19 July 2013
[12-13]
Call for submissions – Qualifying criteria for nutrition content
claims about dietary fibre
Standard 1.2.7 – Nutrition, Health and Related Claims was gazetted in January 2013. In the Standard,
the respective qualifying criteria for nutrition content claims about dietary fibre are 2 g, 4 g and 7 g
dietary fibre per serving for source, good source and excellent source claims.
In mid-2012, several breakfast cereal and bread manufacturers expressed concern that the qualifying
criteria recommended for inclusion in Standard 1.2.7 were set above the criteria in the voluntary 1995
Code of Practice on Nutrient Claims in Food Labels and in Advertisements (CoPoNC) (National Food
Authority, 1995), and that this would affect their ability to make nutrition content claims about dietary
fibre. In response to this concern, FSANZ committed to considering this issue further during the threeyear transition period for Standard 1.2.7.
FSANZ is seeking stakeholder views and available evidence relating to the qualifying criteria for
nutrition content claims about dietary fibre.
To aid submitters in providing comments, questions are provided. Submitters are encouraged
to use the response template provided at Attachment 2.
All submissions will be published on our website. We will not publish material that is provided
in-confidence, although that information might be subject to release under freedom of information
laws. Submissions will be published as soon as possible after the end of the public comment period.
Where large numbers of documents are involved, FSANZ will make these available on CD, rather
than on the website.
Under section 114 of the FSANZ Act, some information provided to FSANZ cannot be disclosed.
More information about the disclosure of commercial-in-confidence information is available on the
FSANZ website at ‘how to make a submission’.
Submissions should be made in writing, be marked clearly with the word ‘Submission’, and quote,
‘Consultation Paper – Qualifying criteria for nutrition content claims about dietary fibre’. While
FSANZ accepts submissions delivered in hard copy to our offices, it is more convenient to receive
submissions electronically through the FSANZ website via the link at ‘how to make a submission’. You
can also email your submission directly to submissions@foodstandards.gov.au.
There is no need to send a hard copy of your submission if you have submitted by email or through
the FSANZ website. FSANZ endeavours to formally acknowledge receipt of submissions within 3
business days.
DEADLINE FOR SUBMISSIONS: 6pm (Canberra time) 29 August 2013
Submissions received after this date will not be considered unless an extension had been given
before the closing date. Extensions will only be granted due to extraordinary circumstances during the
submission period. Any agreed extension will be notified on the FSANZ website and will apply to all
submitters.
Questions about making submissions can be sent to standards.management@foodstandards.gov.au.
i
Hard copy submissions may be sent to one of the following addresses:
Food Standards Australia New Zealand
PO Box 7186
Canberra BC ACT 2610
Food Standards Australia New Zealand
PO Box 10559
154 Featherston St, Level 3
WELLINGTON 6011
NEW ZEALAND
Tel +64 4 978 5630
AUSTRALIA
Tel +61 2 6271 2222
ii
Table of Contents
1
INTRODUCTION ................................................................................................................................... 2
2
BACKGROUND ..................................................................................................................................... 3
2.1
DEVELOPMENT OF QUALIFYING CRITERIA FOR NUTRITION CONTENT CLAIMS ABOUT DIETARY FIBRE .. 3
2.2.1 Consideration of qualifying criteria by the Australian National Food Authority ...................... 3
2.2.2 Consideration of qualifying criteria by FSANZ (Proposal P293 – Nutrition, Health &
Related Claims) ........................................................................................................................................... 4
2.2
INDUSTRY PRACTICE WITH CLAIM CONDITIONS IN COPONC ............................................................... 5
2.3
AMOUNT OF DIETARY FIBRE IN FOOD .................................................................................................... 6
2.4
QUALIFYING CRITERIA FOR NUTRITION CONTENT CLAIMS ABOUT DIETARY FIBRE IN OTHER
JURISDICTIONS .................................................................................................................................................... 6
3
QUESTIONS FOR STAKEHOLDERS................................................................................................. 9
INDUSTRY DATA – IMPACT OF QUALIFYING CRITERIA IN STANDARD 1.2.7 ON FOODS CARRYING
NUTRITION CONTENT CLAIMS ABOUT DIETARY FIBRE ......................................................................................... 9
3.1
3.2
4
STAKEHOLDER VIEWS AND EVIDENCE ................................................................................................. 11
NEXT STEPS ....................................................................................................................................... 11
REFERENCES .................................................................................................................................................... 11
ATTACHMENT 1: AMOUNT OF DIETARY FIBRE IN SELECTED FOODS ............................................................. 13
ATTACHMENT 2: SUBMISSION TEMPLATE ..................................................................................................... 15
1
1
Introduction
Standard 1.2.7 – Nutrition, Health and Related Claims was gazetted in January 2013. In the
Standard, the respective qualifying criteria for nutrition content claims about dietary fibre are
2 g, 4 g and 7 g dietary fibre per serving for source, good source and excellent source
claims. These qualifying criteria were developed during Proposal P293 – Nutrition, Health
and Related Claims, following two rounds of public consultation (see section 2.2.2).
