Australia New Zealand Food Standards Code – Standard 1.5.3 – Irradiation of food

The core concept regulating this Standard is the notion of a positive permission list. Rather than setting performance standards for irradiation technologies or maximum residue limits, the Standard declares that only specified foods may be irradiated, and only for specified purposes, within specified dose ranges. This creates a binary legal status: if a food type is not named in sections 1.5.3‑3, 1.5.3‑4 or 1.5.3‑5, or if the dose falls outside the prescribed range, the irradiation is unauthorised and the food cannot be sold. The purpose condition is equally important - irradiating fresh fruit for bacterial decontamination, for example, is not permitted even if the dose falls within the 150 Gy‑1 kGy band, because section 1.5.3‑3(1) limits the purpose to pest disinfestation for a phytosanitary objective.

Dose is defined by absorbed energy per unit mass (Gy, kGy). The Standard sets both floors and ceilings for many permissions. For herbs and spices irradiated for bacterial decontamination, the absorbed dose must be no lower than 2 kGy and no higher than 30 kGy. That floor ensures the intended decontamination effect occurs, but it also prevents a business from labelling a product as irradiated for bacterial decontamination after a trivial dose that may not achieve the claimed purpose. The ceilings cap the permitted dose to avoid adverse chemical or nutritional changes that higher doses might cause, though the justifications for these caps are not stated in the text.

Another concept is phytosanitary objective. The Standard uses this term only for fresh fruit and vegetables. It connects to Australia’s and New Zealand’s international obligations under the International Plant Protection Convention and to domestic biosecurity regimes. Irradiation as a phytosanitary measure can replace chemical fumigation (e.g. methyl bromide) for export or import clearance. The permission is narrow: it does not extend to domestic pest control that has no biosecurity dimension.

Re‑irradiation is a distinct concept. It acknowledges that some processing chains may involve multiple irradiations: for example, an ingredient may be irradiated at source, then later incorporated into a composite food that is itself irradiated. The conditions in section 1.5.3‑6 set thresholds to prevent cumulative doses from exceeding safe levels. The 50 g/kg ingredient threshold means that if a food contains more than 5% by weight of previously irradiated ingredients, it cannot be re‑irradiated unless it meets the other conditions. This acts as a practical brake on batch‑level re‑irradiation of compounded foods.

The Standard also creates a record‑keeping obligation that attaches to the person who irradiates food. That obligation runs for the entire lifetime of the food plus one extra year. Since minimum durable life may be years for spices or dried herbal materials, the record‑keeping period can be long, imposing storage, retrieval and audit costs on the irradiating facility. The records must include dose data and prior irradiation history, making them essential for tracing compliance with the re‑irradiation rule.

Finally, the labelling concept is that the consumer must be told if irradiation has occurred. The statement must be to the effect that the food (or ingredient/component) has been treated with ionising radiation. This is a warning label in effect, though the Standard does not require a warning symbol, a detailed explanation, or a notice of any alleged risks. The note to section 1.5.3‑9 cross‑references Standard 1.2.1 for labelling provisions, meaning the statement can appear on the ingredients list or elsewhere, but the precise placement and wording are governed elsewhere.

The most directly affected class is commercial irradiators - businesses that own and operate cobalt‑60 irradiators, electron beam machines or X‑ray sources. Every such facility that treats food for the Australian or New Zealand market must comply with the dose limits, source restrictions, record‑keeping and labelling requirements. Because the Standard permits only three radiation source types (section 1.5.3‑7), any irradiator using a different technology - such as ultraviolet light or a higher‑energy electron beam - cannot lawfully treat food under this standard. The prescribed energy ceilings (5 MeV for X‑rays, 10 MeV for electrons, and 7.5 MeV for X‑rays with tantalum/gold targets) are technology constraints that directly limit capital investment decisions. Irradiators must purchase equipment that generates radiation within those parameters.

Second, upstream food producers and processors who wish to use irradiation as a preservation or disinfestation method are affected. A grower of fresh fruit or vegetables who wants to use irradiation as a domestic phytosanitary treatment must ensure the dose is within 150 Gy‑1 kGy and must not use it for bacterial decontamination. A spice importer may want irradiated spices to reduce microbial loads; that business must buy from irradiators who comply with the 2‑30 kGy dose band for bacterial decontamination and must check that the spice type is covered under the definition in section 1.5.3‑4(3). Similarly, manufacturers of herbal teas (excluding tea) can have their raw plant material irradiated, but only for sprouting/pest control (up to 6 kGy) or bacterial decontamination (up to 10 kGy). Any manufacturer wanting irradiated material not listed - for example, dried pulses, legumes, nuts or seeds - cannot lawfully irradiate them regardless of dose or purpose, because section 1.5.3‑3(3) expressly excludes those from the definition of fruit or vegetables.

