Australia New Zealand Food Standards Code – Schedule 13 – Nutrition information required for food in small packages

The Schedule rests on three main structural concepts: claim-triggered disclosure, per-serving centric labelling, and cross-references to computation methods elsewhere in the Code.

1. Claim-triggered disclosure. The table in S13,2 ties the duty to disclose to the content of a label claim. If a claim is about a named nutrient, nutrient subclass, vitamin or mineral with an RDI, or other listed substance, the label must include the corresponding information in Column 2. The obligation is not a blanket nutrition panel requirement for all small packages; it arises when the label makes a qualifying claim. The Schedule therefore creates conditional disclosure duties that activate on the existence of particular claims.

2. Per-serving emphasis. Every entry in Column 2 requires the average quantity or average energy per serving of the food. For vitamins and minerals with an RDI, an additional related obligation is to state the percentage of the RDI contributed by one serving calculated under s 1.2.8,9. For several nutrient classes the Schedule requires multiple per-serving figures together (for example, saturated, trans, polyunsaturated and monounsaturated fatty acids together, where a claim touches certain fatty acid types). The Schedule therefore operationalises small-package nutrition information around the serving unit, not per 100 g or per 100 mL, although the Code elsewhere may require those measures for different contexts.

3. Cross-referenced computation methods. The Schedule deliberately delegates how to calculate particular figures to other Code provisions. Vitamins and minerals with an RDI require percentage RDI calculations in accordance with s 1.2.8,9. Carbohydrate-related entries require calculation of carbohydrate, sugars and dietary fibre per S11,4. The Schedule itself does not define serving sizes, RDI values, or analytical methods; it assumes adherence to the referenced sections of the Code for those details. It also references Standards 2.4.1 and 2.4.2 when distinguishing requirements for foods that are standardised in those Standards.

Other notable embedded concepts include cross-obligations between related nutrients. For example, a potassium-related claim requires the label to include “average quantity of sodium content per serving” whereas a sodium or salt claim requires average quantities of both sodium and potassium per serving (S13,2 table). Similarly, an omega-3 claim triggers a composite disclosure including both the broader fatty-acid profile and specific omega-3 species quantities and totals (S13,2 table, omega-3 row). These pairings show the Schedule’s intent to present comparative nutrient information rather than isolated single-nutrient figures in certain claim contexts.

Finally, the Schedule is limited to “food in small packages” and operates in tandem with Standard 1.2.8,14(1)(b), so its effect and scope must be read against the rest of the Code, the definitions and labelling placement rules in Standard 1.2.8 and the calculation rules in S11,4.

The Schedule’s primary legal addressees are persons who make or are responsible for nutrition-related claims on small-package food labels within jurisdictions where the Code applies. Practically, this means food manufacturers, brand owners, importers, private-label producers, and packaging designers who place claims on small packages that fall within the categories listed in the S13,2 table. The Schedule is part of the Code and, according to Note 1, is a Standard under the Food Standards Australia New Zealand Act 1991 (Cth). In New Zealand the relevant provisions of the Code are incorporated or adopted under the Food Act 2014 (NZ), (Note 2), so the Schedule is addressed to traders operating in both jurisdictions subject to local implementation arrangements.

Regulatory compliance professionals in food businesses will need to map existing claims to the table in S13,2 to determine which additional label elements must be provided. Where a claim mentions any nutrient or biologically active substance (other than vitamins/minerals with an RDI), the label must show the average quantity of that substance per serving. Where a claim concerns a vitamin or mineral with an RDI, the label must include average quantity per serving and the percentage of the RDI as calculated under s 1.2.8,9. Claims about fatty acids, cholesterol, carbohydrates, energy, omega-3 species, lactose, potassium, sodium or salt each trigger specific per-serving disclosures (S13,2 table). The schedule therefore affects product development teams and lab-testing budgets because the required analytical or compositional data must be obtained and recorded.

Retailers who sell small-package foods carrying qualifying claims are indirectly affected because their suppliers must supply compliant labels; wholesalers and distributors need to know whether transitional arrangements apply for stock-in-trade (see transitional provisions described under the Amendment instrument table). Regulators and enforcement officers are affected because S13,2 creates a discrete set of mandatory label items to check when inspecting small-package claims.

Consumers are an indirect affected group because the Schedule changes the information that must be available on small-package foods when claims are made. However, the Schedule does not itself define serving sizes or how serving sizes are presented; therefore the consumer-facing effect depends on the implementation of definitions and calculation methodologies in referenced sections of the Code.

