The green triangle with the gold kangaroo is one of the most trusted symbols in Australian retail, and it earns that trust through a certification scheme rather than goodwill alone. The Australian Made logo is a registered certification trade mark, and every product that carries it sits inside a licensing system run by Australian Made Campaign Limited (AMCL), layered on top of the country of origin rules in the Australian Consumer Law (the ACL), which is Schedule 2 to the Competition and Consumer Act 2010 (Cth) (the CCA).
If you are thinking about putting the logo on your packaging, the practical question is how the whole system operates: who controls the mark, which of the descriptors under the logo your product can honestly carry, how the licence and fees work, where the consumer law rules bite, and when you need professional help before you commit to printing. That is what this guide covers.
Who runs the scheme
The logo was created in 1986 at the request of the then Prime Minister, Bob Hawke, and designed by Ken Cato. Between 1986 and 1996 it was administered by the Advance Australia Foundation. In 1999 a new organisation took over: AMCL, a not-for-profit public company established by the chamber of commerce movement with the assistance of the Federal Government. AMCL administers the logo under a formal agreement with the Government, its members include the Australian Chamber of Commerce and Industry, the state and territory chambers and the National Farmers Federation, and it receives no government funding for its core functions. The fees licence holders pay fund the scheme.
A certification trade mark works differently from an ordinary trade mark. An ordinary trade mark tells consumers which trader a product comes from. A certification trade mark certifies that goods carrying it meet a standard, and here the standard is Australian origin. Because consumers assume AMCL has checked the products behind the logo, AMCL actively polices it: its compliance team assesses every product before licensing, an annual audit program samples licence holders at random using an independent auditor, and AMCL can take legal action against misuse. The logo is registered as a trade mark in many countries, so that enforcement can extend overseas.
There is a second actor you need to know about: the Australian Competition and Consumer Commission (ACCC). The ACCC does not administer the logo, but it enforces the ACL rules on country of origin claims, which apply whether or not you use the logo at all.
The two layers of rules
Two separate sets of rules govern what you can put on a pack:
- The licence layer: AMCL's Code of Practice sets out the rules for using the logo, including which descriptors can appear under it, and AMCL must approve each product before the logo can go on it.
- The consumer law layer: claims such as "Made in Australia" or "Product of Australia" are regulated by the ACL regardless of any licence. Two provisions do most of the work: s 18, which bans misleading or deceptive conduct, and s 29(1)(k), which bans false or misleading representations about the place of origin of goods.
The two layers operate together. A licence shows you have AMCL's permission to use the mark. The ACL determines whether your claims are lawful for consumers to rely on. Getting the licence does not make an overreaching claim safe, and staying within the ACL does not entitle you to use the logo without a licence.
The eligibility tests: which descriptor fits your product
The logo can be used with five approved descriptors, each with a different test: Australian Made, Australian Grown, Product of Australia, Australian Seafood, and Australian (which is only for export markets and requires the product to meet one of the other four tests). You cannot use the logo with other wording, such as "Australian Designed". The logo can only be used on goods, not services.
Australian Made: the substantial transformation test
A product can be described as Australian Made if it underwent its last substantial transformation in Australia. Section 255 of the ACL defines the concept: goods are substantially transformed in a country if, as a result of one or more processes undertaken there, they are fundamentally different in identity, nature or essential character from all of their imported ingredients or components.
AMCL uses a practical example. A business imports plastic pellets and wire, then injection moulds the pellets into a bucket and bends the wire into a handle. The end product is fundamentally different from all the imported inputs, so the bucket has been substantially transformed in Australia. But if the finished bucket body and handle are imported and simply assembled here, the product has not been substantially transformed. Packaging is not a transformation either: packing imported sweetener into sachets does not make it "made in Australia".
There is no percentage-of-content test for this descriptor. Until February 2017 the law required at least 50% of production costs to be incurred in Australia for "made in" claims. That requirement was removed from the ACL and from the rules for using the logo, so the test is now purely whether the last substantial transformation happened here.
