www.pwc.com.au
Cost
Schedule
for Food
Labelling
Changes
Department of Health
April 2014
Executive summary
This report, prepared by PricewaterhouseCoopers (PwC) for the Department of Health,
presents a schedule which estimates the costs incurred by food companies to changing food
and beverage labelling as a result of regulatory and non-regulatory changes. This schedule is
an update of a report developed previously by PwC in 2008 entitled ‘cost schedule for Food
Labelling Changes’ (“the cost schedule”) developed for Food Standards Australia New
Zealand (FSANZ).
The original 2008 cost schedule was developed to provide an indication of the scale and
types of costs incurred by companies when considering changes to food and beverage
labelling. This renewed cost schedule has been commissioned to bring these estimates up to
date.
While the cost schedule serves as a useful starting point when considering the impacts that
regulatory and non-regulatory changes have on labelling, it must be recognised that
particular changes will need to be investigated on a case by case basis as impacts of changes
will vary across companies, industry sectors and products.
Direct costs
Companies incur many costs, however for the purposes of developing the cost schedule,
direct costs are defined as:

Label design – the cost of engaging designers to make changes to or re-design the label
(or package for direct print labels)

Label production – the costs associated with the production of labels over and above
printing, such as new printing plates

Proofing – the cost of viewing incorporated text, colour and/or graphics changes to the
label, to ensure that the label is how it should be before printing. This may include
testing of new plates

Package redesign – the costs associated with changing the shape, or size of packaging.
The direct costs include packaging redesign costs and packaging proofing costs

Labour – the labour inputs involved in responding to regulatory changes, such as
marketing, management, administration, technical and regulatory expertise.
Labelling change scenarios
The scale and scope of changes to food labelling are also vast and varied, and for the purpose
of this assignment, three generic scenarios of label changes were developed and are defined
as:

Minor – changes to text and one printing plate only

Medium – changes to text and/or label layout, changes to three printing plates and
proofing required
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Executive Summary

Major – changes to text and/or label layout, changes to six printing plates, proofing
required and changes to packaging shape/size/design.
Industry participation
PwC has developed this cost schedule leveraging a similar survey methodology used to
develop the original 2008 cost schedule (originally developed in conjunction with FSANZ
and the Australian Food and Grocery Council (AFGC)).
The current survey was sent to 143 food industry companies in Australia and New Zealand
and the updated 2014 cost schedule was developed using data received from 27 Australian
companies and 9 New Zealand companies.
Cost schedule – high level results
The cost schedule is separated by different types of packaging. A summary of the total
estimated cost per stock keeping unit (SKU) is provided in the tables below. The detailed
costs including estimates of each direct cost can be found in Chapter 0.
Table 1: Minor change
Packaging
Glass
Metal
Plastic
Fibre
Flexible
Packaging
sub-category
Non-labour
costs
Labour costs
Total cost
Glass bottle
$1,031
$870
$1,901
Glass jar
$848
$821
$1,669
Aluminium can
$1,479
$965
$2,444
Steel can
$1,733
$2,643
$4,376
Plastic tub
$1,249
$1,470
$2,719
Plastic bottle
$875
$1,469
$2,345
Plastic jar
$1,431
$957
$2,388
Folding carton
$1,015
$1,501
$2,516
Liquid paperboard
carton
$2,695
$608
$3,304
Corrugated carton
$1,422
$1,706
$3,128
Flexible pouch / bag
$1,980
$1,769
$3,748
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Executive Summary
Table 2: Medium Change
Packaging
Glass
Metal
Plastic
Fibre
Flexible
Packaging subcategory
Non-labour
costs
Labour costs
Total cost
Glass bottle
$3,116
$1,409
$4,524
Glass jar
$3,803
$1,579
$5,383
Aluminium can
$3,188
$1,822
$5,010
Steel can
$4,668
$2,795
$7,464
Plastic tub
$4,235
$2,008
$6,243
Plastic bottle
$3,903
$1,891
$5,794
Plastic jar
$3,461
$1,573
$5,034
Folding carton
$3,602
$1,706
$5,308
Liquid paperboard
carton
$3,205
$906
$4,111
Corrugated carton
$7,327
$2,108
$9,434
Flexible pouch / bag
$7,200
$2,290
$9489
Table 3: Major Change
Packaging
Glass
Metal
Plastic
Fibre
Flexible
Packaging subcategory
Non-labour
costs
Labour costs
Total cost
Glass bottle
$5,297
$1,700
$6,998
Glass jar
$5,561
$1,851
$7,412
Aluminium can
$5,735
$2,923
$8,658
Steel can
$7,452
$3,832
$11,284
Plastic tub
$7,036
$2,250
$9,286
Plastic bottle
$4,380
$2,250
$9,286
Plastic jar
$4,380
$2,369
$6,750
Folding carton
$6,470
$2,043
$8,513
Liquid paperboard
carton
$3,811
$1,349
$5,160
Corrugated carton
$8,388
$2,676
$11,063
Flexible pouch / bag
$9,446
$2,849
$12,295
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Executive Summary
Considerations that would assist in the robustness of any future costing exercise include:

Consistency across industry regarding the definition of labour inputs – labour is an
important cost consideration in monitoring compliance and enacting change. To gain a
consistency in approach, FSANZ (and other Australian Government entities) may wish to
work collaboratively with industry to agree on the scope of activities and tasks
undertaken by staff which are within or outside of scope.

Provision of detailed cost information – going forward it would be useful to obtain
detailed cost information at the supplier level broken down by:
o
Label type – direct or pre-printed
o
Packaging type – broadly, glass, metal, plastic, fibre and flexible. Where
appropriate, differentiation of packaging subcategories should be included (e.g.
aseptic versus gable top, the different types of flexible film)
o
Printing method – flexography, lithography or gravure
o
Printing plates – number of printing plates changed/replaced
o
Proofing – the type of proofing undertaken
o
Stock keeping units (SKUs) – number of SKUs impacted by the regulatory change
o
Other – such as travel, legal and marketing.
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Contents
Executive summary
i
1
Introduction
1
2
Background to food labelling
3
3
Food labelling cost schedule
7
4
Indirect costs not quantified in the cost schedule
19
5
Conclusions and recommendations
21
Appendix A Survey
24
Appendix B Generic product categories
54
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1 Introduction
This report, prepared by PricewaterhouseCoopers (PwC) for the Department of Health,
presents a schedule of costs which estimates the costs incurred by food companies when
changing food and beverage labelling. This schedule is an update of work done previously by
PwC in 2008 for Food Standards Australia New Zealand (FSANZ).
The original 2008 cost schedule was developed to provide an indication of the scale and
types of costs incurred by companies when considering changes to food and beverage
labelling. This renewed cost schedule has been commissioned to bring these estimates up to
date.
While the cost schedule serves as a useful starting point when considering the impacts that
regulatory and non-regulatory changes have on labelling, it must be recognised that
particular changes will need to be investigated on a case by case basis as impacts of labelling
changes will vary across companies, industry sectors and products.
1.1
Scope of the cost schedule
The cost schedule will only consider the direct costs associated with a change to labelling. For
the purposes of this study, direct costs are defined narrowly, and only capture the immediate
costs required to change the text, colour or scope of a label. Direct costs include:
 Label design – the cost of engaging designers to make changes to or re-design the label
(or package for a direct print label)
 Label production – costs associated with the production of labels over and above printing,
such as new printing plates
 Proofing – the cost of viewing incorporated text, colour and/or graphics changes to the
label, to ensure that the label is how it should be before printing. This may include testing
of new plates
 Package redesign – the costs associated with changing the shape, or size of packaging.
The direct costs include packaging redesign costs and packaging proofing costs
 Labour – the labour inputs involved in responding to regulatory changes, such as
marketing, management, administration, technical and regulatory expertise.
Other features of the scope of the cost schedule are that it should, as far as possible:
 include Australian and New Zealand product categories
 be limited to the impact of labelling changes on packaged foods and beverages for retail
sale for domestic consumption
 provide cost estimates for generic products (i.e. should not identify particular brands).
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Introduction
1.2
Approach
The preparation of the cost schedule was based on a multi-faceted approach of review and
development. Key steps included:
 a review of the existing literature, research and information pertaining to costs associated
with food labelling to establish the context for labelling regulation in Australia and New
Zealand
 consultation with the Department of Health to update the existing survey
 consultation with Department of Health, and through them the Australian Food and
Grocery Council (AFGC), to identify participants for the survey
 survey to industry with participation from industry members to collect cost data and
other inputs to quantify the scope of cost impact
 the construction and testing of a cost schedule.
1.3
Report structure
The chapters of the report are as following:
 Chapter 2 provides the contextual background to food labelling in Australia and New
Zealand.
 Chapter 3 provides indicative costs for changes to food and beverage labelling, and a
discussion of the limitations of the cost schedule and other key findings.
 Chapter 4 identifies some of the indirect costs not quantified as part of the cost schedule.
 Chapter 5 outlines some of the conclusions from this study.
1.4
Disclaimer
This report was prepared by PricewaterhouseCoopers (PwC) for the Department of Health
for the sole purpose of providing indicative cost estimates for changes to food and beverage
labelling. Given the generic nature of the cost schedule, it is intended to be used as an initial
guide in the early consideration of labelling changes. It does not attempt to cover the full
range of potential costs or change scenarios.
This report is not intended to be utilised or relied upon by any organisation, or its employees,
other than the Department of Health, nor is it to be used for any purpose other than that
articulated above. Accordingly, PwC accepts no responsibility in any way whatsoever for the
use of this report by any other persons or for any other purpose.
This report has been prepared based on consultation with and information received from a
variety of food manufacturers and packaging companies. PwC has not endeavoured to seek
any independent confirmation of the reliability, accuracy or completeness of this
information. While the statements made in this report are given in good faith, PwC accepts
no responsibility for any errors in the information on which they are based, nor the effect of
any such errors on our comments.
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2 Background to food
labelling
2.1 Food and beverage packaging and labelling
2.1.1 Food packaging types
There are several types of packaging that can be broadly categorised by the type of material
used.