Before the gazettal of Standard 1.2.7, there were no qualifying criteria for nutrition content
claims about dietary fibre in the Australia New Zealand Food Standards Code (Code),
however a voluntary code of practice, the 1995 Code of Practice on Nutrient Claims in Food
Labels and in Advertisements (CoPoNC) (National Food Authority, 1995), was available in
Australia which included qualifying criteria for dietary fibre (see Table 1). The New Zealand
Food Regulations (1984) included qualifying criteria for good source claims only (4 g dietary
fibre per serving), however these regulations were revoked in 2002.
In mid-2012, several bread and breakfast cereal manufacturers asked FSANZ to review the
qualifying criteria for nutrition content claims about dietary fibre. Their main concern was that
the qualifying criteria proposed for inclusion in Standard 1.2.7 were set above the qualifying
criteria in CoPoNC and that this would affect their ability to make nutrition content claims
about dietary fibre on their foods. The concern was primarily about the ‘loss’ of claims, in
particular that foods previously meeting good source would now only meet source criteria.
The manufacturers suggested that the qualifying criteria for nutrition content claims about
dietary fibre in Standard 1.2.7 should be the same as those in CoPoNC.
Table 1: Qualifying criteria for nutrition content claims about dietary fibre
Descriptors for the dietary
fibre nutrition content claim
Source
Good source
Very high or Excellent source
CoPoNC qualifying criteria
Standard 1.2.7 qualifying
criteria
g dietary fibre per serving
2
4
7
1.5
3
6
In response to this request, FSANZ indicated in the Review Report for Standard 1.2.71 that
further consideration would be given to the qualifying criteria for nutrition content claims
about dietary fibre during the three-year transition period for the Standard (January 2013 –
January 2016).
FSANZ is seeking views of stakeholders and information about the extent of food
reformulation or changes to the labelling of dietary fibre on food labels in response to the
qualifying criteria for dietary fibre nutrition content claims in Standard 1.2.7. FSANZ is aware
that some food businesses have already commenced changing labels/food formulations in
response to the qualifying criteria in Standard 1.2.7 and seeks information on such changes
as part of this consultation. Information provided by submitters will assist FSANZ in
identifying issues involved with the change from the previous CoPoNC qualifying criteria for
dietary fibre nutrition content claims to those now in Standard 1.2.7.
1
P293 - Review Report
2
2
Background
2.1
Development of qualifying criteria for nutrition content claims
about dietary fibre
Table 2 summarises the evolution of qualifying criteria for nutrition content claims about
dietary fibre prior to, and during the development of, Standard 1.2.7.
Table 2: Evolution of qualifying criteria for nutrition content claims about dietary fibre
Descriptor
for
nutrition
content
claim (or
synonym)
Source
Good
source
Very high
OR
Excellent
source
2.2.1
New
Zealand
Food
Regulations
(1984)
(revoked in
2002)
Proposed
qualifying
criteria for
Proposal P18
– Nutrient
Claims
(early 1990’s)
Minimum
amount of
dietary fibre
per serving
Not
prescribed
4
Minimum
amount of
dietary fibre
per 100g
1.5
Not
prescribed
CoPoNC
Standard 1.2.7 (Proposal
P293)
Draft
Final
Draft
Preliminary
(1993)
(1995) Assessment Assessment
Report
Report
(2005)2
(2007), Final
Assessment
Report
(2008)3 and
Review
report
(2012)4
Minimum amount of dietary fibre per serving
2
1.5
2
2
4
4
3
4
4
10
6
6
NA
7
Consideration of qualifying criteria by the Australian National Food Authority
In the early 1990s, the then National Food Authority began developing qualifying criteria for
nutrition content claims about dietary fibre and other food components under Proposal P18 –
Nutrient Claims, for possible inclusion in the Australian Food Standards Code. At that stage,
based on consideration of the dietary fibre content of a wide range of foods, it was proposed
that the respective qualifying criteria for source, good source and excellent source nutrition
content claims be 1.5 g, 4 g and 10 g dietary fibre per 100 g food. 5
2
P293- Draft Assessment Report - 7 December 2005
P293 - Preliminary Final Assessment Report
4 P293 - Review Report
3
5
Historical information sourced from documents prepared for the 22nd meeting of the National Food Authority
(1994)
3
In 1993, it was decided to manage nutrition content claims by way of a voluntary code of
practice instead of a food standard. Consequently, P18 was abandoned and CoPoNC6
(National Food Authority, 1995), was developed. In response to submissions from the
Council of Australian Food Technology Associations (CAFTA) and other stakeholders, the
National Food Authority changed the basis for dietary fibre claim criteria to per serving as it
was recognised that dietary fibre quantities per 100g would unfairly advantage certain dry
foods while disadvantaging fruits and vegetables. The 1.5 g, 4 g, 10 g dietary fibre per 100 g
criteria were converted to 2 g, 4 g, 6 g dietary fibre per serving as these were considered to
most closely reflect the previous per 100 g criteria, taking into account the levels of dietary
fibre in a wide range of food and typical serving sizes.
