Does Country of Origin Labelling for food (CoOL Information Standard) apply to retail trade businesses?
A computed answer from the Rules Mate applicability engine, with the exact condition, the outcome for every structure and size, and the primary source.
Short answer: Only if
Only if you supply priority food (CoOL Information Standard). Being in this industry makes the obligation worth checking (Industry: Retail trade), but the trigger is a fact the industry alone does not settle.
The obligation in brief
Country of Origin Labelling for food (CoOL Information Standard). The Country of Origin Food Labelling Information Standard 2016 (made under the ACL) requires priority food sold in retail to carry CoOL labels including the kangaroo logo for products made/grown/produced/packed in Australia, plus the percentage of Australian-sourced ingredients on a coloured bar chart.
Trigger: Supplying priority food (most food not consumed as it leaves the supplier) at retail.
Why retail trade get a different answer
Rules Mate runs its applicability engine across 9 business structures and 6 size bands for each of the 35 industries it maps. For 33 of those industries the answer for "Country of Origin Labelling for food (CoOL Information Standard)" is no. Retail trade is one of the 2 where the answer is different: only if.
The deciding fact for retail trade businesses: Industry: Retail trade; applies only if you supply priority food (CoOL Information Standard)
About the industry: Retailers covered by the General Retail Industry Award and ACL product safety.
Compare a professional services (general) business with 6–19 employees structured as a Pty Ltd company: the obligation does not apply (Requires a trigger outside this questionnaire).
Answer by business structure and size
Each cell is the engine's outcome for a business in retail trade with that structure and size, assuming it sells to consumers and small businesses and holds customer contact details. "Check" means the obligation turns on a fact the industry does not settle.
| Structure | No employees | 1–5 employees | 6–19 employees | 20–99 employees | 100–499 employees | 500+ employees |
|---|---|---|---|---|---|---|
| Sole trader | Check | Check | Check | Check | Check | Check |
| Partnership | Check | Check | Check | Check | Check | Check |
| Trust | Check | Check | Check | Check | Check | Check |
| Pty Ltd company | Check | Check | Check | Check | Check | Check |
| Public company | Check | Check | Check | Check | Check | Check |
| Not-for-profit (unregistered) | Check | Check | Check | Check | Check | Check |
| Registered charity | Check | Check | Check | Check | Check | Check |
| Super fund | Check | Check | Check | Check | Check | Check |
| Foreign company | Check | Check | Check | Check | Check | Check |
What the obligation requires
- When due
- Continuous.
- Evidence to keep
- Compliant labels, supplier declarations, percentage-of-AU calculations.
- Maximum penalty
- Civil penalty up to $16.665M for false/misleading representations (ACL)
- Regulator
- ACCC
- Jurisdiction
- Commonwealth (national)
Other obligations where retail trade differ from the norm
- Button + coin battery safety standard (mandatory): Only if
- Comply with mandatory product safety standards + bans (ACL): Yes
- Notify ACCC of a voluntary recall within 2 days: Yes
- Comply with Heavy Vehicle Chain of Responsibility (CoR): Only if
- Food and Grocery Code of Conduct (now mandatory): Only if
- Franchising Code of Conduct (mandatory industry code): Only if
- All 16 answers for retail trade
Questions
- Does Country of Origin Labelling for food (CoOL Information Standard) apply to retail trade businesses?
- Only if you supply priority food (CoOL Information Standard). Being in this industry makes the obligation worth checking (Industry: Retail trade), but the trigger is a fact the industry alone does not settle.
- Is the answer the same for every industry?
- No. For 33 of the 35 industries Rules Mate maps, the answer is no. Retail trade is one of 2 industries with a different answer.
Related
Sources
Computed by the Rules Mate applicability engine from the published obligation corpus; facts last checked 3 October 2026. Rules Mate is not a law firm and this is general information, not legal advice. Confirm your position with the regulator source or a qualified adviser before acting.