned in Column 1 of Schedule 2; and\n (b) the health effect claimed for that food or property of food is mentioned in the corresponding row in Column 2 of Schedule 2; and\n (c) the food complies with the relevant conditions in Column 5 of Schedule 2.\n\n(4) If the health claim is a general level health claim, either –\n\n each of the following –\n\n (i) the food or the property of food is mentioned in Column 1 of Schedule 3;\n (ii) the health effect claimed for that food or property of food is mentioned in the corresponding row in Column 2 of Schedule 3; and\n (iii) the food complies with the relevant conditions in Column 5 of Schedule 3; or\n (b) the person who is responsible for making the health claim has notified the Chief Executive Officer of the Authority of the details of a relationship between a food or property of food and a health effect that has been established by a process of systematic review that is described in Schedule 6.\n\n(5) Despite subclause (2) a food that is standardised in Part 2.9 of this Code does not need to meet the NPSC.\n\n18 Requirement when making a general level health claim under paragraph 17(4)(b)\n\n(1) A person who gives the notice mentioned in paragraph 17(4)(b) is required to –\n\n (a) provide the name of the person that is giving the notice and the address in Australia or New Zealand of that person; and\n (b) consent to the publication by the Authority of the information given for the purposes of paragraph 17(4)(b) and paragraph 18(1)(a); and\n (c) certify that the notified relationship between a food or property of food and a health effect has been established by a process of systematic review that is described in Schedule 6; and\n (d) if requested by a relevant authority, provide records to the relevant authority that demonstrate that –\n\n (i) the systematic review was conducted in accordance with the process of systematic review described in Schedule 6; and\n (ii) the notified relationship is a reasonable conclusion of the systematic review.\n\n(2) A certificate provided for a body corporate must be signed by a senior officer of the body corporate.\n\n19 How health claims are to be made\n\n(1) If a health claim is a high level health claim based on a relationship described in Schedule 2 or a general level health claim based on a relationship described in Schedule 3, the health claim must –\n\n (a) state –\n\n (i) the food or the property of food mentioned in Column 1 of Schedule 2 or Column 1 of Schedule 3; and\n (ii) the specific health effect mentioned in Column 2 of Schedule 2 or Column 2 of Schedule 3 that is claimed for the food or the property of food; and\n\n (b) if Column 3 of Schedule 2 or Column 3 of Schedule 3 refers to a relevant population group to which the specific health effect relates, include a statement of that population group in conjunction with the health claim.\n\n(2) If a health claim is a general level health claim based on a relationship that has been notified under paragraph 17(4)(b), the health claim must –\n\n \n\n (a) state the food or the property of food and the specific health effect; and\n (b) include together with the health claim a statement about the relevant population group, if any, that is a reasonable conclusion of the systematic review mentioned in paragraph 17(4)(b).\n\n(3) In addition to the requirements under subclause (1) or (2), whichever applies, the health claim must also include together with the health claim –\n\n (a) a dietary context statement according to the principles for a dietary context statement set out in subclause (4); and\n (b) a statement of the form of the food to which the health claim relates.\n\n(4) A dietary context statement must –\n\n (a) state that the health effect must be considered in the context of a healthy diet involving the consumption of a variety of foods; and\n (b) be appropriate to the type of food or the property of food that is the subject of the claim and the health effect claimed; and\n (c) either –\n\n (i) if the health claim is a high level health claim based on a relationship described in Schedule 2 or a general level health claim based on a relationship described in Schedule 3, include words to the effect of the relevant dietary context statement in the corresponding row of Column 4 of Schedule 2 or Column 4 of Schedule 3, if any; or\n (ii) if the health claim is a general level health claim based on a relationship that has been notified under paragraph 17(4)(b), include words to the effect of a relevant dietary context statement that is a reasonable conclusion of the systematic review.\n\n(5) Despite paragraph (3)(a), a dietary context statement need not be included on a label on a food product that is contained in a small package.\n\n(6) Despite paragraph (3)(b), if the form of the food to which the claim relates is the food as sold, the form of the food to which the claim relates need not be stated.\n\n20 Split health claims\n\nIf the statements required by subclauses 19(1) and (3) or 19(2) and (3) appear on a label or in an advertisement, the matters referred to in paragraph 19(1)(a) or (2)(a), as appropriate, may also appear in another statement on the label or in the advertisement if that other statement indicates where on the label or advertisement the statements required by subclauses 19(1) and (3) or 19(2) and (3) are located.\n\n21 Statements for claims about phytosterols, phytostanols and their esters\n\nA dietary context statement for a claim about phytosterols, phytostanols and their esters need not include a statement required by paragraph 19(4)(a) if the claim appears together with the mandatory advisory statement required by clause 2 of Standard 1.2.3.","sortOrder":4},{"sectionNumber":"Division 3","sectionType":"division","heading":"Endorsements","content":"### Division 3 – Endorsements\n\n22 Endorsing bodies\n\n(1) An endorsing body must –\n\n (a) not be related to; and\n (b) be independent of; and\n (c) be free from influence by;\n\n \n\nthe supplier of food in relation to which an endorsement is made.\n\n(2) An endorsing body is related to a supplier if the supplier –\n\n (a) has a financial interest in the endorsing body; or\n (b) established, either by itself or with others, the endorsing body; or\n (c) exercises direct or indirect control over the endorsing body.\n\n23 Criteria for endorsements\n\n(1) A supplier of food may make or include an endorsement on a label or in an advertisement for the food, or otherwise use the endorsement, if:\n\n (a) the supplier keeps the required records for the information period; and\n (b) the supplier upon request by the relevant authority, makes the required records available for inspection within the time specified by the relevant authority; and\n (c) the endorsement complies with clause 7; and\n (d) the endorsing body complies with clause 22.\n\n(2) If a label on, or an advertisement for, imported food makes or includes an endorsement, the importer of the food must –\n\n (a) keep the required records for the information period as if the importer of the food were the supplier of the food; and\n (b) upon request by the relevant authority, make the required records available for inspection within the time specified by the relevant authority.\n\n(3) An endorsement must not refer to a serious disease except in a reference to the endorsing body if the serious disease is part of the name of the endorsing body.\n\n(4) Part 2 (other than clause 7) and Part 3 Divisions 1, 2 and 4 do not apply to an endorsement.\n\n(5) In this clause –\n\n> information period, in relation to food, means the period –\n\n (a) during which the food is available for sale or advertised for sale; and\n (b) the period of 2 years after the food was last sold, or advertised or available for sale, whichever is the latest.\n\n> required records means a document or documents that demonstrate that –\n\n (a) a supplier using an endorsement has obtained the permission of the endorsing body to use the endorsement; and\n (b) the endorsing body has a nutrition- or health-related function or purpose; and\n (c) the endorsing body is a not-for-profit entity; and\n (d) the endorsing body is not related to the supplier using the endorsement.","sortOrder":5},{"sectionNumber":"Division 4","sectionType":"division","heading":"Additional labelling of food required to meet the NPSC","content":"### Division 4 – Additional labelling of food required to meet the NPSC\n\n24 Method for calculating a nutrient profiling score\n\nThe method for calculating a nutrient profiling score is described in Schedule 5.\n\n25 Labelling of food required to meet the NPSC\n\n(1) This clause applies if a food must meet the NPSC in order to make a claim.\n\n(2) The particulars of a property of food must be declared in the nutrition information panel if – \n\n (a) the property of food, other than fvnl, is relied on to meet the NPSC; and\n (b) those particulars are not otherwise required to be included in the nutrition information panel.\n\n(3) The calcium content of a food must be declared in the nutrition information panel if the food –\n\n (a) is classified in Category 3 of Schedule 4 for the purposes of determining the food’s nutrient profiling score; and\n (b) is a cheese or processed cheese.\n\n(4) If a food scores V points under item 4 of Schedule 5, the percentage of each element of fvnl that is relied on to meet the NPSC must be declared on the label, unless the claim is a health claim about fruits and vegetables.\n\n(5) If food is not required to bear a label under subclause 2(1) of Standard 1.2.1, the information prescribed in subclause (2), (3) or (4) of this clause must be provided to the purchaser of the food on request by the purchaser or –\n\n (a) in the case of information prescribed in subclause (2) or (3), declared in a nutrition information panel displayed on or in connection with the display of the food; or\n (b) in the case of information prescribed in subclause (4), declared on a label displayed on or in connection with the display of the food.\n\n26 Labelling exemptions for certain foods\n\nThe declaration required by subclauses 25(2), (3) or (4) is not required if food is in a small package.","sortOrder":6},{"sectionNumber":"Schedule 1","sectionType":"schedule","heading":null,"content":"## Schedule 1\n\nConditions for nutrition content claims\n\n```html\n

