Opening Message/Context

• Australia’s food, beverage and grocery manufacturing industry is vital to national resilience, regional employment, and food security. 

• The sector contributes over $175 billion annually to the economy, employs over 290,000 Australians, and supports countless regional communities. 

• AFGC members are committed to investing in advanced manufacturing, sustainability, and innovation — but this requires a competitive, stable, and supportive policy environment. 

Strengthening Domestic Manufacturing Capability

Our Position 

• Australia needs a strong, sovereign food and grocery manufacturing base to ensure resilience, supply chain security, and economic diversity. 

• Targeted government support is essential to attract investment, improve competitiveness, and transition to low-emissions and digital manufacturing. 

Key Points 

• Input costs (energy, logistics, labour) are higher in Australia than key international competitors, impacting competitiveness and increasing pressure on margins. 

• Global and domestic shocks (COVID-19, floods, war, inflation) have exposed the risks of over-reliance on imports and under-investment in local production. 

• Energy reliability and cost volatility are impacting operating budgets and investment confidence. 

• Ensure affordable, reliable energy supply during the net zero transition, including incentives for energy efficiency and onsite generation. 

Asks 

• Expand access to targeted investment incentives for advanced manufacturing (e.g., tax incentives, grants, accelerated depreciation). 

• Prioritise food and grocery manufacturing under national industry and innovation agendas. 

• Partner with industry to de-risk major investments in modernisation, automation, and decarbonisation technologies. 

Supply Chain Resilience and Costs

Our Position 

• Reliable and efficient supply chains are essential for food security, affordability, and industry viability. 

• The sector needs policy settings that strengthen infrastructure, support efficient freight, energy, and workforce supply chains. 

Key Points 

• Transport and logistics costs have risen significantly and are eroding margins, particularly for regional manufacturers. 

• Workforce shortages, especially in regional areas, are limiting productivity and constraining growth. 

Asks 

• Invest in freight infrastructure, including intermodal hubs, ports, and regional transport links. 

• Improve workforce planning particularly on key roles including food technologists and engineers. 

Regulatory Burden and Modernisation

Our Position 

• The food and grocery sector is heavily regulated across multiple layers of government. 

• A more efficient and nationally consistent regulatory environment is needed to reduce duplication and compliance costs. 

Key Points 

• Complex and inconsistent regulations across states and local governments lead to delays, duplication, and increased compliance costs. 

• These challenges impact SMEs disproportionately, limiting innovation and investment in manufacturing capability. 

Asks 

• Commit to streamlining and harmonising regulations across jurisdictions, especially for manufacturing facilities and supply chain operations. 

• Engage industry early in the policy and regulatory development process to improve outcomes and reduce unintended impacts. 

Decarbonisation and Transition Support

Our Position 

• AFGC members are committed to reducing emissions and supporting the transition to a low-carbon economy. 

• However, the transition must be economically viable, technically feasible, and supported by transitional assistance. 

Key Points 

• Many manufacturers are already implementing energy efficiency, renewable energy, and emissions reduction projects. 

• Transition challenges include: 

• • Capital costs for clean tech 

• • Technological limitations of renewable energy sources 

• • Grid limitations and energy reliability 

• • Access to credible carbon data (especially for Scope 3) 

• Without support, decarbonisation targets could shift production offshore — undermining both climate and economic goals. 

Asks 

• Provide transition grants, loans, and tax incentives for decarbonisation projects in food and grocery manufacturing. 

• Commitment to gas for the short-medium term as part of a sensible transition pathway.  

General Industry Commitment

• AFGC members are committed to: 

• • Investing in Australian jobs and communities 

• • Modernising facilities and processes 

• • Building a competitive and sustainable manufacturing base 

• We seek a long-term partnership with government to drive economic growth, sustainability, and sovereign capability. 

Final Message 

“We are ready to invest in Australia’s future – in jobs, in innovation, and in sustainability. With the right policy settings, the food and grocery manufacturing industry can lead a new era of competitive, secure, and sustainable growth.” 

Opening Message/Context

• The food, beverage and grocery manufacturing industry is committed to improving public health outcomes through innovation, consumer education, and responsible marketing. 

• As AFGC members, we recognise the importance of a healthy diet and support evidence-based, proportionate regulation that balances public health objectives with consumer choice, food security, and industry viability. 

• We welcome partnership with government to develop policies that are effective, evidence-based, and practical to implement. 

Front-of-Pack Labelling and Reformulation

Our Position 

• The AFGC supports transparent, evidence-based nutrition labelling, including the Health Star Rating (HSR) system, to help consumers make informed choices. 

• Innovation and reformulation of food is a key strategy for improving population nutrition, and it must be guided by technical feasibility, safety, consumer acceptance, and appropriate lead times. 

Key Points 

• The HSR system, where used appropriately, has encouraged reformulation and innovation. It should remain science-backed and supported by an ongoing communication strategy.

• Mandatory reformulation targets risk unintended consequences if they fail to consider: 

• • The role of nutrients such as sodium, sugar, and saturated fat in food safety, shelf life, and taste 

• • Consumer preferences and purchasing behaviour 

• • Technical feasibility 

• Industry has made progress in reducing sodium, sugar, and saturated and trans fats in key categories – ongoing improvement requires collaborative and voluntary frameworks, not punitive regulation. 

• The industry is making efforts to reduce food portion/serving size and packaging sizes to address overconsumption of energy, as well as food wastage. 

Asks 

• Maintain the current algorithm of the HSR which is based on nutrition science principles. 

• Collaborate with industry on  voluntary reformulation targets to ensure technical feasibility and consumer acceptance. 

• Recognise and promote industry-led initiatives to improve public health outcomes, including innovation and education. 

