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Submission: Personal response to
Exposure Draft – Country of Origin
Labelling (CoOL) for Seafood in
Hospitality Settings
Thank you for the opportunity to provide feedback on the Exposure Draft of the Competition and Consumer (Australian Consumer Law – Country of Origin Information for Seafood for
Immediate Consumption) Information Standard 2025.
Disclaimer: This submission is made in a personal capacity. The views and opinions expressed are solely my own and do not reflect those of any organisation with which I am professionally affiliated.
As a consumer, I strongly support the introduction of mandatory country of origin labelling in hospitality settings—I want to know where my seafood comes from, and I believe all
Australians should have access to that information when dining out.
In my view, fish names should be mandated and standardised, not voluntary. Correct, scientific naming helps prevent misrepresentation, protects Australian brands from substitution risk, and gives consumers the clarity they rightly expect, particularly in high-value categories where provenance is a unique selling point. Accurate, consistent naming of seafood species is critical to supporting consumer trust, avoiding misrepresentation, and protecting the integrity of both domestic and imported products in a highly competitive market.
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Key Feedback on the Exposure Draft
1. Seaweed and Aquatic Plants Are Omitted
The draft excludes any reference to aquatic plants, including seaweed, despite their growing relevance in modern seafood cuisine. According to AgriFutures Australia, the domestic seaweed industry could generate $100 million annually within five years, scaling to $1.5 billion over 20 years. With dishes like kelp noodles, nori wraps and wakame salads now common in hospitality, the legislation should clarify whether aquatic plants fall within scope.
While this may not be viewed as a key priority today, I believe it is better to include clarity now than to trigger a separate review process down the line.
2. Digital Menus and Food Delivery Platforms Must Be Explicitly Included
The draft only vaguely refers to information being “in writing” or “on menus,” with no explicit inclusion of digital menus, QR codes, online ordering, or food delivery platforms.
Yet this is where modern consumers engage, and I believe is a critical gap:
● > 70% of Australian diners now use digital platforms (e.g. QR codes, online menus or
apps) to place food orders, particularly post-COVID (Hospitality Magazine, 2023).
● As of 2024, more than 40% of Australians order food digitally at least once per week,
either through apps or venue-linked platforms (Statista, 2024).
● The online food delivery market in Australia exceeded $2.6 billion in 2024, with
platforms like Uber Eats and DoorDash accounting for a growing share of seafood
sales—particularly in metro areas (IBISWorld, 2024).
If digital environments aren’t clearly included, the regulation will fail to meet consumers at the point of purchase and risk creating an uneven playing field across hospitality. Resulting in a substantial portion of seafood sold for immediate consumption remaining unlabelled, and thereby undermining the purpose of the standard.
3. No Penalty Framework Risks Weak Compliance
The draft lacks any detail on enforcement or penalties, despite consensus across industry that the current voluntary model has failed. Without a clear deterrent, the legislation risks replicating the ineffectiveness of the voluntary model.
I support the Seafood Industry Australia (SIA) recommendation to apply penalties consistent with the Australian Consumer Law, with sufficient deterrents for non-compliance. Otherwise, the regulation will lack integrity and effectiveness.
I support aligning penalties with the Competition and Consumer Act 2010, which provides mechanisms for fines and substantiation requests. Enforcement must be visible, scalable and backed by compliance checks.
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4. Phased Rollout and National Education Campaign
I support the recommendation of a 12-month implementation period, followed by full compliance and enforcement at 24 months. This is aligned with menu print cycles and operational readiness.
This should be supported by a national awareness campaign, covering:
● Consumer education,
● Foodservice training (especially small venues),
● Bilingual and culturally appropriate materials.
The successful 2016 CoOL retail campaign is a proven model.
5. ‘Immediate Consumption’ Requires Definition
The term is undefined in the draft. I support the recommend the recommended definition that:
“Immediate consumption refers to food or beverages intended to be consumed
shortly after supply, whether on-site or off-site, including takeaway.”
This ensures consistency across restaurants, cafés, pubs, and quick-service venues.
6. Record-Keeping Period Is Too Short
The proposed three-month retention window is insufficient for enforcement or audit processes. I support the recommendation to extend the requirement to 24 months, in line with standard accounting and food safety practices.
7. Clarify Terminology: Use ‘Imported’, Not ‘International’
I believe that the allowance for both “imported” and “international” labelling is unnecessary and risks consumer confusion. The term “imported” is widely understood and should be standardised across the regulation.
8. Mandate Use of the Australian Fish Names Standard
I strongly advocate for the mandatory use of the Australian Fish Names Standard in hospitality. Voluntary uptake of the standard has proven ineffective, with widespread and most often unintentional mislabelling and inconsistency in naming applications. Accurate naming is fundamental to provenance, species protection, and informed consumer decision-making.
Accurate, standardised naming will:
● Protect consumers from misrepresentation;
● Provide seafood business with the standardised and accurate naming conventions to
use;
● Safeguard the integrity of Australian seafood species and brands;
● Support regulatory compliance and export equivalency.
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