Column 1

Column 2

Column 3

Column 4

Property of food

General claim conditions that must be met

Specific descriptor

Conditions that must be met if using specific descriptor in column 3

Carbohydrate

Reduced or light/lite

The food contains at least 25% less carbohydrate than in the same quantity of reference food.

Increased

The food contains at least 25% more carbohydrate than in the same quantity of reference food.

Cholesterol

The food meets the conditions for a nutrition content claim about low saturated fatty acids.

Low

The food contains no more cholesterol than –

(a) 10 mg per 100 mL for liquid food; or

(b) 20 mg per 100 g for solid food.

Reduced or Light/Lite

The food contains at least 25% less cholesterol than in the same quantity of reference food.

Dietary fibre

A serving of the food contains at least 2 g of dietary fibre unless the claim is about low or reduced dietary fibre.

Good source

A serving of the food contains at least 4 g of dietary fibre.

Excellent source

A serving of the food contains at least 7 g of dietary fibre.

Increased

(a) the reference food contains at least 2 g of dietary fibre per serving; and

(b) the food contains at least 25% more dietary fibre than in the same quantity of reference food.

Energy

Low

The average energy content of the food is no more than –

(a) 80 kJ per 100 mL for liquid food; or

(b) 170 kJ per 100 g for solid food.

Reduced or Light/Lite

The food contains at least 25% less energy than in the same quantity of reference food.

Diet

(a) the food meets the NPSC, unless the food is a food standardised by Part 2.9 of the Code; and

(b) (i) the average energy content of the food is no more than 80 kJ per 100 mL for liquid food or 170 kJ per 100 g for solid food; or

(ii) the food contains at least 40% less energy than in the same quantity of reference food.

\n```","sortOrder":7},{"sectionNumber":"Schedule 2","sectionType":"schedule","heading":null,"content":"## Schedule 2\n\nConditions for permitted high level health claims\n\n```html\n

Column 1

Column 2

Column 3

Column 4

Column 5

Food or property of food

Specific health effect

Relevant population

Context claim statements

Conditions

A high intake of fruit and vegetables

Reduces risk of coronary heart disease

Diet containing a high amount of both fruit and vegetables

(a) claims are not permitted on –

(i) fruit juice or vegetable juice as standardised in Standard 2.6.1; or

(ii) a food standardised in Standard 2.6.2; and

(b) the food must contain no less than 90% fruit or vegetable by weight.

Beta-glucan

Reduces blood cholesterol

Diet low in saturated fatty acids

Diet containing 3 g of beta-glucan per day

The food must contain –

(a) one or more of the following oat or barley foods –

(i) oat bran;

(ii) wholegrain oats; or

(iii) wholegrain barley; and

(b) at least 1 g per serving of beta-glucan from the foods listed in (a).

Calcium

Enhances bone mineral density

Diet high in calcium

The food must contain no less than 200 mg of calcium per serving.

Reduces risk of osteoporosis

Persons 65 years and over

Diet high in calcium, and adequate vitamin D status

The food must contain no less than 290 mg of calcium per serving

Reduces risk of osteoporotic fracture

\n```","sortOrder":12},{"sectionNumber":"Schedule 3","sectionType":"schedule","heading":null,"content":"## Schedule 3\n\nConditions for permitted general level health claims\n\nPart 1 – Minerals\n\n```html\n

Column 1

Column 2

Column 3

Column 4

Column 5

Food or property of food

Specific health effect

Relevant population

Dietary context

Conditions

Calcium

Necessary for normal teeth and bone structure

The food must meet the general claim conditions for making a nutrition content claim about calcium

Necessary for normal nerve and muscle function

Necessary for normal blood coagulation

Contributes to normal energy metabolism

Contributes to the normal function of digestive enzymes

Contributes to normal cell division

Contributes to normal growth and development

Children

Chromium

Contributes to normal macronutrient metabolism

The food must meet the general claim conditions for making a nutrition content claim about chromium

Copper

Contributes to normal connective tissue structure

The food must meet the general claim conditions for making a nutrition content claim about copper