At that time, CAFTA generally supported the criteria of 1.5 g, 3 g and 6 g dietary fibre per
serving, for source, good source and excellent source claims, respectively, as they
considered that:


whole wheat grain products should be the benchmark for allowing a good source claim
since white bread was a major source of dietary fibre in the diet, it should be possible
to refer to white bread as a source of dietary fibre.
Most white breads were able to meet the figure of 1.5 g dietary fibre per serving at that time if
the serving size was 2 slices, but not 2 g dietary fibre per serving. The final version of
CoPoNC was released in 1995 and included the qualifying criteria of 1.5 g, 3 g and 6 g
dietary fibre per serving, for source, good source and excellent source claims, respectively.
2.2.2
Consideration of qualifying criteria by FSANZ (Proposal P293 – Nutrition,
Health & Related Claims)
Proposal P293 – Nutrition, Health & Related Claims commenced in 2003. In the Draft
Assessment Report (2005)7, FSANZ first proposed that the qualifying criteria for source and
good source claims be increased from 1.5 g to 2 g per serving and from 3 g to 4 g per
serving, respectively. The key reasons for proposing these changes were:



1.5 g per serving and 3 g per serving were equivalent to only 5% and 13.3% of the
regulatory reference value for dietary fibre of 30 g8, respectively. In comparison, for
vitamins, minerals and protein, 10% and 25% of the reference value were required to
make a source and good source claim, respectively. Therefore it was considered
appropriate to increase the qualifying criteria for dietary fibre.
alignment with Canada’s approach for source and good source claims (see Table 3)
the 2 g and 4 g of dietary fibre per serving would still allow a variety of foods to make
claims (noting that at present some white breads, particularly toast slices, have more
than2 g dietary fibre per serving).
Qualifying criteria for a very high claim were not proposed in the Draft Assessment Report.
One of the reasons for this was concern expressed by submitters with the practice of food
manufacturers adding dietary fibre to processed foods.
6
CoPoNC was a voluntary code of practice that was developed by the National Food Authority (now FSANZ) and
managed by the Food Code Management Committee that comprised representatives from industry and the
community. A large number of nutrition content claims were self-regulated through the guidance provided in
CoPoNC. CoPoNC did not apply in New Zealand.
7
P293- Draft Assessment Report - 7 December 2005
8
The dietary fibre regulatory reference value of 30 g per day is based on a year 2000 nutrition target
recommended in Towards better health for Australians published by the Commonwealth Department of Health in
1987.
4
In the Draft Assessment Report it was also proposed that voluntary declaration of dietary
fibre in the nutrition information panel would be permitted without requiring the food to meet
the conditions for a source claim. This meant that the dietary fibre content of foods that did
not meet the qualifying criteria for source claims could still be provided in the NIP thereby
providing consumers with information. This provision was included in the consequential
amendments to Standard 1.2.8 – Nutrition Information Requirements at the time Standard
1.2.7 was gazetted.
In the Preliminary Final Assessment Report (2007)9, which was the last opportunity for
stakeholders to specifically comment on the qualifying criteria for nutrition content claims
about dietary fibre, FSANZ continued to propose that the qualifying criteria be 2 g (6.67% of
reference value), 4 g (13.3% of reference value) and also included 7 g (23.3% of reference
value) per serving for an excellent source claim. There was a mixed response from
submitters with some industry and public health stakeholders supporting the proposed
approach while others opposed the approach. Key reasons for supporting the approach
included the desirability of moving towards a percentage of the reference value consistent
with the qualifying criteria for nutrition content claims about vitamins, minerals and protein,
and consistency with international regulations. Submitters who opposed the approach cited
the following reasons:

the regulatory reference value of 30 g/day was too high because it aligned with the
NHMRC reference value for men aged 19 years and over
there is no evidence that raising the levels was necessary or would increase dietary
fibre intakes
serving sizes may be manipulated in order to meet the higher criteria
foods such as wheat biscuits would be unable to make good source claims despite
being almost 100% wholegrain
the criteria were not aligned to Codex or to the European Union (EU) requirements
consumers may be confused if foods carrying existing claims were reformulated or
claims were removed.





