Q1. To what extent should the food regulatory system be used to meet broader
public health objectives?
Food labels are an ideal medium to convey healthy eating messages at the point of
decision. While recognising there is a need to ensure adequate space is allocated to
depicting priority information (Eg allergen alerts), it is potentially an important
strategy in supporting public health messages. Meeting these objectives however,
should not be dependent on food regulations.
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)?
Adequate information needs to include all key safety aspects, such as use by or best
before dates; storage instructions, allergen alerts, as well as ingredients (noting GM
foods) & nutrient information panel & country of origin. Also a point of contact for
more information – this should not just be a web address as not everyone has easy
access to the internet.
Q3. How can accurate and consistent labelling be ensured?
This is difficult, but without accuracy & consistency the labels are of little value. Food
manufacturers need to take responsibility for undertaking this, with significant
disincentives for those that do not (Eg fines, being publicly identified). If there was
more of a trend back to unprocessed foods, this burden would not be so great for
manufacturers and consumers.
Raising public awareness (advertising campaigns) will ensure consumer
demand/pressure on manufacturers.
Q4. What principles should guide decisions about government intervention on
food labelling?
There should be some mandatory minimum requirements to address the key factors
as noted in Answer 2, as well as incentives (Eg public recognition) for undertaking
voluntary codes of practice that benefit the consumer.
Q5. What criteria should determine the appropriate tools for intervention?
Needs to be factual.
Q6. Is this a satisfactory spectrum for labelling requirements?
Fast food outlets should have nutrient information panels available for all products.
Restaurants & other food outlets should have ingredient lists for all menu items – list
should be available on request, not necessarily have to be on menu.
Q7. In what ways could these misunderstandings and disagreements be
overcome?
By providing clear guidelines about the minimum requirements. These may need to
be tailored for individual food categories.
Use local resources to educate – eg Shire Environmental Health Officers during their
usual inspections.
Q8. In what ways can food labelling be used to support health promotion
initiatives?
“Health claims” should be limited to the facts. Eg good source of calcium or fibre –
with different categories of food having defined criteria for key nutrients, including
sodium, fat, saturated fat, carbohydrates and added sugars. Eg good source of fibre
for breakfast cereal – more than 3 grams per serve.
Ideally standard serve sizes would also be addressed to reinforce appropriate serve
sizes.
Back the information up with media campaign – women’s/men’s magazines etc.
Source of info should be very clearly identified so it can be recognised as reliable (ie
NH&MRC / FSANZ etc).
Q9. In what ways can disclosure of ingredients be improved?
Ensure consistency in the way the information is provided and have some public
awareness campaigns that will inform consumers about how to read the revised food
labels. This could fit with a broader health promotion strategy and supported by key
agencies such at the Cancer Council or Heart Foundation.
Q10. To what extent should health claims that can be objectively supported by
evidence be permitted?
Health claims should be restricted to foods that are “healthy” (ie meet specific criteria
for key nutrients as described in the answer to question 8). For example, it would not
be reasonable to label chocolate as a recommended source of calcium for healthy
bones, given its sugar and fat content.
Health claims could be used in conjunction with traffic light labelling so that
consumers could also determine the nutritional quality of the food in terms of fat,
saturated fat, sodium, added sugars and fibre.
Q11. What are the practical implications and consequences of aligning the
regulations relating to health claims on foods and complementary medicine
products?
Ideally the review will result in consistency of the labelling requirements of food and
complementary medicine products to simplify this for the consumer.
However, the TGA needs to have more say in what sort of evidence is required
before a complementary medicine can be put on market. Unless this happens, can’t
align food labelling requirements with complementary medicines.
Q12. Should specific health warnings (e.g., high level of sodium or saturated fat
per serve) and related health consequences be required?
This issue may be overcome with the suggestions offered in the answer to question
10.
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?
Ideally food labelling requirements will be such that they support a
responsible and sustainable food supply. The difficulties of limited space for
labelling as well as the issue of verifying the information is acknowledged.
Consumers often worried about insecticide residues etc, so it might be useful to have
this information on this on label (eg. “meets Aust standards for residues levels…. Or
meets Aust standard number xyz).)
Q14. What criteria should be used to determine the inclusion of specific types of
information?
