Food Claims Do Not Have to Copy the Code Word for Word
We hear it often, from public health dietitians, food businesses and regulatory teams alike:
“That claim is non-compliant because it does not use the exact words from Schedule 4 of the Food Standards Code.”
It is a persistent misconception, and it quietly holds back clear, accurate and consumer-friendly communication. The Code gives food businesses more wording flexibility than some people assume. The catch is knowing where that flexibility ends.
What the Code says
Section 1.2.7-10 of Standard 1.2.7 makes the point directly. The Standard does not lock you into a fixed form of words. In its own terms:
Nothing in this Standard is to be taken to prescribe the words that must be used when making a claim.
Standard 1.2.7, section 1.2.7-10
In plain English: a nutrition content claim or a health claim does not have to repeat the exact words used in Schedule 4. What matters is whether the claim communicates a permitted meaning, meets the relevant criteria, and can be substantiated for the specific product. Repeating a phrase from the Code is not necessary for compliance nor, on its own, sufficient.
Why this matters commercially
Consumers do not always respond well to technical regulatory language. A claim that is technically precise but awkward may fail to help a shopper understand the product, and it may not suit the brand, category or target market.
The flexibility in the Code lets you close that gap, but it has limits. Nutrition content claims and health claims still need to meet the relevant requirements in Standard 1.2.7 and Schedule 4, including the applicable claim conditions, substantiation requirements and required supporting information.
When we review a claim or suggest new wording, we ask:
“Does this claim accurately communicate a permitted meaning, can the product support it and what else needs to go on the label because of it?”
Different wording, the same compliance question
A product can use wording that differs from the Code and still be compliant. Equally, a product can use familiar, Code-style wording and still be non-compliant if it does not meet the criteria. The wording is the surface; the compliance question sits underneath it.
Take protein. A food providing at least 10 g of protein per serving can be able to support a “good source of protein” type claim, provided the other conditions in the Code are met. Alternative wording such as:
• “high in protein”, or
• “rich in protein”
is not automatically non-compliant simply because the words differ. But neither is it automatically equivalent. Different wording does not switch off the requirements of the Code; it just changes the wording that you need to check.
Health claims need extra care
Health claims demand more care than nutrition content claims because they do more than describe what is in a food. A health claim implies a relationship between a food, or a property of a food, and a health effect. That means the permitted or self-substantiated relationship behind the claim matters as much as the words on the front of pack.
A calcium and bone-health relationship, for example, might be expressed in several consumer-friendly ways:
• Calcium contributes to normal bone structure
• Calcium supports healthy bones
• Calcium helps maintain bone health
The wording is only part of the question. The product must be eligible to carry the claim, the food-health relationship must be either pre-approved or properly self-substantiated, and any required dietary context and label information must be handled correctly. General level health claims can rely on a pre-approved food-health relationship or one established through the self-substantiation process under the Code.
See the FSANZ guidance on nutrition, health and related claims and on notifying a self-substantiated food-health relationship.
Do not forget the nutrient profiling scoring criterion
Most foods that carry a health claim must meet the nutrient profiling scoring criterion (NPSC), with some exceptions set out in the Code. The NPSC is a gate: if a food does not meet it, no amount of careful wording will make a health claim compliant.
It is not only health claims that are affected. Some nutrition content claims, such as those about glycaemic index and glycaemic load also carry NPSC-related requirements for most foods. Check whether the specific claim triggers the NPSC before settling on wording.
For detail, see the FSANZ nutrient profiling scoring criterion guidance.
Dietary fibre: a real-life wording challenge
In our experience, dietary fibre is one of the trickiest areas to get right. The Schedule 4 relationship for a dietary fibre health claim is that fibre “contributes to regular laxation”. That is technically correct, but it is not consumer-friendly, and you will rarely see it printed on a pack.
The task is to find wording that preserves the permitted meaning while reading naturally. “Helps support regularity”, for instance, stays close to the approved relationship. Going a bit further out a limb, wording like “Helps your body find its natural rhythm” could work. The risk is wording that drifts away from the substantiated outcome and into broader, unsupported “gut health” territory, which the relationship does not cover.