Contributes to normal iron transport and metabolism

Contributes to cell protection from free radical damage

Necessary for normal energy production

Necessary for normal neurological function

Necessary for normal immune system function

Necessary for normal skin and hair colouration

Contributes to normal growth and development

Children

Fluoride

Contributes to the maintenance of tooth mineralisation

The food must contain no less than 0.6 mg fluoride per L

\n```","sortOrder":14},{"sectionNumber":"Schedule 4","sectionType":"schedule","heading":null,"content":"## Schedule 4\n\nNutrient profiling scoring criterion\n\n| | Column 1 | Column 2 |\n| -------- | ---------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------- | ---------------------------------------------- |\n| Category | NPSC category | The nutrient profiling score must be less than |\n| 1 | Beverages | 1 |\n| 2 | Any food other than those included in Category 1 or 3. | 4 |\n| 3 | (a) cheese and processed cheese as defined in Standard 2.5.4 (with calcium content >320 mg/100 g)*; and(b) edible oil as defined in Standard 2.4.1; and(c) edible oil spreads as defined in Standard 2.4.2; and(d) margarine as defined in Standard 2.4.2; and(e) butter as defined in Standard 2.5.5.*All other cheeses (with calcium content ≤320 mg/100 g) are classified as a category 2 food product. | 28 |","sortOrder":19},{"sectionNumber":"Schedule 5","sectionType":"schedule","heading":null,"content":"## Schedule 5\n\nNutrient profiling scoring method\n\n1 Steps in determining a nutrient profiling score\n\n(1) For a food in Category 1 in Schedule 4, calculate the food’s –\n\n (a) baseline points in accordance with item 2 of this Schedule; then\n (b) fruit and vegetable points in accordance with item 4 of this Schedule (V points); then\n (c) protein points in accordance with item 5 of this Schedule (P points); then\n (d) final score in accordance with item 7 of this Schedule (the nutrient profile score).\n\n> Note: Editorial note:\n\n> Note: Category 1 foods do not score fibre (F) points.\n\n(2) For a food in Category 2 in Schedule 4, calculate the food’s –\n\n (a) baseline points in accordance with item 2 of this Schedule; then\n (b) fruit and vegetable points in accordance with item 4 of this Schedule (V points); then\n (c) protein points in accordance with item 5 of this Schedule (P points); then\n (d) fibre points in accordance with item 6 of this Schedule (F points); then\n (e) final score in accordance with item 7 of this Schedule (the nutrient profile score).\n\n(3) For a food in Category 3 in Schedule 4, calculate the food’s –\n\n (a) baseline points in accordance with item 3 of this Schedule; then\n (b) fruit and vegetable points in accordance with item 4 of this Schedule (V points); then\n (c) protein points in accordance with item 5 of this Schedule (P points); then\n (d) fibre points in accordance with item 6 of this Schedule (F points); then\n (e) final score in accordance with item 7 of this Schedule (the nutrient profile score).\n\n2 Baseline points for Category 1 or 2 foods\n\n(1) Use the information in Table 1 and the formula in subitem (2) to work out the baseline points, for the average energy content and the average quantity of each nutrient listed in that Table that is in 100 g or 100 mL of the food product (based on the units used in the nutrition information panel).\n\nTable 1\n\nBaseline Points for Category 1 or 2 Foods\n\n| Baseline points | Average energy content (kJ) per 100 g or 100 mL | Average quantity of saturated fatty acids (g) per 100 g or100 mL | Average sugars (g) per 100 g or 100 mL | Average quantity of sodium(mg) per 100 g or 100 mL |\n| --------------- | ----------------------------------------------- | ---------------------------------------------------------------- | -------------------------------------- | -------------------------------------------------- |\n| 0 | ≤335 | ≤1.0 | ≤5.0 | ≤90 |\n| 1 | >335 | >1.0 | >5.0 | >90 |\n| 2 | >670 | >2.0 | >9.0 | >180 |\n| 3 | >1005 | >3.0 | >13.5 | >270 |\n| 4 | >1340 | >4.0 | >18.0 | >360 |\n| 5 | >1675 | >5.0 | >22.5 | >450 |\n| 6 | >2010 | >6.0 | >27.0 | >540 |\n| 7 | >2345 | >7.0 | >31.0 | >630 |\n| 8 | >2680 | >8.0 | >36.0 | >720 |\n| 9 | >3015 | >9.0 | >40.0 | >810 |\n| 10 | >3350 | >10.0 | >45.0 | >900 |\n\n(2) Calculate the baseline points using the following formula –\n\nTotal baseline points = (points for average energy content) + (points for average saturated fatty acids) + (points for average total sugars) + (points for average sodium)\n\n3 Baseline points for Category 3 foods\n\n(1) Use the information in Table 2 and the formula in subitem (2) to work out the baseline points, for the average energy content and the average quantity of each nutrient listed in that Table that is in 100 g or 100 mL of the food product (based on the units used in the nutrition information panel).\n\nTable 2\n\nBaseline Points for Category 3 Foods\n\n| Baseline Points | Average energy content(kJ) per 100 g or 100 mL | Average quantity of saturated fatty acids (g) per 100 g or100 mL | Average sugars(g) per 100 g or 100 mL | Average quantity of sodium(mg) per 100 g or 100 mL |\n| --------------- | ---------------------------------------------- | ---------------------------------------------------------------- | ------------------------------------- | -------------------------------------------------- |\n| 0 | ≤ 335 | ≤1.0 | ≤ 5.0 | ≤ 90 |\n| 1 | >335 | >1.0 | >5.0 | >90 |\n| 2 | >670 | >2.0 | >9.0 | >180 |\n| 3 | >1005 | >3.0 | >13.5 | >270 |\n| 4 | >1340 | >4.0 | >18.0 | >360 |\n| 5 | >1675 | >5.0 | >22.5 | >450 |\n| 6 | >2010 | >6.0 | >27.0 | >540 |\n| 7 | >2345 | >7.0 | >31.0 | >630 |\n| 8 | >2680 | >8.0 | >36.0 | >720 |\n| 9 | >3015 | >9.0 | >40.0 | >810 |\n| 10 | >3350 | >10.0 | >45.0 | >900 |\n| 11 | >3685 | >11.0 | | >990 |\n| 12 | | >12.0 | | >1080 |\n| 13 | | >13.0 | | >1170 |\n| 14 | | >14.0 | | >1260 |\n| 15 | | >15.0 | | >1350 |\n| 16 | | >16.0 | | >1440 |\n| 17 | | >17.0 | | >1530 |\n| 18 | | >18.0 | | >1620 |\n| 19 | | >19.0 | | >1710 |\n| 20 | | >20.0 | | >1800 |\n| 21 | | >21.0 | | >1890 |\n| 22 | | >22.0 | | >1980 |\n| 23 | | >23.0 | | >2070 |\n| 24 | | >24.0 | | >2160 |\n| 25 | | >25.0 | | >2250 |\n| 26 | | >26.0 | | >2340 |\n| 27 | | >27.0 | | >2430 |\n| 28 | | >28.0 | | >2520 |\n| 29 | | >29.0 | | >2610 |\n| 30 | | >30.0 | | >2700 |\n\n(2) Calculate the baseline points using the following formula –\n\nTotal baseline points = (points for average energy content) + (points for average saturated fatty acids) + (points for average total sugars) + (points for average sodium)\n\n4 Fruit and vegetable points (V points)\n\n(1) V points can be scored for fruits, vegetables, nuts and legumes including coconut, spices, herbs, fungi, seeds and algae (fvnl) including –\n\n (a) fvnl that are fresh, cooked, frozen, canned, pickled or preserved; and\n (b) fvnl that have been peeled, diced or cut (or otherwise reduced in size), puréed or dried.\n\n(2) V points cannot be scored for –\n\n (a) a constituent, extract or isolate of a food mentioned in subitem (1); or\n (b) cereal grains mentioned as a class of food in Schedule 4 of Standard 1.4.2.\n\n> Note: Editorial note:\n\n> Note: An example of a constituent, extract or isolate under paragraph 4(2)(a) is peanut oil derived from peanuts. In this example, peanut oil would not be able to score V points. Other examples of extracts or isolates are fruit pectin and de-ionised juice.