Policy paper current to 27 July 2026
Executive Summary
Australia’s recent food policy changes form a connected package rather than a single legislative reform. Together, they shift the regulatory system towards earlier risk control, stronger supply-chain evidence and clearer consumer information.
Five developments carry particular significance:
- Hospitality businesses must identify seafood as Australian, imported or of mixed origin from 1 July 2026.
- National food safety standards for berries, leafy vegetables and melons have applied since 12 February 2025.
- Imported retorted salmon roe, including qualifying caviar products, now requires an Official Government Certificate.
- Standard 3.2.2A places training, supervision and evidence requirements on food service, catering and related retail businesses handling unpackaged, potentially hazardous ready-to-eat food.
- The sell-through period for food labelled under the previous allergen rules ended on 25 February 2026.
The common policy direction is clear. Australian regulators increasingly expect businesses to demonstrate control, not simply claim compliance.
This approach should improve traceability and reduce preventable illness. It also creates new administrative pressures for growers, importers, seafood suppliers and smaller hospitality operators.
Australia’s Food Regulatory Structure
Australia does not regulate food through one agency or statute.
Food Standards Australia New Zealand, or FSANZ, develops the Australia New Zealand Food Standards Code. Australian states and territories adopt and enforce those standards through their own legislation.
Country-of-origin rules can also operate through Australian Consumer Law. Biosecurity requirements for imported foods are administered separately by the Australian Government Department of Agriculture, Fisheries and Forestry.
This division matters.
A restaurant serving prawns may face seafood-origin obligations under consumer law, allergen duties under the Food Standards Code and food-handling requirements enforced by its state or local authority. An importer supplying the same restaurant may also be subject to biosecurity certification and border inspection.
Compliance systems therefore need to connect purchasing, food safety, menu management and supplier records.
The Recent Regulatory Timeline
8 December 2023
Standard 3.2.2A took effect. It introduced nationally consistent food safety management tools for specified food service, catering and retail businesses.
25 February 2024
The Plain English Allergen Labelling requirements became mandatory for food packaged and labelled from this date.
12 February 2025
Standards 4.2.7, 4.2.8 and 4.2.9 commenced for berries, leafy vegetables and melons.
25 February 2026
The two-year sell-through period for food labelled under the previous allergen rules ended.
1 June 2026
The new official certification requirement commenced for imported retorted salmon roe, including relevant caviar products.
1 July 2026
Seafood country-of-origin labelling became mandatory in Australian hospitality settings.
Seafood Country-of-Origin Labelling in Hospitality
The most visible 2026 reform is the new seafood labelling requirement.
The Competition and Consumer Information Standard for Seafood for Immediate Consumption operates under Australian Consumer Law. It became mandatory on 1 July 2026 following a 12-month transition period.
The AIM Labelling Model
Businesses must identify seafood using one of three classifications:
- A for Australian
- I for imported
- M for mixed origin, meaning the dish contains Australian and imported seafood
A business may use the letters with an explanatory legend. It may instead use the complete words “Australian”, “imported” or “mixed”.
The information must be prominent, legible, accurate and written in English. Customers must be able to see it before ordering.
This applies to printed menus, menu boards, websites and digital ordering platforms.
Which Businesses Are Covered?
The rules generally cover businesses serving seafood for immediate consumption, including:
- Restaurants and cafés
- Pubs and clubs
- Takeaway and fast-food outlets
- Food trucks
- Ready-to-eat market stalls
- Hotels and motels offering food or room service
- Casinos and amusement parks
Schools, hospitals, medical institutions, prisons and canteens are among the excluded settings.
The rule covers dine-in, takeaway and home-delivery orders. The location where the customer eats the food does not determine coverage.
Which Seafood Dishes Require Labels?
The requirement applies where a dish is marketed as seafood or as containing seafood. Examples include fish and chips, chilli prawns, ceviche and seafood marinara.
It covers fish, eels, crustaceans, molluscs, aquatic animals, roe and caviar.
There are important exceptions. The origin of fish sauce, shellfish stock and other liquid or powdered seafood ingredients does not generally require disclosure. Shelf-stable seafood that has been chopped, minced, puréed or shaved, such as canned tuna or shrimp paste, can also fall outside the requirement.
Businesses must keep evidence of seafood origin for three months after the product was last offered to customers. Acceptable evidence may include invoices, supplier emails, receipts and photographs of packaging.
Detailed guidance is available through the Australian Government’s hospitality seafood labelling resource.
Policy Significance
The reform closes a longstanding information gap between retail seafood and prepared meals.
It also makes suppliers part of the compliance chain. Hospitality operators need written origin information, while suppliers must maintain accurate product records.
The AIM system is deliberately simple. That supports menu usability but limits the information available to consumers. An “I” label does not identify the exporting country, fishing method, production system or sustainability status.