A word of caution on “gut health”
“Gut health” is a good example of a phrase that sounds positive but can create real risk. It is broad and imprecise, without a consensus-based official medical definition which makes it hard to substantiate as a single, defined health effect. A softer, more consumer-friendly phrase is still a health claim if it implies a relationship between a food and a health effect.
If you want to talk about the gut, a self-substantiated claim is safer when it points to a narrower, measurable outcome, such as a specific effect on gut symptoms or on gut microbiome diversity, rather than a vague, all-encompassing benefit.
Where the flexibility runs out
The flexibility in section 1.2.7-10 does not support a Wild-west for claims. It will not rescue a claim that is inaccurate, overstated, unsupported or likely to mislead. Common risk areas include:
• Claims that do not meet the criteria. If a product does not meet the conditions for a “source of protein” claim, rebranding it as “protein power” does not fix the underlying problem.
• Health claims on foods that fail the NPSC. If the food does not meet the NPSC where required, the health claim is not available, whatever the wording.
• Therapeutic or over-extended claims. Pushing beyond the permitted relationship is a classic trap. Stating that “calcium prevents osteoporosis”, for example, over-extends a bone-health relationship into a disease-prevention claim the Code does not permit.
• Soft wording that still implies a health relationship. A gentle, consumer-friendly phrase can still be a health claim. Vague or unsupported relationships, such as broad “gut health” messaging, are the danger zone.
• Missing supporting information. Claims trigger extra requirements, such as nutrient information in the Nutrition Information Panel and dietary context statements for health claims.
• Artwork-stage errors. Required supporting information can quietly fall off as packaging moves through design, layout and artwork approval.
Code compliance also sits alongside consumer law. The ACCC warns that businesses may need to back up the claims they make, and that misleading claims can lead to enforcement action. See the ACCC false or misleading claims guidance.
Don’t just ask whether the words appear in the Code. Ask what the claim means, whether the criteria are met, and whether the product can support it.
The practical takeaway
Food claims do not need to use the exact words in the Food Standards Code. They do need to be accurate, permitted, and supported by the product’s composition and label information.
So the next time someone says, “That claim is non-compliant because it does not use the exact words,” the better response is simple:
“Let’s check the meaning, the criteria and the supporting information.”
That is where the real compliance work sits.
Need help with compliant, consumer-friendly claims?
Good claims review is not just a word-matching exercise.
At Food360, we bring together food regulatory expertise and nutrition science. We do not just ask whether a phrase appears in the Code. We look at what the claim means, whether the product can support it, how the science sits behind it, and how consumers are likely to understand it.
That combination matters. It helps food businesses move beyond technically correct wording to claims that are accurate, substantiated, commercially useful and clear.
If you are developing new packaging, refreshing product claims or trying to make technical nutrition messages more consumer-friendly, Food360 can help you find claim wording that works in the real world and stands up to scrutiny.
Disclaimer: This article is general information based on publicly available FSANZ material as at 26 May 2026. It does not constitute regulatory or legal advice. For tailored advice on your products, please contact Food360.
References
• Australia New Zealand Food Standards Code – Standard 1.2.7 – Nutrition, health and related claims — https://www.legislation.gov.au/Latest/F2015L00394 and Schedule 4 – Nutrition, health and related claims – https://www.legislation.gov.au/F2015L00474/latest/versions
• FSANZ nutrition, health and related claims guidance — https://www.foodstandards.gov.au/business/labelling/nutrition-health-and-related-claims
• FSANZ self-substantiated food-health relationship guidance — https://www.foodstandards.gov.au/business/labelling/nutrition-health-and-related-claims/notifying-fhr
• FSANZ nutrient profiling scoring criterion (NPSC) guidance — https://www.foodstandards.gov.au/business/labelling/nutrition-health-and-related-claims/nutrient-profiling-scoring-criterion
• ACCC false or misleading claims guidance — https://www.accc.gov.au/consumers/advertising-and-promotions/false-or-misleading-claims