>>Dr Schaper: Now, we're going to take a look at
how to calculate the percentage of Australian
grown or produced content in a food.
This is shown on the new picture labels via the bar
chart.
This new requirement to provide clear information
about the percentage of Australian content
is actually quite a big change for businesses.
In some ways, though, this task is simple because
it's a numbers game, at least in part.
You add these figures, you divide them by another,
multiply it and there you go, you have your answer.
However, there are some things that can make this
more complicated like compound ingredients,
working out whether something is a processing
aid or a food additive and accounting for the vexed
issue of water.
In this section, we're going to run through some
practical examples about how to correctly calculate
these percentages and we're going to give you
the answers to some of these tricky questions.
I'd like to stress here, though,
that you simply can't get around having to do these
calculations.
The Standard is very clear about how the proportion
of Australian ingredients must be calculated and
businesses are clearly going to have to follow
these steps.
If you don't, you risk breaching the new
Standard, as well as the laws against false or
misleading claims.
Chris, when will producers need to work out the
percentage of Australian ingredients?
>>Mr Preston: Well, if you're responsible for
labelling a priority food that was grown, produced,
made or packed in Australia,
chances are you'll be required to state the
percentage of Australian ingredients in that food.
Now, the two key questions people face here are, one,
how do I work out that percentage and, two,
what counts as an ingredient?
The calculation is based on the ingoing weight of
ingredients prior to processing.
It's the recipe, not the finished product.
For instance, if you were making a loaf of bread,
you'd work out the weight of the ingredients that
you added into the mix, not what comes out of the
oven at the other end.
Claims must always be rounded down to the
nearest whole number and the important thing to
bear in mind is that you're generally claiming
the minimum proportion of Australian content in the food.
This will be framed as an 'at least' statement,
for example, packed in Australia from 'at least'
35% Australian ingredients.
In the event this percentage changes over
time, it's possible for businesses to instead use
an average percentage claim.
There are lots of reasons why the proportion of
Aussie content could vary like seasonality changes,
changes in supplier, availability of
ingredients or environmental issues like
drought or cyclone.
>>Ms Chapman: A tip for businesses here could be
that if your suppliers change regularly or you're
reliant on a steady supply that could be compromised
easily, it's worth considering whether to use
an average content claim.
This would mean that for a set period of time you
wouldn't have to change your labels if the
percentage of Australian content went down or up.
>>Dr Schaper: So, working out the minimum percentage
of Australian grown or produced content in a food
is actually pretty straightforward.
The first thing you do is add up the total ingoing
weight of the Australian ingredients,
you then divide this number by the total weight
of all the ingredients and this will give you a
fraction, multiply this number by 100 and it will
give you the percentage of Australian ingredients in
the food.
>>Mr Preston: Yeah, we have an example up on the
slides for a pasta sauce.
It contains a bunch of Australian ingredients,
including tomatoes.
The weight of the Australian ingredients is
1,350 grams.
There's also imported onion,
garlic and the food additive.
The total weight of the ingredients is
1,500 grams.
Dividing this number by the total weight of the
ingredients gives me 0.9.
I then multiply it by a hundred to end up with 90%.
Now, if your food has compound ingredients in
it, you still do these same steps,
you just also have to work out the percentage of
Australian content in the compound ingredient.
Tania, do you want to take us through the compound
ingredient example?
>>Ms Chapman: Certainly.
As background, compound ingredient is just the
fancy name used to describe an ingredient in
a food that's, itself, made up of two or more things.
For example, the tomato sauce we just discussed
would be a compound ingredient if it was used
to make another food.
When it comes to doing the calculation,
the important thing to remember is that only the
Australian proportion of the compound ingredient counts.
So, if you're making a lasagne using the sauce
that we worked out contained 90% Australian
grown or produced ingredients,
you could only count 90% of the sauce as being
Australian.
We have a lasagne example up on the slide.
Let's imagine you're making the lasagne with
the sauce, Aussie beef and vegies and pasta that has
36% Australian content.
How do you do the calculation here?
First, you figure out the weight of the Aussie
ingredients in the compound ingredients;
the sauce and the pasta.
For example, the sauce has a total weight of 80 grams
in the lasagne, we worked out that 90% of the sauce
is Australian, so that equals 72 out of the
80 grams of sauce.
You'd then do the same calculation for the pasta.
The next step would be to add these weights to
the weight of the other Aussie ingredients and
follow the same steps we did before.