Glass – glass packaging is typically made into jars or bottles and is used to store a cross
spectrum of food and beverage products including sauces, spreads, instant coffee, oils,
and fruit juices. Glass containers may be made into a variety of sizes – beverage bottles
usually contain 375ml or 750ml, and contents in jars can range from 50g to 1kg.

Metal – aluminium and steel are common metals used for metal packaging.

o
Aluminium is typically transformed into beverage cans to store beer, carbonated
soft drinks and pre-mixed alcoholic drinks. These cans usually come in 250ml,
330ml, 355ml, 375ml, 440ml and 500ml sizes.
o
Steel is typically made into foods cans and aerosol cans. Food cans are assembled
using two or three pieces (two-piece / three-piece can) that may have a variety of
features, such as stackable, welded, easy open end (ring-pull). The range of
products packaged in steel cans include: fish, fruit, vegetables, soups, condensed
milk and whipped cream. Can sizes may range from containing contents of 100g to
1.25kg.
Plastic – plastic packaging can be moulded into various shapes and is a versatile
packaging type. Plastic packaging is made from a variety of materials including:
o
Polyethylene – High density polyethylene (HDPE) is widely used for plastic bottles
and provides good protection at below freezing temperatures. Examples of
products packaged in HDPE include milk and water. Low density polyethylene
(LDPE) is similar to HDPE in composition, but is less rigid. LDPE is primarily
used for squeezable applications. A product example includes wasabi paste and
tomato sauce.
o
Polyethylene terephthalate (PET) – PET is a strong, clear material suitable and is
commonly used for beverages such as carbonated drinks, juices and water.
o
Polyvinyl chloride (PVC) – PVC has good resistance to oil and is a suitable
packaging for salad dressings and vinegar.
o
Polypropylene (PP) – PP has rigid properties and has resistance to high
temperatures. PP is usually made into jars, and can be used to store products such
as spreads and pancake syrup.
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Background to food labelling
o


Polystyrene (PS) – PS is an economical plastic that has rigid qualities. When mixed
with another chemical to make high-impact polystyrene (HIPS), its rigid qualities
are enhanced. HIPS is often used to package yoghurt, fruit and tomato paste.
Fibre – fibre packaging typically comes in the form of cartons:
o
Folding cartons – Folding cartons are made from multi-layered paperboard (a
paper-like material) that is quite thin in thickness. Folding cartons are typically
used as secondary packaging for cereals and for grouping multiple items of like
products (e.g. six-pack of beer, eight muesli bars, and two individual serves of
powdered packet soups).
o
Corrugated cartons – corrugated cartons are formed by gluing one or more sheets
of fluted (wave shapes) sheets to one or more flat linerboards which form the inner
and outer facings of cartons. Flute serves as protective cushioning and helps
strengthen a carton. These cartons are generally used as secondary packaging for
products such as beer and soft drink beverages.
o
Liquid paperboard cartons – There are two types of liquid paperboard packaging,
usually used to store products such as milk, juice, custard and liquid stock.

Gable top cartons are made from a layer of board sandwiched
between two layers of very thin plastic. Fresh milk is commonly
stored within gable top cartons.

Aseptic packaging is made from five layers: three of plastic, one of
foil and one of board. The products in the cartons are sterilised
before being packaged and, as the cartons fully seal the contents,
they need not be refrigerated during storage. These cartons are
suitable for preserving products for a long shelf life.
Flexible – flexible packaging covers a wide range of packaging that can be single and
multi-layered and is supplied in reels or bags. It can be paper/poly/foil or nylon or a
combination of materials which are supplied either plain/printed/coated and/or
laminated to provide long shelf life properties. End products packaged include
confectionery, snack foods, frozen foods, soups and pharmaceuticals.
2.1.2 Labelling and printing
There are two key types of labelling:

Pre-printed labelling – this involves the printing of a label onto paper-based or plastic
material and is transferred onto product packaging. Some paper-based labels are made
with adhesive qualities, so that the label may be easily transferred onto the packaging.
Pre-printed labels made from plastic are commonly known as shrink sleeves. Typical
packaging that uses pre-printed labels include: glass bottles and jars, plastic bottles and
jars, and steel food cans.

Direct print labelling – the label information is printed directly onto the product
packaging. Thus, these labels form part of the packaging manufacturing process. Typical
packaging that uses direct print labelling include: aluminium beverage cans, cartons and
flexibles.
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Background to food labelling
2.1.3 Printing methods
There are three key printing processes used in the production of food and beverage
packaging and labels.
Flexography
Flexography can be thought of as a sophisticated method of printing with plates made from
rubber material. The required image is mirrored onto the rubber printing plate, which is then
wrapped around a cylinder. The plate is dipped into ink and the cylinder rotates to make
contact with the print material to transfer the ink and resulting image.
Flexographic printing is able to use a wide range of ink and is suitable for printing on a
variety of different materials. The inks used in the printing process are usually fast drying
and therefore allows for faster production and reduces costs. Flexographic printing plates are
relatively inexpensive compared to plates of other printing methods, and due to the low cost
of label production, flexography is a popular printing mechanism.
Flexographic printing is typically use for corrugated cartons, flexible plastics, self-adhesive
labels, shrink sleeve labels, gable top liquid paperboard cartons
Offset Lithography
Offset lithography is a widely used technique, based on the principle of water and oil
repulsion. Non-image areas of printing plates are coated with water receptive solution,
whereas image areas are coated with ink-receptive solution. This ensures that only image
areas pick up ink and other areas repel it by being washed away by water. The inked image is
transferred (or offset) from a plate to a rubber blanket which is wrapped around a cylinder.
The cylinder rotates so that the inked blanket transfers the image to the print material.
Dry offset lithography is used to print aluminium cans and instead of using water receptive
solutions for non-image areas, silicone rubber is used, as this material does not attract ink.
Offset lithography produces high quality images and printing plates are relatively quick and
easy to produce.
The offset lithographic printing method is typically used for folding cartons, metal cans,
paper labels, aseptic liquid paperboard cartons and shrink sleeves.
Rotogravure
Rotogravure (or gravure, for short) works by having an engraved image on a copper cylinder
that rotates into an ink fountain. Ink fills the cavities of the engraved cylinder plate and
excess ink is removed by a doctor blade (which acts like a squeegee). The print material is
sandwiched between the impression roller and cylinder plate, and as the print material
passes through, ink is transferred and the impression roller applies pressure to ensure
maximum coverage of the ink.
The gravure printing method is used for long print runs and is the most expensive printing
method. The gravure printing process is able to produce high quality graphics and companies
tend to use this method for its premium product range.
The rotogravure printing method is typically used for aseptic liquid paperboard cartons,
flexibles and shrink sleeves.
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Background to food labelling
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Food labelling cost schedule
3 Food labelling cost
schedule
3.1 Labelling costs
A change to labelling, depending on the extent and complexity of the change, may result in
the need to re-design an existing label to accommodate the required information or content
change. The major costs associated with labelling changes include:

label design – the cost of engaging designers to make changes to or re-design the label
(or package for direct print labels)

label production – costs associated with the production of labels over and above
printing. Generally this includes a new set of printing plates that encompass the changes,
but may also include new software or new label printers

proofing – proofs allow companies to view incorporated changes (text, colour, graphics)
to the label before printing. Proofing also allows companies to test the new plates to
ensure that it meets quality standards before undertaking a full print run

