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					Q1. To what extent should the food regulatory system be used to meet broader public
    health objectives?

The food regulatory system can help to achieve broader public health objectives, for example:
assist consumers to make informed food choices through the provision of relevant nutrition
and health-related information and claims. However the extent to which a food regulatory
system can achieve this is limited. Therefore the role of the food regulatory system should be
to support the Government‟s broader health strategy.

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

Adequate information is enough information for a consumer to make an informed decision,
there for AECL recommends that not only the „bad‟ nutrients are on front of pack labelling,
as recommended in the traffic light labelling system, but also the beneficial vitamins and
minerals to give a more balanced picture. This information should be presented as % of RDI
rather than a simplistic traffic light system. In addition to front of pack, the full Nutrition
information panel (NIP) with full explanation should be available on the product‟s website. In
the case of Australian eggs, all nutritional information is available on
which also hosts a series of positioning statements about egg consumption and various
chronic diseases, life stages and other conditions to ensure consumers have as clear an
understanding about eggs as possible.
AECL believes that all products, irrespective of being whole foods or packaged foods, should
have a similar level of transparency on their website.
Further to on-pack and online, AECL also invests a large part of its budget in education,
AECL‟s market education pillar focuses greatly on the education of three audiences:
             1)      Healthcare professionals through direct mail, conferences and
                     advertorials in Medical Observer, Australian Doctor and relevant
             2)      Main grocery buyers through online, Infomed and an integrated Public
                     relations campaign
             3)      Students; AECL will launch an incursion program in the coming 6
                     months which will aim at educating primary school aged students on the
                     nutritional aspects of eggs as well as its different production methods.
AECL believes that being proactive in creating greater consumer understanding of nutrition
as well as farming methods is imperative to a healthy and flourishing Australian population.

Q3. How can accurate and consistent labelling be ensured?

AECL believes that accurate and consistent labelling should be monitored firstly by self
regulation and this should be supported by government initiatives and incentives. Within the
Australian egg industry, the accurate and consistent labelling is ensured by an independently
audited Quality Assurance Program administered and monitored by AECL. This QA Program
ensures transparency in the industry, truth in labelling and strict quality guidelines (food
safety). For more information about the program, please refer to

Q4. What principles should guide decisions about government intervention on food
AECL believes that the principles which should guide government intervention should
    1)   protect the health and safety of the Australian public and to prevent product
         misrepresentation and fraud;
    2)   promote an informed food choice, by providing consumers with reliable and
         comparable information, that reflects current food technology and nutrition
         recommendations and that can be easily understood;
    3)   support marketplace equity and fair competition
    4)   respect obligations under international and federal trade agreements
    5)   do not entail costs of implementation that outweigh the benefits to society

Q5. What criteria should determine the appropriate tools for intervention?

The criteria that should determine the tools for intervention include:
   1)     risk to the general public – food safety or illness wise
   2)     cost of implementation versus benefits to society
   3)     graveness of the mislabelling and the impact of mislabelling

Q6. Is this a satisfactory spectrum for labelling requirements?

AECL would also recommend that the labelling should be extended to include menus at
restaurants, especially in regards to terms such as “Wagyu Beef” and “organic/free-range

Q7. In what ways could these misunderstandings and disagreements be overcome?

There should be a uniform guideline for all fresh produce, including eggs, meat, diary and
fruit and vegetables in regards to:
    1)      Pack date
    2)      Use by date
    3)      Correct storage (at home, wholesale or back of store/restaurant)
    4)      Batch number for transparency and traceability

Q8. In what ways can food labelling be used to support health promotion initiatives?

As described in “review and analysis of current literature on consumer understanding of
nutrition and health claims made on food” by EdComs in April 2007; the key learning from
the findings above is that claims need to be in simple, non-technical language in order for the
majority of consumers to understand what they mean. Most studies show that consumers
prefer, and are better at, using adjectival or visual information than numerical information.
(Synovate, 2005). Therefore AECL recommends the government to set one standard for the
provision of health promotion initiatives on-pack which is in line with the research outcomes
of the study mentioned above.

Q9. In what ways can disclosure of ingredients be improved?
Q10. To what extent should health claims that can be objectively supported by evidence
     be permitted?

