The government has presented a snapshot of its proposed new country-of-origin food labels, after a four-month development and consultation process. The current laws came under fire in February, after a hepatitis A outbreak from frozen berries that were grown in China and Chile.

Reluctant to act initially because he said new labels may impose a “burden on industry”, Prime Minister Tony Abbott changed his mind just days later, announcing an inquiry to be led by Agriculture Minister Barnaby Joyce and Industry and Science Minister Ian Macfarlane. The information released yesterday during a joint press conference is a glimpse of what Australia’s country-of-origin food labels could look like as early as “later this year”.

A new look

At the centre of the information released on Tuesday is a series of logos proposed to appear on food labels.

Where a processed food product is made in Australia, the label will appear on packaging (as pictured above) complete with the kangaroo icon, the bar below it, and text. A second category – grown in Australia – will be used for frozen or canned fruit and vegetables, where there is no or minimal processing.

Food products that feature one of these icons will also have a “packed in” statement. This means there are two labels on-pack: one for made in or grown in Australia, including the bar-icon to indicate the percentage of local ingredients, and the other label, a “packed in” statement.

These logos offer a solution to the problem regularly cited by consumers: that country-of-origin information appears “somewhere on the pack in small font”. On this point, the logos are a step in the right direction. But how do they fare in answering a question posed by most consumers: where does this food come from?

People want to know where the ingredients of a product originate and where the food is made and packaged. They also want the information presented in a simple easy-to-see “icon”, and to know who they can tell if they don’t believe the country-of-origin label. So, how do the new guidelines stack up?

Where ingredients come from

The proposed label for where ingredients come from shows how much of a food product’s ingredients is from Australia, calculated as a percentage by mass. It’s represented in the bar sitting just under the kangaroo.

But while consumers can understand the amount of Australian-sourced ingredients from this bar, there’s much this logo doesn’t tell us. It doesn’t say where the ingredients are from when they are not local, for instance. For example, you can see from the bar-icon when none of the ingredients are from Australia (0%), but you will be left to guess where the ingredients do come from.

The good news is that the text added in the “packed in” logo can be used for this purpose to say French peas packed in Australia, for instance. But this separates the answer to “where are the ingredients from?” across two separate icons.

So, under the proposed labelling laws, there’s still no way for consumers to identify where ingredients are sourced from, unless the ingredients are 100% Australian.

One possible option to represent country of origin is to label each ingredient with the country from which it’s sourced:

But this could be quite difficult from a food manufacturer’s perspective; individual ingredients may be sourced from different countries at different times for seasonal or economic reasons, and each such change would require re-labelling.

Where is the food made and packaged

Where a product is “made in Australia” it qualifies for the use of the icon as pictured – kangaroo, bar and text. A statement about where the product is packed is also proposed as an icon. But if a product is not “made in Australia”, there’s no option to state this in any of the proposed labels.

This raises a number of questions: for products not made in Australia, is the kangaroo icon removed, even where the ingredients may be 100% Australian? Do products not made in Australia default to needing only the “packed in” statement, which allows an add-on of “made in” or “grown in”?

The kangaroo icon itself holds “meaning” separate from country-of-origin labelling. Such meaning may not be consistent for all consumers. If the government is going to use an icon as entrenched in existing meaning as this, surely it should undertake consumer consultation to determine current meaning. And then whether this meaning holds true in the context of country-of-origin labelling.

Perhaps “made in Australia” should be stated as text. That would allow the kangaroo icon to be reserved for products that meet all three categories as Australian: made in Australia, packed in Australia and having a certain percentage of Australian ingredients.

A simple easy-to-read icon?

Consumers were invited to comment on the draft labelling proposal. The results show the green and gold kangaroo and triangle icon is overwhelmingly popular for representing Australian products. The label is intended as a “symbol” to confirm the product is Australian.

But the invitation to comment didn’t seek feedback on what consumers expect the icon to mean when it comes to food, which instinctively seems that most of the food’s ingredients are from Australia. If this is the case, then the proposed country-of-origin label is unclear and may even be misleading.

In further bad news, there’s no information about whom to contact if you believe claims on a label are incorrect.

So, overall do the new labels say where our food comes from? Yes, if the product is made in Australia and all ingredients are from Australia. For everything else: no, the proposed labelling system doesn’t allow for clear statements about where the “food” comes from if it’s not Australian.

Aside from a re-working of definitions and on-pack representation, systematic “testing” of prototypes against real products could provide evidence for revising a flawed and confusing proposal. Still, this is a step in the right direction. And it offers a sound starting point for achieving the goal of informing consumers about where a food product comes from.