Third, downstream food businesses that buy irradiated ingredients are affected through the labelling requirement. A bakery that uses irradiated spices must include a statement on the label that the ingredient has been treated with ionising radiation. The statement may be in the ingredients list or elsewhere. This is not optional. The cost of redesigning labels, updating packaging specifications and verifying supply chain data falls on those businesses. If they retail or supply catering outlets, they must also ensure unpackaged irradiated foods are disclosed to the consumer, as the note to section 1.5.3‑9 indicates the labelling provisions apply to both packaged and unpackaged irradiated foods.

Fourth, regulators and enforcement personnel - state and territory food safety authorities in Australia, and the Ministry for Primary Industries in New Zealand - must verify compliance. They inspect irradiator facilities, examine records, take samples to measure absorbed dose, and check labels. The record‑keeping requirement (section 1.5.3‑8) provides a compliance trail but also gives regulators a tool to discover unauthorised practices. The Standard interacts with each jurisdiction’s food legislation and the broader Food Standards Code, so enforcement actions can involve multiple layers of law.

Fifth, consumers are indirectly affected through increased product choice and price effects. Irradiation can enable greater shelf life and reduce spoilage, potentially lowering waste and price. However, mandatory labelling may stigmatise irradiated products and reduce consumer acceptance, dampening demand. Some consumers may avoid irradiated foods entirely, reducing the commercial incentive to use the technology. The Standard does not require consumer education or risk communication, so the labelling alone carries the burden of informing the market.

The central duty is to comply with the permissions in Division 2. Any person who irradiates food for sale must ensure the food type, the purpose of irradiation, and the absorbed dose are within the four corners of sections 1.5.3‑3, 1.5.3‑4, 1.5.3‑5 and 1.5.3‑6. There is no right to irradiate any food that is not listed, or to irradiate for a non‑permitted purpose, or to exceed the dose ceilings. The duty extends to ensuring the radiation source is one of those listed in section 1.5.3‑7. That duty is strict: ignorance of the food’s nature or the dose is not a defence.

A second duty applies to the person who irradiates food: they must create and maintain the records specified in section 1.5.3‑8(1). The records must be kept at the facility (subsection (2)) and for a period exceeding the minimum durable life by one year (subsection (3)). This means the irradiator must know the minimum durable life of every product treated and set up a retention schedule. The duty to keep records is not delegable; even if the irradiator contracts out the irradiation process, the person who actually irradiates is responsible. Failure to keep records is a breach of the Code and may attract penalties under the underlying legislation.

A third duty is imposed on any person who sells irradiated food (whether as a whole food or as an ingredient) at retail or to a catering business. That person must ensure the food bears a label statement indicating it has been treated with ionising radiation, as set out in section 1.5.3‑9. The duty falls on the seller at the point of retail or catering supply, not necessarily the original irradiator. A manufacturer who uses irradiated ingredients and sells a packaged food to a retailer must ensure the label complies. A butcher who buys irradiated spices for sale to consumers must ensure the statement appears on the label. If the food is unpackaged, the seller must still provide the information in some form, as the labelling provisions under Standard 1.2.1 apply.

There is no duty for consumers or intermediaries to prove the absence of irradiation. The legal expectation is that the industry, through the record‑keeping and labelling chain, self‑regulates compliance. The irradiator’s duty to record the dose and prior irradiation history supports the downstream seller’s duty to label correctly, but the seller may need to rely on supplier declarations or certificates.

The Standard confers no private rights of action. It is a standard under the Food Standards Australia New Zealand Act 1991 (Cth), and enforcement is through the regulatory apparatus of that Act and complementary state/territory and New Zealand legislation. Individuals cannot sue for breach of the Standard directly; they can only complain to a regulatory authority. However, a breach may be used as evidence in a civil claim for negligence or misleading conduct if the breach caused harm, but that would be indirect.

The right to use irradiation for permitted purposes is a right only in the sense that the prohibition is lifted. It is not a guaranteed right; regulatory changes could narrow permissions, remove food categories, or alter dose limits. Users should treat the permissions as temporary privileges subject to future amendments.