labour – the labour inputs involved in responding to labelling changes, such as
marketing, management, administration, technical and regulatory expertise.
3.2 Methodology
The cost schedule takes into account a number of factors such as:

type of label printing used

type of packaging

generic product categories

the scale of the change to the label.
The scale of change is one of the single largest drivers of cost. However, because of the
inherent complexity, variability and unpredictability associated with labelling changes, three
change scenarios were developed and they form the basis upon which to collect data from
food manufacturers. This is the same approach used to develop the 2008 cost schedule. The
following table summarises each of the three change scenarios used to assist with cost
estimation.
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Food labelling cost schedule
Table 4: Categories of label changes
Scale of
change
Minor
change
Scope of change
Label design – text
changes only, no change
to layout of label
Label production –
change to one colour (one
printing plate) only
Proofing – not required
Package redesign – no
change to packaging
shape / size
Examples of scenarios
 Additions to ingredients list – no change to
label layout
 Change to mandatory warning statements – no
change to label layout
 Change to the contents of nutritional panel –
no change to label layout
 Amendments to country of origin information
– no change to label layout
 Additions to requirements of manufacturer’s
details – no change to label layout
 Amendments to text regarding serving or
preparation instructions – no change to label
layout
 Amendments to text regarding storage
instructions – no change to label layout
Medium
change
Label design – changes to
text and label layout
 Additions to ingredients list – change to label
layout
Label production –
change to three colours
(three printing plates)
 Change to health or product claim – change to
label layout
Proofing – required
 Change to mandatory warning statements –
change to label layout
Package redesign – no
change to packaging
shape / size
 Removal/addition/change of endorsements
(e.g. “tick of approval”) – minimal change to
label layout
 Change to the contents of nutritional panel –
change to label layout
 Amendments to country of origin information
– change to label layout
 Additions to requirements of manufacturer’s
details – change to label layout
 Amendments to text regarding serving or
preparation instructions – change to label
layout
 Amendments to text regarding storage
instructions – change to label layout
Major
change
Label design – changes to
text and label layout
Label production –
change to six colours (six
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 Re-naming of product
 Redesign or amendment of
image/logo/graphic
8
Food labelling cost schedule
Scale of
change
Scope of change
printing plates)
Proofing – required
Package redesign –
change required to
packaging shape / size
Examples of scenarios
 Removal / addition / change of endorsements
(e.g. “tick of approval”) – redesign of label
layout
To collect data, PwC employed the same survey methodology that was used to develop the
2008 cost schedule. The survey itself was based on the same survey used in 2008 and revised
in consultation with the Department of Health. The survey was then sent to 143 companies
leveraging existing contact lists from the Department of Health as well as peak industry
bodies in Australia and New Zealand. The full survey to food processors is provided in 0.
Data from 27 Australian and 9 New Zealand companies were received that was appropriate
for use in the cost schedule. For commercial in confidence reasons, this report does not
identify individual companies. Survey responses are categories into five categories based on
packaging type, and then divided into sub-categories shown in the table below.
Table 5: Packaging categories and sub-categories
Packaging type
Glass
Packaging sub-category
 Bottle
 Jar
Metal
 Aluminium can
 Steel can
Plastic
 Tub
 Bottle
 Jar
Fibre
 Folding carton
 Corrugated carton
 Liquid paperboard carton
Flexible
 Pouch / bag
In compiling and revising the cost schedule, cost data was provided by companies on a cost
per SKU basis. This data was then weighted so as to ensure the smaller companies with fewer
SKUs did not unduly influence cost estimates. The rationale for this is that in a competitive
market, smaller companies with fewer SKUs likely do not have purchasing power sufficient
to ‘drive price’ to the same degree as larger companies.
To weight responses, PwC used employment figures taken from survey responses as a proxy
figure to differential small, medium and large businesses. Further, respondents were asked
to report the number of SKUs their company products based on the following categories:
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9
Food labelling cost schedule