\n\n(3) Despite subitem (2), V points may be scored for –\n\n (a) fruit juice or vegetable juice as standardised in Standard 2.6.1 including concentrated juices and purees;\n (b) coconut flesh (which is to be scored as a nut), whether juiced, dried or desiccated, but not processed coconut products such as coconut milk, coconut cream or coconut oil; and\n (c) the water in the centre of the coconut.\n\n(4) Calculate the percentage of fvnl in the food in accordance with the appropriate method in Standard 1.2.10 and not the form of the food determined in accordance with clause 6 of this Standard.\n\n> Note: Editorial note:\n\n> Note: The effect of subitem (4) is to make it a requirement to determine the percentage of fvnl using only the appropriate method in Standard 1.2.10. For this subitem only, it is not necessary to consider the form of the food determined by clause 6 of this Standard.\n\n(5) Use Column 1 of Table 3 if the fruit or vegetables in the food product are all concentrated (including dried).\n\n \n\n> Note: Editorial note:\n\n> Note: For example, if dried fruit and tomato paste are the components of the food product for which V points can be scored, column 1 should be used.\n\n(6) Use Column 2 of Table 3 if –\n\n (a) there are no concentrated (or dried) fruit or vegetables in the food product; or\n (b) the percentages of all concentrated ingredients are calculated based on the ingredient when reconstituted (according to subclauses 3(3) or (4) of Standard 1.2.10); or\n (c) the food product contains a mixture of concentrated fruit or vegetables and non-concentrated fvnl (after following the formula mentioned in subitem (8)); or\n (d) the food product is potato crisps or a similar low moisture vegetable product.\n\n(7) Work out the V points (to a maximum of 8) in accordance with Table 3.\n\nTable 3\n\nV Points\n\n| | Column 1 | Column 2 |\n| ------ | ---------------------------------- | -------- |\n| Points | % concentrated fruit or vegetables | % fvnl |\n| 0 | <25 | ≤40 |\n| 1 | ≥25 | >40 |\n| 2 | ≥43 | >60 |\n| 5 | ≥67 | >80 |\n| 8 | =100 | =100 |\n\n(8) If the food product contains a mixture of concentrated fruit or vegetables and non-concentrated fvnl, the percentage of total fvnl must be worked out as follows –\n\n| | x | 1001 |\n| --- | --- | ---- |\n\nwhere –\n\n> %non-concentrated fvnl/concentrated fruit or vegetables means the percentage of fvnl in the food determined using the appropriate calculation methods outlined in Standard 1.2.10.\n\n(9) For the formula in subitem (8), potato crisps and similar low moisture vegetable products are taken to be non-concentrated.\n\n5 Protein points (P points)\n\n(1) Use Table 4 to determine the ‘P points’ scored, depending on the average quantity of protein in 100 g or 100 mL of the food product (based on the units used in the nutrition information panel). A maximum of five points can be awarded.\n\n(2) Food products that score ≥13 baseline points are not permitted to score points for protein unless they score five or more V points.\n\n \n\nTable 4\n\nP Points\n\n| Points | Protein (g) per 100 g or 100 mL |\n| ------ | ------------------------------- |\n| 0 | ≤1.6 |\n| 1 | >1.6 |\n| 2 | ≥3.2 |\n| 3 | >4.8 |\n| 4 | >6.4 |\n| 5 | >8.0 |\n\n6 Fibre points (F points)\n\n(1) Use Table 5 to determine the ‘F points’ scored, depending on the average quantity of dietary fibre in 100 g or 100 mL of the food product (based on the units used in the nutrition information panel). A maximum of five points can be awarded.\n\n(2) The prescribed method of analysis to determine total dietary fibre is outlined in clause 18 of Standard 1.2.8.\n\nTable 5\n\nF Points\n\n| Points | Dietary fibre (g) per 100 g or 100 mL |\n| ------ | ------------------------------------- |\n| 0 | ≤0.9 |\n| 1 | >0.9 |\n| 2 | >1.9 |\n| 3 | >2.8 |\n| 4 | >3.7 |\n| 5 | >4.7 |\n\n(3) Category 1 foods do not score F points.\n\n7 Calculating the final score\n\nCalculate the final score using the following formula –\n\nFinal Score = baseline points – (V points) – (P points) – (F points)","sortOrder":20},{"sectionNumber":"Schedule 6","sectionType":"schedule","heading":null,"content":"## Schedule 6\n\nRequired elements of a systematic review\n\nA systematic review must include the following elements –\n\n1 A description of the food or property of food, the health effect and the proposed relationship between the food or property of food and the health effect.\n\n2 A description of the search strategy used to capture the scientific evidence relevant to the proposed relationship between the food or property of food and the health effect, including the inclusion and exclusion criteria.\n\n3 A final list of studies based on the inclusion and exclusion criteria. Studies in humans are essential. A relationship between a food or property of food and the health effect cannot be established from animal and in vitro studies alone.\n\n4 A table with key information from each included study. This must include information on –\n\n (a) the study reference\n (b) the study design\n (c) the objectives\n (d) the sample size in the study groups and loss to follow-up or non-response\n (e) the participant characteristics\n (f) the method used to measure the food or property of food including amount consumed\n (g) confounders measured\n (h) the method used to measure the health effect\n (i) the study results, including effect size and statistical significance\n (j) any adverse effects.\n\n5 An assessment of the quality of each included study based on consideration of, as a minimum –\n\n (a) a clearly stated hypothesis\n (b) minimisation of bias\n (c) adequate control for confounding\n (d) the study participants’ background diets and other relevant lifestyle factors\n (e) study duration and follow-up adequate to demonstrate the health effect\n (f) the statistical power to test the hypothesis.\n\n6 An assessment of the results of the studies as a group by considering whether –\n\n (a) there is a consistent association between the food or property of food and the health effect across all high quality studies\n (b) there is a causal association between the consumption of the food or property of food and the health effect that is independent of other factors (with most weight given to well-designed experimental studies in humans)\n (c) the proposed relationship between the food or property of food and the health effect is biologically plausible\n (d) the amount of the food or property of food to achieve the health effect can be consumed as part of a normal diet of the Australian and New Zealand populations.\n\n7 A conclusion based on the results of the studies that includes –\n\n (a) whether a causal relationship has been established between the food or property of food and the health effect based on the totality and weight of evidence; and\n (b) where there is a causal relationship between the food or property of food and the health effect:\n (i) the amount of the food or property of food required to achieve the health effect\n (ii) whether the amount of the food or property of food to achieve the health effect is likely to be consumed in the diet of the Australian and New Zealand populations or by the target population group, where relevant.