Australia New Zealand Food Standards Code – Schedule 11 – Calculation of values for nutrition information panel

The Schedule operates around a small set of core technical concepts, each used to produce values to appear on the nutrition information panel (NIP) governed by Standard 1.2.8 (referred to throughout the Schedule).

• Average energy content (AE): the energy per 100 g of food. AE is calculated by summing the products of measured average quantities (Wi) of components, in g/100 g, and the applicable energy factor (Fi) in kJ/g for each component (S11,2(1)). The Schedule lists general and specific energy factors to apply (S11,2(2)-(3)). The Schedule also provides for conversion of AE to kilocalories per 100 g where allowed under Standard 1.2.8 (S11,2(4)).

• Components and average quantity (Wi): the Schedule uses the term “component” to mean measurable constituents of the food (S11,2(1)). “Average quantity” is the measure in g per 100 g of food used in the arithmetic. The Schedule requires the use of the measured average quantity for every component included in the calculation (S11,2(1); S11,3).

• Energy factors (Fi): fixed constants expressed in kJ per gram that convert a component’s mass to its energetic contribution. The Schedule distinguishes general components (alcohol, available carbohydrate, unavailable carbohydrate including dietary fibre, fat, protein) with stated factors (S11,2(2)), and specific components (polyols, isomers and sugar substitutes, organic acids, polydextrose etc.) with their own listed energy factors (S11,2(3)). The Schedule instructs use of the specific factor where a component is one of the listed specific components (S11,2(3)).

• Available carbohydrate and available carbohydrate by difference: two permitted modes for reporting carbohydrate. The Schedule defines available carbohydrate as a sum of measured available sugars and starch and, where quantified or added, available oligosaccharides, glycogen and maltodextrins (S11,3(1)). The “by difference” method reduces 100 per cent by measured percentages of enumerated constituents, including any specific components listed in S11,2(3) (S11,3(2)).

• Dietary fibre measurement methods: the Schedule requires the use of enumerated AOAC Official Methods of Analysis section numbers for total dietary fibre and for specific fibre types (S11,4(2)). It adopts AOAC International’s 21st edition (2019) as the reference (S11,4(4)). Where more than one analytical method is used, the Schedule prescribes mathematical aggregation with subtraction of any overlap to avoid double counting (S11,4(3)).

• Incorporation by reference: the Schedule directly incorporates external standards , the AOAC methods , as the authorised analytical procedures (S11,4(2)-(4)). The Schedule therefore binds labelling outcomes to both the Code and to those external method descriptions.

These concepts are procedural and technical: they convert laboratory or compositional measurements into the numeric panel values required by Standard 1.2.8, using fixed numeric conversion factors and prescribed analytical methods.

The Schedule affects any person or business required to prepare nutrition information panels under Standard 1.2.8 of the Food Standards Code. That group includes, at a minimum:

• Food manufacturers and packagers who label foods for sale in Australia and New Zealand, because the Schedule prescribes how AE and carbohydrate values must be calculated where they appear on the NIP (S11,2; S11,3). Producers who supply pre-packaged foods with an NIP will need to apply the arithmetic rules and energy factors in labelling.

• Food technologists and laboratory analysts, because the Schedule prescribes specific AOAC lab methods for determining total dietary fibre and named fibre fractions (S11,4(2)-(4)) and provides rules for combining results from multiple analytical techniques (S11,4(3)). Laboratories performing nutritional analysis for labelling must apply or map their methods to the enumerated AOAC methods and account for overlaps as required.

• Compliance and quality assurance staff, auditors and consultants engaged by manufacturers and importers, because the Schedule’s prescribed calculations and method references define compliance requirements to be tested under Standard 1.2.8 (S11,2-4).

• Importers of food into Australia and New Zealand and distributors who place food on the market with nutrition claims, because compliance with the Code (including Schedule 11) is a precondition for labelling legal saleable products in those jurisdictions. Note 2 expressly states that provisions of the Code that apply in New Zealand are incorporated in, or adopted under, the Food Act 2014 (NZ), so affected New Zealand participants must apply the same calculations where the Code applies in New Zealand.

• Regulators and enforcement agencies that administer and enforce the Food Standards Code at the Commonwealth and state/territory level, because the Schedule sets the technical standard they will apply when assessing the correctness of energy and carbohydrate figures in NIPs (Note 1 and S11,1).

