Australia New Zealand Food Standards Code – Standard 1.2.5 – Information requirements – date marking of food for sale

The Standard revolves around a small set of defined date concepts and rules about how those dates must be communicated on packaging. The definitions are the pivot for all obligations and are stated in s 1.2.5,2:

• Best-before date. Defined as the date up to which the food will remain fully marketable and retain any specific claimed qualities, provided the food remains in its intact package and is stored according to any applicable storage conditions in Standard 1.2.6. This definition ties the label claim to both packaging integrity and proper storage (s 1.2.5,2, definition of best-before date).

• Use-by date. Defined as the date after which it is estimated the food should not be consumed for health or safety reasons, again conditional on the package being intact and storage complying with Standard 1.2.6. This frames use-by as a safety-related threshold dependent on storage and packaging status (s 1.2.5,2).

• Baked-on and baked-for dates (bread only). The Standard gives specific definitions for bread: baked-on date is the date the bread was baked; baked-for date depends on whether the baking time is before or after midday , if baked before midday, the baked-for date is the baked-on date; if baked after midday, the baked-for date is the day after the baked-on date (s 1.2.5,2). The Standard illustrates that bread baked after midday on one day may carry a baked-for date that is the following day.

The Standard distinguishes between types of date marking information that count for labelling purposes (s 1.2.5,3(1)):

• If a use-by date exists, that is the date-marking information for labelling.
• Otherwise, any of: best-before date; or for bread with shelf life under seven days, best-before, baked-for or baked-on date.

Exceptions and special cases:

• No date-marking information required where best-before is two or more years after its determination, or the food is an individual portion of ice cream/ice confection , but the “infant formula product” exception prevents those exceptions from applying to infant formula products (s 1.2.5,3(2)).
• Small packages have a narrower requirement: if the food is in a small package, the only date-marking information required is the use-by date, if any (s 1.2.5,3(3)).

Formatting and wording rules are prescriptive (s 1.2.5,5):

• Specified wording: ‘Best Before’, ‘Use By’, ‘Baked For’ / ‘Bkd For’, ‘Baked On’ / ‘Bkd On’ (s 1.2.5,5(2)(a)).
• The wording must be accompanied by the relevant date or a reference to where the date is located on the label (s 1.2.5,5(2)(b)).
• Day must be numeric; month numeric or letters; year numeric (full or last two digits). The date must include at minimum day and month if the date is within three months from labelling, or month and year if more than three months from labelling, with rules to ensure components are clearly distinguishable (s 1.2.5,5(3)-(5)).
• The Standard permits additional dates or codes such as packed-on dates and manufacturer/packer codes (s 1.2.5,6).

Cross-references in the Standard are material to interpretation and compliance: “labelling provisions” referenced in s 1.2.5,3(1) are contained in Standard 1.2.1, and storage conditions that affect the meaning of best-before/use-by are contained in Standard 1.2.6. The instrument is presented as part of the broader Code and the definitions note indicates that expressions with an asterisk (for example, *use-by date) connect to the Code’s notation and cross-references.

The Standard applies to any food for sale that falls within the labelling requirements of the Code. The text repeatedly refers to “a food for sale” and “the labelling provisions” (s 1.2.5,3(1), note after that subsection), which locates the application within the Code’s regime of labelling obligations. Actors materially affected by the Standard are therefore:

• Food businesses that place food for sale with labelling, including manufacturers, packers, and importers who supply packaged goods to retailers. The Standard prescribes what must appear on a label where date marking is required (s 1.2.5,3(1), s 1.2.5,5).

• Retailers and other sellers of packaged goods. Retailers are constrained by the prohibition on selling food after its use-by date (s 1.2.5,4). Where use-by dates are present those are determinative for labelling purposes (s 1.2.5,3(1)(a)), and retailers must ensure goods offered for sale carry required date-marking information.

• Bakers and businesses selling bread. The Standard contains special definitions and options for bread with a shelf life of less than seven days, allowing a best-before, baked-for, or baked-on date as the label date-marking information (s 1.2.5,3(1)(b)(i)-(ii); s 1.2.5,2 definitions of baked-for and baked-on).

• Producers and packers of infant formula products. The Standard explicitly negates the general exemption for long-shelf-life best-before dates in the case of infant formula products: the exemption in s 1.2.5,3(2) does not apply to infant formula products. That means infant formula products must carry date marking information even where a best-before date is two years or more after determination (s 1.2.5,3(2) and opening phrase “Unless the food is an infant formula product”).

