PRC Howe - Submission to Food Labelling Review Panel
Having contributed to the debate over food labelling policy in the last two decades since the formation of the National Food Authority, I am concerned to think that we may be going back once again to the drawing board and that the submissions and expert reports on the topic in which so many of us have invested valuable time will become redundant. I certainly hope that this is not the case and that the Panel will fully utilise pre-existing resources (as required in the Terms of Reference) to expedite its review. Many of the questions raised for this public consultation have already been addressed ad nauseam.
One of the Government’s stated primary drivers impacting on food labelling is the need to provide adequate information relating to food to enable consumers to make informed choices. Indeed, withholding such information could be considered as conflicting with another of its primary drivers, viz. the protection of public health and safety.
In the long gestation period since the release of P293: Nutrition, Health and Related Claims and the subsequent introduction of the pilot claim for folate, the public have been subjected to a free for all of information, ranging from reliable and informative to invalid and misleading, on health attributes of foods. While the rigour of the policy development process has fostered protracted academic debate, food producers continue to be denied a mechanism to convey new evidence-based information on the health attributes of their products and consumers suffer from inability to discriminate between reliable information and unsubstantiated claims.
Thus, in answer to Question 1, the food policy should no longer deny consumers information that may promote healthy eating. I trust that a priority for the Panel is to expedite the process.
The Terms of Reference apply ostensibly to food labelling. However, food labelling should not be considered in isolation from other forms of food advertising which are equal to if not more important than the label on the product in influencing consumer choices. Thus, when seeking opinions about minimum font sizes for food labels (Q21), equal attention should be given to media advertising strategies.
Q20 asks whether alcohol products should be regulated as a food. Whatever the basis for the existing distinction, the omission of energy content from labels on alcoholic drinks is unacceptable, especially considering that 4% of our daily energy intake is attributable to their alcohol content alone! (National Nutrition Survey 1995). How can we be serious about helping individuals to cope with an obesogenic environment without addressing this issue?
Q37 addresses the definition of a product as food or complementary medicine. Section 5.9 implies that a food or nutrient would be regulated under the Therapeutic Goods Act if it can be regarded as a complementary medicine. This seems inappropriate. Regulatory authorities elsewhere have treated products according to how they are presented or promoted. Hence if a bioactive food ingredient is presented in a functional food to promote good health, it should be considered as a food and regulated accordingly. However, if it is presented as either a food or a supplement for the treatment of an established health condition, then it should be considered as a therapeutic good. Numerous food ingredients are registered accordingly with the TGA. However, this should not prevent them from also being promoted and regulated, where appropriate, as foods. Hence the intended use should define the category.