Who sets the rules for pet packaging in Australia
Unlike human food, pet food in Australia has no FSANZ code and no national mandatory labelling standard. Three things govern the pack instead.
- AS 5812:2023 Manufacturing and marketing of pet food (cats and dogs), the Australian Standard developed with the Pet Food Industry Association of Australia (PFIAA). It is voluntary in law, a condition of PFIAA membership, and the reference the retailers, the vets and the ACCC use. The 2023 edition replaced AS 5812:2017.
- The Australian Consumer Law, enforced by the ACCC: no misleading or deceptive conduct, no false representations about composition, origin or benefits. This is where most pet packaging actually gets into trouble.
- Trade measurement law under the National Measurement Institute for the net quantity statement, and GS1 for barcodes, exactly as for any grocery product.
Two adjacent regimes sometimes apply. Products that make a therapeutic claim for an animal (treats a condition, prevents fleas, a veterinary medicine) are regulated by the APVMA, not the pet food standard, and need registration and an APVMA number on the label. Imported pet food and treats also need to clear Department of Agriculture import conditions, which can dictate ingredients and even packaging declarations before anything reaches a shelf.
The South Australian bill
In June 2024 the Pet Food (Marketing and Labelling) Bill 2024 was introduced in the South Australian Legislative Council. It would make it an offence to sell pet food in South Australia that is not labelled and marketed in line with AS 5812:2023, with penalties starting at $20,000. It passed the Legislative Council with bipartisan support and was before the House of Assembly at our last check. If it becomes law it is the first mandatory pet food labelling regime in the country, and because no brand runs a separate South Australian label, it effectively becomes national. Design to AS 5812 now and the question is moot.
What AS 5812 puts on the label
The Standard itself is a paid document from Standards Australia. The labelling elements it requires, as summarised by the PFIAA, are these.
| Element | What it means on the pack |
|---|---|
| Identification as pet food | The words PET FOOD ONLY (or words to the same effect) conspicuously on the label, or printed on the end of a can, plus an illustration of the whole body or head of the species it is for. |
| Brand and variety name | The variety name must be informative and an accurate description of style and flavour. Chicken and rice has to be chicken and rice. |
| Nutrition information | A guaranteed or typical (average) analysis, protein and fat at minimum. Energy and other nutrients are optional. |
| Nutritional adequacy statement | Whether the product is complete and balanced for a stated life stage, or intended for intermittent or supplemental feeding (a treat, a topper, a complementary food). |
| Feeding guide | Directions for use by weight or life stage. They are a guide and the label can say so. |
| Ingredients | In descending order by weight, water excepted, naming the species of meat (poultry, beef, fish) and declaring additives: flavours, colours, preservatives, added vitamins and minerals. Sulphur dioxide and sulphites must be identified by name or FSANZ code number. |
| Date marking | Long-life products (two years and over) carry a packaging date. Shorter-life and chilled products carry a best before or use by date and any storage conditions. |
| Net weight | Trade measurement rules apply: the net quantity in metric units, in the character heights the NMI sets for the pack size. |
| Name and address | The manufacturer's or importer's name and address. |
| Barcode | Expected by every major retailer; see below. |
Everything else on a pet pack is marketing, and marketing is where the ACCC lives.
Claims: what the ACCC and the retailer will challenge
Pet owners read labels harder than they read their own food. The claims that generate complaints, retailer pushback and ACCC interest are predictable.
- Composition claims. Grain free, single protein, 80 percent meat, no fillers. Each is a factual representation and the formulation has to prove it. Percentage claims in particular need a basis (as fed or dry matter) and the basis stated.
- Origin claims. Australian made and Australian owned are separate claims under the ACCC's country of origin rules, and the kangaroo logo and bar chart used on food can be used on pet food voluntarily but must then be accurate. Imported ingredients packed here are not Australian made unless substantial transformation occurred.
- Human grade. There is no Australian definition. The ACCC treats it as a representation that every ingredient and the facility meet human food standards. Most products cannot prove that; the term is a complaint waiting to happen.