• Producers of ice cream and ice confection. The Standard makes an exception for individual portions of ice cream or ice confection in s 1.2.5,3(2)(b), indicating that individual portions of such products are excluded from the date marking information requirement.

• Label designers and compliance staff. Because the Standard prescribes exact words, permitted abbreviations (for baked-for/baked-on), and formatting rules for day/month/year, those responsible for label content and artwork must apply the exact phrasings and numeric/letter rules (s 1.2.5,5).

• Regulators and enforcement agencies. While the Standard itself does not set out enforcement mechanisms or penalty provisions, it is a Code standard made under the Food Standards Australia New Zealand Act 1991 (Cth) (note 1), and therefore it forms part of the legal requirements that regulators enforce under relevant Acts and local laws. The Standard also applies in New Zealand through incorporation or adoption under the Food Act 2014 (NZ) (note 2), so New Zealand regulators enforcing the Food Act are indirectly concerned.

The Standard’s cross-references (Standard 1.2.1 for labelling provisions and Standard 1.2.6 for storage conditions) mean that parties responsible for labelling must also consider those Standards to determine full compliance. The term “small package” used in s 1.2.5,3(3) is starred in the Standard, indicating its definition is elsewhere in the Code and must be checked by affected businesses to determine whether the small package rule applies.

This section sets out the operative duties imposed on food businesses by the text of the Standard and what limited rights or options the Standard confers to label makers.

Primary duties

• Date marking requirement. A food for sale must be date marked according to the labelling provisions and the rules in the Standard. For labelling purposes, the required date marking information is the use-by date if one exists; otherwise a best-before date, except that for certain breads with shelf life under seven days the labeller may use best-before, baked-for or baked-on date (s 1.2.5,3(1)). The duty to provide date-marking information applies unless a statutory exception in s 1.2.5,3(2) applies.

• Prohibition on selling after use-by. A seller must not sell a food after its use-by date (s 1.2.5,4). The Standard frames this prohibition in absolute terms: “A food must not be sold after its *use-by date.”

• Wording and form requirements. Where a date is provided, the label must use the exact prescribed wording for the date type (for example ‘Best Before’ or ‘Use By’) and may only express date marking information in accordance with s 1.2.5,5. That includes requirements that the wording accompany the date or a reference to where it is located on the label (s 1.2.5,5(2)(a)-(b)).

• Minimum date elements by time-to-date. The label must include day and month (at least) when the best-before/use-by date is not more than three months from the date it is applied, and at least month and year when it is more than three months from that date (s 1.2.5,5(4)). The day must be numeric; the month may be numeric or alphabetic; the year must be numeric and may be expressed as four digits or two (s 1.2.5,5(3)).

• Clarity of components. The day, month and year must be expressed so it is apparent which is which (s 1.2.5,5(5)).

Conditional duties and exceptions

• Exemptions for long shelf-life and individual ice cream portions. Unless the food is an infant formula product, date-marking information is not required if the best-before date is two years or more after the date it is determined, or if the food is an individual portion of ice cream or ice confection (s 1.2.5,3(2)). Thus the duty to label is conditional and depends on product type and shelf life.

• Small package rule. If the food is in a small package, the only date marking information required is the use-by date, if any (s 1.2.5,3(3)). This narrows labelling duties for small packages but only in relation to date marking; other labelling obligations in Standard 1.2.1 may still apply.

Rights and permitted options for label content

• Choice of date type when no use-by date. Where a use-by date does not exist, the labeller has an option to use the best-before date; for qualifying bread the labeller may choose best-before, baked-for or baked-on (s 1.2.5,3(1)(b)). That is a positive flexibility for short-life bread producers.

• Permitted abbreviations for baked terms. ‘Bkd For’ and ‘Bkd On’ are expressly permitted abbreviations in place of ‘Baked For’ and ‘Baked On’ (s 1.2.5,5(2)(a)(iii)-(iv)).

• Additional coding permitted. The Standard permits packed-on dates and manufacturer’s or packer’s codes to be added to the label in addition to the required date marking (s 1.2.5,6). That preserves business practices for traceability and internal coding.

Limits and linkage to other Standards

• Dependence on storage requirements. The meaning of best-before and use-by dates is conditional on the food remaining in its intact package and being stored in accordance with any storage conditions applicable under Standard 1.2.6 (definitions in s 1.2.5,2). Consequently, labelling duties are linked to compliance with storage conditions specified elsewhere.