Criteria should be guided by the key aspects of evidence based nutrition information,
environmental sustainability and ethical values.
Q15. What criteria should determine which, if any, foods are required to have
country of origin labelling?
Ideally all products should have country of origin requirements.
Q16. How can confusion over this terminology in relation to food be resolved?
Consistency of the terminology, combined with public awareness strategies.
Imported goods required to follow Aust labelling language/terminology.
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 there is a need to define these terms, and have them referenced in the Food
Standards Code. As well as providing information on how to find where they are
referenced. Media campaigns on what the words mean. Education in schools on
labelling.
Food labelling info should be part of school curriculum Aust wide (this comment
could go with several of the questions on this survey)
Q18. What criteria should be used to determine the legitimacy of such
information claims for the food label?
Determine some criteria that would be relevant for key aspects of food production.
Eg sustainable practice, ethical treatment of animals and staff.
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?
Not sure
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?
Alcohol should be regulated as food. Particularly as it can have such a large
impact on a person’s energy intake. It is also valuable to have the standard drinks
information to assist consumers that drink, to do so in a safe manner.
Q21. Should minimum font sizes be specified for all wording?
Yes, this is particularly important for the aging Australian population.
Q22. Are there ways of objectively testing legibility and readability? To what
extent should objective testing be required?
Not sure
Q23. How best can the information on food labels be arranged to balance the
presentation of a range of information while minimising information
overload?
Use the traffic light system for key nutrients. Minimal words, symbols instead – as in
traffic light.
Q24. In what ways can consumers be best informed to maximise their
understanding of the terms and figures used on food labels?
Use traffic lights as pictorial and generally well understood. Use other symbols to
recognise other relevant factors eg sustainability, country of origin etc. Use clear and
simple text for important information, eg allergens, use-by / best before dates.
Q25. What is an appropriate role for government in relation to use of pictorial
icons on food labels?
Use “endorsed” icons and promote these as well as restricting / prohibiting the use of
potentially confusing similar looking symbols.
Have signage at prominent places in the supermarket aisles to explain the symbols.
Also, have reading food labels as part of school curriculum.
Q26. What objectives should inform decisions relevant to the format of front-ofpack labelling?
To provide relevant information.
To be easily read.
Q27. What is the case for food label information to be provided on foods
prepared and consumed in commercial (e.g., restaurants, take away shops)
or institutional (schools, pre-schools, worksites) premises? If there is a
case, what information would be considered essential?
Fast food chains should have nutritional information displayed for all menu items.
Other take away shops, restaurants and institutions should have details of potential
allergenic ingredients available on request.
Q28. To what degree should the Food Standards Code address food
advertising?
It would seem that to ensure the integrity of food lables, that the food standards code
would need to address food advertising – to a high degree.
Q29. In what ways can consistency across Australia and New Zealand in the
interpretation and administration of food labelling standards be improved?
Not sure
Q30. In what ways can consistency, especially within Australia, in the
enforcement of food labelling standards be improved?
Not sure
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?
Not sure
Q32. If such an approach was adopted, what are the strengths and weaknesses
of such a national authority being an existing agency; or a specific food
labelling agency; or a specific unit within an existing agency?
It is logical to use an existing agency & expand their role – less expensive,
less complicated, existing experts, already recognised & understood by
community.
Q33. If such an approach was adopted, what are appropriate mechanisms to
deal with the constitutional limits to the Commonwealth’s powers?
Not sure
Q34. What are the advantages and disadvantages of retaining governments’
primary responsibility for administering food labelling regulations?
One major advantage should be impartiality – the Government is generally
recognised by community for impartiality.
Q35.
If a move to either: self regulation by industry of labelling requirements; or
co-regulation involving industry, government and consumers were to be considered,
how would such an arrangement work and what issues would need to be
addressed?
Not sure
Q36. In what ways does such split or shared responsibility strengthen or weaken
the interpretation and enforcement of food labelling requirements?
Need to have clearly defined roles and responsibilities to ensure all necessary
functions are allocated.
Q37. What are the strengths and limitations of the current processes that define a
product as a food or a complementary medicine?
Not sure
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 strength would be that there would be a minimum standard to which all had to
comply. It also helps importers to understand what Australia is looking for.
Q39. Should food imported through New Zealand be subject to the same AQIS
inspection requirements?
Yes