The Standard itself does not prescribe monetary penalties or imprisonment. It is a subordinate instrument under the Food Standards Australia New Zealand Act 1991 (Cth). Enforcement penalties for breaching a standard are found in that Act and in complementary state, territory and New Zealand food laws. Under the FSANZ Act, a person who contravenes a standard may be subject to civil penalties or criminal prosecution, depending on the jurisdiction and the nature of the breach. For example, under the Australia New Zealand Food Standards Code generally, the maximum civil penalty for an individual may be up to $444,000 (indexed) and for a body corporate up to $1.11 million, with criminal penalties potentially higher for intentional or reckless conduct. In New Zealand, the Food Act 2014 imposes fines of up to NZ$500,000 for individuals and NZ$5 million for bodies corporate for serious offences. These penalties apply to the irradiation permissions, record‑keeping and labelling duties.

Enforcement is typically triggered by routine inspections, targeted audits of irradiator facilities, product testing (to measure absorbed dose), or consumer complaints. Regulators such as the Australian Department of Agriculture, Fisheries and Forestry for phytosanitary issues, state food safety authorities, and the New Zealand Ministry for Primary Industries can take enforcement action. They may issue improvement notices, prohibition orders, seizure and destruction orders, or initiate prosecution.

The record‑keeping requirement under section 1.5.3‑8 is a key enforcement tool. If an irradiator cannot produce records showing the dose, lot identification, and prior irradiation history, the regulator can treat the food as non‑compliant. The burden of proof may then shift to the business to demonstrate compliance through alternative means, which is difficult. Failure to keep records is itself a breach, separate from any substantive irradiation permission breach. A business could be penalised for lacking records even if the irradiation was technically within dose limits.

For labelling, enforcement is straightforward: inspectors examine retail labels for the required statement. Omission leads to a breach of Standard 1.2.1 read with section 1.5.3‑9. Again, the penalty flows from the underlying Act. Repeat offenders may face escalating fines, and directors could be personally liable under state food acts that impose due diligence obligations.

Notably, there is no defence of reasonable mistake of fact for strict liability offences under many Australian food laws. Businesses may be liable simply because the food was irradiated without permission, even if they honestly believed it was exempt. The only practical mitigation is demonstrating that all reasonable precautions and due diligence were taken, but given the clear statement of permissions in the Standard, ignorance of the food type or dose is unlikely to succeed.

The Standard itself contains no enforcement powers. Enforcement is delegated to the existing regulatory machinery. This means that the practical severity of penalties depends on the jurisdiction and the regulator’s discretion. In high‑profile cases involving safety or trade, regulators may seek maximum penalties. For minor breaches, they may issue a warning or infringement notice with a lower fine.

This Standard is part of the Australia New Zealand Food Standards Code, and interacts with multiple other parts of that Code. The most immediate interaction is with subsection 1.1.1‑10(5)(d) and (6)(h), which create the default prohibition on irradiated food. Without this Standard, all irradiated food would be banned. The Standard provides the only route to lawfulness. It also interacts with subsection 1.1.1‑14(2) which makes mandatory any record‑keeping requirements set in the Code. Division 3 of this Standard sets those requirements, so the general section compels compliance with section 1.5.3‑8.

Standard 1.2.1 - Labelling of food requires the statements prescribed by section 1.5.3‑9 to appear on labels. The note to section 1.5.3‑9 directs practitioners to Standard 1.2.1 for the detailed labelling rules, such as legibility, format, and placement. The cross‑reference means that any change to Standard 1.2.1 automatically affects the presentation of irradiation statements. For example, if Standard 1.2.1 were to require a specific font size or warning symbol, that would apply to irradiation labels.

The Standard interacts with food import laws in both countries. The Imported Food Control Act 1992 (Cth) and the Biosecurity Act 2015 (Cth) in Australia, and the Food Act 2014 and Biosecurity Act 1993 (NZ) in New Zealand, set controls on imported food, including phytosanitary measures. The irradiation permissions for fresh fruit and vegetables are explicitly linked to a phytosanitary objective. Imported irradiated fruit or vegetables must comply with section 1.5.3‑3 to be lawful for sale. But they must also meet import conditions set by the relevant biosecurity department. If the importing country’s phytosanitary authority requires a different dose range (for example, a higher dose to kill a particular pest), the food cannot comply with both regimes simultaneously. The trader must choose between the phytosanitary requirement and the Code permission. In practice, the importing country may issue a specific import permit that overrides the Code, but the Standard does not address this.

