Charles is one of Australia’s leading FMCG regulatory lawyers, with deep expertise in marketing, compliance, labelling, classification, licensing, safety and food-crisis management. Particularly operating at the frontier of food technology where scientific innovation crunches up against legal compliance, Charles is recognised as a national leader. He supports clients developing novel products, powerful marketing campaigns, advanced manufacturing techniques and breakthrough ingredients, from R&D through to market entry, with precision and commercial pragmatism.
Charles expertise extends to the regulation of supplements, pet foods, cosmetics, therapeutic goods and medical devices.
Clients seek Charles’s expertise on:
- Marketing of food products – particularly health, natural and origin claims under both food regulations and consumer protection laws.
- Identifying the most efficient regulatory pathway for innovative products to enter the Australian and New Zealand markets.
- Determining whether a product is best regulated as a food, cosmetic, special purpose food, complementary medicine or therapeutic good (or a combination of all the above).
- Assessing whether a new ingredient may be considered a novel food, nutritive substance, non-traditional food, food additive, processing aid or poison.
- Classifying products under the Food Standards Code (and other regulations) to enable optimal recipe flexibility and fortification options.
- Recipe and label compliance.
- Navigating licensing obligations that apply to food businesses, including liquor licensing, primary production and food delivery services.
- Understanding the regulatory implications of online sales and marketing, including authority-to-leave and labelling requirements.
- Engaging with regulators including State and Territory health departments, primary production regulators, the ACCC, and the Federal Department of Agriculture, Fisheries and Forestry, among others.
- Advising on food-safety crisis situations, including whether a product recall is required.
Recent examples of Charles’ work include:
- Supporting an Australian-based global food tech company to achieve the first cultured-meat approval in Australia and New Zealand.
- Assisting a global dairy and plant-based food producer to manage registration obligations relating to its portfolio of medical devices.
- Advising a global healthcare company on the viability of shifting from a pharmacy-only sales model to general grocery, including Australian Consumer Law and therapeutic-goods compliance.
- Advising soft drink manufacturers on expanding their portfolios to include alcoholic beverages, including application of relevant industry codes such as the Australian Beverages Advertising Code Scheme.
- Advising on the use of cultivated plant stem cells in cosmetic products.
Charles brings a rare capability to navigate complex regulatory frameworks and guide clients along commercially grounded pathways to market. He has strong relationships with various industry regulators, advocating for the benefit of his clients and the industry more broadly. He frequently appears at leading industry events, including the Australian Institute of Food Science and Technology (AIFST) Convention, Cellular Agriculture Australia and Fine Foods Australia.
Charles is a recommended lawyer in the Competition & Trade category of Legal 500 Asia Pacific (2023).