AM I PUTTING MY CUSTOMERS AT RISK?
Reusable cups and containers are one of the most important tools we have to reduce plastic pollution.
However, many cafes and consumers are concerned around the health and safety implications of using reusables, and confused about the the law on using/accepting them.
This guide aims to clear up some of the conflicting information that’s out on this topic.
What is ‘reusable’ food/drink ware?
There is currently no strict guidance on what is considered reusable food/drink ware in Australia. We define it as any food or drink receptacle that is capable of multiple uses, where such reuse will not compromise the integrity of the product or render it unable to be washed via sanitary processes.
By contrast, a single-use product is typically intended to be used just once or for a short period of time before being disposed of.
What is the law on accepting reusables?
Legally, food safety matters relating to packaging are contained in the Australia New Zealand Food Standards Code- Standard 3.2.2.
It requires food businesses when packaging food to:
- only use packaging material that is fit for its intended use,
- only use packaging material that is not likely to cause food contamination,
- ensure food is protected from contamination during all stages,
- not reuse single-use items (noting the code does not define single-use).
Therefore, accepting reusable cups and containers from customers is allowable under the code, providing these are fit for its intended use, not likely to cause food contamination, and not designed for single-use.
Will accepting reusables increase the risk of food contamination?
There is NO EVIDENCE that reusables increase the risk of food contamination. As long as a reusable container is free from defects and properly cleaned, then the risk of food contamination can be considered the same as that of a single-use item.
To mitigate any potential risk:
- Only accept clean, undamaged reusables. This is a rule of thumb and cancels out issues of potential contamination.
- Only accept reusables that are genuinely ‘reusable’. This way you can be sure that the material is made to be washed, withstand heat and hold food or drinks safely.
- If you're still concerned, you can wash/sanitise BYO reusables in-house. This can be done quickly and efficiently by having a vessel on hand with food grade sanitiser.
Are reusables less hygienic than single-use products?
Provided the reusable container is clean, it is NO LESS hygienic than a single-use product. A clean reusable container will be handled by the server in the same way as a single-use product and will hold the same food or drink item.
Will I be fined for accepting reusables?
No. There is currently no legislation or regulation in any state or territory in Australia that can be used to fine a business for accepting reusables.
Do I have to accept reusables?
No. A business can refuse reusables if they decide to, but equally a customer can choose to go to a business that does allow them to. Increasingly customers are choosing to frequent businesses that are more reusable friendly.
Do I need an onsite dishwasher to use/accept reusables?
No. Under the Australia & New Zealand Food Standards Code, a food business must ensure eating and drinking utensils are in a clean and sanitary condition, but it does not prescribe specific procedures to achieve this.
Instead, The Code prescribes that food businesses may use any procedure or a combination of procedures, provided that the process achieves the two following outcomes:
(a) The item is clean; and
(b) it has had applied to it heat or chemicals, heat and chemicals, or other processes, so that the number of microorganisms on the surface or utensil has been reduced to a level that does not compromise the safety of the food with which it may come into contact; and does not permit the transmission of infectious disease.
Therefore, a dishwasher is not required to effectively clean and sanitise eating and drinking utensils. Please refer to The Code Appendix 6: Cleaning and sanitising surfaces and utensils for detailed information on cleaning and sanitising.
It’s important to note that some local councils may have requirements around dishwashers linked to the issuing of food licences, so it is advisable to check with your local council.
Please note: the content of this guide is the advice of Boomerang Alliance. It may not reflect the view of your state government and you are encouraged to seek your own independent advice. Boomerang Alliance is an impartial non-profit organisation, and we don't benefit commercially from any information we provide, or brands or products we identify.