A post-implementation review should examine whether consumers require greater detail without imposing excessive menu complexity.
Fresh Produce Safety Standards
Australia’s national horticultural standards commenced on 12 February 2025. They apply through:
- Standard 4.2.7 for berries
- Standard 4.2.8 for leafy vegetables
- Standard 4.2.9 for melons
The standards cover primary producers and specified early-stage processors. Relevant processing can include washing, trimming, sorting, sanitising, storing, combining, packing and transport between packhouses.
Why the Standards Were Introduced
Fresh produce is often eaten raw. There may be no cooking step capable of destroying pathogens introduced during growing, harvest or packing.
Contamination can arise through:
- Irrigation and washing water
- Soil, fertiliser, manure and compost
- Animals and faecal material
- Floods and extreme weather
- Poor worker hygiene
- Unclean equipment or premises
- Inadequate post-harvest controls
FSANZ identified foodborne illness, recalls and deaths associated with fresh horticultural produce. Its assessment considered hazards including Salmonella, Listeria monocytogenes, Shiga toxin-producing Escherichia coli and foodborne viruses.
The standards are risk-based. They do not simply impose universal pathogen testing. They require businesses to identify hazards and control the conditions through which contamination can occur.
Core Compliance Duties
Across the three commodity groups, requirements include:
- Notification of relevant regulatory authorities
- Product traceability
- Control of agricultural and processing inputs
- Worker health and hygiene
- Cleaning and sanitation of equipment and premises
- Management of contamination associated with weather or environmental events
Leafy vegetable and melon businesses must also have an approved food safety management statement. The statement must show how the business identifies and manages relevant food safety risks.
Berry businesses face notification, hazard-control and traceability duties, but the approved management-statement requirement is not structured in precisely the same way.
The FSANZ horticulture guidance provides the national baseline. Growers and processors must still consult the regulator responsible for implementation in their state or territory.
Policy Significance
These standards move national food safety regulation further onto the farm.
That is a substantial policy change. Historically, food regulation has often concentrated on processors, retailers and hospitality operators. The horticulture standards recognise that contamination introduced before harvest can be difficult or impossible to remove later.
The principal implementation risk is inconsistent enforcement. Different audit practices between jurisdictions could undermine the objective of a national baseline.
Stronger Import Verification for Salmon Roe and Caviar
The Department of Agriculture, Fisheries and Forestry announced a change to the evidence requirements for imported retorted salmon roe, including qualifying caviar products, on 5 March 2026.
The new requirement applied from 1 June 2026.
An Official Government Certificate must now confirm that the product satisfies Australia’s biosecurity conditions. A manufacturer’s declaration is no longer sufficient.
A Narrow but Important Requirement
This change should not be described as a certification requirement for all imported fish or all caviar.
It specifically concerns salmonid roe represented as retorted. Retorting involves intensive thermal processing in a sealed container. Pasteurisation is not automatically equivalent to retorting for Australian biosecurity purposes.
The policy responds to the risk that products may be presented as retorted even though the processing applied does not meet the prescribed conditions.
Consequences for Importers
Importers must now establish whether the competent government authority in the exporting country can issue the required certificate.
This should occur before a purchase order is finalised. Commercial assurances from a manufacturer cannot replace the official document.
Importers should also verify that:
- The product is correctly classified.
- Processing records support its retorted status.
- Certificate details match the shipment and product.
- Original documents are available when required.
- Contracts allocate responsibility for rejected or delayed consignments.
The reform transfers part of the assurance burden from private manufacturers to exporting-country authorities. It may improve biosecurity confidence, but it can also restrict supply from countries without suitable certification arrangements.
Food Safety Management Under Standard 3.2.2A
Standard 3.2.2A has operated since 8 December 2023, but it remains central to Australia’s current food policy direction.
It applies to food service, catering and related retail businesses that handle unpackaged, potentially hazardous food that is ready to eat. Restaurants, cafés, caterers, takeaway shops, supermarkets, delis and food vans may fall within its scope.
Category One Businesses
Category one businesses process unpackaged, potentially hazardous food into ready-to-eat, potentially hazardous food that is served without further processing.
These businesses must use all three food safety management tools:
- A food safety supervisor
- Food handler training
- Evidence that critical food safety controls are working
Restaurants and caterers commonly fall into this category.
Records or other reliable evidence may be needed for receiving, storage, processing, display, transport, cleaning and sanitising. Records must generally be retained for at least three months.
Category Two Businesses
Category two businesses sell unpackaged, potentially hazardous ready-to-eat food but do not substantially prepare or process it on site. Limited activities such as slicing, weighing, repacking, reheating or hot holding may still occur.
