{"id":"F2015L00414","name":"Australia New Zealand Food Standards Code – Standard 2.5.4 – Cheese","slug":"f2015l00414","collection":"legislative_instrument","jurisdiction":"commonwealth","status":"in_force","isInForce":true,"actNumber":null,"makingDate":null,"administeringDepartment":null,"currentVersion":{"id":315770,"registerId":"commonwealth-F2015L00414-current","compilationNumber":null,"startDate":"2026-04-08","status":"InForce","reasons":null,"registeredAt":null},"sections":[{"sectionNumber":"1","sectionType":"section","heading":"Australia New Zealand Food Standards Code – Standard 2.5.4 – Cheese","content":"![Description: FS_Logo_K](image.001.png)\n\nFood Standards (Proposal P1025 – Code Revision) Variation\n\nThe Board of Food Standards Australia New Zealand gives notice of the making of this standard under section 92 of the Food Standards Australia New Zealand Act 1991. The Standard commences on 1 March 2016.\n\nDated 25 March 2015\n\n![](image.002.png)\n\nStandards Management Officer\n\nDelegate of the Board of Food Standards Australia New Zealand\n\n> Note:\n\n> Note: This Standard will be published in the Commonwealth of Australia Gazette No. FSC 96 on 10 April 2015.\n\nStandard 2.5.4 Cheese\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\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\nNote 3 In Australia, dairy products must be processed in accordance with Standard 4.2.4.\n\n2.5.4—1 Name\n\nThis Standard is Australia New Zealand Food Standards Code – Standard 2.5.4 – Cheese.\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\n2.5.4—2 Definitions\n\nNote In this Code (see section 1.1.2—3):\n\ncheese means:\n\n(a) the ripened or unripened solid or semi-solid milk product, whether coated or not, that is obtained by one or both of the following processes:\n\n    (i) wholly or partly coagulating milk, or materials obtained from milk, or both, through the action of rennet or other suitable coagulating agents, and partially draining the whey which results from such coagulation;\n    (ii) processing techniques involving concentration or coagulation of milk, or materials obtained from milk, or both, which give an end-product with similar physical, chemical and organoleptic characteristics as the product described in subparagraph (a)(i); or\n\n(b) such a product with any of the following additional ingredients added during production:\n\n    (i) water;\n    (ii) lactic acid producing microorganisms;\n    (iii) flavour producing microorganisms;\n    (iv) gelatine;\n    (v) starch;\n    (vi) vinegar;\n    (vii) salt;\n    (viii) tall oil phytosterol esters added in accordance with this Standard.\n\nprocessed cheese means a product manufactured from cheese and products obtained from milk, which is heated and melted, with or without added emulsifying salts, to form a homogeneous mass.\n\n2.5.4—3 Requirement for food sold as cheese\n\nA food that is sold as cheese or processed cheese must be cheese or processed cheese as appropriate.\n\n2.5.4—4 Compositional requirement for tall oil phytosterol esters in cheese\n\nTall oil phytosterol esters may only be added to cheese or to processed cheese if:\n\n(a) the cheese or processed cheese contains no more than 12 g total fat/100 g; and\n\n(b) the tall oil phytosterol ester is added at no less than 70 g/kg and no more than 90 g/kg.\n\n\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_","sortOrder":0}],"analysis":{"kimi_summary":{"content_quality":"ok","complexity_score":3,"scope_assessment":{"changed":false,"description":"The legislation maintains its original narrow scope: defining cheese and processed cheese for food standards purposes. The 2016 revision (Proposal P1025) was a Code Revision that did not expand the substantive scope beyond the original intent of regulating cheese composition and labelling."},"complexity_factors":["Short length (approximately 1.5 pages of substantive content)","Only 2 defined terms ('cheese' and 'processed cheese')","Simple conditional structure with one specific exception (tall oil phytosterol esters)","Minimal cross-referencing (only refers to section 1.1.2—3 for definitions and Standard 4.2.4 for dairy processing requirements)","Clear, descriptive language without nested exceptions or complex logical operators","Single quantitative restriction (fat content and additive concentration limits)"],"plain_english_summary":"This standard defines what can be sold as \"cheese\" or \"processed cheese\" in Australia and New Zealand, specifying allowed ingredients, manufacturing methods, and limits on certain additives. It affects food manufacturers, importers, consumers and regulators by requiring products labelled as cheese to meet these definitions.\n\nNotably, a plant-derived cholesterol‑lowering additive (tall oil phytosterol esters) may be used only in low‑fat cheeses (≤12% fat) and at a tightly specified dose."},"flash_summary":{"complexity_score":4,"scope_assessment":{"changed":true,"description":"This instrument is a variation (Proposal P1025) that establishes the current Standard 2.5.4 definitions and a new compositional permission and limits for tall oil phytosterol esters. Concretely it changes the Code by specifying what may be sold as cheese (2.5.4–2, 2.5.4–3) and by permitting the additive only in cheeses ≤12 g fat/100 g at 70–90 g/kg (2.5.4–4), therefore altering the scope of permitted additives and compositional requirements for certain cheeses."},"complexity_factors":["Defined terms with broad phrasing — the cheese definition includes products with “similar physical, chemical and organoleptic characteristics,” which is subjective and may require case-by-case interpretation (2.5.4–2).","Numeric compositional limits and dosage bands — precise measurement of total fat (g/100 g) and tall oil phytosterol ester addition (g/kg) creates technical testing and quality-control obligations for manufacturers (2.5.4–4).","Cross-references to other law and standards — processing requirement for dairy products (Standard 4.2.4) and applicability in New Zealand under its Food Act create multi-regulatory compliance points (notes and 2.5.4–1).","Enforcement and verification burden — regulators must determine whether a product “is cheese” and verify additive concentrations, creating administrative and testing work for both industry and regulators (2.5.4–3, 2.5.4–4).","Narrow permitted use — the additive is allowed only in low-fat cheeses (≤12 g fat/100 g) and within a tight 70–90 g/kg range, which constrains formulation choices and may drive reformulation costs (2.5.4–4).","Instrument formality and commencement timing — as a gazetted variation with a set commencement date, businesses have a fixed lead time to comply (commencement note, 2.5.4–1)."],"plain_english_summary":"This Standard sets what counts as “cheese” and “processed cheese”, requires foods sold as cheese to meet that definition, and allows tall oil phytosterol esters only in cheeses with no more than 12 g total fat per 100 g at an addition rate of 70–90 g/kg. It commences 1 March 2016 and applies in Australia (and via adoption in New Zealand). \n\nAffected parties are dairy manufacturers and processors, who must meet the compositional limits and control additive use; regulators enforce those requirements and oversee compliance."},"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/f2015l00414","history":"/api/acts/f2015l00414/history","analysis":"/api/acts/f2015l00414/analysis","conflicts":"/api/acts/f2015l00414/conflicts","importantCases":"/api/acts/f2015l00414/important-cases","documents":"/api/acts/f2015l00414/documents"}}