Country of origin requirements (COOL)

Country of origin has to be declared but not at ingredient level. There are 3 main possible declaration of the country of origin:

(a) “Product of (name of country)” if all the main ingredients, processing and labour used to make the foodstuff are from one specific country;

(b) “Produced in (name of country)”, “Processed in (name of country)”, “Manufactured in (name of country)”, “Made in (name of country)” or similar words when a foodstuff is processed in a second country which changes its nature; or

(c) the words “Packed in (name of country)” may be used in addition to the requirement of paragraph (a) or (b) above.

There are some variations, for example, where for seasonal availability reasons some ingredients may be substituted by others from another country in which case and/or notation is permitted where specifically provided for.

Definitions of vegetarian and vegan

“strict vegetarian diet” means a diet which excludes all ingredients and additives derived from animal origin and the expression “vegan diet” has the same meaning;

“vegetarian” means a diet which –

(i) consists of ingredients of multi-cellular plant, fungal, algal and bacterial origin;

(ii) may include honey, dairy foods produced without any slaughter by-products, and/or unfertilised eggs obtained from live animals; and

(iii) excludes all animal flesh and products obtained from the slaughter of an animal, such as gelatine, animal fats, caviar and roe;

(1) Claims that a foodstuff is suitable for vegetarians shall specify the category of vegetarian by adding one or a combination of the following prefixes to the word “vegetarian”:

(a) “Lacto (milk)” – means milk and milk products are included but products in which animal rennet is used during preparation are excluded.

(b) “Ovo (egg)” – means unfertilised eggs (preferably free-range) and egg products are included.

(c) “Honey” -means honey is included.

(d) “Strict vegetariam[sic]” ”or “vegan” means ingredients of multicellular plant, fungal, algal and bacterial origin are included but all ingredients and additives derived from animal origin are excluded.

(2) When a foodstuff is manufactured for the “strict vegetarian” or “vegan” market and a claim in respect of “strict vegetarian” or “vegan” is made on the label and it is not possible to conclude from the name of the ingredient or additive that they are derived from non-vegetarian origin, any additive or ingredient derived from non-vegetarian origin which is added to the foodstuff shall be declared as “non-vegetarian origin” or in words that specify the source in parenthesis after the name of the additive or ingredient.

Fortification of foods

In South Africa “fortification” has a specific meaning and implies that the regulations relating to fortification of foodstuffs are complied with.

“fortification” means the addition of one or more micronutrients by means of a fortification mix to a foodstuff whether or not it is normally contained in a foodstuff for the purpose of preventing or correcting a demonstrated deficiency of one or more nutrients in the general population or specific population group of South Africa as determined by the Department;

Thus, fortification is the means whereby staple foodstuffs are used as a vehicle to ensure that the population receive sufficient micronutrients, as defined:

“micronutrient” means a natural or synthesised vitamin, mineral, or trace element that is essential for normal growth, development and maintenance of life and of which a deficit will cause characteristic biochemical or physiological changes.

Fortification should not be confused with enrichment which is a voluntary process and which has limits above which a foodstuff may be considered a medicine or not be permitted to be enriched above.

Cannabis as an ingredient in food or supplements

Cannabis may not be an ingredient in a foodstuff.

If used in a supplement the THC levels must be below 0.001% and CBD levels need to be limited as well as the maximum daily consumption must be below 20 mg/day as indicated on the packaging.

Where raw cannabis is used in a supplement it may not be enriched and the native CBD levels must be present but the THC levels must still be below 0.001% which implies it should be hemp that is being used.


This is general information rather than legal advice and is current as of 30 May 2024. We recommend you contact a specialised food lawyer for legal advice for your particular circumstances to support commercial decisions which could impact your product or business.