These businesses require a food safety supervisor and appropriately trained food handlers. The separate evidence tool does not apply in the same way as it does to category one businesses.
Training and Supervisor Requirements
A food safety supervisor must hold recognised formal certification obtained within the previous five years.
Food handler training must address:
- Safe food handling
- Food contamination
- Cleaning and sanitising
- Personal hygiene
The standard does not necessarily require every handler to hold a formal certificate. A business must ensure that handlers have completed suitable training or possess the appropriate skills and knowledge before working with relevant high-risk foods.
This distinction matters. Describing the rule as mandatory certification for every handler would overstate the legal requirement.
Further detail is available in the FSANZ overview of Standard 3.2.2A.
Plain English Allergen Labelling
Plain English Allergen Labelling, commonly called PEAL, became mandatory for food packaged and labelled from 25 February 2024.
Food packaged and labelled before that date could continue to be sold under the previous format until 25 February 2026. That transition has now ended.
What PEAL Requires
Specified allergens must be declared using prescribed names. Individual tree nuts, molluscs and relevant cereals must be identified separately.
For packaged foods with an ingredients list:
- The allergen name must appear in bold within the ingredients list.
- The font must be no smaller than the surrounding ingredients.
- A separate bold allergen summary must begin with “Contains”.
- The summary must appear beside the ingredients list and within the same field of view.
For example, a product may list “milk powder” in bold and carry the summary “Contains milk”.
Food that does not require a label, including some food served in cafés and takeaway businesses, must display the allergen information with the food or provide it to the purchaser on request using the prescribed names.
FSANZ provides the complete requirements in its allergen labelling guidance for food businesses.
Remaining Policy Gap
PEAL standardises mandatory declarations. It does not regulate voluntary statements such as “may contain” in the same way.
That leaves businesses responsible for managing allergen cross-contact and avoiding vague precautionary warnings. Overuse of “may contain” statements can reduce their value to consumers and unnecessarily restrict food choices.
The Broader Policy Direction
The reforms point to four consistent priorities.
Prevention Before Sale
The horticulture standards address risk during growing and early processing. Standard 3.2.2A targets food handling before a meal reaches the consumer. Import certification intervenes before a shipment enters Australia.
Policy is moving towards prevention rather than relying on recalls and outbreak investigations.
Evidence-Based Compliance
Menu claims must be supported by supplier records. Critical food safety controls must be documented or demonstrable. Imported salmon roe requires official certification.
Businesses need an auditable chain of evidence.
Greater Supply-Chain Accountability
Growers, processors, importers, distributors and hospitality operators can no longer treat compliance as an isolated function.
Incorrect information at one stage can create breaches further down the chain. Supplier agreements and purchasing systems therefore become regulatory controls.
Clearer Consumer Information
PEAL improves the visibility of allergens. AIM seafood labels disclose broad origin. Both reforms aim to make safety and purchasing information available at the point of decision.
Policy Recommendations
Create a Unified National Compliance Map
The Australian Government should publish a consolidated framework explaining how FSANZ standards, Australian Consumer Law, biosecurity rules and state enforcement interact.
Businesses should not need to consult several agencies before understanding one product’s compliance pathway.
Standardise Digital Traceability Records
A common minimum data format should cover supplier identity, product description, batch details, origin, relevant certificates and movement dates.
This would reduce duplicate record-keeping and accelerate recalls.
Support Smaller Producers and Hospitality Businesses
Templates, translated guidance and low-cost digital tools should be prioritised for small farms, independent restaurants and market operators.
Rules that appear straightforward at policy level can create significant operational work across frequently changing menus and supply arrangements.
Harmonise State and Territory Enforcement
National standards require consistent interpretation.
Regulators should coordinate audit protocols, inspector training and guidance on acceptable evidence. Businesses operating in several jurisdictions should not face materially different expectations for the same national obligation.
Measure Outcomes Publicly
Government reporting should track:
- Seafood menu compliance
- Horticultural outbreak and recall trends
- Trace-back speed
- Allergen-related recalls
- Import certificate failures
- Small-business compliance costs
Publication of these measures would allow policymakers to determine whether the reforms are producing measurable public-health and consumer benefits.
Review the AIM Model After Implementation
The initial review should examine whether the three classifications remain sufficient.
Possible future options include voluntary disclosure of the exporting country, species, production method or fishery. Any expansion should be tested against menu readability and small-business costs.
The Immediate Policy Test
Australia’s recent food reforms establish a stronger preventative framework. They extend responsibility from the farm and border to the menu and product label.
The next challenge is implementation.
Success will depend on consistent enforcement, usable guidance and reliable information moving through the supply chain. If those elements are secured, the reforms can deliver clearer consumer choices, faster traceability and lower food safety risk without imposing unnecessary complexity on compliant businesses.