You'd end up with a final figure of 66% Australian
content.
>>Dr Schaper: Now, these same principles will apply
if you're trying to calculate the average
percentage of Australian content in your food as well.
The only added step is that you have to do these
calculations over a 12, a 24 or a 36-month period in
order to work out an average.
Our Food Labelling guide has some detailed examples
on pages 15 and 16 that'll run you through how to do this.
The other things that we said can make doing the
calculations harder relate to the basic question of
what counts as an ingredient?
Before we get into processing aids,
food additives and water, let's lay out some basic
principles first.
In general, everything that goes into a food,
including water, usually counts as an ingredient,
but there are two exceptions to this.
First, processing aids don't count as ingredients
and, secondly, while water will generally be regarded
as an ingredient, you don't count water that's
being used as the liquid packing medium if it isn't
usually consumed as part of the food.
Think of the brine in a package of feta cheese or
in a tin of tuna.
Food additives, though, will count as ingredients.
>>Mr Preston: So, even if a food is 99.9% Australian
and the other 0.1% is an imported food additive
that can't be sourced in Australia,
that food additive would still need to be counted?
>>Dr Schaper: That's right, Chris.
And, remember, as we said before,
if the food is a priority item and it has to use the
new labels, then the kangaroo picture label
couldn't say 'Grown in Australia' or 'Produced in
Australia' as the food isn't exclusively
Australian.
>>Mr Preston: For businesses that are unsure
whether something is being used as a processing aid
or a food additive, you should look at the Food
Standards Code.
Your supplier or the product manufacturer may
also be able to help you work out how to classify
the item.
>>Ms Chapman: Michael, just on liquid packing
mediums, what if the liquid is sometimes used
and sometimes discarded?
For instance, tinned apricots in syrup don't
necessarily come with usage instructions,
sometimes the syrup is consumed and sometimes
it's discarded.
Would the water here count as an ingredient or a
liquid packing medium?
>>Dr Schaper: Look, I think people are going to
need to take a commonsense approach here and ask
themselves is this normally consumed?
In the case of apricot syrup,
in the Schaper household it is always consumed,
I can tell you that.
But let's use the example of water in a tin of
legumes and that'd usually be drained,
so we'd regard that as a liquid packing medium.
But the syrup in those tinned apricots would
usually be consumed, like I said before,
so this wouldn't be regarded as just a liquid
packing medium.
Now, what are some of the other instances where
water gets a bit complicated?
>>Ms Chapman: Reconstituted imported
juice concentrates might be a really good place to
start.
If an Australian processor imports a Brazilian orange
juice concentrate, adds water to it and puts it in
a bottle, can they claim that it contains 80, 90%,
whatever, Australian ingredients,
because the water is Australian?
>>Dr Schaper: The short answer is no.
While water is generally taken to have as its
origin the country where it was collected or where
it was harvested, this isn't the case when it's
being used to reconstitute imported dehydrated or
concentrated ingredients.
In the case you've mentioned,
because the concentrate came from Brazil,
the water would be effectively regarded as
having come from there too.
However, if you add more water than what's needed
for reconstitution, then that extra water would
count towards the percentage of Australian
ingredients.
>>Mr Preston: Michael, one issue that we've come
across is cooking water.
Let's say I'm cooking dried pasta,
some of the water is absorbed during the
cooking process, but most of it is discarded at the end.
>>Dr Schaper: In that case,
you would count the water that's absorbed into the
pasta, but you definitely couldn't count the
additional water that's discarded.
Okay, so some takeaways - let's recap.
What are our key takeaways in this case for
calculating the weight of Australian ingredients in
their food products?
>>Ms Chapman: There are a couple of things.
Firstly, make sure you know where your
ingredients come from and get your weights right.
Don't forget, the calculation is based on
what goes into the food before processing and if
your product has water, have a real think before
you do that calculation.
Is the water an ingredient?
Is it reconstituting or is it part of the packing
medium?
>>Mr Preston: Manufacturers and
processors who make food where the percentage of
Australian content changes also need to think
seriously about which method of calculation to use.
If you're going to use an average percentage claim,
I'd just remind businesses that this doesn't mean you
get to avoid doing the calculations.
The Standard requires that you make this information
available in another way for your customers,
either through an app, a website or a hotline.
Page 19 of the ACCC Guide has an example of how this
information should be included on a label.
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