fruit and vegetables

nuts and seeds

meat and poultry

seafood

dairy

oils

confectionery and sugar products

seasonings and preservatives

bread and bakery products

prepared and preserved foods

beverages

cereal and grains
These product categories were cross-referenced with turnover data taken from IBIS World to
create a secondary weight. Finally, to create a single cost schedule applicable to both
Australian and New Zealand, depending on the location of the respondent data was adjusted
for current exchange rates and to account for relative economic size (based on IMF data).
3.3 Key findings
The following tables provide indicative data as to the cost burden resulting from minor,
medium and major changes, by packaging type. These results are PwC estimates and are
provided on a stock keeping unit (SKU) basis.
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Food labelling cost schedule
Table 6: Glass
Packaging
type
Glass bottle
Glass jar
Label type
Flexography/Off
set Lithography
Flexography/Off
set Lithography
Generic
product
example
Scenario
Cost 1:
Label
design
Cost 2:
Label
production
Cost 3:
Proofing
Subtotal:
Cost 1 ,2
and 3
Cost 4:
Technical &
regulatory
Cost 5:
Admin
Cost 6:
Executive
Subtotal:
Cost 1, 2
and 3
Total
costs
Beverages,
Vinegars,
Seasonings
and
Preservatives
minor
$404
$368
$260
$1,031
$286
$584
n/a
$870
$1,901
medium
$1,533
$1,287
$296
$3,116
$465
$649
$295
$1,409
$4,524
major
$2,677
$2,346
$275
$5,297
$554
$736
$411
$1,700
$6,998
Spreads,
Spices,
Extracts and
Relishes
minor
$430
$173
$245
$848
$270
$551
n/a
$821
$1,669
medium
$1,909
$1,619
$275
$3,803
$569
$643
$368
$1,579
$5,383
major
$2,816
$2,440
$305
$5,561
$621
$734
$496
$1,851
$7,412
Note:
Costs related to one stock keeping unit
n/a = due to sample size of individual cost components this observation can’t be further disaggregated.
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Food labelling cost schedule
Table 7: Metal
Packaging
type
Label type
Aluminium
beverage can
Offset
Lithography
Steel can
Offset
Lithography
Generic
product
example
Scenario
Cost 1:
Label
design
Cost 2:
Label
production
Cost 3:
Proofing
Subtotal:
Cost 1 ,2
and 3
Cost 4:
Technical &
regulatory
Cost 5:
Admin
Cost 6:
Executive
Subtotal:
Cost 4, 5
and 6
Total
costs
Beverages
(both
alcoholic and
non-alcoholic)
minor
$586
$605
$288
$1,479
$317
$648
n/a
$965
$2,444
medium
$2,232
$622
$334
$3,188
$551
$1,003
$267
$1,822
$5,010
major
$4,710
$638
$387
$5,735
$852
$1,452
$619
$2,923
$8,658
Soups,
preserved
variety
products
minor
$539
$368
$826
$1,733
$895
$1,074
$674
$2,643
$4,376
medium
$2,774
$970
$924
$4,668
$1,000
$1,114
$681
$2,795
$7,464
major
$4,856
$1,585
$1,010
$7,452
$1,382
$1,605
$845
$3,832
$11,284
Note:
Costs related to one stock keeping unit
n/a = due to sample size of individual cost components this observation can’t be further disaggregated.
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Food labelling cost schedule
Table 8: Plastic
Packaging
type
Plastic tub / cup
Plastic bottle
Plastic jar
Label type
Offset
Lithography
Offset
Lithography
Offset
Lithography
Generic
product
example
Yoghurts,
Meat and
Poultry
Cream, Oils,
Sauces,
Beverages
Spreads
Scenario
Cost 1:
Label
design
Cost 2:
Label
production
Cost 3:
Proofing
Subtotal:
Costs 1, 2
and 3
Cost 4:
Technical &
regulatory
Cost 5:
Admin
Cost 6:
Executive
Subtotal:
Costs 4,
5 and 6
Total
costs
minor
$480
$462
$306
$1,249
$494
$644
$332
$1,470
$2,719
medium
$2,166
$1,523
$546
$4,235
$729
$794
$485
$2,008
$6,243
major
$3,522
$2,305
$1,208
$7,036
$837
$864
$550
$2,250
$9,286
minor
$285
$346
$245
$875
$430
$604
$435
$1,469
$2,345
medium
$2,412
$1,176
$315
$3,903
$599
$807
$485
$1,891
$5,794
major
$2,783
$1,258
$339
$4,380
$767
$1,041
$561
$2,369
$6,750
minor
$581
$564
$286
$1,431
$314
$643
n/a
$957
$2,388
medium
$1,594
$1,498
$368
$3,461
$478
$744
$351
$1,573
$5,034
major
$3,548
$2,522
$399
$6,470
$686
$810
$547
$2,043
$8,513
Notes:
Costs related to one stock keeping unit
n/a = due to a small sample size for individual cost components this observation can’t be further disaggregated.
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Food labelling cost schedule
Table 9: Fibre
Packaging
type
Folding carton
Liquid
paperboard
carton
Corrugated
carton
Label type
Offset
Lithography
Offset
Lithography /
Rotogravure
Offset
Lithography
Generic
product
example
Scenario
Cost 1:
Label
design
Cost 2:
Label
production
Cost 3:
Proofing
Subtotal:
Costs 1, 2
and 3
Cost 4:
Technical &
regulatory
Cost 5:
Admin
Cost 6:
Executive
Subtotal:
Costs 4,
5 and 6
Total
costs
Biscuits,
Cookies,
Grain
based
products
minor
$373
$366
$276
$1,015
$444
$568
$489
$1,501
$2,516
medium
$1,801
$1,361
$439
$3,602
$543
$631
$532
$1,706
$5,308
major
$4,483
$2,118
$533
$7,134
$1,051
$889
$602
$2,541
$9,674
Beverages,
Milk and
Seasoning
variety
packs
minor
n/a
n/a
n/a
$2,695
n/a
n/a
n/a
$608
$3,304
medium
$445
$2,457
$304
$3,205
$341
$240
$325
$906
$4,111
major
$529
$2,921
$361
$3,811
$508
$357
$483
$1,349
$5,160
Eggs,
Milk,
Baking
supplies
minor
$400
$631
$390
$1,422
$500
$702
$505
$1,706
$3,128
medium
$2,998
$3,806
$523
$7,327
$761
$824
$523
$2,108
$9,434
major
$4,667
$3,102
$619
$8,388
$1,080
$1,040
$555
$2,676
$11,063
Notes:
Costs related to one stock keeping unit
n/a = due to a small sample size for individual cost components this observation can’t be further disaggregated.
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Food labelling cost schedule
Table 10: Flexible
Packaging
type
Plastic pouch
/ bag
(generic)
Label type
Flexography
Generic product
example
Fruit and
Vegetables, Seafood,
Confectionery,
Bakery products,
Grains, Pasta,
Sandwiches
Scenario
Cost 1:
Label
design
Cost 2:
Label
production
Cost 3:
Proofing
Subtotal:
Costs 1, 2
and 3
Cost 4:
Technical &
regulatory
Cost 5:
Admin
Cost 6:
Executive
Subtotal:
Costs 4, 5
and 6
Total
costs
minor
$684
$858
$437
$1,980
$523
$669
$576
$1,769
$3,748
medium
$3,462
$3,232
$506
$7,200
$858
$735
$697
$2,290
$9,489
$5,146
$3,726
$575
$9,446
$1,238
$869
$741
$2,849
$12,295
major
Notes:
Costs related to one stock keeping unit
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Food labelling cost schedule
3.4 Limitations
While this cost schedule serves as a useful starting point when considering the impacts from
labelling changes, it must be recognised that particular changes will need to be investigated
on a case by case basis as impacts of labelling changes will vary across companies, industry
sectors and products. Therefore, the results should be interpreted with care. Some of the
limitations of the cost schedule are explained below.
3.4.1 Methodology and variability of data
The survey used for this Costs Schedule was adapted from the one used in 2008. These
amendments and updates were developed in consultation with the Department of Health.
The survey was then sent to 143 companies leveraging existing contact lists from the
Department of Health as well as peak industry bodies in Australia and New Zealand. The full
survey to food processors is provided in 0.
Data from 27 Australian and 9 New Zealand companies were received that was appropriate
for use in the cost schedule. For commercial in confidence reasons, the cost schedule and this
report does not identify individual companies whose information is used as part of this
assignment. However, the product offerings of the participating companies included dairy
products, confectionary, bakery products and other prepared foods.
A limitation to the cost schedule is the inherent limitation associated with a survey
methodology. While the sample size of this survey was larger than the sample size from
2008, give time and cost constraints, not all companies were able to estimate cost for all
products and all complexity scenarios. In some cases, respondent companies were the only
company that responded for a particular product/complexity scenario.
While individual component information was missing for only a handful of observations,
liquid paperboard carton had a particularly low response rate under the minor scenario.
While many respondents provided a total cost estimate for liquid paperboard carton, data
was limited on labour sub-components; therefore only sub-total and total cost estimates for
liquid paperboard carton were published in the final cost schedule. Given potential sample
error at the individual component level for all packaging categories, the reader may wish to
rely on total and sub-total figures.
3.4.2 The implications for each company is different
While the cost schedule provides an average cost per SKU under a variety of different
packaging types, individual businesses may not conform to the industry average. The
implementation costs will have a bigger impact on smaller businesses than on larger
businesses given the large majority of food manufacturing businesses employ less than 20
people. These businesses are also less likely to take advantage of economies of scale as the
costs associated with labelling changes are spread over less units of output (SKUs).
Based on responses from the survey, the premium for short term or small labelling orders
ranged from 20-50%. Therefore, the impact of a change to labelling will depend on the
packaging/labelling lifecycle of individual products (according to the survey, range from 1-5
years).
3.4.3 Other
There are a number of other costs borne by food manufacturers that are not considered in
the survey, as they are outside the scope of finding the cost of changing labelling/packaging
due to three different scenarios.
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Food labelling cost schedule
These estimates are based on top of overheads that are involved in the day-to-day running of
the business and are designed to find the cost to producers for a change to labelling under
three distinct scenarios (minor, medium and major).
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Food labelling cost schedule
3.5 Differences from previous cost schedule
Table 11: Key differences between 2008 and 2014 surveys
Parameter
2008
2014
Sample
12
36
Timing
March 2008
March/April 2014
Weights
Employment size
Industry coverage
N/A
IMF economy size
Currency
Average
Simple
Weighted arithmetic mean
Average Cost per SKU
$9,1621
$5,624
Included
Excluded
Package redesign – a label
change may also necessitate
a change in the shape, or size
of packaging. The direct
costs include packaging
redesign costs and packaging
proofing costs2
Key points

Costs are around 40 per cent lower per SKU than 2008 survey.

Sample size three times as large as 2008.

Weighted arithmetic mean reduces the impact of outliers on the sample.
1 Estimate based on simple average of medium term scenario in 2008 published schedule (unadjusted for inflation).
2 Due to lack of responses this category was removed from the cost schedule. Given the lack of responses in the 2008 cost schedule
for this category, and given the larger sample in obtained in this survey, the likely impact is immaterial.
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4 Indirect costs not
quantified in the cost
schedule
In the preparation of this cost schedule, and the one that preceded it in 2008, a number of
indirect costs associated with labelling changes were identified. While these were outside the
scope of the study and have not been quantified, we have nevertheless documented some of
the key indirect costs. These include the below.
4.1 Write off costs and stock on hand
After a label change, companies are often left with labels, packaging and products that do not
meet regulatory standards and the write off costs of these items can be quite significant.
However, not all labelling changes will have write off costs. This will depend on whether the
change is voluntary or regulatory, and if it is regulatory, the time frame given for
implementation. If an appropriate timeframe is given, no write off costs will be necessary,
although a company may choose to bring in the new labels sooner. Even in a voluntary
change, companies may choose to maintain a single look/feel to their products, which may
require disposal of obsolete stock or packaging material.
4.2 Labelling lifecycle
The lifecycle of a package or label varies considerably depending on the product. For
dynamic products, the packaging/label lifecycle may be every 12 months, however for other
products, the packaging/label may change once every two to five years (sometimes even
longer for well established brands). If the implementation of regulatory changes were able to
coincide with a packaging/label lifecycle change, the cost burden would be substantially
reduced.
The majority of products considered as part of the cost schedule had a packaging/labelling
life cycle of 3 to 5 years, although some where as low as 6 months. It was noted in analysis
that small businesses can have longer label lifecycles.
4.3 Product testing or related investigation
This can include the testing of food and beverage products in the event of a changing
nutritional or other requirement which needs to be reflected in labelling. It may also include
costs such as gathering information about product supply chains (e.g. country of origin rules
for ingredients). Additional product testing may also require updates of recording keeping
for this information.
This will not be necessarily required for all labelling changes.
4.4 Marketing costs
A significant label change (e.g. a change of logo or product claim) may also require a change
to a product marketing and/or branding strategy. It may also require companies to update
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Indirect costs not quantified in the cost schedule
and/or reproduce marketing material and websites. This may include the need for new
consumer research to develop the product marketing strategy.
4.5 Legal costs
Some label changes (e.g. logo) may require design patents etc to protect the integrity of the
brand or require the expertise of legal professionals.
4.6 Travel costs
Many companies source their packaging and labelling from interstate or overseas. When
changes to packaging or labelling occur, some companies send their product managers
overseas/interstate to ensure the new package or label meets quality standards. The cost
schedule does not include costs related to travel limits and thus may underestimate the costs
incurred by companies.
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5 Conclusions and
recommendations
The cost schedule developed as part of this study provides some generic indicative costs of
the impacts of food labelling changes. While the cost schedule serves as a useful starting
point when considering the cost of labelling changes, it must be recognised that particular
changes will need to be investigated on a case by case basis as impacts will vary across
companies, industry sectors and products.
Considerations that would assist in the robustness of any future costing exercise include:

Consistency across industry regarding the definition of labour inputs – labour is an
important cost consideration in monitoring compliance and enacting change. To gain a
consistency in approach, FSANZ (and other Australian Government entities) may wish to
work collaboratively with industry to agree on the scope of activities and tasks
undertaken by staff which are within or outside of scope.