• Nutrition-related product developers and formulators, because specific low-calorie sweeteners and polyols listed in S11,2(3) have lower energy factors and therefore will affect calculated AE and carbohydrate-by-difference outcomes. The Schedule’s specific listing of these substances (and the recent insertion of D-allulose, see Amendment History) matters to formulation decisions where labelling energy and carbohydrate numbers determine product positioning.

Who does not get new substantive duties from the Schedule itself: the Schedule does not set out enforcement penalties or procedures; those are governed by the broader legislative framework (the Schedule is a standard under the Food Standards Australia New Zealand Act 1991 and interacts with other parts of the Code and domestic enforcement laws) (Note 1; S11,1). The Schedule therefore primarily imposes technical measurement and calculation obligations on the labelling and testing side of the food supply chain.

The Schedule imposes a limited, technical set of duties and leaves other regulatory detail to the broader Code and enabling Acts. The main duties are as follows.

• Duty to use prescribed calculation for average energy content: where AE is required under Standard 1.2.8, the duty is to calculate AE in kJ/100 g using the formula that multiplies the measured average quantity (g/100 g) of each component by its energy factor (kJ/g) and sums across components (S11,2(1)-(3)). This is a mandatory arithmetic duty because AE “means” the value calculated using the equation in subsection (1).

• Duty to apply the correct energy factor: for each component included in the AE calculation, the duty is to apply the energy factor given for that component in the Schedule. General components have their listed factors (alcohol 29; carbohydrate excluding unavailable carbohydrate 17; unavailable carbohydrate including dietary fibre 8; fat 37; protein 17) (S11,2(2)). Specific components such as polyols, certain sugars and organic acids have their own factors and those must be used where relevant (S11,2(3)).

• Duty to calculate or report available carbohydrate according to one of the two provided rules: either sum measured available sugars and starch and quantified oligosaccharides/glycogen/maltodextrins (S11,3(1)), or use the by-difference method and subtract measured percentages of enumerated constituents from 100 (water; protein; fat; dietary fibre; ash; alcohol; any other unavailable carbohydrate if quantified or added; and substances listed in S11,2(3)) (S11,3(2)). The duty is a choice between methods but both are authorised; selection of a method should be deliberate and consistent.

• Duty to determine dietary fibre by specified analytical methods: when dietary fibre content is required under subsection 1.2.8,7(7) and S5,6(2), the duty is to use any one or more of the enumerated AOAC methods for total dietary fibre or for specific fibres as listed (S11,4(1)-(2)). The Schedule names exact AOAC section numbers and adopts AOAC International, twenty-first edition, 2019, as the reference (S11,4(4)).

• Duty to aggregate multiple fibre methods correctly: if more than one method is used, the total dietary fibre must be calculated by adding results from each method and subtracting any portion counted more than once to avoid double counting (S11,4(3)).

Rights and flexibilities embedded in the Schedule:

• Choice of analytical method within a specified set: the Schedule allows use of “any one or more” of the listed AOAC methods for dietary fibre, giving analysts choice among enumerated procedures provided those are the methods used (S11,4(2)-(4)).

• Choice of carbohydrate calculation approach: the Schedule offers two authorised ways to produce the available carbohydrate value (direct summation or by difference), permitting a lab or manufacturer to select the approach that best fits available analytical data (S11,3(1)-(2)). However, choice brings obligations to include or subtract the specific components as required by the chosen method.

• Conversion to kilocalories allowed where Standard 1.2.8 permits: AE may be expressed in kilocalories/100 g provided the conversion equation in subsection (4) is used to derive AE in kilocalories from AE in kilojoules (S11,2(4)).

Matters not specified here (and therefore not duties in this Schedule): rounding rules, sampling procedures, tolerances for labelling variances and enforcement and penalties are not set out in the Schedule and are to be sought elsewhere in the Code or in enforcement legislation. The Schedule’s duties are strictly the calculation and analytical method prescriptions it contains (S11,2-4).

The Schedule itself does not set out enforcement instruments, sanctioning mechanisms or civil/criminal penalties. It is a standard under the Food Standards Australia New Zealand Act 1991 (Cth) (Note 1) and part of the Australia New Zealand Food Standards Code; enforcement and penalties for non-compliance with Code standards are provided by domestic implementing and enforcement law rather than by this Schedule text.

Practical implications from the Schedule’s text:

• Non-compliance with the calculation rules or with the prescribed analytical methods as required when the NIP must contain AE, available carbohydrate or dietary fibre would constitute non-compliance with the relevant provisions of the Code (the Schedule repeatedly cross-references Standard 1.2.8 and specific sections such as 1.1.2,2, 1.2.8,4, 1.2.8,6(9)(a), 1.2.8,14(1)(c)(ii), 1.2.8,7(7) and S5,6(2)) (see S11,2 and S11,3 and S11,4). Enforcement consequences therefore flow from the statutory regime implementing the Code in each jurisdiction.

