Submission on Review of Food Labelling Law and Policy
It is essential that members of the public are able to make informed choices when selecting the foods they will buy. This requires that sufficient basic information with regard to nutrition and health be included on the label of foods. Most shoppers are unlikely to look beyond this. There is the possibility however of access to a secondary source of additional information via a bar code reader, regulated web site or official phone number.
The aspects of food labelling law that I am particularly concerned about are listed below as 1-4. Items nos. 5 – 7 I consider of less importance.;
1 . Indication of the country of origin of food .
The current system is too vague and suggests foods are Australian in origin whereas they may only be partly processed and/or packaged here. The current definitions seem designed to confuse rather than inform the consumer. New, honest definitions are required with sufficient categories to cover the range from 100% Australian grown, manufactured and packaged to 100% imported. It might require a number code such as
“50% Made in Australia”.
Information on the origin of foods is important to enable shoppers to support local producers. It also gives an indication of food miles and enables shoppers to avoid purchasers from countries with poor records regarding the environment or human rights.
2. Food Content
2a) Genetically Modified (GM) foods.
The current requirements for the labelling of GM and GM derived foods are inadequate.
The labelling requirements under the Food Standards Code need to be altered so that food derived from a GM source, such as canola oil, or from animals fed on GM crops, should be required to have this information listed on the label.
There should be at least two categories for labelling of GM foods, one for those that contain artificially modified DNA or protein and another for those sourced from GM crops or animals Examples would be vegetable or fish oils, meat and eggs.
The large agricultural companies who market GM crops should not have the power to veto research. Such a veto throws into question the results derived from such research regarding the safety of GM foods for human consumption. It means that labelling information derived from such sources is of questionable value.
2B) Foods Containing Nano-sized Particles (Nano foods ).

Labelling of Nano foods is at least as much a concern as the labelling of GM foods. The properties of nano-sized particles can not be assumed to be the same as those of the bulk materials. The properties resulting from the enormous increase in the surface area to volume/weight ratio of these tiny particles means a major and frequently unknown change in both their physical and chemical properties with consequent potential for harm to humans and other animals. The tiny size of these particles means they are able to enter areas of the body not previously accessible. It should be mandatory to carry out safety testing on nano materials as though they were new chemicals. There should also be a requirement for testing to be done over extended periods of time as some of the effects of nano materials may not be immediately obvious.
Packaging or food handling that involves nano materials (eg use of equipment treated with nano-scale antibacterial or other materials) should also be listed on food labels.
Protection of human health is of more importance than the possible inhibition of the development of new technology.
3.Administering and enforcing food labeling.
Manufacturers’ preferences should not be put before the rights of the consumer to readily access information regarding the foods they purchase. If manufacturers in the US can list
GM ingredients on their food packaging there seems no reasonable excuse for Australian and New Zealand Manufacturers not to do the same.
Regulations concerning food labelling should be enforceable, otherwise they afford little protection for consumers.
4. Need to define terms used.
It should be possible for the consumer to have confidence in interpreting words such as
“organic” and “natural” or “low salt”. This is not presently the case.
These definitions should be included in the Food standards code.
5. Nutrition panels
A single table giving quantity per 100 gm is sufficient and would free up space for other information. It could include an indication of an average serve e.g. 200g, without a second table as this seems redundant information and a poor use of space.
6. Restaurants

Restaurants do not need to display food labelling on menus as this would render them quite impractically large. Information should be available from staff if requested. A note to the effect that e.g. gluten free or low salt options were available could be included on the menu.
7. Wine
Wine does not need the same amount of information as other food substances e.g. nutrition panel. Alcohol content and additives such as sulphur dioxide should be required to be listed. GM and nano information should also be included.