In the Final Assessment Report (2008)10, FSANZ maintained the higher levels for the
qualifying criteria for the reasons provided at Draft Assessment, namely, that the CoPoNC
criteria were too low relative to the regulatory reference value of 30 g and the criteria for
claims about vitamins, minerals and protein, and the criteria would still allow a variety of
foods to make claims.
In 2008 when the COAG Legislative Forum on Food Regulation (the Forum) asked FSANZ to
review Standard 1.2.7, the issue of qualifying criteria for dietary fibre claims was not included
in the review request and therefore was not given further consideration as part of the Review.
2.2
Industry Practice with claim conditions in CoPoNC
Data collected in 2001, 2003 and 2005 has indicated that food businesses in Australia have
tended to follow the claim conditions in the voluntary CoPoNC (Williams et al. 2003, FSANZ
2005, FSANZ 2007). An independent study of compliance with CoPoNC carried out in
Australia in 2001 found that the level of compliance in a sample of 6662 foods was 85% for
the 3194 claims covered by CoPoNC (Williams et al. 2003).
9
P293 - Preliminary Final Assessment Report
P293 - Final Assessment Report
10
5
The FSANZ Label Monitoring Survey carried out in 2003 found that, of the 721 labels
sampled in Australia, 153 labels carried 220 claims that were covered by CoPoNC (FSANZ
2005). Ninety-seven per cent of the claims were found to be consistent with the labelling
conditions in CoPoNC. Findings from the 2005 FSANZ Label Monitoring Survey (FSANZ
2007), suggested an increase in the use of nutrition content claims about dietary fibre on
labels compared with that reported in the 2003 survey. Of the 746 labels sampled in Australia
in 2005, 244 labels carried 369 claims that were covered by CoPoNC. Eighty-six per cent of
the claims were found to be consistent with the labelling conditions in CoPoNC. Of the claims
that were inconsistent with CoPoNC (n=51), 80% were due to dietary fibre claims not
meeting either source or good source criteria. Current compliance with claim conditions in
CoPoNC by food businesses is not known. In addition there are no data available on the
compliance with CoPoNC in New Zealand.
2.3
Amount of dietary fibre in food
In the 2008–09 National Nutrition Survey, the main sources of dietary fibre in the diets of
New Zealanders (aged 15 years and over) were reported to be (in decreasing amounts)
breads, vegetables, potatoes, kumara and taro, fruits, grains and pasta, breakfast cereals
and bread-based dishes (University of Otago and Ministry of Health, 2011). Similarly in
Australia, breads, vegetables, fruits, potatoes, cereal-based foods and breakfast cereals,
were the main sources of dietary fibre reported in the 1995 National Nutrition Survey
(Australian Bureau of Statistics 1998).
Attachment 1 shows typical levels of dietary fibre in a range of foods. Note that not all foods
eligible to carry voluntary nutrition content claims about dietary fibre do so, hence the need to
collate information on foods currently carrying nutrition content claims about dietary fibre
from food businesses as part of this consultation.
2.4
Qualifying criteria for nutrition content claims about dietary
fibre in other jurisdictions
Table 3 compares the qualifying criteria for nutrition content claims about dietary fibre in
Standard 1.2.7 with international regulations and guidance.
6
Table 3: Qualifying criteria for dietary fibre in Standard 1.2.7, CoPoNC and international regulations and guidance
Descriptors for
dietary fibre
nutrition
content claims
Source
Good source or
high
Excellent
source or very
high
Standard 1.2.7
2013
CoPoNC
1995
Canada
2003
EU
2006
2 g per serving
(6.7% of reference
value (30g))
1.5 g per serving
2 g per reference
amount and
serving of stated
size2
3 g/100g or
1.5 g/100 kcal
4 g per serving
(13.3% of
reference value
(30g))
3 g per serving
4 g per reference
amount and
serving of stated
size
6 g/100g or
3 g/100 kcal
7 g per serving
(23.3% of
reference value
(30g))
6 g per serving
(‘high’ is used,
‘good’ is not
permitted)
6 g per reference
amount and
serving of stated
size
(‘very high’ is used,
‘excellent’ is not
permitted)
1
Not permitted
Codex
20091
USA
2008
3 g/100g or
1.5 g/100kcal or
10% of dietary
reference value
per serving3
6 g/100g or
3 g/100kcal
or
20% of dietary
reference value
per serving4
10-19% of Dietary
Reference Value
(25g) per
prescribed RACC4
(for good source,
contains or
provides claims)
Not permitted
20% of Dietary
Reference Value
(25g) per
prescribed RACC4
(for high, rich,
excellent claims)
Codex Alimentarius: Guidelines for use of nutrition and health claims (CAC/GL-1997). Countries may choose which approach to use.
