Q1. To what extent should the food regulatory system be used to meet broader
public health objectives?
A1: The fundamental link of food with health is not made by the current
regulatory arrangements, nor is there sufficient cross-departmental
involvement to deliver this. Hence the food regulatory system should be used
far more effectively to meet broader public health objectives, from avoidance
of ingredients, through to obesity and other public health challenges.
Q2. What is adequate information and to what extent does such information need to
be physically present on the label or be provided through other means (eg education
or website)?
A: It is critical that more, and simple, information is available for consumers in
areas as are outlined in our attached briefing.
Q3. How can accurate and consistent labelling be ensured?
A: More detailed specifications on prohibitions on the making of some claims
(eg free range, natural, no synthetic colours, etc) while also clear and simple
and more transparent labelling requirements for novel or related food items (eg
GM foods, nanotechnology, processing aids).
Q4. What principles should guide decisions about government intervention on food
labelling?
A: Transparency, greater information and choice for consumers.
Q5. What criteria should determine the appropriate tools for intervention?
A: Where there is potential for consumer confusion. Also where there is a lack
of an ability for the consumer to make a choice at purchase (eg presence of
GM derived ingredients not required to be labelled).
Q6. Is this a satisfactory spectrum for labelling requirements?
Q7. In what ways could these misunderstandings and disagreements be overcome?
A: Specific prohibitions on some claims being made (eg no synthetic colours,
when in fact there may be nature identical as opposed to natural colours
present, and also free range or similar claims) where this is identified in the
marketplace.
More and specific requirements for labelling of ingredients or derivatives not
currently required on packaging.
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Q8. In what ways can food labelling be used to support health promotion initiatives?
A: See attached brief.
Q9. In what ways can disclosure of ingredients be improved?
A: See attached brief.
Q10. To what extent should health claims that can be objectively supported by
evidence be permitted?
A: A: See attached brief.
Q12. Should specific health warnings (e.g., high level of sodium or saturated fat per
serve) and related health consequences be required?
A: See attached brief. Yes.
Q13. To what extent should the labelling requirements of the Food Standards Code
address additional consumer-related concerns, with no immediate public health and
safety impact?
A: As noted in the brief, the requirements should be expanded, both due to a
very limiting notion and definition in the first instance of public health and
safety, while also not recognising that consumers remain confused and misled
by many claims that could be rectified by simple additions or modifications to
the Code.
Q14. What criteria should be used to determine the inclusion of specific types of
information?
A: Consumer interest; greater ability for consumers to actually be able to
choose via simple information and mandated declarations on packaging; and a
broader definition of public (which includes environmental) health.
Q15. What criteria should determine which, if any, foods are required to have country
of origin labelling?
A: Some reference to imported product or imported ingredients more clearly
labelled on the packaging (on the front in clear font) should be mandated to
avoid this area of confusion. The current requirements lead to much confusion
and consumer mistakes in purchase of products being assumed Australian
when indeed they are in large measure not.
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Q16. How can confusion over this terminology in relation to food be resolved?
A: As above. “Imported Ingredients” OR “Imported product” should be
mandated on any product in clear font on the front of packaging for products
or ingredients imported into Australia where more than 95% of ingredients, or
any single major ingredient, are imported.
Q17. Is there a need to establish agreed definitions of terms such as ‘natural’, ‘lite’,
‘organic’, ‘free range’, ‘virgin’ (as regards olive oil), ‘kosher’ or ‘halal’? If so, should
these definitions be included or referenced in the Food Standards Code?
A: See attached brief.
Q18. What criteria should be used to determine the legitimacy of such information
claims for the food label?
A: See attached brief. Existing industry standards and certification for organic.
Other labelling claims remain of some concern.
Q19 In what ways can information disclosure about the use of these technological
developments in food production be improved given the available state of scientific
knowledge, manufacturing processes involved and detection levels?
A: See attached brief.
Q23. How best can the information on food labels be arranged to balance the
presentation of a range of information while minimising information overload?
A: See attached brief. The organic industry has such logos as the Organic Bud
and the words “Australian Certified Organic” or “International Certified
Organic” on labelling. This is clear and simple and by nature references clearly
a separate standard and denotes independent certification to that standard.
More of this should be both encouraged, and where an industry lacks this, be
mandated.
Q24. In what ways can consumers be best informed to maximise their understanding
of the terms and figures used on food labels?
Q25. What is an appropriate role for government in relation to use of pictorial icons
on food labels?
A: See attached brief. This should be left to industry in large measure, not
governments.
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Q28. To what degree should the Food Standards Code address food advertising?
A: See attached brief. This should be approached similarly as for labelling. The
case of “no synthetic colours” is a recent case in point, while such ingredients
may still not be “natural” as per the definition in the Code but are then
assumed as such by consumers.
Q30. In what ways can consistency, especially within Australia, in the enforcement of
food labelling standards be improved?
A: See attached brief.
Q31. What are the strengths and weaknesses of placing the responsibility for the
interpretation, administration and enforcement of labelling standards in Australia with
a national authority applying Commonwealth law and with compatible arrangements
for New Zealand?
A: See attached brief.
Q33. If such an approach was adopted, what are appropriate mechanisms to deal
with the constitutional limits to the Commonwealth’s powers?
A: See attached brief in reference to State based Consumer Affairs agencies.
Q35. If a move to either: self regulation by industry of labelling requirements; or coregulation involving industry, government and consumers were to be considered,
how would such an arrangement work and what issues would need to be addressed?
A: See attached brief in relation to organic foods.
Q36. In what ways does such split or shared responsibility strengthen or weaken the
interpretation and enforcement of food labelling requirements?
A: See attached brief.
Q38. What are the strengths and weaknesses of having different approaches to the
enforcement of food labelling standards for imported versus domestically produced
foods?
A: See attached brief.
Q39. Should food imported through New Zealand be subject to the same AQIS
inspection requirements?
A: Yes.