As featured in the latest edition of the QHA Review
From 1 July 2026, hotels, pubs, restaurants and other hospitality venues across Australia will be subject to new country of origin labelling requirements for seafood sold for immediate consumption.
While the reforms may appear to be a straightforward exercise in updating menus, the new requirements introduce broader compliance obligations and potential consumer law risks for hospitality operators. Venues will need to ensure not only that menus and ordering systems are updated, but also that supplier arrangements and internal records are capable of supporting accurate seafood origin claims.
what are the new requirements?
The new rules are introduced under the Competition and Consumer (Australian Consumer Law – Country of Origin Information for Seafood for Immediate Consumption) Information Standard 2025, made under the Australian Consumer Law (ACL).
The reforms apply to hospitality businesses supplying seafood for immediate consumption, including pubs, hotels, restaurants, cafes, clubs, takeaway venues and food delivery services. “Immediate consumption” includes dine-in, takeaway and delivered meals.
Under the reforms, businesses must disclose whether seafood served to customers is Australian (A), imported (I), or mixed origin (M). This information must be clearly visible before customers place an order, meaning venues may need to update printed menus, menu boards, QR code ordering systems, websites and online ordering platforms.
The rules apply to dishes marketed as containing seafood, including dishes commonly associated with seafood such as “spaghetti marinara” or “surf and turf”. However, some products are excluded, including seafood in liquid form (such as fish sauce) and shelf-stable seafood products such as canned tuna.
How can venues label seafood?
There are three (3) approved methods for labelling the origin of seafood ingredients:
- Single letter AIM labels: using (A) for Australian seafood, (I) for imported seafood, and (M) for mixed origin seafood. Where this method is used, each letter is placed next to the relevant menu item and must be accompanied by a legend explaining the meaning of each label;
- Detailed AIM labels: using wording such as “Australian seafood”, “contains imported seafood” or “mixed origin seafood” next to each menu item; or
- A single statement for the whole business: where a venue only serves Australian seafood or only imported seafood. For example, “We only serve Australian seafood.” However, this option cannot be used if both Australian and imported seafood products are used.
Where a venue temporarily changes seafood suppliers or seafood origin due to shortages or availability issues, businesses may use temporary signs, stickers or notices to communicate the change to customers. Digital menus and ordering platforms must also be updated.
Australian Consumer Law risks
Under section 29 of the ACL, businesses must not make false or misleading representations regarding the place of origin of goods. Doing so may constitute an offence under section 151 of the ACL. Additionally, section 203 of the ACL requires businesses to comply with applicable information standards.
Potential consequences for non-compliance may include Australian Competition and Consumer Commission (ACCC) investigations, infringement notices, enforceable undertakings, corrective advertising orders and significant financial penalties.
The ACCC may issue infringement notices where it has reasonable grounds to believe a business has breached the ACL. Current infringement notice penalties may include:
- $19,800 (60 penalty units) for corporations;
- $198,000 (600 penalty units) for listed corporations; and
- $3,960 (12 penalty units) for individuals.
For more serious breaches, individuals may face penalties of up to $2.5 million, and for corporations, the maximum penalty is the greater of:
- $100 million;
- three times the value of the reasonably attributable benefit obtained; or
- 30% of the corporation’s adjusted turnover during the breach period.
Businesses may also face reputational damage or claims from customers arising from inaccurate seafood origin representations.
record keeping and supplier management
Businesses must retain records evidencing the origin of seafood products for at least 3 months after the seafood was last offered for sale. This may include supplier invoices, receipts, supplier emails or photographs of packaging displaying country of origin information.
Businesses are entitled to request country of origin information from suppliers in writing and may therefore wish to review supplier arrangements to ensure seafood origin information is being provided accurately and consistently.
Final thoughts
While the reforms are aimed at improving transparency for consumers, they also create new compliance obligations for hospitality businesses across Australia.
For many venues, compliance will involve more than simply updating menus. Businesses may also need to review supplier arrangements, ordering systems, staff training and internal procedures to reduce the risk of ACL breaches by making inaccurate seafood origin representations.
Please contact me on 07 3224 0230 if your business requires assistance in understanding the new obligations under the ACL, or any other matters affecting your business.