For example, the reference amount for bread is 50g and the permitted serving size for bread ranges from 25 to 70g. This means that if the chosen serving size for bread was
40g and it carried a source claim, the bread would need to contain 2g dietary fibre per 40g bread. (reference amounts are at http://lawslois.justice.gc.ca/eng/regulations/C.R.C.,_c._870/page-368.html#h-371). Serving sizes are at http://www.inspection.gc.ca/english/fssa/labeti/guide/ch6e.shtml#tab6-3.
3 Serving size and dietary reference values to be determined at national level
4 RACC - Reference Amounts Customarily Consumed Per Eating Occasion (reference amounts are at
http://www.accessdata.fda.gov/scripts/cdrh/cfdocs/cfcfr/CFRSearch.cfm?fr=101.12). Reference amounts are used to determine whether a food meets the criteria for nutrient
content claims. If the serving size declared on the food label differs from the reference amount, and the food meets the criteria for the claim only on the basis of the reference
amount, the claim must be followed by a statement that states the basis on which the claim is made.
2
7
As indicated in Table 3, the way in which qualifying criteria are expressed differs among the
various jurisdictions. Examples are provided in Tables 4 and 5 to facilitate comparison. It is
clear that the qualifying criteria in Standard 1.2.7 are similar to those prescribed in Canada
and, for foods with a serving size of 67 g or higher, they are also similar to the EU criteria
and to the criteria in the Codex Guideline. The approach taken in the USA (same criteria
used for good source, contains or provides claims) differs from that taken in other
jurisdictions.
Table 4: Comparison of minimum amounts of dietary fibre (g per serving) required for
source and good source/high claims for bread*, across a number of jurisdictions
Descriptors
for dietary
fibre
nutrition
content
claims
Source
Good source
or high
Standard
1.2.7
2013
CoPoNC
1995
2 g per
serving
1.5 g per
serving
4 g per
serving
3 g per
serving
Canada
2003
2.8 g per serving
(reference amount
is 50g, permitted
serving size 2570g)
5.6 g per serving
(reference amount
is 50g, permitted
serving size 2570g)
EU
2006
Codex
2009
2.1 g
per
serving
2.1 g per
serving
or
3 g per
serving
4.2 g per
serving
or
6 g per
serving
4.2 g
per
serving
USA
2008
2.5 g per
50 g
RACC1
(Dietary
Reference
Value is
25 g dietary
fibre per
day)
*serving size 70g (typical serving size declared by manufacturers in Australia and New Zealand)
1 RACC - Reference Amounts Customarily Consumed Per Eating Occasion
Table 5: Comparison of minimum amounts of dietary fibre (g per serving) required for
source and good source/high claims for breakfast cereal*, across a number of
jurisdictions
Descriptors
for dietary
fibre
nutrition
content
claims
Source
Good source
or high
Standard
1.2.7
2013
CoPoNC
1995
2 g per
serving
1.5 g per
serving
4 g per
serving
3 g per
serving
Canada
2003
2 g per serving
(reference amount
is 30g, permitted
serving size 2045g)1
4 g per serving
(reference amount
is 30 g, permitted
serving size
20-45g)
EU
2006
Codex
2009
1.2 g
per
serving
1.2 g per
serving
or
3 g per
serving
2.4 g per
serving
or
6 g per
serving
2.4 g
per
serving
USA
2008
2.5 g per
30 g
RACC2,3
(Dietary
Reference
Value is
25 g dietary
fibre per
day)
*serving size 40g (typical serving size declared by manufacturers in Australia and New Zealand)
1 For ready-to-eat breakfast cereals, puffed and coated, flaked, extruded, without fruit or nuts (20 g to 42 g per
250 ml), very high fibre cereals (with 28 g or more dietary fibre per 100 g)
2 RACC - Reference Amounts Customarily Consumed Per Eating Occasion
3 For breakfast cereals, ready-to-eat weighing 20 g or more but less than 43 g per cup; high fibre cereals
containing 28 g or more of dietary fibre per 100 g
8
3
Questions for stakeholders
3.1
Industry data – impact of qualifying criteria in Standard 1.2.7
on foods carrying nutrition content claims about dietary fibre
A range of foods in the marketplace currently carry nutrition content claims about dietary fibre
such as breakfast cereals; breads; muesli bars; breakfast drinks; canned, chilled and frozen
vegetable products; fruit products; wholegrain rice and wholegrain pasta. FSANZ is seeking
information on the extent to which foods currently carrying nutrition content claims about
dietary fibre will no longer be able to continue carrying the same claims following the end of
the transition period for Standard 1.2.7 in January 2016. We would appreciate information on
the costs of changing labels and/or product formulations in order to meet the present
qualifying criteria in Standard 1.2.7 as well as information on any technical issues associated
with increasing the amount of dietary fibre in foods.