The Standard also interacts with state and territory food acts. In Australia, each state and territory has adopted the Code as law, often with minor variations. Enforcement of the Standard occurs under those acts. For example, the Food Act 2006 (Qld) makes it an offence to sell food that does not comply with the Code. That means a breach of section 1.5.3‑3 or 1.5.3‑8 is a breach of Queensland law. Similarly, the Food Act 2003 (NSW) applies. In New Zealand, the Food Act 2014 adopts the Code as regulations. The same breach therefore has enforcement consequences under New Zealand law.

For re‑irradiation, the Standard interacts with existing food processing and ingredient supply contracts. A food manufacturer who buys irradiated ingredients must check the supplier’s irradiation history to determine if the ingredient itself has already been irradiated. If the ingredient was irradiated at a dose over 1 kGy, then the 50 g/kg rule may apply. The contract terms must require the supplier to disclose prior irradiation. Failure to do so could lead to a downstream business unknowingly violating the re‑irradiation rule, with regulatory consequences.

The Standard does not interact directly with workplace health and safety laws, but facilities using radiation sources must obtain licences from the Australian Radiation Protection and Nuclear Safety Agency (ARPANSA) or state environmental protection authorities under the relevant radiation control acts. The cobalt‑60 and X‑ray sources must meet separate safety standards for worker exposure. This Standard does not address worker safety, but using a non‑permitted source (e.g. an electron beam at 12 MeV) would breach this Standard even if the source is lawfully operated under radiation safety laws.

Standard 1.5.3 was originally published on 10 April 2015 in the Food Standards Gazette No. FSC96 as part of Amendment 154 (F2015L00406, registered 31 March 2015). It commenced on 1 March 2016. Since then, seven amendments have been made, each expanding or clarifying the permissions.

Amendment 157 (F2015L01374, registered 1 September 2015, Gazette FSC99, commenced 1 March 2016) added a table to subsection 1.5.3‑3(2) listing specific fruits and vegetables that were previously authorised under a separate permission (A1092). This incorporated earlier permissions into the new standard structure, ensuring continuity for traded commodities.

Amendment 166 (F2017L00025, registered 5 January 2017, Gazette FSC108, commenced 12 January 2017) added blueberries and raspberries to the table in subsection 1.5.3‑3(2). This expanded the range of fresh fruit that could be irradiated for phytosanitary purposes, likely driven by trade access negotiations for these berries.

Amendment 190 (F2020L00024, registered 15 January 2020, Gazette FSC131, commenced 17 January 2020) amended the permissions for irradiated herbs and spices in section 1.5.3‑4(3). The amendment added chives to the definition of herbs and spices and updated the list in Schedule 22. This broadened the range of herbs and spices that could be irradiated.

Amendment 201 (F2021L00983, registered 14 July 2021, Gazette FSC142, commenced 22 July 2021) amended section 1.5.3‑3 generally. The description in the amendment history states “Permissions for fresh fruit and vegetables”. The effect was likely to refine the permissions or add new items to the schedule, broadening the range of permitted produce.

Amendment 211 (F2022L01118, registered 26 August 2022, Gazette FSC151, commenced 1 September 2022) made two changes: it amended the definition of “vegetables” in subsection 1.5.3‑3(2) and the definition of “herbs and spices” in subsection 1.5.3‑4(3). This update aligned the definitions with the current Schedule 22, likely adding new commodities.

Amendment 230 (F2024L00986, registered 13 August 2024, Gazette FSC170, commenced 15 August 2024) repealed and substituted paragraph 1.5.3‑7(b), which deals with X‑ray source energy limits. The substituted paragraph now includes a specific provision that if the machine source uses tantalum or gold as target material, the energy level may be up to 7.5 MeV, rather than the general 5 MeV cap. This change reflects technological developments or safety assessments that allow higher energy X‑rays with those target materials while maintaining food safety.

The cumulative effect of these amendments is a gradual expansion of the list of commodities that can be irradiated and a minor adjustment to the permitted radiation source parameters. No amendment has narrowed permissions or reduced dose limits. The Standard has moved from a relatively restrictive set of permissions in 2015 to a more permissive regime in 2024, particularly for fruit, vegetables, herbs and spices. The trend reflects increased international trade acceptance of food irradiation and demands from industry for broader access.

The source text does not record any litigation history. The Amendment History and the Standard itself mention no court cases, tribunal decisions, or judicial review proceedings. This absence is consistent with food irradiation being a niche, low‑litigation area. Since the Standard is a detailed technical instrument with clear rules, disputes may be resolved through regulatory enforcement rather than private litigation.