Product of Australia and Australian Grown: the stricter tests
These two descriptors are much harder to meet. Product of Australia requires all significant ingredients or components to originate in Australia and all, or virtually all, of the manufacturing or processing to happen in Australia. Australian Grown is the same test for produce: all significant ingredients must be grown in Australia, with all or virtually all processing here. These match the "produce of" and "grown in" safe harbour items in s 255 of the ACL.
A significant ingredient is one that matters to the product: if it were removed, the product would not be the same. There is no minimum percentage, so a tiny but essential ingredient can still be significant. Packaging is not treated as an ingredient or component.
Applying for the licence and what it costs
The application is lodged with AMCL, and its compliance team reviews each product against the relevant criteria before approval. Once approved, AMCL invoices the licence fee, and once paid you receive the logo artwork and your products are listed on the Australian Made website. One licence covers all your products: there is no per-product fee and no charge for the assessment or the website listing.
The annual fee is based on the actual sales of your licensed products over the previous 12 months, with a fixed fee per turnover band. The minimum is $300 plus GST for annual sales up to $300,000, and the top band is $25,000 for sales above $45 million. If a product has not been on the market for a full year, the fee is based on an estimate. Only sales of licensed products count, so products that do not carry the logo are excluded from the calculation.
Using the logo under the Code of Practice
The Code of Practice and the Style and Marketing Guide govern the artwork itself: which descriptors may be paired with the logo, colours, proportions and placement. The familiar green and gold combination is iconic but not mandatory, and the logo may be used in other solid colour combinations under the style rules.
The practical point for a small business is control. Designers, marketplaces and social media managers should work from an approved master file of logo assets and approved wording, rather than improvising variants. AMCL monitors compliance and runs the annual audit program, so an audit can arrive without warning. Keeping a folder of the evidence behind your claims, including supplier invoices, bills of materials and process descriptions, makes both the audit and any consumer law dispute far easier to manage.
The consumer law layer: when origin claims bite
Section 18 of the ACL bans conduct that is misleading or deceptive or likely to mislead or deceive, and s 29(1)(k) specifically bans false or misleading representations about the place of origin of goods. Part 5-3 of the ACL then provides safe harbours. Section 255 sets out representations that do not contravene s 18 or s 29(1)(k) if the stated requirements are met: a "grown in" representation (each significant ingredient grown there and all or virtually all processing there), a "produce of" representation (each significant ingredient or component originating there and all or virtually all processing there), a "made or manufactured in" representation (last substantially transformed there), and marks specified in an information standard.
Failing the safe harbour does not automatically breach the law. As the ACCC explains, a business can still make a claim if an ordinary reasonable consumer would not consider it false, misleading or deceptive. But that is a harder argument to win, which is why well-advised businesses aim for the safe harbour wording their product genuinely meets.
The "overall impression" principle is the trap most businesses underestimate. Courts assess the whole presentation, including what is left out, not just the literal words. The Full Federal Court's decision in Australian Competition and Consumer Commission v LG Electronics Australia Pty Ltd (No 2) [2018] FCAFC 128 illustrates the point. LG had handled consumers, retailers and repairers as though its own warranty were the only source of their rights, without mentioning the consumer guarantees under the ACL. The Court concluded that the ACCC's appeal should be allowed in part because LG had contravened the ACL on two occasions. The same logic applies to origin claims: wording that is technically accurate can still mislead if the surrounding imagery, flags or styling imply a stronger Australian connection than the product has.
The consequences of getting it wrong are serious. Under s 224 of the ACL, a court can order a pecuniary penalty for a contravention of a Part 3-1 provision such as s 29. For a body corporate the maximum is the greater of $100 million, three times the value of the benefit obtained from the conduct, or 30% of adjusted turnover, and for an individual it is $2.5 million. Courts can also make other orders, including injunctions and corrective advertising, and the ACCC can issue substantiation notices requiring a business to produce information supporting a claim it has made.