- Health claims. Supports joints, improves coat, calms anxiety. A functional claim with evidence is fine; a therapeutic claim (treats, cures, prevents a condition) moves the product into APVMA territory and off the pet food shelf.
- Natural and holistic. Not defined, not regulated, widely used. The risk is pairing them with an ingredients list that includes synthetic preservatives or colours. The pack has to be consistent with itself.
- Vet recommended and breed-specific claims. Both are representations that need substantiation. Petbarn, which owns a vet network, is particularly alert to the first.
The retailers: Petbarn, Petstock and grocery
Australian pet retail runs through three channels with different buyers and different shelves: the specialist chains, grocery, and online (Pet Circle, the retailers' own sites, Amazon). This guide is about the first two.
Petbarn
Petbarn is owned by Greencross, which also runs Greencross Vets, City Farmers and the Habitat stores it acquired. It is the largest specialist chain and the one with the deepest premium and vet-adjacent range. Petbarn ranges its own private label brands, including Providore for Dogs, which the studio designed; a national brand pack sits beside that on the shelf and is judged against it. Greencross buyers look for a reason to range: a format, a protein, a price point or a positioning the shelf does not already have. New suppliers go through a buyer and a supplier set-up process with the usual trading terms, GS1 barcodes and product data requirements.
Petstock
Petstock is the second specialist chain. Woolworths Group acquired a 55 percent interest in December 2023, under an ACCC undertaking that required Petstock to divest 41 stores, 25 co-located vet hospitals, four brands and two online stores. Petstock continues to run as a standalone business, but the direction of travel is towards Woolworths-grade supply chain compliance. Expect Petstock's barcode, carton and data expectations to move towards the Woolworths Packaging and Barcode Specifications over time, and design cartons to that standard now.
Grocery
Coles and Woolworths carry the volume brands and their own private labels, on the same supplier compliance regimes as every other grocery category: Coles Supply Standards and Supplier Central, Woolworths Vendor Quality Compliance and the Partner Hub. The pet aisle in a supermarket is bought on price and rotation; the specialist shelf is bought on ingredient story and format. The same brand often needs two front panels: one that competes on value at 500 grams, one that competes on provenance at 2.5 kilograms.
What all of them require of the carton
- A GS1 GTIN on the retail unit in EAN-13, and a GTIN-14 in ITF-14 or GS1-128 on the trade unit. Pet food bags are large and often laminated or gusseted; the barcode must sit on a flat panel, not across a gusset or a seal.
- Shelf-ready and shippable cartons for small-format lines (treats, cans, pouches), with the five easies the grocers expect: easy to identify, open, shelve, shop and dispose of.
- Carton weight within the retailer's manual handling limit (Coles sets its trade unit limit; check the current figure) and a weight icon on heavy bags.
- Date and batch coding legible on the outer, not only the inner.
- Sustainability data and, in grocery, the Australasian Recycling Label on the retail unit. Multi-layer pet food bags are usually not kerbside recyclable; say so accurately rather than claiming otherwise.
Formats and what they demand of the artwork
| Format | Design constraint |
|---|---|
| Large dry food bag (2 to 20 kg) | Front panel is read standing up on the floor stack; the hero zone is the top third. Side gussets carry the feeding guide and analysis. Handles, zips and the carry orientation decide where the barcode can go. |
| Small bag and pouch (treats, toppers, cat food) | Peg hook hang or shelf stand; two orientations, two front panels. Resealable zip and the hang hole eat into the artwork area. |
| Can and tin | The label or printed can carries PET FOOD ONLY on the end as the Standard allows; the curved face limits barcode placement to ladder orientation. |
| Tub and chilled roll | Short shelf life, so use by dating and storage instructions move to the front. Chilled cabinets are lit differently; test colour in situ. |
| Supplement and treatment | Dose and count on the front, directions and warnings on the back, and the classification question (pet food, feed supplement or APVMA-registered veterinary chemical) answered before a line is drawn. |
The Standard's requirement for a species illustration is a design opportunity rather than a constraint. Where the brand already uses a dog or cat as the hero, the requirement is met by the brand itself; the mistake is adding a token silhouette to an otherwise typographic pack because someone read the rule late.