However, it is worth noting that the Standard could be challenged on procedural grounds under the FSANZ Act. For example, an application for judicial review of a FSANZ decision to amend the Standard could allege that the Authority failed to follow the required assessment process, or that the amendment is ultra vires the Act. No such challenge appears in the public record. Similarly, a person prosecuted for selling unirradiated food labelled as irradiated could defend by arguing the food was not actually irradiated, but that would be a factual dispute rather than a test of the Standard.

The lack of reported litigation does not mean the Standard has been dispute‑free. Many enforcement actions are resolved by infringement notices or administrative orders that do not reach courts. Also, international trade disputes about irradiation standards may occur under the WTO Sanitary and Phytosanitary Agreement, but those are not domestic litigation under this Standard. The absence of litigation history suggests that the irradiation permissions and record‑keeping obligations are clear enough that businesses comply or settle with regulators rather than litigate.

For practitioners advising clients, this absence means there is no body of case law interpreting specific phrases (e.g., “pest disinfestation for a phytosanitary objective” or “specific technological reason” in the re‑irradiation condition). Regulatory guidance from FSANZ or state authorities is therefore the primary interpretive aid. In the event of litigation, a court would apply ordinary principles of statutory construction to the text of the Standard and the broader Code.

Several provisions in the Standard can trap the unwary. The first is the exclusion of dried pulses, legumes, nuts and seeds from the definition of fruit and vegetables for the purposes of section 1.5.3‑3 (subsection (3)). A business that wishes to irradiate chickpeas, almonds or lentils for phytosanitary or decontamination purposes cannot rely on the fruit and vegetable permission, even if those items are botanically fruits or seeds. They are not permitted under any other section, so their irradiation is illegal. The only way around this is to apply for a variation of the Standard through FSANZ’s amendment process, which takes months or years.

The second gotcha is the purpose limitation in section 1.5.3‑3(1): fresh fruit and vegetables may only be irradiated for pest disinfestation for a phytosanitary objective. Irradiating them for bacterial decontamination, shelf‑life extension, or sprout control is not permitted, even within the 150 Gy‑1 kGy dose band. The dose band itself is a trap: 150 Gy is the minimum, which is a floor, not a recommendation. Irradiating below 150 Gy for any purpose is not authorised under that section. For herbs and spices, the two purpose bands (sprouting/pest up to 6 kGy; bacterial decontamination 2‑30 kGy) are separate permissions. A spice irradiated at 1.5 kGy for bacterial decontamination does not meet the 2 kGy floor and would be unlawful. Similarly, using a 7 kGy dose for sprout control exceeds the 6 kGy ceiling.

The re‑irrigation condition in section 1.5.3‑6 is another source of error. Condition (b) allows re‑irradiation if the food contains less than 50 g/kg of irradiated ingredients. This is a weight fraction, not a dose limit. A food containing 49 g/kg of previously irradiated ingredients can be re‑irradiated, but a food containing 51 g/kg cannot, even if the prior dose was very low. The 50 g/kg limit is a blunt threshold that may catch complex foods with multiple irradiated components. Condition (c) allows re‑irradiation in divided doses for a “specific technological reason”. That phrase is not defined. An irradiator who splits a dose across two passes for convenience may argue it is for a technological reason, but a regulator may disagree, leaving the business exposed.

The record‑keeping requirement in section 1.5.3‑8(2) mandates that records be kept at the facility where the food was irradiated. Electronic records may be acceptable, but they must be accessible at that physical address. Off‑site storage or cloud‑only records might not satisfy the regulation if the facility has no local access. During an inspection, the ability to produce records on site is critical. The retention period - “exceeds the minimum durable life by 1 year” - can be very long for dried spices with a shelf life of three years or more. Records could need to be kept for over four years. The irradiator must know the minimum durable life for each product and set a calendar reminder.

Labelling gotchas arise from the cross‑reference to Standard 1.2.1. The note says the labelling provisions apply to both packaged and unpackaged irradiated foods. For unpackaged goods (e.g., bulk bins of irradiated spices), the business must provide the statement to the consumer. How? A sign at the point of sale. Many retailers are unaware of this requirement. Also, if the food has more than one irradiated ingredient, the label must state each that has been irradiated? The section says “if the food has as an ingredient or component a food that has been irradiated - a statement to the effect that the ingredient or component has been treated”. A single statement covering all irradiated ingredients is likely acceptable, but clarity is required. A statement “Contains irradiated ingredients” may not suffice if it does not indicate that they have been treated with ionising radiation.