• Labelling provisions elsewhere. The Standard treats date-marking information as one element of the Code’s broader labelling regime and refers readers to Standard 1.2.1 for the labelling provisions (note after s 1.2.5,3(1)). Duties under Standard 1.2.1 may be relevant to how date marking is presented in relation to other mandatory label information.

Mandates are precise and prescriptive. The Standard imposes mandatory words and specific formatting rules, leaves limited flexibility in choice of which date to present in certain scenarios (e.g. short-life bread), and creates a bright-line prohibition on sale after use-by date (s 1.2.5,4). The Standard does not contain explicit penalty provisions or enforcement procedures within its text.

The text of the Standard itself does not set out specific penalties or an enforcement scheme. The instrument is described as a standard under the Food Standards Australia New Zealand Act 1991 (Cth) and is part of the Australia New Zealand Food Standards Code (note 1). The Code’s standards are legal instruments that must be applied and enforced under the relevant federal, state and territory Acts and regulations, and in New Zealand through adoption or incorporation under the Food Act 2014 (NZ) (note 2). However, the Standard as provided contains no clauses establishing criminal offences, civil penalties, inspector powers, or administrative sanctions.

Consequently, the practical enforcement and sanctions that may flow from contravention of the Standard will arise under other legal instruments that give domestic force to the Code (for example, the enabling Acts and state-level or territory-level regulations or the New Zealand Food Act regime). The Standard is silent on:

• which enforcement agencies are responsible for monitoring or inspecting compliance with these date marking rules;
• the procedures for handling breaches of the Standard;
• the specific penalties, fines or remedies available for non-compliance.

Practitioners and compliance officers should therefore note two points grounded in the text:

• The Standard creates mandatory duties (for example the prohibition on sale after use-by date in s 1.2.5,4). Non-compliance with those duties will be actionable under the regulatory framework that adopts and enforces the Code in the relevant jurisdiction, but the Standard itself does not describe those remedies.
• The Standard cross-references other Standards and the enabling Act, which suggests that enforcement, penalty scales and administrative mechanisms are located in the wider legal framework that gives the Code effect. The code references (note 1 and note 2) indicate the legal provenance and that enforcement practice will depend on the domestic instrument that incorporates the Code.

Because the Standard does not provide an enforcement or penalty schedule, businesses and advisers should consult the relevant domestic legislation and enforcement agencies in each jurisdiction to identify:

• the statutory instruments that give the Code force in that jurisdiction;
• the offences or penalty provisions that apply for breaches of Code standards; and
• enforcement powers and procedures used by regulators who administer food safety and labelling law.

The Amendment History and compilation notes in the Standard document administrative changes and commencement dates for amendments, but they likewise do not specify enforcement measures. The Standard’s silence on penalties and enforcement in the text is itself material: obligations are precise, but the instrument expects enforcement to be located in the wider domestic regulatory framework rather than within the Standard.

This Standard does not operate in isolation; it forms part of the Australia New Zealand Food Standards Code and explicitly links to other Code provisions and national legislation. The following interactions are stated in the text:

• Enabling Act relationship. The Standard is made under the Food Standards Australia New Zealand Act 1991 (Cth) and is therefore part of the Code that the Act establishes (note 1). That connection indicates that the Standard’s legal force depends on the mechanisms in that Act and on the domestic law that incorporates and enforces the Code in each jurisdiction.

• Application in New Zealand. The document notes that the provisions of the Code that apply in New Zealand are incorporated in, or adopted under, the Food Act 2014 (NZ) (note 2). That means the same Standard’s content is brought within New Zealand law through that Act rather than directly by the FSANZ Act. Enforcement practices, penalty regimes and administrative arrangements in New Zealand will therefore follow the Food Act 2014 (NZ) and the way the Code is adopted under that Act.

• Labelling regime linkage. The Standard explicitly treats date-marking information as part of the labelling provisions and refers to Standard 1.2.1 for labelling requirements (note after s 1.2.5,3(1)). This signals that date marking must be considered alongside other mandatory label elements and design rules contained elsewhere in the Code. The cross-reference means obligations in Standard 1.2.1 (for example location of label elements, readability, language requirements) may affect how date marking is presented.

• Storage conditions in Standard 1.2.6. The definitions of best-before and use-by tie those concepts to storage conditions: each definition contains the condition that the food remains in an intact package during its storage and is stored in accordance with any storage conditions applicable under Standard 1.2.6 (s 1.2.5,2). Thus, the legal effect of a best-before or use-by date depends on compliance with storage requirements found in another Standard. Non-compliance with storage conditions may undermine reliance on the stated date.