• The Schedule anchors the technical basis that regulators will use when assessing whether reported energy, carbohydrate and fibre figures on an NIP are correct. Although it does not enumerate penalties, regulators will typically test labelling against the Schedule’s equations and method references during inspections and compliance assessments. The Schedule’s requirement to use specific AOAC methods (S11,4(2)-(4)) and the specified energy factors (S11,2(2)-(3)) means laboratory and compositional evidence that deviates from those prescriptions will be vulnerable to enforcement action under the Code.

• The Schedule identifies no tolerance thresholds or acceptable deviation ranges. Because it is silent on tolerance and enforcement procedures, the exercise of sanctions, including any administrative or court action, depends on how the broader Code, and the enforcement laws in the relevant jurisdiction, allocate powers and impose penalties for breach.

Where to look for enforcement detail:

• The Schedule’s Note 1 identifies the enabling Act (Food Standards Australia New Zealand Act 1991 (Cth)), under which the Code is made. Enforcement, offences and penalties are matters for the enabling Act and for state and territory legislation that administers the Code domestically. The Schedule does not supply those provisions. Users seeking the exact penalty regime and enforcement mechanisms must consult the relevant parts of the Code, the FSANZ Act, and the domestic legislation under which the Code is administered.

The Schedule is designed to be a technical annex to and to operate within the broader architecture of the Australia New Zealand Food Standards Code and the enabling law. The Schedule itself cross-references and incorporates other parts of the Code and an external analytical compendium.

• Relationship with Standard 1.2.8 and other Code provisions: the Schedule exists to support Standard 1.2.8 (nutrition information requirements) and to give effect to calculation and measurement needs referenced in that Standard and elsewhere in the Code. The Schedule explicitly says it “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 sets out how to determine dietary fibre for subsection 1.2.8,7(7) and subsection S5,6(2); and lists substances for paragraph 1.2.8,6(9)(a) and subparagraph 1.2.8,14(1)(c)(ii)” (top explanatory text). The Schedule therefore interoperates with multiple sections of the Code that impose labelling or compositional obligations.

• Incorporation of AOAC methods by reference: S11,4(2)-(4) adopts specified Official Methods of Analysis of AOAC International, twenty-first edition, 2019, as the authorised laboratory methods for dietary fibre and specified named fibre analyses. This is an explicit incorporation by reference of an external standard-setting body’s methods into the Code. Laboratories and analysts must treat the AOAC methods as part of the legal standard to determine compliance with the Code in the areas S11,4 covers.

• New Zealand law: Note 2 states that the provisions of the Code that apply in New Zealand are incorporated in, or adopted under, the Food Act 2014 (NZ). That means the Schedule’s prescriptions take legal effect in New Zealand where the Code applies, through the domestic mechanism of adoption or incorporation under the NZ Act. The Schedule therefore functions cross-jurisdictionally, subject to the domestic mechanisms for giving effect to the Code in New Zealand.

• Enabling Act commencement and administrative interaction: S11,1 notes that the Standard commenced 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.” Those references show that the Schedule’s operation depends on formal commencement notices under the FSANZ Act and that administrative interaction with that Act governs how and when the Schedule becomes operative.

• Interaction with labelling obligations and cross-referenced Code provisions: the Schedule provides calculation and measurement rules but does not itself set labelling formats, rounding or tolerances. Those matters may be set out elsewhere in the Code (for example in Standard 1.2.8 or other labelling provisions). Users must therefore map the numerical outcomes produced under this Schedule into whatever labelling presentation, rounding and tolerances are required elsewhere in the Code.

• Amendment and edition control: S11,4(4) ties fibre analysis to a specific edition of an external standard (AOAC 21st edition, 2019). This creates a fixed reference point for methods that can interact with later changes in analytical science; accordingly, change management and amendments to the Schedule are relevant to keep law and analytical method alignment current. The Amendment History at the end of the Schedule shows prior amendments made under the FSANZ Act and how the Schedule has been changed over time.

In sum, the Schedule functions as a technical bridge between laboratory measurements (via AOAC methods) and legal labelling obligations (via Standard 1.2.8), and it is implemented under the FSANZ Act with parallel application in New Zealand through the Food Act 2014 (NZ) adoption mechanism (Note 1; Note 2; S11,4(4)).