The food context works differently and is worth knowing even if you do not sell food. The Country of Origin Food Labelling Information Standard 2016 requires most food offered for retail sale in Australia to carry country of origin information, and for priority foods the standard mandates a label that includes the kangaroo logo and shows the percentage of Australian ingredients. Food businesses following the standard can use the logo in that label without an AMCL licence, whereas non-food use always requires the licence. The rectangular bar chart showing the percentage of Australian ingredients can be used on non-food goods without a licence. From 1 July 2026, a new information standard will also require hospitality venues serving seafood to label whether it is Australian, imported or a mix.
If you export, add a third layer. Other countries have their own origin and labelling rules, and the logo is registered as a trade mark in many of them. The "Australian" descriptor exists specifically for export markets. Check the rules of each destination market before printing export packaging, and consider designing templates that satisfy the strictest rules across your channels.
Where the traps usually sit
The same mistakes recur across applications, audits and consumer law complaints:
- Assembly versus transformation: importing a finished product and adding a sticker or doing basic assembly is not substantial transformation. The product must change fundamentally in identity, nature or essential character in Australia. If the process is borderline, document it and get advice before claiming.
- Descriptor drift: "Product of Australia" is a stricter claim than "Australian Made". If only some components are Australian, choose "Australian Made" based on the last substantial transformation, and keep evidence of where every input came from.
- Services and non-approved wording: the logo is for goods only, and it cannot be paired with descriptors such as "Australian Designed". A service business or an importer using the logo is outside the scheme from day one.
- Supply chain changes: switching a component supplier or moving a process offshore can change eligibility overnight. Build a review trigger into your product change process so packaging and marketing updates pause until origin status is rechecked.
- Inconsistent claims across channels: if packaging says one thing and the website or a marketplace listing says another, the inconsistency itself becomes evidence in a misleading conduct complaint. Keep one master claims file used everywhere.
- Evidence gaps: AMCL audits a random sample of licence holders each year and the ACCC can demand substantiation. Supplier invoices, bills of materials, process descriptions and origin statements from contract manufacturers are the file that saves you.
When a lawyer earns their keep
A licensing lawyer adds the most value at five points in the life of an origin claim:
- Before you invest in packaging: mapping your supply chain against each descriptor and deciding which claim the product genuinely meets is the highest-leverage step. A lawyer can pressure-test that assessment before you spend money on artwork and print runs.
- Supplier and manufacturing agreements: the paper trail behind an origin claim is built in the contracts. Manufacturing and supply agreements should include warranties that inputs and processing locations are as represented, rights to audit and to obtain origin documentation, obligations to notify you of any change, and indemnities for inaccurate origin information.
- Marketing review: before publishing, packaging and ads should be checked for overall impression issues and safe harbour alignment, not just individual sentences.
- Enforcement and audits: if AMCL audits you, the ACCC issues a substantiation notice, or a competitor or customer complains about your claims, get advice early rather than drafting a response cold.
- Your own brand: licensing the Australian Made logo does not protect your own brand. If you have a house brand, consider registering a trade mark so you can stop others using a confusingly similar name or logo for similar goods.
Why the descriptor decision is where the money goes
The licence fee is the cheap part of this scheme. A small business can hold a full licence for $300 plus GST a year. The expensive part is the decision made before you apply: which descriptor to use, and whether you can prove it. Reprinting packaging, pulling stock from retail shelves, or defending an ACCC matter costs multiples of any licence fee, and those costs land precisely when a supply chain detail you did not document turns out to be wrong. Getting the descriptor right at the start, with a documented supply chain and contracts that force suppliers to prove origin, is where the leverage sits. A lawyer can run that assessment quickly, and an initial consultation is a small price compared with a packaging recall.