• Code terminology and starred terms. The Standard uses starred expressions (for example *use-by date and *small package). The presence of the asterisk signals that those terms are governed by the Code’s terminology or defined elsewhere in the Code. Practitioners must consult the Code’s definitions (for example section 1.1.2,2 referenced in the Definitions note) and related Standards to locate the precise meaning of starred terms.

• Amendments and commencement procedures. The Standard’s Amendment History explains that amendments are made under s 92 of the FSANZ Act unless otherwise indicated, and that amendments do not have specific cessation dates unless indicated. This makes the Standard part of a dynamic Code where changes are effected through the legislative and administrative processes set out in the FSANZ Act. The compilation note also sets out that uncommenced amendments or provisions ceasing to have effect may be shown in shaded text in the published compilation, indicating an interaction between the Standard text and administrative publication practices (Amendment History section).

• Relation to traceability and internal coding. The Standard allows packed-on dates and manufacturer’s or packer’s codes to be present in addition to required date marking information (s 1.2.5,6). That preserves the ability of regulated entities to comply with traceability and product identification obligations that might be found in other parts of the Code or in other food safety laws.

Because the Standard references and depends upon other Code standards and national Acts for its application and meaning, proper legal compliance requires reading the Standard together with the Code’s definitions, the labelling Standard (1.2.1), storage requirements (1.2.6), and the domestic legislation that adopts and enforces the Code in a given jurisdiction.

The Standard includes explicit compilation and amendment details. The compilation presented is No. 3 of Standard 1.2.5 as in force on 3 June 2021 (up to Amendment No. 200). It was prepared by Food Standards Australia New Zealand on 3 June 2021. The document describes that amendments are generally made under section 92 of the Food Standards Australia New Zealand Act 1991 and that amendments do not have a specific cessation date unless so indicated.

The published history in the compilation lists three recorded amendments affecting particular sections:

• Amendment No. 157: Affected section 1.2.5,3(1). The FRL registration/Gazette entry is F2015L013741 Sept 2015 / FSC993 Sept 2015. The commencement date for that amendment is 1 March 2016. The table entry describes this amendment as a correction of typographical errors.

• Amendment No. 168: Affected section 1.2.5,3(2). The FRL registration/Gazette entry is F2017L0041411 April 2017 / FSC11013 April 2017. The commencement date for that amendment is 13 April 2017. The table entry notes this subsection was “rs” (repealed and substituted) and describes the amendment as a subsection to correct typographical errors.

• Amendment No. 200: Affected section 1.2.5,3(3). The FRL registration/Gazette entry is F2021L006842 June 2021 / FSC1413 June 2021. The commencement date for that amendment is 3 June 2021. The table entry describes the amendment as omitting ‘small package’ and substituting ‘*small package’.

Additional compilation metadata:

• The Standard was published in the Food Standards Gazette No. FSC96 on 10 April 2015 as part of Amendment 154 (F2015L00401 - 31 March 2015) and has been amended subsequently as listed.
• The compilation notes that uncommenced amendments or provisions ceasing to have effect may be reflected in the published Standard as shaded text with the relevant commencement or cessation date. Such administrative publication practices are noted but the compilation itself records only commenced amendments up to the compilation date.

Practical reading of the amendment history shows:

• The Standard has been subject to targeted, discrete amendments, largely described in the table as corrections (typographical or substitution), and one amendment that changed the wording regarding small packages to use a starred term (Amendment No. 200). The amendments listed are identified by section numbers and amendment numbers with commencement dates so that practitioners can determine which version applied at given times.

Users of the Standard should consult the FRL registration/Gazette notices referenced in the table entries if they need the formal notices or want to trace the exact textual changes made by each amendment. The compilation notes the exact FRL numbers and Gazette identifiers for each amendment.

The compilation of the Standard provided contains no case law, judicial decisions, or litigation references. The text of the Standard and the Amendment History do not record any litigation concerning the Standard. The document explicitly records administrative and amendment actions (Amendment Nos. 157, 168, 200) and commencement dates, but it does not reference any court decisions or tribunal determinations.

Given the absence of litigation references in the supplied text, the following points are supported by the compilation itself:

• There are no cases named or cited in the Standard as part of its internal text or notes. The Standard is presented as a Code instrument with definitions, operative requirements and administrative amendment history.