The Schedule contains a published Amendment History summarised in the compilation accompanying the text. Key points in the amendment record as presented in the Schedule are as follows.

• Publication and commencement: Schedule 11 was published in the Food Standards Gazette No. FSC96 on 10 April 2015 as part of Amendment 154 (F2015L00481 - 2 April 2015). The Schedule’s commencement for the initial instrument is recorded as 1 March 2016 in S11,1 (Note Commencement).

• Post-publication amendments captured in the compilation up to 29 October 2024 (Compilation No. 6): the Schedule includes an amendment table that lists specific amendment numbers, FRL registration and Gazette references, commencement dates and brief descriptions of how the Schedule was altered. The amendments recorded include:

  • Amendment No. 168 (FRL F2017L00414, Gazette 11 April 2017): a correction to the structure of subsection S11,2(4), with commencement dated 13 April 2017. The table records this as “rs” (repealed and substituted).

  • Amendment No. 179 (FRL F2018L00655, Gazette 24 May 2018): omitted and substituted S11,4(2)(e) and (f), with commencement dated 24 May 2018.

  • Amendment No. 182 (FRL F2018L01594, Gazette 23 Nov 2018): omitted and substituted S11,4(2) and (3), with commencement dated 29 Nov 2018.

  • Amendment No. 200 (FRL F2021L00684, Gazette June 2021): omitted and substituted S11,2(1), with commencement dated 3 June 2021.

  • Amendment No. 205 (FRL F2022L00027, Gazette 14 Jan 2022): amended S11,4(2)(a) and S11,4(4) (AOAC reference), with commencement dated 20 Jan 2022.

  • Amendment No. 233 (FRL F2024L01377, Gazette 28 October 2024): added D-allulose to the table in S11,2(3), with commencement dated 29 October 2024 (entry shows “ad”: added or inserted).

• Compilation note and effective date: the text provided is compilation No. 6 as in force on 29 October 2024 and was prepared by FSANZ on that date, and it includes amendments commenced up to that date. The compilation notes that uncommenced amendments or provisions ceasing to have effect will be shown separately where applicable; the table entries above represent amendments that have commenced and affected the Schedule as of the compilation date.

• Scope of amendment descriptions: the table entries give brief descriptions (for example, “Correction to structure of subsection” or “Omitted and substituted S11,4(2) and (3)”), not the full details of the textual changes; to understand precise drafting changes one must compare versions or consult the amendment instruments listed by FRL registration and Gazette reference.

These amendment entries show that the Schedule has been subject to iterative technical updates since publication, including corrections to structure, updates to the list of acceptable analytical methods, substitution of subprovisions, and addition of new substances to the specific components table (notably D-allulose in 2024). Users should therefore rely on the most recent compilation or the Federal Register of Legislation instrument for the operative text and note that the Schedule’s content has been actively maintained.

The Schedule text contains no references to litigation, judicial decisions or case law applying or interpreting Schedule 11. It lists no cases, no judicial authorities, and the Amendment History describes administrative amendment instruments only.

Consequences of the absence of litigation references in the Schedule:

• No precedent contained in the instrument: because the Schedule does not record any cases, there is no internal jurisprudential guidance about how courts or tribunals have interpreted its equations, the application of energy factors, or disputes over AOAC method equivalence in labelling disputes.

• External litigation possible but not recorded here: the Schedule’s silence on litigation does not mean disputes have not occurred in practice; it only means that the Schedule document itself does not provide a litigation history. Where disputes arise about whether a manufacturer applied the correct energy factors or the correct AOAC method, issues would be determined under the enforcement provisions of the Code and by the relevant competent court or tribunal. Those decisions would need to be searched for in external case law databases or enforcement records.

• Policy and regulatory guidance may exist elsewhere: because the Schedule is technical, interpretive guidance, enforcement policy statements, or administrative determinations issued by regulators (which often inform how standards are applied in practice) are not included in the Schedule text but may exist in separate regulatory guidance. The Schedule itself does not include or cite such guidance.

Practitioners seeking litigation history or authoritative interpretations for use in compliance advice, defence in enforcement actions, or in contested administrative proceedings must therefore consult court and tribunal databases, regulatory decisions and agency guidance outside of the Schedule text. The Schedule provides the written standard that such decisions would apply, but not the interpretive case law.

The Schedule is concise but contains several technical points that commonly cause compliance traps if overlooked. These “gotchas” are directly grounded in the Schedule’s text.