\n\n8 An existing systematic review may be used if it is updated to include –\n\n (a) the required elements 1 to 6 above for any relevant scientific data not included in the existing systematic review\n (b) the required element 7 above incorporating the new relevant scientific data with the conclusions of the existing systematic review.\n\n \n\nAmendment History\n\nThe Amendment History provides information about each amendment to the Standard. 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 a compilation of Standard 1.2.7 as in force on 18 January 2016 (up to Amendment No. 159). It includes any commenced amendment affecting the compilation to that date.\n\nPrepared by Food Standards Australia New Zealand on 18 January 2016.\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 Standard 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 Legislative Instruments 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\nStandard 1.2.7 was published in the Food Standards Gazette No. FSC 80 on 18 January 2013 as part of Amendment No. 138 (F2013L00054 –\\- 7 January 2013) and has since been amended as follows:\n\n| Clause affected | A’ment No. | FRLI registrationGazette | Commencement(Cessation) | How affected | Description of amendment |\n| --------------- | ---------- | --------------------------------------- | ----------------------- | ------------ | ----------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------- |\n| Part 1 | 157 | F2015L013711 Sept 2015FSC 993 Sept 2015 | 18 Jan 2016 | ad | Editorial note after heading. |\n| 1 | 138 | F2013L0005014 Jan 2013FSC 8018 Jan 2013 | 18 Jan 2016 | rep | Editorial note before clause. |\n| 1 | 159 | F2015L019303 Dec 2015FSC1017 Dec 2015 | 7 Dec 2015 | ad | Editorial note after clause.See clause 1A of Standard 1.1.1 for transitional arrangements. |\n| 2 | 159 | F2015L019273 Dec 2015FSC1017 Dec 2015 | 7 Dec 2015 | ad | Definitions of ‘maximum claimable amount’ and ‘reference quantity’. |\n| 3(b) | 157 | F2015L013831 Sept 2015FSC 993 Sept 2015 | 3 Sept 2015 | am | Inclusion of reference to gluten content. |\n| 3(b) | 159 | F2015L019273 Dec 2015FSC1017 Dec 2015 | 7 Dec 2015 | rs | Paragraph to include a reference to salt or sodium content about a food that is not a beverage. |\n| 5 | 159 | F2015L019303 Dec 2015FSC1017 Dec 2015 | 7 Dec 2015 | am | Inclusion of new paragraph (d) to reference the Health Star Rating System. |\n| 18(1) | 150 | F2014L0142728 Oct 2014FSC9230 Oct 2014 | 30 Oct 2014 | am | Clause to correct missing subclause number. |\n| 18(1) | 159 | F2015L019303 Dec 2015FSC1017 Dec 2015 | 7 Dec 2015 | am | Paragraph (b) to correct typographical error. |\n| Sch 1 | 159 | F2015L019303 Dec 2015FSC1017 Dec 2015 | 7 Dec 2015 | am | Entries for lactose, salt and sodium and omega-3 fatty acids in relation to references to the nutrition information panel.See clause 1A of Standard 1.1.1 for transitional arrangements. |\n| Sch 1 | 159 | F2015L019273 Dec 2015FSC1017 Dec 2015 | 7 Dec 2015 | am | Entry for vitamin or mineral (not including potassium or sodium) to clarify its intent. |\n| Sch 3 | 150 | F2014L0142728 Oct 2014FSC9230 Oct 2014 | 30 Oct 2014 | am | Correct incorrect spelling of ‘utilisation’ in Part 1. |\n| Sch 5 | 159 | F2015L019303 Dec 2015FSC1017 Dec 2015 | 7 Dec 2015 | am | Clarify intent of subitems 2(1), 3(1), paragraph 4(6)(c), the headings to Tables 1 and 2 in relation to sugars, sodium, fatty acids and subitems 5(1) and 6(1).See clause 1A of Standard 1.1.1 for transitional arrangements. |\n| Sch 6 | 150 | F2014L0142728 Oct 2014FSC9230 Oct 2014 | 30 Oct 2014 | am | Correct incorrect punctuation marks. |","sortOrder":21}],"analysis":{"summary":{"complexity_score":9,"scope_assessment":{"changed":true,"description":"The original purpose of Standard 1.2.7 (first published in 2013 as Amendment 138) was to regulate nutrition content claims and health claims on food labels and advertisements — a focused, single-topic standard. However, subsequent amendments have expanded its scope in several directions. Amendment 159 (2015) incorporated the Health Star Rating system into the Standard (new clause 5(d)), bringing a parallel front-of-pack rating scheme within its regulatory framework. The same amendment added definitions and rules for 'maximum claimable amount' and 'reference quantity,' linking the Standard more tightly to the broader fortification regime in Standard 1.3.2. Amendment 157 extended the alcohol exception to include gluten and salt/sodium claims, adding further complexity to what was a straightforward prohibition. The notification pathway in clause 17(4)(b), which allows suppliers to self-certify new general level health claims based on their own systematic reviews (subject to FSANZ oversight), creates a quasi-regulatory approval mechanism within what was designed as a prescriptive list-based standard — representing a significant expansion of the regulatory model. The Standard also now extensively governs endorsement body governance (Division 3), which goes beyond labelling claims regulation into the structural independence requirements of third-party organisations — a scope arguably beyond simple claims control."},"complexity_factors":["Approximately 30+ defined terms in the interpretation section (clause 2), many of which cross-reference definitions in other Standards (1.2.8, 1.2.1, 2.10.2, etc.)","Six Schedules each with their own internal logic: Schedule 1 (nutrition content claim conditions), Schedule 2 (high level health claims), Schedule 3 (general level health claims in three Parts covering minerals, vitamins and other substances), Schedule 4 (NPSC categories), Schedule 5 (multi-step nutrient profiling scoring method with separate calculations for three food categories), Schedule 6 (systematic review methodology)","Tiered health claims framework with two parallel tracks for general level health claims (Schedule 3 pre-approved list OR notification pathway under clause 17(4)(b)), each with different procedural obligations","Nutrient profiling score calculation in Schedule 5 involves multiple sequential steps, conditional rules (e.g., baseline points calculation differs for Category 1/2 vs Category 3 foods, protein points cannot be scored above 13 baseline points unless V points ≥5), and a formula involving four independent sub-scores","Heavy reliance on external cross-references to at least 15 other Standards within the Food Standards Code (e.g., Standards 1.1.1, 1.2.1, 1.2.3, 1.2.8, 1.2.10, 1.3.2, 1.4.2, 2.4.1, 2.4.2, 2.5.4, 2.5.5, 2.6.1, 2.6.2, 2.8.1, 2.9.1, 2.9.3, 2.9.4, 2.10.2)","Nested conditional logic throughout: e.g., clause 11 operates with general conditions (Column 2) that are overridden by specific descriptor conditions (Column 4) when descriptors from Column 3 are used, with the specific prevailing over the general (subclause 11(4))","Multiple layered exemptions and exceptions: clause 3 prohibits claims on certain foods with sub-exceptions (e.g., alcohol foods can still carry gluten/energy/salt claims), clause 4 exempts certain supply contexts, clause 5 exempts certain types of claims, clause 26 exempts small packages from labelling requirements triggered by clause 25","Schedule 1 contains approximately 15 food properties, each with multiple permitted descriptors and distinct quantitative thresholds that differ between solid and liquid food, creating a matrix of over 40 individual conditions","Transitional arrangements operating concurrently (Standard 1.1A.8 and its interaction with clause 11), creating a parallel compliance pathway for dietary fibre claims during the transition period","The V points calculation in Schedule 5 (item 4) involves a conditional formula for mixed concentrated/non-concentrated fvnl ingredients, with separate columns in Table 3 depending on whether concentrated or non-concentrated ingredients are present, plus special rules for potato crisps and coconut products"],"plain_english_summary":"Standard 1.2.7 sets the rules for nutrition and health claims on food labels and advertising in Australia and New Zealand. It governs who can make such claims (manufacturers, suppliers, retailers, endorsing not‑for‑profits) and when products may say they’re “low,” “high,” or confer health benefits.