• The Amendment History and compilation were prepared by Food Standards Australia New Zealand and record amendments and commencement details, but they do not report any judicial consideration, challenges, or interpretative rulings.

For practitioners seeking judicial or administrative determinations about the Standard’s interpretation, validity, enforcement or interaction with other legal instruments, the Standard itself does not supply such material. To locate litigation or interpretative decisions, one would need to search external legal databases, tribunal records or court judgments for cases that reference Standard 1.2.5, but that task lies outside the text provided here.

This Standard is compact and prescriptive; a number of practical pitfalls flow directly from its wording and cross-references. The following are concrete issues and rules to watch, grounded in the text:

• Use-by date is determinative for labelling. If a product has a use-by date, that date is the date-marking information for labelling purposes (s 1.2.5,3(1)(a)). That means a product that carries both use-by and best-before would be labelled using the use-by date for labelling obligations under this Standard. Practitioners should not assume best-before can be substituted where a use-by exists.

• Bread timing rule. The baked-for date for bread depends on whether the bread was baked before or after midday. If baked after midday, the baked-for date is the following day (s 1.2.5,2, definition of baked-for date). That midday cut-off is a specific mechanical rule that can affect the date applied on bread labels and may be counterintuitive for businesses that do not track bake times precisely.

• Short shelf-life bread options. For bread with a shelf life of less than seven days, the label may display best-before, baked-for or baked-on (s 1.2.5,3(1)(b)). The Standard therefore allows substituted date representations for short-life bread but the choice must still comply with the wording and format rules in s 1.2.5,5.

• Infant formula carve-out. The exemption in s 1.2.5,3(2) for foods whose best-before date is two years or more after determination does not apply to infant formula products. Infant formula products therefore must carry date marking information even where the best-before date is long. This is an express statutory exclusion that increases labelling obligations for infant formula lines.

• Small package nuance. The Standard was amended to substitute the starred term ‘*small package’ in s 1.2.5,3(3). That implies the precise definition of “small package” is located elsewhere in the Code and may carry technical criteria. Entities relying on the small package rule (which narrows date marking to the use-by date only) must confirm whether their packaging meets the Code definition of *small package. Treat the starred term as a cross-reference rather than a plain English term.

• Day/month/year formatting requirements. The Standard requires the day be numeric, the month numeric or alphabetic, and the year numeric (s 1.2.5,5(3)). It requires minimum elements dependent on proximity of the date and insists components be expressed so it is apparent which number is which (s 1.2.5,5(4)-(5)). International date conventions (for example month/day formats used in some jurisdictions) could create ambiguity; the Standard’s clarity requirement means labellers must design date presentation to avoid misunderstanding.

• Mandatory wording and permitted abbreviations. The Standard prescribes the exact phrases ‘Best Before’ and ‘Use By’ and allows only specific wordings or abbreviations (‘Baked For’ or ‘Bkd For’, ‘Baked On’ or ‘Bkd On’) (s 1.2.5,5(2)(a)). Using alternative phrasings or non‑specified abbreviations risks non-compliance.

• The sale prohibition is absolute and not limited to packaged goods. Section 1.2.5,4 states “A food must not be sold after its *use-by date.” The provision does not limit the prohibition to packaged food or to products with intact packaging; the definition of use-by itself requires the food to remain in an intact package and be stored according to Standard 1.2.6 for the use-by to have the meaning provided (s 1.2.5,2). That interaction means sellers should be cautious about selling unpackaged products or goods whose storage status or packaging integrity is in doubt.

• Cross-standard dependencies create hidden compliance requirements. The definitions of best-before and use-by require storage in accordance with Standard 1.2.6 and package integrity (s 1.2.5,2). Labelling a food with a particular date therefore implicitly depends on the product’s storage instructions and the ability to maintain those storage conditions in practice. Failure to meet storage conditions may undermine the legal effect of the date marking.

• No enforcement text in the Standard. The Standard imposes precise duties but contains no enforcement provisions or penalties in its own text. Practitioners should therefore not assume the Standard supplies procedural detail on enforcement; that must be obtained from the domestic laws that adopt and enforce the Code.

• Packed-on and manufacturer codes permitted but not substitutes. Section 1.2.5,6 confirms packed-on dates and manufacturer/packer codes may be added, but these do not replace the requirement to provide the prescribed date marking where it applies. Any packed-on or coded information is supplementary.

