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AUSTRALIAN GOVERNMENT
DEPARTMENT OF INDUSTRY, SCIENCE AND
RESOURCES
COUNTRY OF ORIGIN FOR SEAFOOD IN
HOSPITALITY SETTINGS
APRIL 2025
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INTRODUCTION
[1] The Restaurant and Catering Industry Association of Australia Incorporated (R&CA) are pleased to provide comments for the Country of Origin for Seafood in hospitality settings – consultation.
ABOUT THE RESTAURANT & CATERING ASSOCIATION
[2] Founded in 1922, R&CA is the national industry association representing the interests of more than 57,000 restaurants, cafés, and catering businesses across Australia. The café, restaurant, and catering sector is vitally important to the national economy, generating over
$35 billion in retail turnover each year as well as employing 580,000 people.
[3] R&CA delivers tangible outcomes to small businesses within the hospitality industry by offering evidence-based solutions to various industry challenges. Our aim is to improve regulations and policies that impact the sector’s operating environment to foster robust and prosperous businesses across Australia.
[4] We work to ensure the industry is respected for its integrity, professionalism, and dedication to excellence. This includes advocating the broader social and economic contribution of the sector to industry and government stakeholders, as well as highlighting the value of the industry to the Australian way of life.
[5] Given our remit, footprint, engagement with the sector, and ongoing advocacy, we provide you with the following submission and speak with authority.
BACKGROUND
[6] The Country-of-Origin Labelling Scheme (CoOL) requires all restaurants, cafes, and similar businesses that sell seafood to provide information about where their seafood is sourced from.
This includes seafood that is served, delivered, packaged, and ready for consumption.
Businesses will need to list whether their produce is of Australian origin, mixed origin, or imported.
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Challenges
[7] The R&CA recognises the regulatory cost burden for businesses under this new requirement. The R&CA notes that this will provide further red tape for an already over- regulated sector.
[8] The main concerns the R&CA has raised are as follows;
• The cost of reprinting and redesigning menus
• The need to update information regularly due to changes in supply
• Inability of the Australian seafood industry to meet domestic demand
• Dissuading consumers from purchasing seafood of mixed or foreign origin when the
quality and safety of seafood are comparable or superior to domestic supply
• Unintended adverse perception of imported seafood
• Implications on future country of origin labelling regulations i.e. poultry, red meat, fruit,
and vegetables etc
• The impractical application of this mandate on catering and event businesses, who
may be opted to disclose the origins of seafood more than once
• The issue of regulating and enforcing adherence to the Country-of-Origin Labelling
Scheme
• Businesses deliberately mislead consumers about seafood country of origin due to
lack of regulatory oversight and enforcement
OUR POSITION
[9] R&CA supports best practices for restaurant and hospitality businesses and believes these new requirements will incur disproportionate costs and regulatory burdens for small businesses. The R&CA also raises that monitoring compliance will likely prove to be difficult for regulatory bodies, who will have to determine whether the responsibility of providing the correct country of origin falls on the supplier or business operator.
[10] This will therefore provide additional record-keeping responsibilities to businesses to ensure they are compliant with these standards. R&CA also raises concern that penalties for non-compliance and the approach to effective regulation will take time to be understood once clarified.
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[11] This will determine whether the policy is practical in its application, and provides sufficient benefit to the consumer, through providing accurate information regarding seafood country of origin.
RECOMMENDATIONS
[12] R&CA recommends that CoOL requirements are adaptable to accommodate the unique requirements of all restaurant and hospitality businesses. R&CA notes that small businesses face a disproportionate cost burden to comply with these new regulations.
[13] It is recommended that the following compliance methods are agreed upon:
• QR Code on top of the menu or placed beside menu items;
• Seafood country of origin is updated on the website; and
• Seafood country of origin is updated on a chalkboard, core flute, whiteboard etc.
[14] R&CA also recommends that catering and venue businesses are not mandated to disclose seafood country of origin when menus are issued. R&CA believes they should only be required at the time of set-menus being purchased.
[15] R&CA thank the Department of Industry, Science and Resources for consideration of our recommendations, and welcome engagement on 1300 722 878 or policy@rca.asn.au.
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