\n\nIt matters because it prevents misleading marketing by requiring verifiable criteria, evidence for health links, limits on endorsements, and a nutrition-quality test so only genuinely nutritious foods can carry health claims."},"flash_summary":{"complexity_score":9,"scope_assessment":{"changed":true,"description":"The Standard’s scope has been amended since original publication. Amendments recorded in the Amendment History modify scope and application: e.g. inclusion of a reference to gluten content in clause 3(b) (Amendment No. 157), addition of a cross‑reference to the Health Star Rating in clause 5(d) (Amendment No. 159), and multiple clarifications to Schedule entries and nutrient profiling (Amendment Nos. 150 and 159). These amendments expand and clarify which foods and claims are covered and how labelling and declaration requirements operate."},"complexity_factors":["Dense definitions and cross‑references (clause 2 references multiple other Standards such as 1.2.8, 1.2.10 and 1.2.1) creating interpretive interdependence.","Extensive numeric thresholds and permitted descriptors in Schedule 1 (used by clause 11) covering many nutrients and multiple descriptor variants.","Two‑tier health‑claim regime with different pathways and evidence: high level (Schedule 2) vs general level (Schedule 3) plus notification based on systematic review requirements (clauses 17–19; Schedule 6).","Nutrient Profiling Scoring Criterion (NPSC) algorithm required for eligibility (clause 17(2), Schedule 4) and the multi‑step scoring method with V, P and F points in Schedule 5.","Category‑specific baseline scoring rules and category classification rules (Schedule 4 and Schedule 5 items 1–3) that materially change eligibility and label obligations.","Detailed labelling obligations where NPSC applies (clauses 24–26) including mandatory NIP declarations and special rules for small packages (clause 26).","Endorsement rules require independence and documentary proof with an information period and record retention/inspection duties (clauses 22–23 and 23(5)).","Comparative claim and ‘diet’ descriptors impose additional disclosure duties (clause 15) and limit permissible language (clause 9, clause 14).","Multiple specific exclusions and exceptions (e.g. kava, alcoholic products, infant formula, foods for further processing) dispersed across clauses 3–5 increasing scope complexity.","Administrative elements: CEO publication/notification duties and relevant authority inspection powers (clauses 17(4)(b), 18 and 23(1)(b)) create procedural compliance steps."],"plain_english_summary":"This Standard prescribes what nutrition‑content and health claims may appear on food labels and in advertising in Australia and New Zealand, and the conditions to use them (nutrient thresholds, NPSC scoring, schedule‑listed relationships). It also sets endorsement, record‑keeping and extra labelling obligations. Suppliers, importers and endorsing bodies must meet the specified wording, evidence (including systematic reviews) and testing or declaration steps before marketing a claim."},"kimi_summary":{"_metrics":{"model":"kimi-k2.5","source":"moonshot-realtime","completionTokens":2269},"content_quality":"ok","complexity_score":8,"scope_assessment":{"changed":false,"description":"The legislation maintains its original focus on regulating nutrition content claims, health claims and endorsements on food labels and advertisements as stated in clause 1. While the provided compilation includes amendment history and transitional arrangements (particularly regarding dietary fibre claims and implementation dates), these represent temporal adjustments rather than substantive expansion beyond the core purpose of controlling food marketing claims."},"complexity_factors":["Six detailed schedules containing tabular data with specific numerical thresholds for nutrients","Nutrient Profiling Scoring Criterion (NPSC) requiring mathematical calculation of baseline points, fruit/vegetable points (V), protein points (P) and fibre points (F)","Extensive cross-referencing to other Standards (1.2.8, 1.2.1, 1.2.10, 2.6.1, 2.9.1, etc.) for definitions and calculation methods","Conditional logic pathways based on three food categories (Category 1 beverages, Category 2 general foods, Category 3 cheese/oils/fats) with different scoring systems","Nested exceptions and exemptions (e.g., foods for further processing, hospital food, Part 2.9 standardised foods exempt from NPSC)","Dual pathways for general level health claims: pre-listed in Schedule 3 OR self-substantiated via systematic review per Schedule 6","27 defined terms including technical definitions like 'biomarker', 'fvnl' (fruit, vegetable, nut, legume), and 'serious disease'","Specific descriptor restrictions (e.g., descriptors for lactose and trans fatty acids restricted to listed synonyms only)","Requirements for comparative claims to identify reference foods and quantify differences","Systematic review requirements for self-substantiated claims requiring human studies, bias assessment and causal relationship demonstration"],"plain_english_summary":"This Standard controls what food companies can say about their products on labels and in ads. It sets the rules for two main types of claims:\n\n**1. Nutrition Content Claims**\nThese are statements about what's in the food (e.g., \"low fat,\" \"high fibre,\" \"reduced sugar\"). The Standard creates a dictionary of permitted words and the exact scientific thresholds required to use them. For example:\n- To claim \"low fat,\" a liquid food must contain less than 1.5g of fat per 100mL\n- To claim \"reduced\" anything, the food must have at least 25% less of that nutrient than a reference version of the same food\n- Comparative claims (like \"light\" or \"lite\") must identify what the food is being compared to and state the exact difference\n\n**2. Health Claims**\nThese suggest a food affects health (e.g., \"calcium strengthens bones\"). The Standard splits these into:\n- **High level claims**: About serious diseases (e.g., heart disease, osteoporosis) — strictly limited to specific food-disease combinations listed in Schedule 2\n- **General level claims**: About general health effects (e.g., \"iron reduces tiredness\") — must either be pre-approved in Schedule 3 or backed by a systematic scientific review notified to regulators\n\n**The Health Filter (NPSC)**\nBefore making any health claim, most foods must pass a nutritional \"health check\" called the Nutrient Profiling Scoring Criterion (NPSC). This is a mathematical formula that:\n- Adds \"bad\" points for energy, saturated fat, sugar and sodium\n- Subtracts \"good\" points for fruit/vegetable content, protein and fibre\n- Only foods scoring below specific thresholds (depending on category) can make health claims\n\n**What You Can't Claim**\n- No claims allowed on kava, infant formula, or alcoholic drinks over 1.15% alcohol (with minor exceptions)\n- No therapeutic claims (can't say a food prevents, diagnoses or cures disease)\n- No slimming implications for \"diet\" products\n\n**Endorsements**\nThird-party endorsements (e.g., \"Tick of Approval\") are allowed only if the endorsing body is independent, not-for-profit, and keeps records proving they permitted the use of their logo."