Provision of detailed cost information – going forward it would be useful to obtain
detailed cost information at the supplier level broken down by:
o
Label type – direct or pre-printed
o
Packaging type – broadly, glass, metal, plastic, fibre and flexible. Where
appropriate, differentiation of packaging subcategories should be included (e.g.
aseptic versus gable top, the different types of flexible film)
o
Printing method – flexography, lithography or gravure
o
Printing plates – number of printing plates changed/replaced
o
Proofing – the type of proofing undertaken
o
Stock keeping units (SKUs) – number of SKUs impacted by the regulatory change
o
Other – such as travel, legal and marketing.
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Appendices
Appendix A Survey
24
Appendix B Generic product categories
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Appendix A Survey
Note: The following provides the survey questions used to inform the Cost Schedule for
Food Labelling Changes. Tables are for example only and are blank.
Introduction:
PricewaterhouseCoopers (PwC) has been commissioned to develop a cost benefit analysis for
the Front-of-Pack Health Star Rating system. The cost benefit analysis will build off of
existing data and literature, but requires additional industry input and data to better
estimate the direct costs associated with changes to labelling requirements.
The purpose of this survey is twofold:
1
Capture defined and specific direct costs incurred by business as a result of changes to
the label and/or packaging of prepacked food or beverages for domestic retail sale,
based on an 'as and when' approach, and
2
Gather industry input with respect to implementation and uptake of the voluntary
Health Star Rating system.
The costs analysis is focused mainly on direct costs and is not intended to incorporate costs
such as opportunity costs, transaction costs or adjustment costs, as these costs vary
significantly and will require investigation on a case-by-case basis.
We request you complete as much of this survey as possible, but if you feel if you cannot
answer a question, or that it is not applicable to your business, you can leave it blank and
move to the next question. If you cannot complete survey in one sitting, your progress will be
saved and can be completed at a later date. Please do not clear your ‘cookies’ or internet
history as this will cause your progress to be lost. The survey will close on 21 March 2014.
Q1.2 What is your business' name?
(Note: this is to ensure the quality of the data (i.e. no double counting of data); your business
will not be individually identified in any way)
Q1.3 Are you responding on behalf of your:
(Note: this should be the basis that all the following survey questions will be answered on)
 Entire business
 A division or subsidiary within your business or group
 Other
Q1.4 If you selected 'other', please provide a description.
Q1.5 How many people does your business employ (i.e head count)?
 0 employees
 1-19 employees
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 20-199 employees
 More than 200 employees
Q1.6 What is you business' average annual turnover?
 Zero to $50,000
 $50,000 to $200,000
 $200,000 to $2,000,000
 More than $2,000,000
Q1.7 Please identify how your business obtains its:
Element
Produced 'in house'
From an external supplier
(please select)
(please select)
Labels (e.g. design, printing)


Packaging (e.g. bottles,
carton, plastic)


Instructions
The following section aims to gather specific data with respect to your labelling and
packaging costs. While we have taken care to ensure that this survey is as user friendly as
possible, in some cases, the questions may be unclear or not applicable to your business
situation. We ask that you try to provide your 'best guess' and include any important
comments or clarifications at the end of the survey.
For each of the following questions, please provide your best estimate with respect to each of
the data points.
In cases where you cannot provide a specific break down of each cost, please provide a single
'all in' cost (where appropriate), leaving the remaining cells 'blank'.
If you are unsure of how to answer a question, you can leave it 'blank' and move on to the
next question.
If you cannot complete the survey in one sitting, the survey tool will save your progress and
you can return to it later. Please ensure not to clear your 'cookies' or internet history as your
progress will be lost.
If you have any questions or concerns please contact PwC for assistance on (02) 6271 3227.
Survey Definitions
This survey is primarily focused on understanding direct cost costs associated with changes
to labelling and packaging. For the purposes of this survey, the following definitions apply:
Label design – refers to the cost of engaging designers to make changes to or re-design the
label (or package for direct print labels).
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Survey
Label production – refers to costs associated with the production of labels over and above
printing. Generally this includes a new set of printing plates that encompass the changes, but
may also include new software or new label printers.
Proofing – refers the process by which companies view (and re-view) incorporated changes
(text, colour, graphics) to the label before printing. Proofing also allows companies to test the
new plates to ensure that it meets quality standards before undertaking a full print run.
Overhead Labour – indirect labour inputs required to support the label and package redesign process, such as management, administration, technical and regulatory expertise.
Examples of this type of cost includes, but is not limited to: Time spent in technical or
regulatory planning or coordination (e.g. legal review)
 Time associated training technical, marketing and graphic staff on requirements
 Any direct administration or management time in organising or coordinating the labelling
change
 Any executive time in reviewing and approving the labelling change.
Note: If you have any comments, clarifications or costs, please provide these at the end of
the survey in the comments box.
As a guide to help estimate the costs associated with a change in the text, content or layout of
the label (where appropriate), please use the following categories of complexity. We have
defined a “minor”, “medium” and “major” change complexity as follows:
Minor change
Design – no change to layout of label
Printing – change to one colour (one printing plate) only
No label proofing
Packaging – no change to packaging shape/size/design
(For example, a minor change may be addition to ingredients list, change to nutritional
panel, addition to manufacturer's details or amendment to serving or storage instructions, all
without label layout change).
Medium change
Design – change to label layout
Printing – change to three colours (three printing plates)
Label proofing required
Packaging – no change to packaging shape/size/design
(For example, a medium change may be changes to ingredients list, nutritional panel or
manufacturer details that would require a layout change or the removal/addition/change of
an endorsement with minimal layout change).
Major change
Design change to label layout
Design – change to name of product or product logo
Printing – change to six colours (six printing plates)
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Survey
Label proofing required
Packaging – change to packaging shape/size/design
(For example a major change may be a re-naming of the product, redesign of an
image/logo/graphic or removal/additional/change of endorsements requiring label layout
changes).
Q2.4 What types of packing and labels does this business use to for its products?
Packaging
Subcategory
Please select
all that apply
Label Type
Direct Print
Pre-Printed Adhesive
Glass - Bottle



