Q1. To what extent should the food regulatory system be used to meet
broader public health objectives?
The prime objective should remain ‘ protection of health and safety of
consumers.’
It is a vital plank in achieving public health objectives.
It also needs to provide adequate information uninfluenced by food corporations.
For this reason it needs to be either audited regularly or come under some form
of regulation so that political or economic drivers do not influence decisions on
labelling and the information available.
To a growing number of people what happens to their food represents a health
hazard so they have a right to know.
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)?
Consumers have a right to know exactly what ingredients are in processed food :
has this food been irradiated, contains nano technology, been grown from GM
seeds or produced using a GM process,contains salt or sugar above a
recommended level , contains trans fats.
These are key issues in the mind of consumers and they have a right to be able
to buy uncontaminated food. If the above is present in food it should be labelled
to inform consumers who have made it clear these are issues they are
concerned about.
As well country of origin should be clear on processed and fresh food.
Fresh food should have on the shelf label, what has happened to the food. Eg
carrots are washed in a strong chlorine solution, onions are sprayed to stop
sprouting, apples are sprayed to lengthen shelf life.
Consumers have a right to know so that they can avoid these additives and
processes
This information needs to be on the label using standard abbreciattions where
needed. Numbers should only be used to back up the word. Numbers on their
own do not provide sufficient information.
Booklets should be available for free in supermarket aisles detailing what
information means. As well this info should be on the internet.
Q3. How can accurate and consistent labelling be ensured?
Terms need clear definitions. Apparently the term public health and safety have
not been defined in the FSANZ Act.
Organic, for instance, requires certification before this term is meaningful.
This needs to be the case for other positive labels like for instance ‘free range’ At
present people are being conned because there is no certification required to use
this term.
Loopholes need to be withdrawn. At present ingredients grown using GM
ingredients can be included without labelling if they have been processed e.g.
GM oil, corn syrup, lecithin.
Consumers want to know the exact level of GM contamination. They have a right
to know so they can avoid these foods if they so choose. That commercial
imperatives have interfered with the open labelling of all GM ingredients and
processes is wrong.
All information can be clarified in further detail in the information booklet
mentioned earlier and on the internet.
Q4. What principles should guide decisions about government intervention
on food labelling?
The primary principle should remain ‘public health and safety’ followed by
the consumers right to know.
Misleading and deceptive conduct is unlawful so this should also be a
priority.
Where there is debate over the safety of certain foods the precautionary
principle should be paramount.
Q5. What criteria should determine the appropriate tools for intervention?
Could ingredients, additives, processes be a health and safety hazard?
There are a number of ingredients and processes which should not even be
in our food, but where there is any debate the right to know must be
paramount.
Scientific findings provided they are from truly independent sources.
As well where there is significant public disquiet there should be labelling
and it be the consumers right to make the decision whether to buy based on
having full knowledge of the ingredients in a product.
Q6. Is this a satisfactory spectrum for labelling requirements?
Q7. In what ways could these misunderstandings and disagreements be
overcome?
Firstly by making the criteria for decision making absolute.
Public health and safety
Consumers right to know
Weeding out deceptive and misleading claims.
Then if the terms are clearly defined by an independent source most argument
should be overcome.
Q8. In what ways can food labelling be used to support health promotion
initiatives?
Food labelling should not be used to promote health promotion initiatives. If food
is clearly labelled people can then make up their own minds.
More emphasis should be on keeping questionable processes and ingredients
out of our food until they are independently assessed as safe. e
Q9. In what ways can disclosure of ingredients be improved?
By clear cut definitions of terminology, numbers only used in conjunction
with abbreviated terms.
Booklets being readily available clarifying terminology and other aspects.
Q10. To what extent should health claims that can be objectively supported
by evidence be permitted?
Health claims that are well documented by evidence could be included as
part of the manufacturers use of their part of the label after all labelling
requirements are met.
Q11. What are the practical implications and consequences of aligning the
regulations relating to health claims on foods and complementary medicine
products?
Q12. Should specific health warnings (e.g., high level of sodium or saturated
fat per serve) and related health consequences be required?
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?
Where there is significant consumer disquiet and request for labelling this
should be done because it is the consumers right to know. Not the
manufacturers right to keep information hidden.
Q14. What criteria should be used to determine the inclusion of specific
types of information?
Q15. What criteria should determine which, if any, foods are required to
have country of origin labelling?
Q16. How can confusion over this terminology in relation to food be
resolved?
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?
Yes
‘Organic’ requires certification to be credible. Information on this could be in the
booklet.
GM derived foods should be clearly labellied. This does not require definitions. If
it’s source is GM seed or process this is sufficient. Same with irradiation and
nanotechnology.
All other terms if not defined/ or requiring certification by the industry, this needs
to be established so consumers understand lwhat all terms mean.
Q18. What criteria should be used to determine the legitimacy of such
information claims for the food label?
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?
Q20. Should alcohol products be regulated as a food? If so, should alcohol
products have the same labelling requirements as other foods (i.e., nutrition
panels and list of ingredients)? If not, how should alcohol products be
regulated?
Q21. Should minimum font sizes be specified for all wording?
Q22. Are there ways of objectively testing legibility and readability? To what
extent should objective testing be required?