• Different energy factors for specific components: the Schedule assigns alternative, often lower, energy factors for specific components such as erythritol (1 kJ/g), xylitol (14 kJ/g), polydextrose (5 kJ/g) and others (S11,2(3)). Using the general carbohydrate factor (17 kJ/g) instead of the specific factor for these components will overstate AE. The Schedule explicitly requires the specific factor where the component is one of those listed (S11,2(3)).

• Inclusion of unavailable carbohydrate in energy calculations: the Schedule distinguishes “carbohydrate (excluding unavailable carbohydrate)” with an energy factor 17 kJ/g, and “unavailable carbohydrate (including dietary fibre)” with energy factor 8 kJ/g (S11,2(2)). Misclassifying dietary fibre or resistant starch as available carbohydrate will distort both AE and carbohydrate-by-difference outcomes.

• Available carbohydrate by difference subtracts specific components: the “by difference” calculation requires subtraction of “a substance listed in subsection S11,2(3)” (S11,3(2)(h)). That means polyols and other specific substances with low energy factors must be subtracted when using the by-difference method if they are quantified or present. Failing to subtract them will produce an inflated available carbohydrate-by-difference value.

• Conditional inclusion phrases: several parts are conditional on the constituent being “quantified or added to the food” (S11,3(1) and S11,3(2)(g)). For example, available oligosaccharides, glycogen and maltodextrins are included in the available carbohydrate sum only if quantified or added (S11,3(1)). Similarly, “any other unavailable carbohydrate” is subtracted in the by-difference method only if quantified or added (S11,3(2)(g)). This conditional language requires a manufacturer to have measured or known quantities of these constituents to apply the rules correctly.

• Multiple methods require overlap subtraction: when more than one AOAC method is used to determine dietary fibre, the Schedule requires adding method results and subtracting any portion included more than once (S11,4(3)). Analytical laboratories must document method-specific results and demonstrate how overlap was identified and subtracted; failure to do so can produce double-counted fibre figures.

• Fixed AOAC edition: S11,4(4) specifies AOAC International, twenty-first edition, 2019. Laboratories that use a later AOAC edition without mapping to the specified edition risk non-conformance with the Schedule. Conversely, an updated Schedule amendment would be required to change the edition; analysts must therefore map any newer method to the prescribed edition or follow the Schedule’s specified edition.

• The Schedule is silent on rounding, tolerances and sampling: the Schedule prescribes calculation and analytical method rules but does not set rounding rules or permissible variances for declared values. Those are matters for the rest of the Code or implementing law. Practitioners should not assume rounding conventions from the Schedule alone.

• Conversion to kilocalories is permitted only by using the specific equation in S11,2(4): where Standard 1.2.8 allows expression in kilocalories, the Schedule requires that AE(C) be calculated in accordance with the equation in subsection (4) from AE(kJ) (S11,2(4)). Use of an alternative conversion method or rounding convention outside subsection (4) could be non-compliant.

• Recent amendments matter in formulation: D-allulose was added to the specific components table by Amendment No. 233 (29 October 2024) (Amendment History). Products using emerging sweeteners may therefore see labelling implications change when new substances are added to S11,2(3).

• Labels versus composition measurement timing: the Schedule’s arithmetic depends on the “average quantity” of a component in g/100 g. That requires appropriate sampling and averaging protocols which the Schedule does not itself specify. Manufacturers must ensure that compositional data used in these calculations reflect the appropriate average for the product as sold; otherwise, the calculated NIP may not reflect true average composition and regulators will assess compliance against the Code and enforcement law.

Each of the above points arises directly from the Schedule’s specific language (S11,2; S11,3; S11,4) and is a concrete operational risk for producing compliant nutrition labels.

Below is a step-by-step practical checklist, grounded in the Schedule’s provisions, for producing compliant AE, available carbohydrate and dietary fibre figures for the nutrition information panel required under Standard 1.2.8.

1. Confirm regulatory applicability and the relevant Standard cross-references.

   • Verify that the food is subject to Standard 1.2.8 and that the values you are producing are required by the Code sections cross-referenced in the Schedule (S11,2 intro; S11,3 intro; S11,4 intro).
   • If placing products in New Zealand, note that the Code provisions apply in New Zealand via adoption/incorporation under the Food Act 2014 (NZ) (Note 2).

