ABCL Submission on Common Commencement Dates for Labelling Changes
Following longstanding advocacy for this reform, the Australian Beverages Council Limited (ABCL) has welcomed Food Standards Australia New Zealand’s (FSANZ) proposal to introduce an annual common commencement date for future FSANZ-initiated labelling changes, describing it as a positive and practical step towards more predictable, coordinated and efficient regulation.
The ABCL supports the proposed 30 May commencement date, noting that it avoids the significant production, distribution and retail pressures associated with the Christmas and year-end period. A consistent annual date would help businesses better plan packaging updates, improve regulatory certainty, reduce compliance costs and minimise unnecessary waste.
While supporting the proposal in principle, the ABCL has emphasised the importance of maintaining flexibility in its implementation. The Council has called for transition periods and stock-in-trade provisions to continue to be assessed on a case-by-case basis and not be shortened as a result of the common commencement date. ABCL has also urged FSANZ to avoid clustering consultation processes around the annual date and to retain the ability to implement urgent or complex regulatory changes outside the annual cycle when needed.
The ABCL believes that, with these safeguards in place, a common commencement date will provide greater regulatory certainty, improve implementation outcomes and support the efficient operation of Australia’s non-alcoholic beverages industry while continuing to meet public health objectives.