Finally, note that the Schedule applies to “small packages”, a term the Schedule references but does not define itself. Practitioners must therefore consult Standard 1.2.8 and the rest of the Code to determine whether a particular package is within the “small package” scope that triggers application of S13,2.

Key duties created by Schedule 13 are duty-of-disclosure obligations that activate on the making of specific label claims for food in small packages. The Schedule’s table (S13,2) assigns an explicit labelling obligation to each class of claim. Each duty is stated in mandatory language: the label must include the specified item. The primary duties are:

• For a claim about any nutrient or biologically active substance other than a vitamin or mineral with an RDI, the label must include the average quantity of that nutrient or substance per serving (S13,2 table, first nutrient row).

• For a claim about any vitamin or mineral with an RDI, the label must include both the average quantity per serving and the percentage of the RDI contributed by one serving, calculated in accordance with s 1.2.8,9 (S13,2 table, vitamin/mineral row).

• For claims about polyunsaturated or monounsaturated fatty acids, or foods standardised in Standards 2.4.1 or 2.4.2, the label must show saturated fatty acids, trans fatty acids, polyunsaturated and monounsaturated fatty acids per serving (S13,2 table, fatty acids rows).

• For claims referencing cholesterol, saturated fatty acids, trans fatty acids, or omega-6/omega-9 fatty acids, the label must include average quantities of saturated fatty acids, trans fatty acids, polyunsaturated fatty acids and monounsaturated fatty acids per serving (S13,2 table).

• For claims about dietary fibre, sugars or any other carbohydrate, the label must include average energy per serving and the average quantities of carbohydrate, sugars and dietary fibre per serving, calculated according to section S11,4 (S13,2 table).

• For a claim about energy or “fat-free”, the label must include average energy content per serving (S13,2 table).

• For omega-3 fatty acid claims, the label must include a set of data: average quantities of saturated, trans, polyunsaturated and monounsaturated fatty acids per serving; average quantity of each omega-3 type per serving (alpha‑linolenic acid, docosahexaenoic acid, eicosapentaenoic acid or a combination); and the average total of omega-3 fatty acids per serving (S13,2 table).

• For lactose claims, the label must include average galactose per serving. For potassium claims, the label must include average sodium per serving. For sodium or salt claims, the label must include average sodium and potassium per serving (S13,2 table).

Rights: The Schedule does not explicitly create affirmative "rights" such as rights to exemptions or to private enforcement. It does, however, provide a transitional arrangement (recorded in the Amendment instrument table) enabling suppliers to comply with either the pre-amendment Code or the amended Code during the transition period from 1 March 2016 to 18 January 2017, and a stock-in-trade deeming provision for a 12-month period commencing on 18 January 2017 for items that complied before that date (transitional clause summary in the instrument table). This transitional arrangement functions as a time-limited operational right to choose one of two compliance regimes during the specified period, subject to the restriction that mixing of old and new rules is not permitted (instrument table, Clause 4(3)).

Obligations as to method of calculation are not fully specified in the Schedule itself; instead the Schedule requires parties to use calculation methods in other parts of the Code. For instance, percentage RDI calculations must follow s 1.2.8,9 and carbohydrate-related quantities must be calculated under S11,4 (S13,2 table). The practical duty therefore includes identifying and applying those calculation provisions and maintaining records to demonstrate compliance.

The Schedule does not set formatting, font-size, placement, or unit conventions. Those aspects are handled elsewhere in the Code. Practitioners must therefore treat S13,2 as specifying content obligations which must be implemented in the form and location required by other Code provisions.

Schedule 13 itself is a Standard under the Food Standards Australia New Zealand Act 1991 (Cth) (Note 1) and forms part of the Australia New Zealand Food Standards Code. The Schedule text does not contain express penalty provisions or administrative enforcement mechanisms. It therefore does not by itself prescribe fines, offences, or administrative sanctions for non-compliance; those mechanisms reside in the enabling legislation and the enforcement framework that applies to the Code in each jurisdiction.

