Labelling a 'Fresh' Juice Blend
A small NSW juice producer blends 70% Australian orange juice (reconstituted from concentrate), 20% apple juice (freshly pressed) and 10% passionfruit pulp. The product is pasteurised, bottled and sold chilled with a 21-day shelf life. The owner wants to label it 'Fresh Australian Orange Juice' and use a 'Product of Australia' logo. A retailer has asked for the percentage of Australian ingredients and whether the product can carry a health claim about vitamin C. The owner has no food technologist on staff and is unsure what the Food Standards Code requires.
1. Assess whether the proposed name and country-of-origin logo are lawful, giving reasons.
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Product name: 'Fresh Australian Orange Juice' is misleading. Under the Food Standards Code, a food must not be labelled in a way that is false, misleading or deceptive. The product is:
- Reconstituted from concentrate, not fresh juice, so 'fresh' is inaccurate.
- Only 70% orange, so calling it orange juice without qualification overstates the main ingredient.
- Contains apple and passionfruit, which the name omits.
A compliant name would identify the blend and note 'reconstituted' where required.
Country-of-origin logo: The 'Product of Australia' claim requires that all significant ingredients be Australian and all or virtually all processing occur in Australia. Only 70% of the orange component is Australian, and the apple and passionfruit origins are unstated. If any significant ingredient is imported, the 'Product of Australia' logo cannot be used; a 'Made in Australia' claim with a percentage bar may be permitted instead.
Conclusion: Both claims as proposed are non-compliant and would need to be changed.
2. The retailer asks for the percentage of Australian ingredients. Explain what the producer must calculate and how this affects the label.
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The producer must calculate the proportion of Australian ingredients by weight or volume of the total product, not just the orange portion.
Worked example (assuming orange concentrate and apple are Australian, passionfruit imported):
- Orange: 70% Australian
- Apple: 20% Australian
- Passionfruit: 10% imported
- Australian content = 90%
If all three were Australian, the figure would be 100%. The label must show this percentage in the country-of-origin bar chart if a 'Made in Australia' claim is used. If the figure is below the threshold for 'Product of Australia', the logo must be dropped.
Judgement point: The percentage is based on ingredient weight in the final product, so water added during reconstitution can change the calculation. The producer should verify each supplier's origin in writing before printing labels, because an incorrect bar chart is a misleading claim.