Glass - Jar



Metal - Aluminium
can



Metal - Steel can



Plastic - Tub



Plastic - Bottle



Plastic - Jar



Fibre - Folding
Carton



Fibre - Corrugated
Carton



Fibre - Liquid
Paperboard Carton



Flexible - Pouch/ Bag



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Survey
Q2.5 For your Glass - Bottle products, please provide the following cost information.
Cost Information
Minor
Medium
Major
$ / SKU
$ / SKU
$ / SKU
Direct - Label Design
Direct - Label
Production
Direct - Proofing
Sub-total (direct
costs)
Indirect - Technical &
Regulatory
Indirect Administration
Indirect - Executive
Sub-total (indirect
costs)
Total costs
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Survey
Q2.6 For your Glass - Jar products, please provide the following cost information.
Cost Information
Minor
Medium
Major
$ / SKU
$ / SKU
$ / SKU
Direct - Label Design
Direct - Label
Production
Direct - Proofing
Sub-total (direct
costs)
Indirect - Technical &
Regulatory
Indirect Administration
Indirect - Executive
Sub-total (indirect
costs)
Total costs
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Survey
Q2.7 For your Metal - Aluminium can products, please provide the following cost
information.
Cost Information
Minor
Medium
Major
$ / SKU
$ / SKU
$ / SKU
Direct - Label Design
Direct - Label
Production
Direct - Proofing
Sub-total (direct
costs)
Indirect - Technical &
Regulatory
Indirect Administration
Indirect - Executive
Sub-total (indirect
costs)
Total costs
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Survey
Q2.8 For your Metal - Steel can products, please provide the following cost information.
Cost Information
Minor
Medium
Major
$ / SKU
$ / SKU
$ / SKU
Direct - Label Design
Direct - Label
Production
Direct - Proofing
Sub-total (direct
costs)
Indirect - Technical &
Regulatory
Indirect Administration
Indirect - Executive
Sub-total (indirect
costs)
Total costs
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Q2.9 For your Plastic - Tub products, please provide the following cost information.
Cost Information
Minor
Medium
Major
$ / SKU
$ / SKU
$ / SKU
Direct - Label Design
Direct - Label
Production
Direct - Proofing
Sub-total (direct
costs)
Indirect - Technical &
Regulatory
Indirect Administration
Indirect - Executive
Sub-total (indirect
costs)
Total costs
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Q2.10 For your Plastic - Bottle products, please provide the following cost information.
Cost Information
Minor
Medium
Major
$ / SKU
$ / SKU
$ / SKU
Direct - Label Design
Direct - Label
Production
Direct - Proofing
Sub-total (direct
costs)
Indirect - Technical &
Regulatory
Indirect Administration
Indirect - Executive
Sub-total (indirect
costs)
Total costs
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Q2.11 For your Plastic - Jar products, please provide the following cost information.
Cost Information
Minor
Medium
Major
$ / SKU
$ / SKU
$ / SKU
Direct - Label Design
Direct - Label
Production
Direct - Proofing
Sub-total (direct
costs)
Indirect - Technical &
Regulatory
Indirect Administration
Indirect - Executive
Sub-total (indirect
costs)
Total costs
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Q2.12 For your Fibre - Folding Carton products, please provide the following cost
information.
Cost Information
Minor
Medium
Major
$ / SKU
$ / SKU
$ / SKU
Direct - Label Design
Direct - Label
Production
Direct - Proofing
Sub-total (direct
costs)
Indirect - Technical &
Regulatory
Indirect Administration
Indirect - Executive
Sub-total (indirect
costs)
Total costs
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Q2.13 For your Fibre - Corrugated Carton products, please provide the following cost
information.
Cost Information
Minor
Medium
Major
$ / SKU
$ / SKU
$ / SKU
Direct - Label Design
Direct - Label
Production
Direct - Proofing
Sub-total (direct
costs)
Indirect - Technical &
Regulatory
Indirect Administration
Indirect - Executive
Sub-total (indirect
costs)
Total costs
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Q2.14 For your Fibre - Liquid Paperboard Carton products, please provide the following cost
information.
Cost Information
Minor
Medium
Major
$ / SKU
$ / SKU
$ / SKU
Direct - Label Design
Direct - Label
Production
Direct - Proofing
Sub-total (direct
costs)
Indirect - Technical &
Regulatory
Indirect Administration
Indirect - Executive
Sub-total (indirect
costs)
Total costs
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Q2.15 For your Flexible - Pouch/ Bag products, please provide the following cost
information.
Cost Information
Minor
Medium
Major
$ / SKU
$ / SKU
$ / SKU
Direct - Label Design
Direct - Label
Production
Direct - Proofing
Sub-total (direct
costs)
Indirect - Technical &
Regulatory
Indirect Administration
Indirect - Executive
Sub-total (indirect
costs)
Total costs
Q2.16 What type of printing method is used in the production of food and beverage
packaging labels?
 Flexography
 Offset lithography
 Rotogravure
 Don't know
 Other
Q2.17 If you selected 'other', please provide a description.
Q2.18 Is there a premium/additional costs associated with the production of labels at short
notice or in small orders?
 Yes
 No
Q2.19 If 'yes', please describe how you would define short notice/small orders and what the
premium would be.
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Survey
Q2.20 Conversely, is there a discount on cost for pre-ordering in advance or ordering in
bulk?
 Yes
 No
Q2.21 If 'yes', please describe how you would define pre-ordering/bulk ordering and what
the discount would be.
Q2.22 Does your business produce products to which the proposed Health Star Rating
(HSR) system could apply?
 Yes
 No
Note: The HSR system has been designed for all packaged food products available for retail
sale. However, there are specific food products that should not use the HSR System
including:

Certain Special Purpose Foods in Part 2.9 of the FSC where there are required
compositional formulations, namely: infant formula products, food for infants,
formulated supplementary foods for young children, formulated supplementary
sports foods, foods for special medical purposes.

Foods where a NIP is not required, specifically: non-nutritive condiments including
vinegar, herbs and spices, salt and pepper, non-nutritive foods including teas,
coffees, herbal infusions, ice, filled rolls, filled bagels, sandwiches and similar
products. However, under the HSR System, where the product is packaged and made
to a standard recipe the HSR may be used appropriately.

Single ingredient foods not intended to be consumed alone.

Alcoholic beverages (>1.15% alcohol by volume).

Alcohol kits.

Kava.