},"issue_detection":{"absurdities":[{"type":"circular_definition","section":"Clause 13(3)","severity":"medium","reasoning":"Clause 13(3) conditions the nutrition content claim on the existence of a health claim about the same substance. A health claim is independently conditioned on NPSC compliance under clause 17(2). A food that does not meet NPSC cannot make the health claim, so it cannot make the nutrition content claim either. This is not itself circular in a strictly logical sense, but it creates a de facto trap: the nutrition content claim pathway is inaccessible unless the food independently qualifies for a health claim, making the nutrition content claim framework for these substances practically redundant for low-NPSC foods. The real absurdity is that the Standard establishes a separate, lighter-touch framework for nutrition content claims (no NPSC requirement for most properties) but then silently imposes full NPSC compliance on choline, fluoride and folic acid via the back door of clause 13(3).","confidence":0.82,"description":"A nutrition content claim about choline, fluoride or folic acid may only be made if a health claim about that substance is also made in relation to the same food. This creates a circular dependency: the health claim (Division 2) requires the food to meet the NPSC (clause 17(2)), but the only way to trigger the NPSC obligation for these three substances in the first place is to make a nutrition content claim about them (clause 13). A manufacturer who wants to make only a nutrition content claim about choline on a food that does not meet the NPSC cannot do so without simultaneously making a health claim — but that health claim independently requires NPSC compliance."},{"type":"self_contradicting","section":"Clause 16","severity":"high","reasoning":"The Standard creates a distinction between general level and high level health claims throughout (definitions in clause 2, separate schedules, different conditions). Yet clause 16 ensures that anyone seeking to ADD a new general level health claim must go through the high level variation process — the most demanding assessment pathway. The Standard defines two levels but then collapses them into one for the purpose of expanding Schedule 3. This is confirmed by the editorial note which acknowledges the effect. While this may be deliberate policy, it is logically self-contradicting within the Standard's own framework.","confidence":0.88,"description":"Clause 16 provides that an application or proposal to ADD a general level health claim to Schedule 3 is TAKEN TO BE an application for a HIGH LEVEL health claims variation. This means that the procedurally simpler 'general level' pathway is never actually available for new general level claims — every attempt to add one is automatically escalated to the more onerous high level variation process, rendering the two-tier distinction between general and high level health claims partially illusory for the purpose of adding new claims."},{"type":"other","section":"Schedule 1 – Saturated fatty acids, 'Free' descriptor","severity":"low","reasoning":"While regulatorily coherent (the drafter clearly intended to prevent a 'saturated fat free' claim on a food that has high trans fats), the structure is confusing because the descriptor 'saturated fatty acids free' does not signal to either the manufacturer or consumer that trans fatty acid levels are a condition. A food with zero saturated fatty acids but detectable trans fatty acids cannot claim to be 'saturated fat free'. This is an unexplained extension of the saturated fat claim into a different nutrient.","confidence":0.75,"description":"The 'free' descriptor for saturated fatty acids requires both (a) no detectable saturated fatty acids AND (b) no detectable trans fatty acids. However, trans fatty acids are a separate property of food listed elsewhere in Schedule 1, and the Standard also includes 'saturated and trans fatty acids' as a combined property. The 'saturated fatty acids free' descriptor silently absorbs the trans fatty acid condition, meaning a food could be labelled 'saturated fat free' and yet that claim is actually contingent on the trans fatty acid content — a fact invisible from the descriptor itself and potentially misleading to consumers."},{"type":"other","section":"Schedule 5, Item 5(2)","severity":"low","reasoning":"This is a deliberate policy choice but creates an arbitrary cliff-edge at 13 baseline points. A food at 13 points with 20g protein/100g scores zero P points, while the same food at 12 baseline points scores up to 5 P points — a 5-point swing in final score from a 1-point difference in baseline. This can make or break NPSC compliance and therefore the ability to make health claims.","confidence":0.7,"description":"Foods scoring ≥13 baseline points cannot score protein (P) points unless they also score 5 or more V points. However, V points max out at 8, and a food scoring 5 V points must contain >80% fvnl. A highly processed food with ≥13 baseline points and high protein content (e.g. a processed meat product) is effectively denied the protein credit that would otherwise reduce its final NPSC score, making it harder for that food to 'meet the NPSC' even if its protein genuinely contributes nutritional value. While this is deliberate policy design, the mechanical operation creates a cliff-edge: a food scoring exactly 13 baseline points gets no protein credit regardless of protein content, while a food scoring 12 gets full credit."},{"type":"retroactive_impossibility","section":"Editorial Note to Part 1 (transitional arrangement)","severity":"low","reasoning":"While not strictly retroactive, the transitional note embedded in the legislation creates a practical impossibility: the standard's own editorial note announces that a key transitional provision expires just 41 days after commencement. Any supplier who needed to update labels, reformulate, or obtain legal advice would find this window unrealistically short for meaningful compliance action. The Standard in effect announces its own partial obsolescence in its own editorial notes.","confidence":0.65,"description":"The Editorial Note states the transitional arrangement under Standard 1.1A.8 'commenced on 18 January 2016 and will cease on 1 March 2016'. This compilation is stated to be 'as in force on 18 January 2016'. The Note therefore describes a transitional window of only 41 days that begins on the very day of this compilation — and then refers to a 'revised Code' that 'will take effect' on 1 March 2016, suggesting the Code in front of the reader is already scheduled for replacement within weeks of coming into force. Suppliers reading this version had an extremely narrow window to rely on its provisions in their original form."