FSANZ is aware that some food businesses have made, or are in the process of making,
label and/or product changes in response to the qualifying criteria for nutrition content claims
about dietary fibre in Standard 1.2.7 and therefore FSANZ is interested in receiving
information on changes that have already been made.
PLEASE REFER TO ATTACHMENT 2 FOR A SUBMISSION TEMPLATE
Part A of template – For food industry
Question 1
What foods do you sell that currently carry nutrition content claims about dietary fibre (e.g.
claims such as source, good source, and excellent source of dietary fibre or synonyms of
these descriptors) and do not meet the relevant qualifying criteria in Standard 1.2.7? Please
provide the following information for these foods:

food name, dietary fibre claim on label, serving size, g dietary fibre per serving
Please also provide:


the number of foods and stock-keeping units (SKUs)11 currently carrying nutrition
content claims about dietary fibre that do not meet the qualifying criteria in Standard
1.2.7
the total number of foods and SKUs currently carrying nutrition content claims about
dietary fibre.
11
SKU - refers to a stock-keeping unit, a unique identifier for each distinct product that can be
purchased in business.
9
Question 2
If you were to change or remove nutrition content claims about dietary fibre on labels in
response to the present qualifying criteria in Standard 1.2.7 for any of the foods listed in
Question 1, what would be the cost of such label changes? Please provide the following
information:




number of SKUs affected for each type of packaging material used
direct cost of making a change (which could include cost of label design, label
production, proofing, package redesign, labour)
indirect cost of making a change (which could include label write-off and managerial
costs (including marketing and advertising))
marginal cost of label changes if such changes could be combined with any other label
changes during the transition period for Standard 1.2.7.
Question 3
If you were to reformulate any of the foods listed in Question 1 in order to meet the present
qualifying criteria in Standard 1.2.7, what would be the cost of such reformulation? Please
provide the following information:


the number of foods you might reformulate and the estimated total cost of reformulation
a description of any technical issues associated with increasing the amount of dietary
fibre in foods, with reference to any specific foods.
Question 4
Have you already made any changes to nutrition content claims about dietary fibre on
food labels in response to the qualifying criteria in Standard 1.2.7? If ‘yes’ please provide
the following information:

number of SKUs for which you have already made labelling changes and the cost of
making a change for each type of packaging material used.
Question 5
Have you already reformulated any foods in order to meet the present qualifying criteria in
Standard 1.2.7? If ‘yes’, please provide the following information:

the number of foods you have reformulated and the total cost of reformulation.
Question 6
What would be the commercial impact if the qualifying criteria for claims about dietary fibre in
Standard 1.2.7 were changed to the criteria in CoPoNC? Please provide detail.
10
3.2
Stakeholder views and evidence
It has been six years since stakeholders were asked to comment on the qualifying criteria for
nutrition content claims about dietary fibre (Proposal P293 Preliminary Final Assessment
Report 2007)12. FSANZ therefore invites comments from all stakeholders and encourages
submitters to provide documented evidence to support viewpoints. Several submitters to the
Preliminary Final Assessment Report suggested that increasing the qualifying criteria for
nutrition content claims about dietary fibre could cause consumer confusion as consumers
may believe that the dietary fibre content of certain foods had been reduced. FSANZ is keen
to hear if this issue is still of concern and whether there are any studies that have
investigated this issue.
Part B of template – For all stakeholders
Question 7
Do you think the qualifying criteria for nutrition content claims about dietary fibre in Standard
1.2.7 should be changed to the levels in CoPoNC? Please provide documented evidence to
support your view.
Question 8
Do you think consumers could be confused if nutrition content claims about dietary fibre that
currently comply with the qualifying criteria in CoPoNC are changed in response to the
qualifying criteria in Standard 1.2.7? If so, please provide any research studies that have
investigated the extent to which consumers understand the difference between foods
carrying different levels of dietary fibre claims, that is, source, good source, and excellent
source claims. Any information on changes in purchasing patterns in response to a change in
the labelling of a dietary fibre claim is also of interest.
4
Next steps
Following the close of the consultation period, FSANZ will collate and evaluate the
information provided by submitters. FSANZ appreciates that this current consultation process
raises some uncertainty for industry in relation to the qualifying criteria. With this in mind,
FSANZ will endeavour to resolve the issue as quickly as possible. Should FSANZ consider
there is merit in changing the qualifying criteria for nutrition content claims about dietary fibre
in Standard 1.2.7, a proposal will be prepared to assess this change and further public
consultation undertaken.
