Where a product comes from can be a big part of a brand. A small flag on a box or the words “Made in Australia” can sway a buyer in seconds. That is exactly why the law takes these claims seriously. Designers and business owners both need to know the rules before the artwork goes to print.

This guide covers the main types of origin claims under the Australian Consumer Law. It also looks at logos, flags and images that can imply origin without a word being said. The aim is to help you build packaging and marketing that stays on the right side of the rules. It is general information only.

What counts as a country of origin claim

A country of origin claim is any statement about where a product was grown, produced or made. The ACCC guidance on country of origin claims says these can be stated outright or implied through words, images and symbols. Every claim must be true, accurate and based on reasonable grounds. That applies to a swing tag, a product page and a social post alike.

For a brand, this matters well beyond the label itself. Your logo, tagline and website copy can all carry an origin message. If a buyer would reasonably read them as saying “this is Australian”, they count. So the rules belong in the design brief from the start.

The main claims and what they mean

The Australian Consumer Law sets out a few standard claims. Each one has its own test. Meeting that test gives a business what is called a safe harbour defence. In plain terms, it is an automatic defence against an allegation that the claim is false, misleading or deceptive.

• Grown in: all significant ingredients or components were grown in that country, and all or virtually all processing happened there.
• Product of or produced in: all significant ingredients or components came from that country, and all or virtually all processing happened there.
• Made in: the product went through its last substantial transformation in that country.
• Packed in: generally used for food when the local processing is not enough for a “made in” claim.

“Product of” is a little broader than “grown in”. The ACCC notes it can cover goods like water or salt that originate somewhere but are not technically grown. “Grown in” also covers things harvested from something grown there, such as eggs, milk or wool. The ACCC small business toolkit on origin claims sets out each of these tests with examples.

Substantial transformation and “Made in Australia”

The “made in” claim is the one that catches most businesses out. Parts and ingredients can come from overseas. What counts is that the last substantial step happened here. That step must make the product fundamentally different in identity and nature from its imported parts.

Changing only the form or look of imported goods is not enough. In one ACCC matter, a food company relabelled 31 frozen fish products from “Made in Australia” to “Packed in Australia”. The steps done here were slicing, crumbing and par frying imported fish, and the ACCC’s view was that these were only minor manufacturing processes. That definition of substantial transformation came in through the Competition and Consumer Amendment (Country of Origin) Act 2017.

For a business that assembles or finishes products locally, it pays to map each step. Ask what arrives from overseas and what leaves your workshop. If the change is mostly cosmetic, a “made in” claim is risky. Different wording, or a “packed in” label for food, may be the safer choice.

Food labelling has its own standard

Food has an extra layer of rules. The Country of Origin Food Labelling Information Standard 2016 requires most food sold at retail to carry country of origin information. If a food cannot be called grown, produced or made in a single country, it must say where it was packed. Food brands should plan the label panel around this from the first draft.

Hospitality businesses have a newer rule to watch. From 1 July 2026, a seafood information standard applies to businesses serving seafood for immediate consumption. They must show whether the seafood is Australian, imported or a mix. Menus and online ordering pages may need a fresh look.

Logos, flags and images can make a claim too

You do not need words to make an origin claim. The ACCC gives the example of the shape of Italy shown in the colours of the Italian flag. That image could suggest an Italian connection to a buyer. Similar care is wise with a map of Australia or other national symbols used on packaging.

Images can also undo a claim that is otherwise correct. The ACCC warns that extra words or pictures can create an overall misleading impression. A product that is truly packed in Australia should not be dressed in artwork that suggests it was grown here. Designers should look at the whole pack, not each element on its own.

The kangaroo logo and the bar chart

The well known kangaroo logo is a registered trade mark. It is administered by Australian Made Campaign Limited. Australian food that meets the food labelling standard may use it free of charge. Goods other than food can only use it under licence.

The rectangle bar chart is a separate graphic. The ACCC says it can be used on goods other than food without a licence or approval. As with any claim, the information it carries still has to be accurate. Check the current rules before adding either mark to your artwork.

Building origin claims into your brand

Origin can be a strong selling point, so it is worth getting right early. Start with the facts of how the product is sourced and made. Then choose the claim that matches those facts, and design around it. That order avoids costly reprints later.

Local makers often lead with origin in their marketing. A business using online marketing strategies for shower screen businesses might put local manufacture front and centre. The same goes for suppliers who talk about materials, such as firms explaining epoxy flooring in your business. Any statement about where a product or its materials come from must meet the same test.

Buyers of larger items often ask where things were made. Someone choosing furniture for an open plan office may compare local and imported pieces. Clear and honest origin details on product pages help them decide. Vague or inflated claims can damage trust that took years to build.

Getting a claim wrong can also cost money. Relabelling stock, reprinting packaging and rebuilding web pages all add up. That is one reason sound financial planning for a growing brand should allow for compliance checks. A short review before launch is far cheaper than a fix afterwards.

Who enforces the rules

The ACCC educates businesses and consumers about origin claims. It accepts reports and may investigate or take compliance or enforcement action. It does not resolve individual disputes or set labelling policy. For seafood labelling questions, the ACCC directs people to their state or territory consumer protection agency.

Rules and standards in this area do change, as the 2026 seafood standard shows. Processes and contacts can also differ between states and territories. Check the current ACCC guidance before you sign off on new packaging. If a claim is borderline, get advice before it goes to print.

Frequently asked questions

Can I say “Made in Australia” if my parts are imported?

Possibly. A “made in” claim allows imported parts if the last substantial transformation happened in Australia. The product must end up fundamentally different from its imported components. Minor processing that only changes form or appearance does not qualify.

Do I need a licence to use the kangaroo logo?

It depends on the product. Food that meets the food labelling standard may use it free of charge. Other goods may only use it under licence from Australian Made Campaign Limited.

Can a picture or flag on my packaging be an origin claim?

Yes. The ACCC says origin can be implied by words, images or symbols. A flag or map could suggest a link to a country. The whole pack must give an accurate overall impression.

What does “Packed in Australia” mean?

It is generally used for food when local processing is not enough for a “made in” claim. Food that cannot be called grown, produced or made in one country must show where it was packed. It is an honest option for many imported foods.

This article is general information only and is not legal advice. Laws and standards change over time, and processes and contacts can differ between states and territories. Speak with a qualified lawyer about your products and labels.