In addition, the HSR System should not be used on food products listed in clause 4
of Standard 1.2.7 – Nutrition, Health and Related Claims of the FSC, which include
those that are intended for further processing or labelled prior to retail sale,
delivered to a vulnerable person by a delivered meal organisation, or provided as an
institutional meal. These food product types align with those described in clause 4 of
Standard 1.2.7 - Nutrition, Health and Related Claims of the FSC, as not being
eligible to carry nutrition content claims and health claims.
If No Is Selected, Then Skip To Q2.36
Department of Health
PwC
39
Survey
Q2.23 Please select all of the food or beverage products your business produces:
(Note: the following categories are based on the Global Product Category (GPC) system).
 Fruits/ Vegetables/ Nuts/ Seeds
 Meat/ Poultry/ Game/ Batrachian
 Seafood
 Milk/ Butter/ Cream/ Yogurts/ Cheese/ Eggs/ Substitutes
 Oils/ Fats (Edible)
 Confectionery/ Sugar / Sweetening Products
 Seasonings/ Preservatives/ Extracts
 Bread/ Bakery Products
 Prepared/ Preserved Foods
 Beverages
 Cereal/ Grain/ Pulse Products
Department of Health
PwC
40
Survey
Q2.24 For your business' Fruits/ Vegetables/ Nuts/ Seeds products, please provide the
following information for each applicable class of product: (Note: Label life span refers to
the average age of a label from the time it is created until is is replaced with a substantially
different design. If the average labelling life span is less than one year, please input as a
decimal - i.e. 6 months = 0.5 years)
For Primary Packaging / Labelling Type (and Secondary if applicable), please choose from
the following options: Glass Bottle, Glass Jar, Metal Aluminium Can, Metal Steel Can, Plastic
Tub, Plastic Bottle, Plastic Jar, Fibre Folding Carton, Fibre Corrugated Carton, Fibre Liquid
Paperboard Carton and Flexible Pouch / Bag.
Product
Primary
Packaging
/ Labelling
Type
Approx.
SKUs
Label
life
span
Secondary
Packaging
(if
applicable)
Approx
SKUS (if
applicable)
Avg. Label
Life Span
(if
applicable)
(type)
(number)
(years)
(type)
(number)
(years)
Vegetables Unprepared/
Unprocessed
Fruit Unprepared/
Unprocessed
Nuts/ Seeds Unprepared/
Unprocessed
Nuts/ Seeds Prepared/
Processed
Fruit/ Nuts/
Seeds
Combination
Fruit Prepared/
Processed
Vegetables Prepared/
Processed
Fruits/
Vegetables/
Nuts/ Seeds
Variety Packs
Department of Health
PwC
41
Survey
Q2.25 For your business' Meat/ Poultry/ Game/ Batrachian products, please provide the
following information for each applicable class of product: (Note: Label life span refers to
the average age of a label from the time it is created until is is replaced with a substantially
different design. If the average labelling life span is less than one year, please input as a
decimal - i.e. 6 months = 0.5 years)
For Primary Packaging / Labelling Type (and Secondary if applicable), please choose from
the following options: Glass Bottle, Glass Jar, Metal Aluminium Can, Metal Steel Can, Plastic
Tub, Plastic Bottle, Plastic Jar, Fibre Folding Carton, Fibre Corrugated Carton, Fibre Liquid
Paperboard Carton and Flexible Pouch / Bag.
Product
Primary
Packaging
/
Labelling
Type
Approx.
SKUs
Label
life
span
Secondary
Packaging
(if
applicable)
Approx
SKUS (if
applicable)
Avg. Label
Life Span
(if
applicable)
(type)
(number)
(years)
(type)
(number)
(years)
Meat/
Poultry/
Game/
Batrachian Unprepared/
Unprocessed
Meat/
Poultry/
Game/
Batrachian Prepared/
Processed
Meat/
Poultry/
Game/
Batrachian
Variety Packs
Department of Health
PwC
42
Survey
Q2.26 For your business' Seafood products, please provide the following information for
each applicable class of product: (Note: Label life span refers to the average age of a label
from the time it is created until is is replaced with a substantially different design. If the
average labelling life span is less than one year, please input as a decimal - i.e. 6 months =
0.5 years)
For Primary Packaging / Labelling Type (and Secondary if applicable), please choose from
the following options: Glass Bottle, Glass Jar, Metal Aluminium Can, Metal Steel Can, Plastic
Tub, Plastic Bottle, Plastic Jar, Fibre Folding Carton, Fibre Corrugated Carton, Fibre Liquid
Paperboard Carton and Flexible Pouch / Bag.
Product
Primary
Packaging
/
Labelling
Type
Approx.
SKUs
Label
life
span
Secondary
Packaging
(if
applicable)
Approx
SKUS (if
applicable)
Avg. Label
Life Span
(if
applicable)
(type)
(number)
(years)
(type)
(number)
(years)
Fish Unprepared/
Unprocessed
Shellfish Unprepared/
Unprocessed
Aquatic Plants
- Unprepared/
Unprocessed
Fish Prepared/
Processed
Aquatic
Invertebrates Prepared/
Processed
Shellfish Prepared/
Processed
Aquatic Plants
- Prepared/
Processed
Aquatic
Invertebrates Unprepared/
Unprocessed
Seafood
Variety Packs
Department of Health
PwC
43
Survey
Product
Primary
Packaging
/
Labelling
Type
Approx.
SKUs
Label
life
span
Secondary
Packaging
(if
applicable)
Approx
SKUS (if
applicable)
Avg. Label
Life Span
(if
applicable)
Aquatic
Invertebrates/
Fish/
Shellfish/
Seafood
Combination
Department of Health
PwC
44
Survey
Q2.27 For your business' Milk/ Butter/ Cream/ Yogurts/ Cheese/ Eggs/ Substitutes
products, please provide the following information for each applicable class of
product: (Note: Label life span refers to the average age of a label from the time it is created
until is is replaced with a substantially different design. If the average labelling life span is
less than one year, please input as a decimal - i.e. 6 months = 0.5 years)
For Primary Packaging / Labelling Type (and Secondary if applicable), please choose from
the following options: Glass Bottle, Glass Jar, Metal Aluminium Can, Metal Steel Can, Plastic
Tub, Plastic Bottle, Plastic Jar, Fibre Folding Carton, Fibre Corrugated Carton, Fibre Liquid
Paperboard Carton and Flexible Pouch / Bag.
Product
Primary
Packaging
/ Labelling
Type
Approx.
SKUs
Label
life
span
Secondary
Packaging
(if
applicable)
Approx
SKUS (if
applicable)
Avg. Label
Life Span
(if
applicable)
(type)
(number)
(years)
(type)
(number)
(years)
Eggs/ Egg
Substitutes
Milk/ Milk
Substitutes
Cheese/
Cheese
Substitutes
Butter/
Butter
Substitutes
Cream/
Cream
Substitutes
Yogurt/
Yogurt
Substitutes
Milk/
Butter/
Cream/
Yogurts/
Cheese/ Egg/
Substitutes
Variety
Packs
Department of Health
PwC
45
Survey
Q2.28 For your business' Oils/ Fats (Edible) products, please provide the following
information for each applicable class of product: (Note: Label life span refers to the average
age of a label from the time it is created until is is replaced with a substantially different
design. If the average labelling life span is less than one year, please input as a decimal - i.e. 6
months = 0.5 years)
For Primary Packaging / Labelling Type (and Secondary if applicable), please choose from
the following options: Glass Bottle, Glass Jar, Metal Aluminium Can, Metal Steel Can, Plastic
Tub, Plastic Bottle, Plastic Jar, Fibre Folding Carton, Fibre Corrugated Carton, Fibre Liquid
Paperboard Carton and Flexible Pouch / Bag.
Product
Primary
Packaging /
Labelling
Type
Approx.
SKUs
Label
life
span
Secondary
Packaging
(if
applicable)
Approx
SKUS (if
applicable)
Avg. Label
Life Span (if
applicable)
(type)
(number)
(years)
(type)
(number)
(years)
Oils Edible
Fats Edible
Oils/
Fats
Edible
Variety
Packs
Department of Health
PwC
46
Survey
Q2.29 For your business' Confectionery/ Sugar / Sweetening Products products, please
provide the following information for each applicable class of product: (Note: Label life
span refers to the average age of a label from the time it is created until is is replaced with a
substantially different design. If the average labelling life span is less than one year, please
input as a decimal - i.e. 6 months = 0.5 years)
For Primary Packaging / Labelling Type (and Secondary if applicable), please choose from
the following options: Glass Bottle, Glass Jar, Metal Aluminium Can, Metal Steel Can, Plastic
Tub, Plastic Bottle, Plastic Jar, Fibre Folding Carton, Fibre Corrugated Carton, Fibre Liquid
Paperboard Carton and Flexible Pouch / Bag.
Product
Primary
Packaging
/
Labelling
Type
Approx.
SKUs
Label
life
span
Secondary
Packaging
(if
applicable)
Approx
SKUS (if
applicable)
Avg. Label
Life Span
(if
applicable)
(type)
(number)
(years)
(type)
(number)
(years)
Sugars/ Sugar
Substitute
Products
Confectionery
Products
Confectionery/
Sugar
Sweetening
Products
Variety Packs
Department of Health
PwC
47
Survey
Q2.30 For your business' Seasonings/ Preservatives/ Extracts products, please provide the
following information for each applicable class of product: (Note: Label life span refers to
the average age of a label from the time it is created until is is replaced with a substantially
different design. If the average labelling life span is less than one year, please input as a
decimal - i.e. 6 months = 0.5 years)
For Primary Packaging / Labelling Type (and Secondary if applicable), please choose from
the following options: Glass Bottle, Glass Jar, Metal Aluminium Can, Metal Steel Can, Plastic
Tub, Plastic Bottle, Plastic Jar, Fibre Folding Carton, Fibre Corrugated Carton, Fibre Liquid
Paperboard Carton and Flexible Pouch / Bag.
Product
Primary
Packaging
/
Labelling
Type
Approx.
SKUs
Label
life
span
Secondary
Packaging
(if
applicable)
Approx
SKUS (if
applicable)
Avg. Label
Life Span
(if
applicable)
(type)
(number)
(years)
(type)
(number)
(years)
Herbs/ Spices/
Extracts
Vinegars/
Cooking Wines
Sauces/
Spreads/
Condiments
Pickles/
Relishes/
Chutneys/
Olives
Seasonings/
Preservatives/
Extracts/
Variety Packs
Department of Health
PwC
48
Survey
