Exhibit 5.11


                    [PEREZ BUSTAMANTE & PONCE LETTERHEAD]

                                                Quito, March 5, 2004

BURNS PHILP ECUADOR S.A.
QUITO.- ECUADOR

Ladies and Gentlemen:

                  Re: 10-3/4% Series B Senior Subordinated Notes Due 2011

         We have acted as special ECUADORIAN counsel to BURNS PHILP ECUADOR
S.A., an ECUADORIAN corporation (the "Company"), in connection with the offer to
exchange (the "Exchange Offer") by Burns Philp Capital Pty Limited, an
Australian corporation and Burns Philp Capital (U.S.) Inc., a Delaware
corporation (the "Issuers"), and each a wholly owned subsidiary of Burns, Philp
& Company Limited ("Burns Philp"), of U.S.$ 210,000,000 aggregate principal
amount of 10-3/4% Series B Senior Subordinated Notes due 2011 (the "Exchange
Notes") which are being registered under the Securities Act of 1933, as amended
(the "Securities Act"), for its existing 10-3/4% Senior Subordinated Notes due
2011 (the "Old Notes"), as described in the Registration Statement on Form F-4
(File No. 333-107085) relating to the Exchange Offer (as amended or
supplemented, the "Registration Statement"), initially filed with the United
States Securities and Exchange Commission on July 16, 2003. The Old Notes were
issued, and the Exchange Notes are proposed to be issued, under an indenture
dated as of February 20, 2003 (the "Indenture"), among the Issuers, Burns Philp
and certain subsidiaries of Burns Philp (together with the Company, the
"Subsidiary Guarantors") and Wells Fargo Bank, National Association, as Trustee
(the "Trustee"). The terms of the Exchange Notes to be issued are substantially
identical to the Old Notes, except for certain transfer restrictions and
registration rights relating to the Old Notes. The Old Notes are, and the
Exchange Notes will be, fully and unconditionally guaranteed by the Company and
the Subsidiary Guarantors on a senior subordinated basis (the "Guarantees"). The
Indenture is an exhibit to the Registration Statement.

         We have examined originals, or copies certified or otherwise identified
to our satisfaction, of the Indenture, the supplemental indenture of additional
subsidiary guarantors, and the minutes of the board of meeting of the company
dated November 25, 2002, (the "Relevant Documents"), as in our judgment are
necessary or appropriate to enable us to render the opinion expressed below. In
rendering such opinion, we have relied as to factual matters upon the
representations, warranties and other statements made in the Relevant Documents.



                    [PEREZ BUSTAMANTE & PONCE ABOGADOS LOGO]

         In our examination, we have assumed, (i) the genuineness of all
signatures (ii) the legal capacity of all natural persons, (iii) the
authenticity of all documents submitted to us as originals, and (iv) the
conformity to the original documents of all documents submitted as conformed,
facsimile or photostatic copies.


         Based upon the foregoing, and subject to the exceptions,
qualifications, limitations and assumptions herein set forth, we are of the
opinion that (i) the execution and delivery of, and the performance by the
Company of its obligations under, the indenture has been duly authorized by all
requisite corporate action on the part of the Company; and (ii) the Company is
validly incorporated and of good standing; and (iii) that the Company has full
power and authority, and all necessary consents and approvals to execute,
deliver and perform its obligations under the indenture; and (iv) that the
execution, delivery and performance of the indenture does not violate or
conflict with the Company's by-laws or the laws of Ecuador; and (v) the
indenture has been duly executed on behalf of the Company by the duly authorized
person and delivered.


         In rendering the foregoing opinion, we express no opinion, directly or
indirectly, as to laws other than the laws of the Republic of Ecuador. The
foregoing opinion is rendered as of the date hereof and we assume no obligation
to update such opinion to reflect any facts or circumstances which may hereafter
come to our attention or any changes in the law which may hereafter occur.

         We hereby consent to the filing of this opinion as an Exhibit to the
Registration Statement and making reference to our name under the caption "legal
matters" in the prospectus included therein. In giving such consent, we do not
thereby admit that we come within the category of persons whose consent is
required under Section 7 of the Securities Act of 1933, as amended, or the rules
and regulations of the Securities and Exchange Commission thereunder. Dewey
Ballantine LLP may rely on our opinion with respect to matters of the laws of
Ecuador for purposes of its opinion filed as an exhibit to the registration
statement, as if our opinion has been addressed to it.

                               Very truly yours,

                               /s/ Raul de la Torre

                               Raul de la Torre