These “gotchas” arise directly from the Standard’s precise wording and its cross-references. They highlight practical compliance traps where a superficial reading might lead to omission or mislabelling.

Compliance requires reading the Standard alongside the Code’s labelling and storage Standards and applying the precise words, formats and choices the Standard permits. The following stepwise operational checklist is grounded in the Standard’s text (cited sections shown):

1. Determine which date type applies to the food

   • If the food has a use-by date, treat that as the date-marking information for labelling (s 1.2.5,3(1)(a)).
   • If there is no use-by date, use a best-before date except for qualifying bread with shelf life <7 days, where best-before, baked-for or baked-on are permitted alternatives (s 1.2.5,3(1)(b)).

2. Check for statutory exemptions

   • If the best-before date is two years or more after the date it is determined, date marking is not required unless the food is an infant formula product (s 1.2.5,3(2)(a)).
   • If the product is an individual portion of ice cream or ice confection, date marking is not required (s 1.2.5,3(2)(b)).
   • Confirm whether the food is an infant formula product; if it is, the long-shelf-life exemption does not apply (s 1.2.5,3(2) opening).

3. For small packages, apply the small package rule

   • If the food is in a *small package (as defined elsewhere in the Code), the only date marking required is the use-by date, if present (s 1.2.5,3(3)). Verify whether your packaging meets the Code definition of *small package before relying on this rule.

4. Use the exact required wording

   • Use ‘Best Before’ for best-before dates and ‘Use By’ for use-by dates. For baked dates, use ‘Baked For’ or ‘Bkd For’ and ‘Baked On’ or ‘Bkd On’ (s 1.2.5,5(2)(a)). Ensure the chosen wording is adjacent to and accompanied by either the date itself or a reference to where the date is located on the label (s 1.2.5,5(2)(b)).

5. Format the date elements correctly

   • Day: numeric (s 1.2.5,5(3)(a)).
   • Month: numeric or letters (upper or lower case permitted) (s 1.2.5,5(3)(b)).
   • Year: numeric, in full or last two digits (s 1.2.5,5(3)(c)).
   • If the date is three months or less from the date of application, include day and month (s 1.2.5,5(4)(a)).
   • If the date is more than three months from the date of application, include month and year at minimum (s 1.2.5,5(4)(b)).
   • Express day, month and year so it is apparent which is which (s 1.2.5,5(5)). Avoid ambiguous layouts that could be misread across jurisdictions.

6. Ensure storage conditions and package integrity

   • The definitions of best-before and use-by predicates depend on the food remaining in an intact package and stored in accordance with any storage conditions applicable under Standard 1.2.6 (s 1.2.5,2). Verify storage statements on labels correspond to the storage conditions in Standard 1.2.6 and that supply chain practices maintain those conditions.

7. Apply the sale prohibition

   • Do not offer for sale any food after its use-by date (s 1.2.5,4). Institute stock rotation and inventory control procedures to prevent sale of products beyond their use-by dates.

8. Keep permitted supplementary information

   • You may add packed-on dates and manufacturer or packer codes in addition to the required date marking (s 1.2.5,6). Use these codes for internal traceability, but do not use them as a substitute for the required labelled date type and wording.

9. Align label design with broader labelling obligations

   • The Standard treats date marking as part of the labelling provisions; see Standard 1.2.1 for broader label requirements (note after s 1.2.5,3(1)). Ensure the date mark’s placement, legibility and prominence accord with the Code’s labelling rules.

10. Track amendments and definitions

• The Standard has been amended (see Amendment Nos. 157, 168, 200 in the Amendment History). The term ‘*small package’ is a starred term whose definition must be located elsewhere in the Code. Regularly check FSANZ compilations and the Federal Register for any further amendments or changes to definitions that affect compliance.

Practical suggestions, consistent with the Standard’s requirements:

• Maintain internal records showing how the relevant date (best-before or use-by) was determined, including testing or shelf-life studies, to support labelling decisions if questioned by regulators. Note: the Standard does not require such records; this is a best practice to manage regulatory risk.
• Institute clear bakery procedures that record bake times relative to midday to apply baked-for date rules accurately for bread when relevant (s 1.2.5,2).
• For products with long shelf lives, verify whether the product is classified as an infant formula product before relying on the two-year exemption (s 1.2.5,3(2)).

By following these steps anchored in the Standard’s text, businesses can operationalise the precise wording, formatting and presentation requirements and align product labelling and inventory controls with the Code’s date marking obligations.