2. Identify and document all components to be used in calculations.

   • Determine all components present in the product that will be part of the AE calculation: alcohol, protein, fat, available carbohydrate, unavailable carbohydrate including dietary fibre, plus any specific components listed in S11,2(3) (e.g. erythritol, xylitol, polydextrose, glycerol, organic acids, isomalt, D-allulose etc.) (S11,2(2)-(3)).
   • For available carbohydrate calculations, identify measured available sugars, starch and any available oligosaccharides, glycogen or maltodextrins if these have been quantified or added to the food (S11,3(1)).

3. Measure average quantities on a g/100 g basis.

   • Use validated compositional analysis and sampling to obtain the “average quantity” Wi for each component, expressed in g per 100 g of the food (S11,2(1)). Maintain records of methods, dates and laboratories used.

4. Apply the correct energy factors.

   • For each component, apply the energy factor Fi in kJ/g from the Schedule. Use the general energy factors for generic components (alcohol 29; carbohydrate excluding unavailable carbohydrate 17; unavailable carbohydrate including dietary fibre 8; fat 37; protein 17) unless the component is one of the specific substances with an alternate factor (S11,2(2)-(3)).
   • For example, if a product contains erythritol, use 1 kJ/g for erythritol rather than the general carbohydrate factor (S11,2(3)).

5. Calculate AE in kJ/100 g.

   • Compute AE by summing Wi × Fi across all N components measured, per the Schedule’s equation in subsection (1) (S11,2(1)). Keep a clear calculation spreadsheet showing each component, measured g/100 g, applied factor and product, with the summation documented.

6. Convert to kilocalories only where permitted and using the Schedule’s formula.

   • If Standard 1.2.8 allows expression in kilocalories, derive AE in kilocalories per 100 g by using the conversion equation required in S11,2(4) from the AE in kJ (S11,2(4)). Use the exact conversion equation in subsection (4) rather than ad hoc rounding.

7. Choose and document the carbohydrate calculation method.

   • Decide whether to use the direct available carbohydrate calculation (sum of available sugars and starch, adding quantified available oligosaccharides, glycogen and maltodextrins where applicable) (S11,3(1)), or the by-difference method (100 minus the measured average percentages of water; protein; fat; dietary fibre; ash; alcohol; any quantified or added other unavailable carbohydrate; and any substance listed in S11,2(3)) (S11,3(2)).
   • Document the reason for selecting the method (data availability, precision) and keep supporting analyses. Ensure that items conditional on being “quantified or added” are only included if you have measured figures (S11,3(1)-(2)).

8. Analyse dietary fibre using accepted AOAC methods and reconcile overlaps.

   • Use one or more of the AOAC Official Methods named in S11,4(2). For total dietary fibre use 985.29, 991.43, or 2017.16; for dietary fibre including resistant maltodextrins use 2001.03; for inulin and fructooligosaccharide use 997.08; for polydextrose use 2000.11; for resistant starch use 2002.02, etc. (S11,4(2)).
   • Ensure the laboratory states which AOAC method(s) were used and that the methods correspond to AOAC International, twenty-first edition, 2019, as adopted in S11,4(4).
   • If more than one method is used, compute total dietary fibre by adding results from each method and subtracting any portion that has been included more than once, and document how overlaps were identified and removed (S11,4(3)).

9. Keep full documentation and traceability.

   • Retain analytical reports, method references, sampling plans, calculation worksheets and versioned records showing the application of the Schedule’s energy factors and AOAC method numbers. These records are the primary evidence of compliance with the Schedule’s technical prescriptions (S11,2; S11,4).

10. Monitor changes and amendments.

• Track amendments to Schedule 11 (see Amendment History) because additions such as new listed substances (for example D-allulose, added by Amendment No. 233 on 29 October 2024) change which energy factors must be applied (Amendment History entry). Rely on the Federal Register of Legislation or FSANZ compilation to confirm the operative text.

11. Map results into the broader Code’s labelling rules.

• After deriving the AE, available carbohydrate and fibre figures, apply any additional presentation, rounding or tolerance rules contained elsewhere in the Code (Standard 1.2.8 or other relevant provisions). The Schedule is the calculation and analytical rules engine; presentation obligations are addressed elsewhere in the Code.

12. Where in doubt, seek technical confirmation.

• For novel ingredients, borderline analytical categories (for example, resistant maltodextrins, resistant starches, or new polyols), or when AOAC method applicability is not clear, consult an analytical laboratory experienced with the AOAC methods named in S11,4(2) and consider regulatory advice.

Following these steps will align production of AE, available carbohydrate and dietary fibre numbers with the Schedule’s legal requirements for calculation and analytical method use (S11,2; S11,3; S11,4).