References
Australian Bureau of Statistics (1998) National Nutrition Survey. Nutrient Intakes and
Physical Measurements Australia 1995. Catalogue Number 4805.0
FSANZ (2005) On-going food label monitoring survey in Australia and New Zealand. Report
on the Re-assessment of 2003 Labels for Nutrition, Health and Related Claims (Phase 2,
Part C). Evaluation Report Series No. 14. Food Standards Australia New Zealand, Canberra,
ACT
12
P293 - Preliminary Final Assessment Report
11
FSANZ (2007) On-going food label monitoring survey in Australia and New Zealand. Report
on the Assessment of 2005 Labels for Nutrition, Health and Related Claims. Evaluation
Report Series No 16. Food Standards Australia New Zealand, Canberra, ACT
NUTTAB (2010) FSANZ Nutrient Tables.
http://www.foodstandards.gov.au/science/monitoringnutrients/nutrientables/nuttab/Pages
/NUTTAB-2010-electronic-database-files.aspx Accessed 10 July 2013
University of Otago and Ministry of Health (2011) A Focus on Nutrition: Key findings of
the 2008/09 New Zealand Adult Nutrition Survey. Wellington: Ministry of Health
Williams P, Yeatman H, Zakrzewski S, Aboozaid B, Henshaw S, Ingram K, Rankine A,
Walcott S. and Ghani F (2003) Nutrition and related claims used on packaged Australian
foods – implications for regulation. Asia Pacific J Clin Nutr, 12 (2): 138-150
Attachments
Attachment 1:
Attachment 2:
Amount of dietary fibre in selected foods
Submission template
12
Attachment 1
Attachment 1:
Amount of dietary fibre in selected foods
Table 1: Amount of dietary fibre in selected foods (NUTTAB, 2010)
Food
Bread
Bread, flat (pita or lebanese), white
Bread, flat (pita or lebanese), wholemeal
Bread, white, sandwich
Bread, white, toast
Bread, white, added fibre, sandwich
Bread, white, added fibre, toast
Bread, wholemeal, sandwich
Bread, wholemeal, toast
Bread, wholemeal, added fibre, sandwich
Bread, wholemeal, added fibre, toast
Bread, wholemeal, grains & seeds, toast
Bread roll, white
Bread roll, wholemeal
Bread, rye, dark
Bread, rye, light
Bread, mixed grain
Breakfast Cereals
Cereal, flaked corn
Cereal, mixed grain,
Cereal, mixed grain, fruit,
Cereal, oat bran
Cereal, wheat bran flakes
Cereal, bran flakes, sultana
Cereal, wheat biscuit
Cereal, wheat biscuit, bran
Cereal, whole wheat flakes
Cereal, wheat, puffed
Muesli, toasted, dried fruit & nut
Muesli, untoasted or natural style, unfortified
Oats, rolled, raw
Breakfast Drinks
Cereal, beverage, flavoured,
Muesli Bars
Bar, muesli, plain or with dried fruit
Bar, muesli, with added nuts
Bar, snack or breakfast, cereal & nut
Biscuits
Biscuit, savoury, rye flour, crispbread
Biscuit, savoury, white flour, plain snack cracker
style
Biscuit, savoury, wholemeal wheat flour, with
sesame
Biscuit, savoury, wholemeal wheat flour,
crispbread
Rice and Pasta
Rice, brown, raw
Pasta, white, with egg, dry
Pasta, wholemeal, dry
Typical serving
size (g unless
otherwise stated)
Dietary fibre (g)
per serving
70
75
60
74
60
74
60
74
60
74
80
60
79
79
70
83
2.1
4.5
1.7
2.1
3.3
4.1
3.8
4.7
4.4
5.4
5.3
1.9
4.5
5.6
3.6
4.0
30
40
40
50
40
50
35
35
40
30
120
100
50 (1/2 cup)
0.9
2.2
3.3
6.2
7.7
7.6
3.9
6.3
4.7
3.0
12.1
9.8
4.8
250ml
4.0
32
32
32
1.9
1.5
2.1
20
20
2.9
0.7
25
1.8
25
3.1
50 (1/4 cup)
40 (1/4 cup)
50 (1/4 cup)
1.6
1.0
5.9
13
Attachment 1
Table 1 continued: Amount of dietary fibre in selected foods (NUTTAB, 2010)
Food
Fruits and Vegetables
Apple, dried
Apple, royal gala, unpeeled, raw
Apricot, dried
Banana, cavendish, peeled, raw
Bean, broad, raw
Bean, green, raw
Beetroot, canned
Broccoli, fresh, raw
Brussels sprout, fresh, raw
Carrot, mature, peeled, raw
Potato, red skin, peeled, boiled
Sweetcorn, kernels, canned
Nuts and Legumes
Baked beans, canned in tomato sauce
Beans, mixed, canned, drained
Bean, red, kidney, canned
Nut, almond, with skin
Nut, cashew, raw
Nut, hazelnut, raw
Nut, peanut, without skin, roasted, with oil, salted
Nut, walnut, raw
Typical serving
size (g unless
otherwise stated)
Dietary fibre (g)
per serving
25
140
35
100
50
50
80
50
50
50
80
50
2.3
2.9
2.9
2.4
3.6
1.6
3.1
1.8
2.4
2.0
1.9
1.8
200
60
60
20
20
20
20
20
10.4
3.7
3.9
1.8
1.2
2.1
1.2
1.3
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Attachment 2
Attachment 2:
Submission template
To assist us in compiling submissions, please complete the tables below.