Because the Schedule is part of the Code, failure to comply with its mandatory labelling requirements would constitute non-compliance with the Code. Enforcement and sanctions for non-compliance with the Code are matters for the relevant enforcement authorities administering food law in each jurisdiction. The Schedule notes that the Code provisions apply in New Zealand by incorporation or adoption under the Food Act 2014 (NZ) (Note 2), indicating that enforcement in New Zealand will be through the mechanisms of that Act and its implementing regulations. The Schedule itself does not list which enforcement body will act, what penalties will apply, nor what administrative powers will be used.

Practitioners should therefore treat enforcement risk as flowing from the Code’s status as a statutory Standard and should consult the Food Standards Australia New Zealand Act 1991, the companion enforcement legislation in each Australian state and territory, and the Food Act 2014 in New Zealand to determine the available remedies, penalty regimes and enforcement processes. The transitional instrument table indicates administrative discretion in transitional arrangement but does not allocate enforcement roles (Clause 4 summary).

In practice, enforcement tends to involve regulatory inspection of labels for required content and may involve requests for supporting documentation demonstrating the compositional calculations used to prepare a label. Schedule 13’s requirements are prescriptive about content (average quantities per serving; percentage RDI where applicable; cross-referenced calculation methods), so enforcement officers checking small-package claims will expect producers to provide supporting analytical data or calculation records consistent with the referenced Code provisions. However, the Schedule does not direct a specific evidentiary standard or procedure for enforcement action. For any formal enforcement consequences, consult the relevant food regulation enforcement framework applicable in the jurisdiction of sale.

Schedule 13 is explicitly linked to several other provisions of the Australia New Zealand Food Standards Code and to primary legislation that underpins the Code. The instrument’s Note 1 states that it is a Standard under the Food Standards Australia New Zealand Act 1991 (Cth), so its legal force derives from that Act and must be read in that statutory context. Note 2 states that Code provisions apply in New Zealand via incorporation or adoption under the Food Act 2014 (NZ), so for supplies in New Zealand the Schedule operates within the Food Act framework.

Within the Code, Schedule 13 is a specification for paragraph 1.2.8,14(1)(b) of Standard 1.2.8. The Schedule therefore interacts with all other parts of Standard 1.2.8 that define serving sizes, RDI values, labelling placement, and general nutrition declaration rules. The Schedule repeatedly cross-references other sections: the requirement to calculate percentage RDI follows s 1.2.8,9; carbohydrate, sugars and dietary fibre quantities are to be calculated in accordance with S11,4. The Schedule also refers to Standards 2.4.1 and 2.4.2 when distinguishing foods that are standardised in those Standards from those that are not, and prescribes different phrasing in the table depending on whether a food is standardised (S13,2 table, fatty-acid rows). These cross-references mean that Schedule 13 cannot be interpreted in isolation; its content obligations depend on the computation, definition and formatting rules elsewhere in the Code.

The transitional variation instrument discussed in the Schedule’s application and saving provisions interacts with section 1.1.1,9 of the Code by suspending its application to the listed variations for the transition period (instrument table summary, Clause 4(2)). The transitional clause also allowed suppliers to comply with either the previous Code or the amended Code during the specified transition period (instrument table summary, Clause 4(3)), but not to mix compliance regimes. The instrument also provided a stock-in-trade deeming arrangement for a 12-month period commencing on 18 January 2017 (instrument table summary, Clause 4(4)). These transitional mechanisms are part of the Schedule’s interaction with the amendment processes under the Food Standards Australia New Zealand Act 1991.

Because Schedule 13 is a Standard, it also interacts with state and territory enforcement regimes in Australia: enforcement of the Code is carried out by agencies in those jurisdictions under mechanisms enabled by the Food Standards Australia New Zealand Act and local implementation laws. The Schedule itself does not set those enforcement processes; it operates as a content Standard binding on entities supplying food where the Code applies.

For New Zealand, the Note makes explicit that the Code provisions are incorporated or adopted under the Food Act 2014, and so the Schedule’s labelling duties will be enforced under the statutory and regulatory architecture established by that Act.

Finally, the Schedule’s amendment history shows interactions with the Code’s amendment machinery and with other Standards: the Schedule arose as part of Amendment 154, then consequentially amended under Item [7] of a later Schedule amendment (Amendment No. 159) and further amended by Amendment No. 200 in June 2021 to substitute “sugars and dietary” with “sugars and dietary fibre” (Amendment History entries). These amendments exemplify how Schedule 13 interacts dynamically with the broader Code via the statutory amendment processes of the Food Standards Australia New Zealand Act 1991.