},{"type":"other","section":"Clause 11(7) and Schedule 1 – Gluten","severity":"medium","reasoning":"Every other quantitative descriptor in Schedule 1 (low, high for GI; low for fat; etc.) has a defined numerical threshold. But the 'high in gluten' claim permitted by clause 11(7)(b) has no corresponding conditions — no minimum gluten level is specified. This creates an inconsistency: a manufacturer could label a food 'high in gluten' with any gluten content at all, as long as the food contains some gluten. This is particularly concerning given gluten's relevance to coeliac disease, which is explicitly referenced in the definition of 'gluten' itself.","confidence":0.85,"description":"Clause 11(7)(b) permits a claim that a food 'contains gluten or is high in gluten' without using a descriptor from Schedule 1 Column 3. However, Schedule 1 defines 'gluten free' and 'low' as the only specific descriptors for gluten. The Standard permits 'high in gluten' as a free-form claim under 11(7)(b) without specifying any conditions for that claim — unlike every other 'high' descriptor in the Standard which has quantitative thresholds. There is no defined threshold for what constitutes 'high' gluten content."},{"type":"other","section":"Clause 19(5) and Clause 19(3)(a)","severity":"medium","reasoning":"The policy rationale for the small package exemption is presumably limited label real estate. But the Standard only partially relieves this constraint: it removes the dietary context statement but retains the form-of-food statement obligation. More importantly, a health claim on a small package label without any dietary context statement could be more misleading than no claim at all — the very risk the dietary context requirement was designed to address.","confidence":0.78,"description":"Clause 19(3)(a) requires a dietary context statement to accompany every health claim. Clause 19(5) creates an exception: the dietary context statement need not be included on labels on food products in a small package. However, clause 19(3)(b) also requires a statement of the form of food — and no parallel exception is created for small packages in respect of that requirement. The asymmetric exemption means small package labels must still carry the form-of-food statement alongside the health claim, but not the dietary context statement — creating a health claim that floats without the contextualising information the Standard clearly considers important enough to mandate in all other circumstances."}],"contradictions":[{"severity":"medium","section_a":"Clause 17(2) – NPSC requirement for all health claims","section_b":"Clause 17(5) – NPSC exemption for Part 2.9 foods","confidence":0.72,"description":"Clause 17(2) states unconditionally that 'the food to which the health claim relates meets the NPSC' as a requirement for ALL health claims. Clause 17(5) then carves out foods standardised in Part 2.9 (special purpose foods) from this requirement. However, the structure of clause 17(1) states a claim must comply with subclause (2) AND either (3) or (4). Reading literally, subclause (2) is always mandatory, and (5) then contradicts it by saying Part 2.9 foods do NOT need to meet it. The contradiction is between the mandatory framing of (2) and the unconditional exemption in (5)."},{"severity":"medium","section_a":"Schedule 1 – 'Saturated fatty acids' Low descriptor (requires no more than 0.75g/100mL or 1.5g/100g of combined saturated AND trans fatty acids)","section_b":"Schedule 1 – 'Saturated and trans fatty acids' Low descriptor (same thresholds: no more than 0.75g/100mL or 1.5g/100g)","confidence":0.9,"description":"The Schedule 1 conditions for 'low saturated fatty acids' and 'low saturated and trans fatty acids' use identical numerical thresholds (0.75g/100mL for liquids, 1.5g/100g for solids) for the combined saturated and trans fatty acid content. This means the two descriptors — which purport to describe different properties of food — impose exactly the same quantitative test. A food that qualifies for 'low saturated fatty acids' automatically qualifies for 'low saturated and trans fatty acids' and vice versa, making the distinction between the two descriptors meaningless in practice."},{"severity":"medium","section_a":"Clause 3(b) – Nutrition content claims permitted for gluten on alcoholic beverages","section_b":"Clause 7 – Claims must not refer to prevention, diagnosis, cure or alleviation of a disease","confidence":0.68,"description":"Clause 3(b)(i) expressly permits nutrition content claims about gluten content on foods containing more than 1.15% alcohol by volume. The definition of 'gluten' in clause 2 explicitly references 'the medical conditions coeliac disease and dermatitis herpetiformis'. A gluten content claim on an alcoholic beverage will therefore inevitably suggest a relationship between the food's gluten content and these medical conditions — in tension with clause 7's prohibition on claims that refer to the alleviation of a disease, disorder or condition. The Standard permits the claim in clause 3 but the claim's subject matter (as defined in clause 2) necessarily implicates the disease-reference prohibition in clause 7."},{"severity":"low","section_a":"Clause 23(4) – Part 2 (other than clause 7) does not apply to endorsements","section_b":"Clause 23(1)(c) – Endorsements must comply with clause 7","confidence":0.8,"description":"Clause 23(4) states that Part 2 (other than clause 7) does not apply to endorsements — meaning clause 7 DOES apply to endorsements. Clause 23(1)(c) separately requires that the endorsement complies with clause 7. These provisions are not contradictory in isolation, but taken together they create redundancy: clause 23(1)(c) states the positive obligation (must comply with clause 7) while clause 23(4) achieves the same result via a double negative (Part 2 except clause 7 doesn't apply, therefore clause 7 does apply). The redundancy is harmless but reflects poor drafting that could cause confusion about whether clause 7 applies to endorsements once (via 23(1)(c)) or twice (via 23(1)(c) and 23(4))."},{"severity":"medium","section_a":"Clause 11(5) – Descriptors for lactose claims restricted to Schedule 1 Column 3 descriptors only","section_b":"Clause 11(8) – Any descriptor not in Column 3 may be used with properties of food in Column 1","confidence":0.73,"description":"Clause 11(8) provides a general permission that any descriptor not listed in Column 3 of Schedule 1 (including numeric descriptors) may be used with any property of food in Column 1, 'subject to this clause'. Clause 11(5) then restricts lactose and trans fatty acid claims to only the specific descriptors in Column 3 (or their synonyms). The tension arises because clause 11(8) says 'subject to this clause' — meaning the clause 11(5) restriction prevails — but the drafting is circular: clause 11(8) appears to grant a broad permission then clause 11(5) within the same clause takes it away for lactose, with neither provision clearly resolving whether a numeric descriptor (e.g. '2g lactose per 100g') constitutes a 'descriptor' caught by clause 11(5) or a factual statement permitted by clause 12."}]}},"importantCases":[],"_links":{"self":"/api/acts/f2013l00054","history":"/api/acts/f2013l00054/history","analysis":"/api/acts/f2013l00054/analysis","conflicts":"/api/acts/f2013l00054/conflicts","importantCases":"/api/acts/f2013l00054/important-cases","documents":"/api/acts/f2013l00054/documents"}}