Submitter name:
Part A - Questions for food industry
Table 1 (response to Question 1): Foods carrying nutrition content claims about dietary fibre that do not meet the relevant qualifying criteria in
Standard 1.2.7 (please add more rows as required)
Food
Dietary Fibre claim on label
Serving size (g)
g dietary fibre per serving
Table 2 (response to Question 1): Number of foods (and SKUs) carrying nutrition content claims about dietary fibre that do not meet the
relevant qualifying criteria in Standard 1.2.7 and total number of foods (and SKUs) carrying nutrition content claims about dietary fibre
Number of foods
SKUs
Item
(as of July 2013)
(as of July 2013)
A. Foods carrying nutrition content
claims about dietary fibre that do
not meet the relevant qualifying
criteria in Standard 1.2.7
B. All foods carrying nutrition
content claims about dietary
fibre
Percentage (A/B X 100)
15
Attachment 2
Table 3 (response to Question 2): Cost of future labelling changes in response to qualifying criteria for nutrition content claims about
dietary fibre in Standard 1.2.7
Flexible
Item
Pouch/bag
Packaging material
Plastic
Fibre
Liquid
paperboard
carton
Corrugated
carton
Folding
carton
Tub
Number of SKUs that
will need the label to
be changed (for each
type of packaging
material)
Direct cost of making
a label change1
Indirect cost of making
a label change2
Can the labelling
changes be made at
the same time as other
labelling changes
during the transition
period for Standard
1.2.7? Indicate YES or
NO for each type of
packaging material
If YES for above item,
what would the
marginal cost be for
making the change to
nutrition content
claims about dietary
fibre (in addition to the
cost of the other label
changes)?
1
Direct costs could include cost of label design, label production, proofing, package redesign, labour
costs could include label write-off and managerial costs (including marketing and advertising)
2 Indirect
16
Bottle
Metal
Jar
Aluminium
can
Glass
Steel
can
Jar
Bottle
Attachment 2
Table 4 (Response to Question 3):
Item
Number of foods you might
reformulate (from those listed in
Table 1)
Estimated total cost of
reformulation
Describe any technical issues
associated with increasing the
amount of dietary fibre in foods,
with reference to any specific foods.
Response
$
17
Attachment 2
Table 5 (response to Question 4): Cost of labelling changes already incurred in response to meeting the qualifying criteria for nutrition
content claims about dietary fibre in Standard 1.2.7
Flexible
Packaging material
Plastic
Fibre
Item
Pouch/bag
Liquid
paperboard
carton
Corrugated
carton
Folding
carton
Tub
Number of SKUs for
which you have
already made labelling
changes (for each type
of packaging material)
Direct cost of making
a label change1
Indirect cost of making
a label change2
1
Direct costs could include cost of label design, label production, proofing, package redesign, labour
costs could include label write-off and managerial costs (including marketing and advertising)
2 Indirect
Table 6 (Response to Question 5)
Item
Have you already reformulated any
foods in order to meet the present
qualifying criteria in Standard 1.2.7
(YES/NO)
If ‘YES’, please provide the number
of foods you have reformulated
If ‘YES’, please provide the total
cost of reformulation
Response
$
18
Bottle
Metal
Jar
Aluminium
can
Glass
Steel
can
Jar
Bottle
Attachment 2
Table 7 (Response to Question 6)
Item
Response
What would be the commercial
impact if the qualifying criteria for
claims about dietary fibre in
Standard 1.2.7 were changed to the
criteria in CoPoNC? Please provide
detail.
19
Attachment 2
Part B – Questions for all stakeholders
Table 8 (Response to Question 7)
Item
Response
Do you think the qualifying criteria
for nutrition content claims about
dietary fibre in Standard 1.2.7
should be changed to the levels in
the CoPoNC? (YES/NO)
Please provide documented
evidence to support your view.
20
Attachment 2
Table 9 (Response to Question 8)
Item
Response
Do you think consumers could be
confused if nutrition content claims
about dietary fibre that currently
comply with the qualifying criteria in
CoPoNC are changed in response
to the qualifying criteria in Standard
1.2.7? (YES/NO)
If YES, please provide any
research studies that have
investigated the extent to which
consumers understand the
difference between foods carrying
different levels of dietary fibre
claims, that is, source, good
source, and excellent source
claims.
Any information on changes in
purchasing patterns in response to
a change in the labelling of a
dietary fibre claim is also of interest.
21