The Schedule provides an explicit amendment history detailing the instruments and dates by which it was altered and the transitional arrangements linked to those amendments. The compilation included in the source is No. 2 as in force on 3 June 2021 and lists amendments up to Amendment No. 200 (Prepared by Food Standards Australia New Zealand on 3 June 2021). The Schedule was originally published in the Food Standards Gazette No. FSC96 on 10 April 2015 as part of Amendment 154 (F2015L00483 - 2 April 2015) (Amendment History header).

Subsequent amendments recorded in the document include:

• Amendment No. 159 (FRLI registration F2015L01931), registered 3 December 2015 and gazetted 7 December 2015, with commencement 1 March 2016. This appears as a consequential amendment arising from amendments to Standard 1.2.7 and Schedule 4 and is recorded in the table to S13,2 as replacing the prior table (rs). The transitional variation instrument attached to this amendment contains Clause 4 which specifies a transition period from 1 March 2016 to 18 January 2017, suspends section 1.1.1,9’s application to the variations, allows for compliance with either the pre-amendment Code or the amended Code (but not a combination) during the transition period, and provides an exemption for stock-in-trade such that food that complied with the Code before 18 January 2017 is deemed to comply with the amended Code for a 12-month period commencing on 18 January 2017 (instrument table summary).

• Amendment No. 200 (FRLI registration F2021L00684), registered June 2021 and gazetted FSC1413 June 2021, with commencement 3 June 2021. This amendment amended the table to S13,2 by omitting “sugars and dietary” and substituting “sugars and dietary fibre” (Amendment History table entry; Action indicated as 'am'). The Amendment History records both the textual change and the commencement date.

The Schedule’s compilation notes that these amendments are made under section 92 of the Food Standards Australia New Zealand Act 1991 unless otherwise indicated, and that amendment entries do not have a specific cessation date unless indicated (Amendment History header). The compilation also warns that uncommenced amendments or provisions ceasing to have effect may be reflected in shaded boxed text in the Standard, but the current compilation is up to date as of 3 June 2021 (About this compilation).

The transitional variation accompanying Amendment No. 159 is the primary vehicle recorded in the Schedule for transitional relief. Clause 4 of that instrument establishes the 1 March 2016 to 18 January 2017 transition period, suspends section 1.1.1,9 for the variation, permits suppliers to choose between old and new compliance for that period, and establishes a 12-month stock-in-trade deeming period from 18 January 2017. These procedural amendment entries are critical for businesses handling stock produced around those changeover dates, and they demonstrate the administrative approach taken when revising labelling obligations for small packages.

Practitioners must therefore pay attention not only to the current text of S13,2 but also to the amendment instruments and their transition clauses, because those instruments create time-limited compliance options and exemptions that affect the legal obligations at given dates.

The Schedule text as provided contains no references to court decisions, tribunal determinations, administrative appeals, or other litigation. The instrument and its Amendment History identify amending instruments and transitional arrangements, but they do not cite any cases, regulatory actions, or judicial interpretations. Consequently, based on the source document alone, there is no litigation history recorded against Schedule 13 in this compilation.

The absence of litigation references in the Schedule means that practitioners cannot rely on judicially developed interpretations of its content or application from this document. Any interpretative issues,such as the meaning of “average quantity”, the definition of “small package”, the interaction between the potassium and sodium rows in the table, or how to apply the cross-referenced calculation methods in s 1.2.8,9 and S11,4,would need to be resolved by reference to the rest of the Food Standards Code, guidance materials published by Food Standards Australia New Zealand, or by seeking administrative clarification or judicial determination outside the Schedule. The Schedule’s own amendment history and transitional instruments do not contain adjudicative findings or precedent.

Practitioners seeking case law interpreting Schedule 13 should note that this Schedule is part of a broader regulatory regime and any relevant decisions could appear under more general Code interpretation litigation where courts or tribunals address labelling disputes, compliance actions, or enforcement proceedings relating to the Code. Those decisions would not be recorded in the Schedule itself; they would be found in jurisdictional case law databases and administrative decisions. The Schedule does not identify any such cases in the compilation provided.

Because the Schedule cross-references other Code provisions for calculations and definitions, litigation that clarifies the meaning of those referenced sections could indirectly affect how Schedule 13 is interpreted and enforced. The Schedule makes no express provision for private rights of action or for particular dispute resolution processes. Any enforcement or dispute would therefore proceed through the general enforcement pathways for the Code and relevant national or state regulatory frameworks, none of which are detailed in the Schedule text.