Q2.31 For your business' Bread/ Bakery Products products, please provide the following
information for each applicable class of product: (Note: Label life span refers to the average
age of a label from the time it is created until is is replaced with a substantially different
design. If the average labelling life span is less than one year, please input as a decimal - i.e. 6
months = 0.5 years)
For Primary Packaging / Labelling Type (and Secondary if applicable), please choose from
the following options: Glass Bottle, Glass Jar, Metal Aluminium Can, Metal Steel Can, Plastic
Tub, Plastic Bottle, Plastic Jar, Fibre Folding Carton, Fibre Corrugated Carton, Fibre Liquid
Paperboard Carton and Flexible Pouch / Bag.
Product
Primary
Packaging /
Labelling
Type
Approx.
SKUs
Label
life
span
Secondary
Packaging
(if
applicable)
Approx
SKUS (if
applicable)
Avg. Label
Life Span
(if
applicable)
(type)
(number)
(years)
(type)
(number)
(years)
Baking/
Cooking
Mixes/
Supplies
Bread
Sweet Bakery
Products
Biscuits/
Cookies
Savoury
Bakery
Products
Bread/
Bakery/
Products
Variety Packs
Department of Health
PwC
49
Survey
Q2.32 For your business' Prepared/ Preserved Foods products, please provide the following
information for each applicable class of product: (Note: Label life span refers to the average
age of a label from the time it is created until is is replaced with a substantially different
design. If the average labelling life span is less than one year, please input as a decimal - i.e. 6
months = 0.5 years)
For Primary Packaging / Labelling Type (and Secondary if applicable), please choose from
the following options: Glass Bottle, Glass Jar, Metal Aluminium Can, Metal Steel Can, Plastic
Tub, Plastic Bottle, Plastic Jar, Fibre Folding Carton, Fibre Corrugated Carton, Fibre Liquid
Paperboard Carton and Flexible Pouch / Bag.
Product
Primary
Packaging
/ Labelling
Type
Approx.
SKUs
Label
life
span
Secondary
Packaging
(if
applicable)
Approx
SKUS (if
applicable)
Avg. Label
Life Span
(if
applicable)
(type)
(number)
(years)
(type)
(number)
(years)
Prepared
Soups
Snacks
Desserts/
Dessert
Sauces/
Toppings
Sweet
Spreads
Sandwiches/
Filled Rolls/
Wraps
Pasta/
Noodles
Baby/ Infant
- Foods/
Beverages
Vegetables
Based
Products
Grain Based
Products
Dough Based
Products
Prepared/
Preserved
Food Variety
Department of Health
PwC
50
Survey
Product
Primary
Packaging
/ Labelling
Type
Approx.
SKUs
Label
life
span
Secondary
Packaging
(if
applicable)
Approx
SKUS (if
applicable)
Avg. Label
Life Span
(if
applicable)
Packs
Dairy/ Egg
Based
Products
Q2.33 For your business' Beverages products, please provide the following information for
each applicable class of product: (Note: Label life span refers to the average age of a label
from the time it is created until is is replaced with a substantially different design. If the
average labelling life span is less than one year, please input as a decimal - i.e. 6 months =
0.5 years)
For Primary Packaging / Labelling Type (and Secondary if applicable), please choose from
the following options: Glass Bottle, Glass Jar, Metal Aluminium Can, Metal Steel Can, Plastic
Tub, Plastic Bottle, Plastic Jar, Fibre Folding Carton, Fibre Corrugated Carton, Fibre Liquid
Paperboard Carton and Flexible Pouch / Bag.
Product
Primary
Packaging
/ Labelling
Type
Approx.
SKUs
Label
life
span
Secondary
Packaging
(if
applicable)
Approx
SKUS (if
applicable)
Avg. Label
Life Span
(if
applicable)
(type)
(number)
(years)
(type)
(number)
(years)
Coffee/
Tea/
substitutes
Alcoholic
Beverages
Non
Alcoholic
Beverages Ready to
Drink
Non
Alcoholic
Beverages Not Ready
to Drink
Beverages
Variety
Packs
Department of Health
PwC
51
Survey
Q2.34 For your business' Cereal/ Grain/ Pulse Products products, please provide the
following information for each applicable class of product: (Note: Label life span refers to
the average age of a label from the time it is created until is is replaced with a substantially
different design. If the average labelling life span is less than one year, please input as a
decimal - i.e. 6 months = 0.5 years)
For Primary Packaging / Labelling Type (and Secondary if applicable), please choose from
the following options: Glass Bottle, Glass Jar, Metal Aluminium Can, Metal Steel Can, Plastic
Tub, Plastic Bottle, Plastic Jar, Fibre Folding Carton, Fibre Corrugated Carton, Fibre Liquid
Paperboard Carton and Flexible Pouch / Bag.
Product
Primary
Packaging
/ Labelling
Type
Approx.
SKUs
Label
life
span
Secondary
Packaging
(if
applicable)
Approx
SKUS (if
applicable)
Avg. Label
Life Span (if
applicable)
(type)
(number)
(years)
(type)
(number)
(years)
Grains/
Flour
Processed
Cereal
Products
Cereal/
Grain/
Pulse
Products
Variety
Packs
Department of Health
PwC
52
Survey
Q2.35 Based on your previous responses, how frequently do you restock your packaging and
labelling materials and what is the approximate annual cost?
Packaging
Subcategory
Packaging
(months)
($ / unit)
Labels
(#
volume)
(months)
($ / unit)
(#
volume)
Glass Bottle
Glass - Jar
Metal Aluminium
can
Metal Steel can
Plastic Tub
Plastic Bottle
Plastic - Jar
Fibre Folding
Carton
Fibre Corrugated
Carton
Fibre Liquid
Paperboard
Carton
Flexible Pouch/ Bag
Q2.36 Are there any promotional/ seasonal or other issues which will affect the packaging
life cycle for a product (e.g. holidays)? Please describe.
Q2.37 What other sort of costs does your company incur in changing food and beverage
labelling? Please describe.
Q2.40 Do you have any other comments you would like to include?
Department of Health
PwC
53
Appendix B Generic
product categories
Global product categories for the food, beverage and
tobacco segment
The Global Product Categories (GPC) is based on a hierarchy system:
 Segment: There are 36 segments, of which Food, Beverage and Tobacco is one segment.
Segments are grouped by industry sector.
 Family: A family is a broad division of a segment. There are 13 families in the Food,
Beverage and Tobacco segment and they are indicated in bold.
 Class: A class is a group of like categories. Classes are indicated by the “” symbol.
 Brick: Bricks are categories of like products and due to the level of detail are not provided
below.
F1:
50100000 - Fruits/Vegetables/Nuts/Seeds
50101500 - Vegetables - Unprepared/Unprocessed
50101600 - Fruit - Unprepared/Unprocessed
50101700 - Nuts/Seeds - Unprepared/Unprocessed
50101800 - Nuts/Seeds - Prepared/Processed
50101900 - Fruit/Nuts/Seeds Combination
50102000 - Fruit - Prepared/Processed
50102100 - Vegetables - Prepared/Processed
50102200 - Fruits/Vegetables/Nuts/Seeds Variety Packs
F2:
50110000 - Meat/Poultry/Game/Batrachian
50111500 - Meat/Poultry/Game/Batrachian - Unprepared/Unprocessed
50112000 - Meat/Poultry/Game/Batrachian - Prepared/Processed
50112100 - Meat/Poultry/Game/Batrachian Variety Packs
54
Department of Health
PwC
Survey
F3:
50120000 - Seafood
50121500 - Fish - Unprepared/Unprocessed
50121700 - Shellfish Unprepared/Unprocessed
50121800 - Aquatic Plants Unprepared/Unprocessed
50121900 - Fish - Prepared/Processed
50122000 - Aquatic Invertebrates - Prepared/Processed
50122100 - Shellfish Prepared/Processed
50122200 - Aquatic Plants Prepared/Processed
50122300 - Aquatic Invertebrates - Unprepared/Unprocessed
50122400 - Seafood Variety Packs
50122500 - Aquatic Invertebrates/Fish/Shellfish/Seafood Combination
F4:
50130000 - Milk/ Butter/ Cream/ Yogurts/ Cheese/ Eggs/ Substitutes
50131600 - Eggs/Egg Substitutes
50131700 - Milk/Milk Substitutes
50131800 - Cheese/Cheese Substitutes
50131900 - Butter/Butter Substitutes
50132000 - Cream/Cream Substitutes
50132100 - Yogurt/Yogurt Substitutes
50132200 - Milk/Butter/Cream/Yogurts/Cheese/Eggs/Substitutes Variety Packs
F5:
50150000 - Oils/Fats Edible
50151500 - Oils Edible
50151600 - Fats Edible
50151700 - Oils/Fats Edible Variety Packs
F6:
50160000 - Confectionery/Sugar Sweetening Products
50161500 - Sugars/Sugar Substitute Products
Department of Health
PwC
55
Survey
50161800 - Confectionery Products
50161900 - Confectionery/Sugar Sweetening Products Variety Packs
F7:
50170000 - Seasonings/Preservatives/Extracts
50171500 - Herbs/Spices/Extracts
50171700 - Vinegars/Cooking Wines
50171800 - Sauces/Spreads/Dips/Condiments
50171900 - Pickles/Relishes/Chutneys/Olives
50172000 - Seasonings/Preservatives/Extracts Variety Packs
F8:
50180000 - Bread/Bakery Products
50181700 - Baking/Cooking Mixes/Supplies
50181900 - Bread
50182000 - Sweet Bakery Products
50182100 - Biscuits/Cookies
50182200 - Savoury Bakery Products
50182300 - Bread/Bakery Products Variety Packs
F9:
50190000 - Prepared/Preserved Foods
50191500 - Prepared Soups
50192100 - Snacks
50192300 - Desserts/Dessert Sauces/Toppings
50192400 - Sweet Spreads
50192500 - Sandwiches/Filled Rolls/Wraps
50192900 - Pasta/Noodles
50193000 - Baby/Infant - Foods/Beverages
50193100 - Vegetable Based Products
50193200 - Grain Based Products
Department of Health
PwC
56
Survey
50193300 - Dough Based Products
50193400 - Prepared/Preserved Foods Variety Packs
50193500 - Dairy/Egg Based Products
F10:
50200000 - Beverages
50201700 - Coffee/Tea/Substitutes
50202200 - Alcoholic Beverages
50202300 - Non Alcoholic Beverages - Ready to Drink
50202400 - Non Alcoholic Beverages - Not Ready to Drink
50202500 - Beverages Variety Packs
F11:
50210000 - Tobacco/Smoking Accessories
50211500 - Tobacco Products/Smoking Accessories
F12:
50220000 - Cereal/Grain/Pulse Products
50221000 - Grains/Flour
50221200 - Processed Cereal Products
50221300 - Cereal/Grain/Pulse Products Variety Packs
F13:
50230000 - Food/Beverage/Tobacco Variety Packs
50230100 - Food/Beverage/Tobacco Variety Packs
Department of Health
PwC
57
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