Food Labelling Law and Policy Review
Clauses of particular interest:
Q28 – Food Advertising
Association of New Zealand
Advertisers Inc (ANZA)
13th May 2010
1. This submission is in response to the Issues Consultation Paper: Food Labelling
Law and Policy Review and addresses in particular Q28 concerning the degree to
which the Foods Standards Code should address food advertising.
2. ANZA does not believe that it is the role of a Food Standards Code to regulate
advertising to any greater extent than presently contained in the Code.
3. ANZA supports continuance of the ASA as the body responsible for the Codes
and Complaints system for food advertising in New Zealand.
The Association of New Zealand Advertisers (ANZA) was formed in 1931 and in
2010 represents approximately 100 leading advertiser companies and organisations
in New Zealand.
Members interests cover most influential industry sectors including, Food and
Beverages, Liquor, Therapeutic/Pharmaceutical Products and Services, Finance and
Banking, Motor Vehicles, Oil Companies, Personal Care, Toys and Non-Government
Food members include most of the major suppliers/advertisers of food and
beverages in New Zealand. Many ANZA Food members are also members of either
the New Zealand Food & Grocery Council (FGC) and/or the Australian Food and
Grocery Council AFGC).
ANZA has been a member of the Advertising Standards Authority since its inception
and two ANZA representatives are included on the eight person Board of Directors.
ANZA’s mission is three-fold:
To promote the development, promotion and advocacy of advertising and
marketing for the benefit of New Zealand.
To promote and advocate for an industry environment of free and legitimate
commercial communication guided by industry self regulation.
Promote commercial transparency with all media, communications agencies
and other support consultancies.
Q28 - To what degree should the Food Standards Code address food
Advertising is self-regulated in Australia and New Zealand through the Advertising
Standards Bureau (ASB) in Australia and the Advertising Standards Authority (ASA)
in New Zealand. Both organisations have been independently audited and rank
highly in meeting best practice advertising self-regulation.
In addition to the ASB and ASA Codes the ACCC and Commerce Commission
ensure advertising is not misleading.
Both the ASB and the ASA have codes dealing specifically with the advertising of
food. In New Zealand, all advertisements for food and beverages consumed by
humans are required to adhere to the principles and guidelines of the Code for
Advertising of Food (2006) as well as the Advertising Code of Ethics and, where
relevant, the Code for Advertising to Children (2006).
Following an extensive public consultation process, the ASA will release in June
2010, revised codes for both Advertising of Food and Advertising to Children. At the
same time a new code, the Code for Advertising of Food to Children will be
The continued developments of Food Advertising Codes under the leadership of the
ASA demonstrate industry’s ongoing commitment to effective self-regulation. ANZA
believes that the ASA remains the best vehicle for ensuring responsible food
The current Food Standard requires advertising to follow the prohibitions outlined in
the Food Standards Code. The Food Codes of both the ASB and ASA make specific
reference to the FSANZ Food Standards Code and require adherence. ANZA does
not believe that it is the role of a Food Standards Code to regulate advertising
to any greater extent than presently contained in the Code. In other words, if
claims are permitted on food labels then the claim should be permitted in food
advertising under the auspices of the ASA codes. By the same token, claims which
are not permitted on food labels (by the Food Standards Code) should not be
permitted in advertising.
General Manager - Commercial