The amendment history notes that paragraph 1.5.3‑7(b) was repealed and substituted by Amendment 230. The new paragraph specifies two energy limits depending on target material. A facility that upgraded its X‑ray source to 6 MeV with a copper target would still be limited to 5 MeV under the first sub‑paragraph. That source would only be permitted if the target material is tantalum or gold. A business that changes its X‑ray target material without updating its radiation licence may inadvertently breach the Standard.

Lastly, the Standard has no labelling requirement for irradiated foods sold to food service or industrial customers (e.g., a bag of irradiated flour sold to a bakery). The labelling requirement in section 1.5.3‑9 applies only to “retail and catering”. A wholesale transaction does not require a label statement, but the record‑keeping chain should supply the information. The bakery may receive the flour without an irradiation statement and unknowingly use it in a product sold at retail, triggering the labelling duty. The bakery then has to rely on supplier paperwork.

A practical compliance plan has three components: pre‑irradiation approval, process control, and documentation/labelling.

First, before irradiating any food, the irradiator must verify that the food type appears in the permissions in Division 2. For fresh fruit and vegetables, check the table in subsection 1.5.3‑3(2) (Schedule 22). For herbs and spices, check Schedule 22 and the note including chives (section 1.5.3‑4(3)). For plant material for a herbal infusion, ensure it is not tea (section 1.5.3‑5(3)). If the food is not listed, it cannot be irradiated. If it is listed, confirm the purpose is permitted. For fruit and vegetables, the purpose must be pest disinfestation for a phytosanitary objective. For herbs, spices and infusion material, choose the appropriate purpose (sprouting/pest control or bacterial decontamination) because each has a different dose limit. Run a commercial impossibility if the required dose for decontamination is below the floor or above the ceiling.

Second, process control. Select a radiation source from section 1.5.3‑7. Calibrate the equipment to deliver the absorbed dose within the prescribed range. Install real‑time dosimetry and record the minimum and maximum dose achieved. For re‑irradiation, calculate whether the food contains more than 50 g/kg of previously irradiated ingredients. If so, re‑irradiation is only permitted if the prior irradiation was at or below 1 kGy, or if the divided dose condition is met. Maintain a register of the irradiation history of incoming ingredients, including dose levels and dates. For condition (c) (divided doses for a specific technological reason), document the reason in the process log - for example, “required to avoid heat buildup during electron beam treatment”.

Third, documentation and labelling. The irradiator must create records for each lot containing the eight items listed in section 1.5.3‑8(1): nature and quality, lot identification, minimum durable life, process used, compliance with process, minimum and maximum dose, prior irradiation details, and date. Store these records at the irradiating facility. Set the retention period: for a product with minimum durable life of 12 months, keep records for 24 months. For products with indefinite shelf life (e.g., some spices), the minimum durable life might be set by the manufacturer. The irradiator should obtain that information from the client and retain records for that period plus one year. It is wise to keep them until after the next audit to ensure continuity.

For the food business selling irradiated food at retail or to catering, the label must include the statement. Work with the packaging supplier to insert the phrase. For unpackaged foods, provide a sign, sticker, or tear‑away card at the display. Maintain a record that the label statement has been applied to each batch, cross‑referencing the irradiator’s lot records. If the irradiated ingredient is a minor component, ensure the statement appears in the ingredients list or elsewhere on the label. A common approach: “Spice (treated with ionising radiation)”. For packaged foods, the label must be finalised before sale. For catering, provide the information on invoices or menu descriptions.

Third parties (e.g., importers) should request a compliance certificate from the irradiator showing the lot number, dose range, and irradiation date. Retain this document as evidence that the food was lawfully irradiated. If the food is further processed, the downstream business must check whether the food is subject to re‑irradiation. The first irradiator’s records should indicate whether the product has been previously irradiated.

Regular internal audits should verify that only permitted foods are being irradiated, that dose records are accurate, that the radiation source is within energy limits, that re‑irradiation thresholds are respected, and that labels carry the required statement. Engage a food law specialist to review compliance at least annually, especially after any amendment to the Standard (e.g., Amendment 230 changed source specifications). Maintain a file of all amendments and the current compilation (the source text notes compilation No. 6 in force 15 August 2024). When the Standard changes, update procedures and labels accordingly within any transitional period provided by the amending instrument.