Marketing and Advertising to Children

Our Position 

• The AFGC is committed to supporting self-regulatory initiatives to complement systems of regulation, co-regulation and other self-regulation mechanisms aimed at of advertising and marketing of food and beverages to children.  

• The AFGC strongly supports the AANA Food & Beverages Advertising Code. The Code sets rules for how food and drinks are advertised, including to children. It is reviewed regularly and reflects community expectations about how occasional foods should be advertised. 

Key Points 

• Industry codes have led to significant improvements in the way food and beverage products are marketed to children, including: 

• • Restrictions on targeting children under 15 in advertising 

• • Limits on the use of licensed characters, promotions, and influencers 

• The current codes are aligned with community expectations and provide robust complaint and enforcement mechanisms. 

• Regulatory duplication or overreach could undermine existing systems without delivering better outcomes. 

Asks 

• Continue to recognise and support the existing industry codes as a credible regulatory framework. 

• Ensure any proposed changes to marketing regulations are evidence-based and developed in consultation with industry. 

• Avoid conflicting or overlapping state and federal initiatives that create uncertainty. 

Food Standards and Regulatory Reform

Our Position 

• The AFGC supports a nationally consistent, evidence-based, and predictable food regulatory system that ensures consumer safety while enabling innovation and trade. 

• Reform of the food regulatory system, including modernising the Food Standards Australia New Zealand (FSANZ Act is essential to reduce duplication, modernise decision-making, and improve timeliness. 

Key Points 

• Australia’s food regulation system must be modernised to keep pace with innovation (e.g., plant-based alternatives, novel ingredients, health claims). 

• Regulatory processes are currently slow, complex, and fragmented, impacting investment and time-to-market for innovative products. 

• Strong, independent science should be the foundation of regulatory decision-making, with clear timelines and accountability. 

Asks 

• Support continued reform of the Food Regulation System and the FSANZ Act, including: 

• • Faster, more efficient approvals of food innovations and health claims 

• • Streamlined, risk-proportionate regulatory processes 

• • A nationally consistent regulatory approach across all jurisdictions 

• Involve industry early in the regulatory development process to ensure practicality and avoid unintended consequences. 

General Nutrition Commitment

• AFGC members are committed to: 
  • Assisting consumers to construct healthy diets by labelling of appropriate serve sizes that help consumers moderate their intake, through innovation and bringing new products and formats to market 

• • Investing in innovation to improve product nutrition profiles 

• • Ensuring clear, science-based consumer information 

• The AFGC supports programs that encourage the consumption of everyday core foods i.e. the five food groups (FFG), provide information and understanding around the Australian Dietary Guidelines (ADG), and promote physical activity and sport as the best way to stay healthy.  

• We believe shared responsibility across government, industry, and consumers is essential to achieving better nutrition outcomes. 

Final Message 

“We’re not just making food – we’re helping to feed the nation. We want to work with government on practical, science-based solutions that empower consumers, protect health, and support innovation.” 

Opening Message/Context

• As the peak body representing Australia’s food, beverage and grocery manufacturing industry, the AFGC is committed to supporting a transition to a more sustainable, low-emissions economy. 

• Our industry recognises the critical role it plays in reducing environmental impacts, including carbon emissions, packaging waste, and supporting the development of a circular economy for Australia 

• We support clear, practical, and industry-informed policies to enable real progress while maintaining food security, affordability, and competitiveness. 

Scope 3 Emissions Reporting

Our Position 

• The AFGC supports increased transparency and consistency in emissions reporting, including Scope 3, provided the regulatory approach is: 

• • Practical 

• • Cost-effective 

• • Aligned with international standards 

• • Supports proportionality for small and medium enterprises. 

Key Points 

• Scope 3 emissions are the most complex and difficult to measure, particularly for food and grocery manufacturers with large, global, and multi-tiered supply chains. 

• Accurate data is often not available or shared upstream/downstream, and current methodologies vary widely. 

• Government and industry need to co-develop practical guidance, sector-specific frameworks, and data-sharing protocols to ensure feasibility and consistency. 

• Incentives and support are needed to help companies, especially SMEs, to build capability and systems to measure and report Scope 3. 

Asks 

• Government support for industry-led pilots or working groups to develop Scope 3 guidance, and support to reduce the sustainability reporting burden across value chains. 

• Flexibility in regulatory design to reflect readiness across sectors. 

Sustainable Packaging and Circular Economy

Our Position 

• The AFGC supports a national, harmonised approach to packaging regulation and recovery infrastructure that: 

• • Drives packaging circularity 

• • Reduces environmental harm 

• • Maintains food safety and product integrity 

• • Supports industry innovation 

Key Points 

• The industry has made strong progress to date, but work is being limited by: 

• • Lack of standardised recycling infrastructure 

• • Inconsistent kerbside collection standards 

• Regulatory certainty and investment are needed to: 

• • Scale up advanced recycling in Australia 

• • Support at-scale collection of packaging waste 

• • Ensure consistent, clear recyclability labelling  

• • Support product stewardship for problematic packaging formats

Asks 

• Accelerate harmonisation of kerbside collection and recycling infrastructure across all jurisdictions. 

• Ensure long lead times in rolling out new packaging regulations and investment or capital tax incentives to support innovation needed for problematic packaging formats 

• Develop changes to packaging materials in consultation with industry ensuring no unintended consequences.  

• Mandatory traceability across the value chain to mitigate against greenwashing risks. 

General Sustainability Commitment

• AFGC members are committed to playing their part in addressing climate change. 

• We seek a partnership approach with government, based on co-design, shared accountability, and mutual support. 

Final Message 

“We are not asking whether to act on sustainability – we are already acting. What we are asking is for government to support a collaborative, coordinated, and realistic approach that enables scalable, lasting impact.”