The Schedule contains several provisions that are likely to produce practical pitfalls for label preparers and compliance officers if not carefully observed. The following are discrete mechanical and interpretive “gotchas” grounded in the Schedule text itself.

1. Cross-obligation surprises. Some entries require disclosure of a different nutrient than the one claimed. For example, a claim about potassium requires the label to include the average quantity of sodium per serving, and a claim about sodium or salt requires average quantities of both sodium and potassium per serving (S13,2 table). These reciprocal requirements can be overlooked when preparing labels that focus only on the nutrient named in the claim.

2. “Fat-free” is not defined in the Schedule. The Schedule maps a “fat-free” claim to the obligation to display average energy per serving (S13,2 table, fat-free row). The Schedule does not specify whether any additional fat figures, or a zero-fat assertion, are required; the only listed mandatory item is average energy per serving. That means producers must check other Code provisions for definitions and qualifying criteria of the “fat-free” claim.

3. Heavy composite disclosure for small packages. Some claims trigger multiple, detailed figures to be presented on a small-package label. An omega-3 fatty-acid claim requires an itemised listing of saturated, trans, polyunsaturated and monounsaturated fatty acids per serving, plus the quantity of each named omega-3 species (alpha‑linolenic acid, docosahexaenoic acid, eicosapentaenoic acid or a combination) and the total omega-3 content per serving (S13,2 table). On small packages with limited space this creates formatting and legibility challenges because the Schedule requires a set of separate numeric entries rather than a simple statement.

4. Delegated calculation rules. Several entries require calculations to be performed in accordance with other Code sections. For vitamins/minerals with an RDI, percentage RDI must be calculated as per s 1.2.8,9; for carbohydrate-related entries, calculations must follow S11,4 (S13,2 table). Failure to use the precise methodologies and rounding conventions from those referenced provisions may produce non-compliance. The Schedule does not reproduce those methods, so practitioners must locate them in the Code.

5. “Small package” scope. Schedule 13 specifies requirements for food in small packages but does not define “small package” within the text provided. That definition is likely elsewhere in Standard 1.2.8. Misclassifying a package as small or not small can lead to incorrect labelling obligations being applied.

6. Transition phase complexity. The transitional instrument attached to the amendment permits a choice between the pre-amendment Code and the amended Code during a defined period (Clause 4(3) of the transitional variation), but prohibits mixing elements from both. Implementers must ensure that both labelling practice and manufacturing records consistently follow one regime during the transition, and must manage stock-in-trade deemed compliance for the 12 months from 18 January 2017 (instrument table summary). Failure to maintain consistent application could create enforcement exposure.

7. Ambiguity about units and presentation. The Schedule requires average quantities per serving and percentages of RDI, but it does not specify units (for example, mg vs g) or labelling format. Those presentation conventions are governed by other Code provisions or guidance, which must be consulted. Absent those conventions in the Schedule, inconsistent units or unclear labelling could lead to misinterpretation by enforcement officers.

8. Potential for inconsistent reading across entries. The Schedule treats foods standardised in Standards 2.4.1 or 2.4.2 differently in at least one row, and otherwise distinguishes between standardised and non-standardised foods for fatty-acid claims. Implementers must check whether a food is “standardised” under those referenced Standards; misclassification will produce incorrect disclosure obligations.

9. No penalty text in the Schedule. Because the Schedule does not specify penalties, implementers might assume that minor label deviations are immaterial; this is incorrect. The Schedule forms part of the Code and non-compliance will be assessed under the enforcement regimes that apply to the Code, which are not reproduced in the Schedule.

10. Typographical or editorial anomalies. The transitional instrument summary in the table references an exemption applying from “18 January 2007” in one passage (instrument table), which appears inconsistent with surrounding dates and likely intends 2017. The Schedule’s primary commencement date is 1 March 2016, and the transition period ends 18 January 2017; practitioners should verify instrument texts and commencement notices to avoid relying on apparent typographical errors in the compilation.

Each of these “gotchas” flows directly from the Schedule text and the cross-references it uses. The practical effect is that label preparation for small-package claims is a composite task: identifying the claim, mapping it to the right row in S13,2, applying the calculation method in the referenced Code sections, ensuring serving-size and unit conventions are correct, and presenting the required information legibly on the package. Missing any of those steps risks regulatory non-compliance.

