Country of origin labelling for seafood in hospitality settings: information standard and explanatory statement

Submission: Feedback on Proposed
Country of Origin Labelling (CoOL)
Requirements for Seafood in
Hospitality
Document Briefs
1. Seafood CoOL Standard Draft Explanatory Statement
Purpose: Explains the rationale and policy intent behind the proposed Seafood
Information Standard 2025.
Audience Usefulness: This document is not suitable as-is for busy hospitality staff. It
reads like a legislative or regulatory brief and contains legal references, background
policy context, and legislative provisions that are dense and technical.
Improvement Suggestion: A simplified summary version is needed (e.g., a 2-page
factsheet or one-page infographic) using plain English, visual examples, and real menu-
based scenarios.
2. Exposure Draft – Seafood Information Standard 2025
Purpose: Sets out the specific requirements that hospitality businesses must follow
when labelling seafood for immediate consumption.
Audience Usefulness: This document provides the core rules but still contains legal
language and formatting errors (e.g., “Error! Unknown document property name”) that
make it hard to navigate.
Improvement Suggestion: Transform key parts (Sections 5–7) into practical guidance
tools for hospitality businesses: flowcharts, signage templates, example menus, FAQ
sheets.

Does the information help you understand the proposed future labelling requirements?

Yes – but only after careful reading. The AIM model (Australian, Imported, Mixed) is logical and helpful.

The flexibility in how the information can be displayed (acronyms with legends, sourcing regions, etc.) is particularly welcome for venues with limited menu space.
However, small businesses and chefs won’t typically read through 40+ pages of legislative and explanatory text. Without a clear quick-start guide or visual examples, the risk of misunderstanding or non-compliance remains high.

Is any of the language confusing?

Yes. Key areas that are likely to confuse small operators include:

The definitions of “immediate consumption” (What if seafood is sold warm but taken home
later?)
Exceptions to the rule – such as food served at charity events or pre-packaged in fridges.
These may be misread or overlooked.
Phrasing like “supplied in circumstances where labelling is required…” is unnecessarily
legalistic.
Use of abbreviations (A, I, M) requires additional space to explain – not always practical for
small boards, food trucks, or QR menus.

What additional examples or scenarios should be included in future guidance material?

To improve compliance and understanding, future materials should include:

1. Menu Examples for:
Fish and chip shop using the AIM model
Mixed seafood platter with local prawns and imported scallops
Vegan seafood substitutes (to confirm whether labelling is needed or exempt)
2. Online Menu and Delivery Apps:
How should the origin be displayed for platforms like UberEats or Menulog?
3. QR Code Menus or Minimal Space Menus:
How to present legend info when physical space is limited?
4. Ordering From Wholesalers:
Template or sample form for requesting country of origin info from seafood suppliers (to
satisfy Section 6).
5. Pre-made food sold same day (e.g., sushi, poke bowls):
Clarify what counts as “immediate consumption” and when CoOL applies.

Recommendations

To ensure successful uptake in hospitality:

Create a Hospitality Industry Quick Guide (2 pages max).
Include pre-designed menu templates for labelling seafood origin.
Provide a compliance checklist for managers.
Offer training videos or animations explaining AIM labelling in under 3 minutes.
Clarify what record-keeping looks like in practice – sample forms, storage tips, and
integration with POS or inventory systems.

Submitted on behalf of:
Hospitality businesses including small restaurants, cafes, pubs, food trucks, takeaway shops, and chefs—who welcome transparency but need practical, time-efficient ways to comply.