Winning the specialist shelf
Four things the studio holds to on pet packaging, learned on both sides of the Petbarn shelf.
- Pet food is bought by a person, not a pet. The owner is the most claim-aware shopper in the store and the pack has to earn trust with ingredient transparency and sourcing first, then be charming.
- On the specialist shelf, private label is the competitor. Petbarn and Petstock range their own premium brands next to yours. A national brand pack has to beat the retailer's own range at a glance, on the retailer's own shelf.
- Transparency is the price of entry, not the point of difference. Every serious brand lists its ingredients and sourcing now. What separates the winners is range architecture: a system that lets the owner find the right life stage, protein and format in seconds.
- Say what the product is for before saying what it is free from. A front panel built out of negatives (grain free, no fillers, no artificial anything) tells the owner what you are not. The shelf is full of that.
Providore for Dogs, designed for Petbarn, is the private-label side of that lesson: a premium range that had to look like the best thing on the shelf while sitting in the retailer's own brand block. Natural Animal Solutions is the supplement side: a therapeutic-adjacent range that had to carry its claims carefully across pet specialty, vet and pharmacy.
What gets a pet pack sent back
- No PET FOOD ONLY statement, or no species image, on a product the retailer expects to meet AS 5812.
- A variety name the formulation does not support, or a meat species not named in the ingredients list.
- A percentage or composition claim with no stated basis.
- Human grade, vet recommended or breed-specific claims with nothing behind them.
- An Australian made claim on a product packed here from imported ingredients.
- A therapeutic claim on a product that is not APVMA registered.
- Barcode across a gusset, a seal or a curved face; carton barcode on one side only.
- Use by or packaging date missing, or a storage condition missing on a chilled line.
- A recyclability claim or ARL that does not match the laminate.
- A national brand pack that is visibly weaker than the retailer's own private label beside it. Not a compliance failure, just a ranging one.
Questions people ask
Not by a national law. The benchmark is the voluntary Australian Standard AS 5812:2023, mandatory for PFIAA members, and the Australian Consumer Law applies to every claim. South Australia has a bill to make AS 5812 compulsory that passed its upper house in 2024.
PET FOOD ONLY and a species image, the brand and an accurate variety name, a guaranteed or typical analysis, a nutritional adequacy statement, a feeding guide, ingredients in descending order naming the meat species, additives declared, date marking, net weight and the manufacturer's or importer's name and address.
There is no legal definition, and the ACCC treats it as a claim that every ingredient and the facility meet human food standards. Unless you can prove that, it is a misleading representation risk. Say what is actually true about the ingredients instead.
Petbarn is owned by Greencross, which also owns Greencross Vets. Woolworths Group acquired a 55 percent interest in Petstock in December 2023 under an ACCC undertaking that required Petstock to divest 41 stores, 25 co-located vet hospitals, four brands and two online stores.
Treats are pet food under AS 5812 and carry the same elements, with the nutritional adequacy statement making clear they are for intermittent or supplemental feeding rather than a complete diet.
Only if the product makes a therapeutic claim or is a veterinary chemical product. A nutritional supplement marketed as a food or feed supplement does not, but the claims on the pack decide which side of the line it sits on.
Sources
- Pet food labelling: keeping up the standard (AS 5812 label elements), PFIAA
- Pet Food Standards, PFIAA
- Pet Food (Marketing and Labelling) Bill 2024, Parliament of South Australia
- Petstock Pty Limited and Woolworths Group Limited, section 87B undertaking, ACCC
- Stockfeed and pet food regulation, APVMA
- Country of origin food labelling, ACCC
- GS1 Australia
Published . Last reviewed . Next scheduled review . Regulatory content is re-checked against the primary sources above at each review. See our editorial standards.