Compliance with Schedule 13 is a procedural exercise that combines claim mapping, analysis against the Schedule table (S13,2), calculation using cross-referenced Code sections, and documentation to support the declared figures. The following sequence, grounded in the Schedule text and its cross-references, provides a practical compliance roadmap.

1. Identify whether the product is within the Schedule’s scope. Confirm that the product is a “food in small packages” as defined by Standard 1.2.8. The Schedule itself applies to paragraph 1.2.8,14(1)(b), so determine whether the package in question meets any “small package” definitions elsewhere in the Code. If the package is not a “small package” as defined, Schedule 13 will not apply.

2. Identify the claim. Determine precisely what claim appears on the small package that triggers S13,2. The Schedule’s obligations are claim-triggered. Map the claim to the appropriate row in the S13,2 table. Common claim types include claims about nutrients or biologically active substances, vitamins or minerals with an RDI, fatty acids, cholesterol, carbohydrate components, energy, fat-free, omega-3 species, lactose, potassium, and sodium/salt.

3. Determine the mandatory label items. For the mapped claim row in S13,2, list the mandatory items that the label “must include” (average quantity per serving; percentage RDI where required; average energy per serving; etc.). Note any multi-element requirements such as the fatty-acid composite or the omega-3 species breakdown.

4. Apply the calculation rules in the referenced Code sections. If the row requires calculations “in accordance with section 1.2.8,9” or “calculated in accordance with section S11,4”, obtain those sections and follow their prescribed methods, rounding rules, and units. The Schedule requires the percentage RDI for vitamins/minerals to be calculated per s 1.2.8,9 and carbohydrate-related quantities per S11,4. Record the exact calculation method used and the supporting laboratory or compositional data.

5. Determine serving size. Because the Schedule’s obligations are per serving, confirm the serving size rules that apply to the product under Standard 1.2.8. The Schedule does not define serving size; that definition and any rounding conventions will be in the other Code provisions. Use the Code-defined serving size consistently across all per-serving declarations.

6. Obtain analytical data or composition estimates. Where average quantity per serving must be declared, obtain laboratory analyses or validated compositional data to establish the mean quantity per serving. Maintain records of sampling plans, test methods, and calculations. For nutrients where the Schedule requires multiple elements simultaneously (for example, saturated, trans, polyunsaturated and monounsaturated fatty acids), ensure analytical methods provide all those figures to the required specification.

7. Prepare label text and layout in accordance with formatting and placement rules in Standard 1.2.8. The Schedule specifies the content but not the formatting, so comply with the Code’s overall labelling format, type size and placement rules. Ensure units and decimals comply with the Code’s conventions and that the percentage RDI figure is calculated using the Code-prescribed RDI values.

8. Transitional considerations. For products manufactured or labelled during the transition period (as specified in the transitional variation instrument), ensure that either the pre-amendment Code or the amended Code is applied consistently, but not a mixture of elements from both (instrument table summary, Clause 4(3)). For stock-in-trade produced before 18 January 2017, apply the deemed compliance rules for the stated 12-month period where relevant (instrument table summary, Clause 4(4)).

9. Record-keeping and audit trail. Keep documentary evidence demonstrating how each per-serving figure was calculated. This should include the claim mapping, analytical reports, calculation spreadsheets citing the relevant Code provisions (s 1.2.8,9, S11,4), serving-size determinations, and version control documenting which Code regime was followed during any transitional period.

10. Training and control of label artwork. Ensure the product development, regulatory, and marketing teams understand that making a claim triggers the S13,2 obligations. Implement approval controls over label artwork to prevent inadvertent claims that would create additional labelling obligations.

11. Seek clarification for edge cases. Where a claim straddles categories, or where the identity of a “biologically active substance” is uncertain, consult the broader Code definitions and guidance from Food Standards Australia New Zealand or the relevant enforcement agency. If necessary, seek written administrative advice from the regulator to reduce enforcement risk.

12. Monitor amendments. The Schedule has an amendment history and may be further amended. Maintain a compliance calendar and legal watch to capture future amendments and any transitional provisions that may affect stock-in-trade or label redesign timelines.

By following these steps and ensuring cross-referenced Code provisions are applied, businesses can produce small-package labelling that satisfies the content obligations set out in Schedule 13. The Schedule’s reliance on other Code sections for calculation and definition means that full compliance requires simultaneous adherence to those referenced provisions.