Health claims that (1) support the Australian dietary guideline recommendations; and (2) can
be objectively supported by evidence-based research should be permitted. The quality of
evidence should be based on reasonably convincing data through peer review research that is

To be effective, the wording of health claims needs to be:
     Free of technical jargon
     Simple, clear and easy to understand by all consumers
     Adaptable to suit a wide range of products on which they are used.

Q11. What are the practical implications and consequences of aligning the regulations
     relating to health claims on foods and complementary medicine products?

The regulations must provide a clear distinction between food and complementary medicine
products including definitions and criteria as to what differentiates a food from a
complementary medicine.

Q12. Should specific health warnings (e.g., high level of sodium or saturated fat per
     serve) and related health consequences be required?

AECL does not support specific health warnings and related health consequences on
food labels. AECL recommends specific health warnings are not required as consumer
health depends on the total dietary pattern, not individual foods. Levels of individual
nutrients are available on the Nutrition Information Panel meaning consumers can select
foods according to their specific health needs. Health warnings across all foods based on
nutrient profiles could result in consumers avoiding otherwise nutritious foods, placing
them „at risk‟ of specific nutrient deficiencies.

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?

Please refer to separate submission, joint submission by MLA, HAL, Dairy and MLA.

Q14. What criteria should be used to determine the inclusion of specific types of

Please refer to separate submission, joint submission by MLA, HAL, Dairy and MLA.
Q15. What criteria should determine which, if any, foods are required to have country of
      origin labelling?
All packaged food product should display the country of origin / country of production

Q16. How can confusion over this terminology in relation to food be resolved?

By standardising and communicating the terminology and definitions to be used as being
„Product of Australia / Produced in Australia‟.

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?

For the egg industry this is regulated under its national QA program which defines the terms
such as free-range, cage, barn and cage free production systems, for more information please
see therefore AECL recommends the Food Standards Code
to adopt the same definitions.

Q18. What criteria should be used to determine the legitimacy of such information
      claims for the food label?
For the Australian egg industry, its independently audited egg QA program should be
considered to determine the legitimacy of such claims.

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?

Only certain messages should have specified font size in order to promote legibility
and clarity of content such as production system, weight and mass.

Q22. Are there ways of objectively testing legibility and readability? To what extent
     should objective testing be required?

ABS or medical Stats on the average population would need to be applied.
Q23. How best can the information on food labels be arranged to balance the
     presentation of a range of information while minimising information overload?

Essential information such as the description of the food product, directions for use
and storage, nutrition information panel, allergens, mandatory warning and advisory
statements, ingredients and additives, use by or best by dates, lot/batch details,
weight, country of origin, manufacturers or importers contact details and consumer
hotline or website should be placed on the label.

Non-essential information should be made available on a voluntary basis by the
manufacturer/producer of the food.

Q24. In what ways can consumers be best informed to maximise their understanding of
     the terms and figures used on food labels?

Consumers can best be informed primarily through government education initiatives, for
example, along the lines of the Measure Up health initiative along with school education
initiatives. A food labeling system may support government initiatives in this area however
should not be primarily responsible for enhancing consumer understanding. Food industry
may support government initiatives via:

    Information on company websites, consumer brochures
    At point of purchase e.g. Supermarkets
    Designs on food labels e.g. optional use of pictorial icons to accompany nutritional
       messages to communicate with consumers

Q25. What is an appropriate role for government in relation to use of pictorial icons on
     food labels?

The Government can play a role in developing criteria for organisations to meet
which are suitable to develop pictorial icons. AECL believes organisations should
meet certain criteria to be certified to develop and market pictorial icons for use on
food labels.
Q26. What objectives should inform decisions relevant to the format of front-of-pack

AECL agrees with the conclusions reached in the National heart foundation research
carried out in regards to FOPL:
The conclusion from this research is that no single labelling scheme under consideration is
the solution to the complex challenge of helping Australians make healthier food choices.
Each has merits and limitations. The best labelling scheme for Australians is not one they
prefer but one that drives them consistently to make healthier choices.
There is no doubt that having nutrition information on the front of pack makes nutrition top-
of-mind. It must therefore help those trying to do the right thing and make a healthier choice.
A truly effective labelling scheme must work across the vast majority of food categories and
all demographics. Given that over one third of the average food budget is now spent eating
out, a labelling scheme that also addresses the eating out sector is essential. This sector
cannot be ignored when potential labelling solutions are being investigated to help combat
the obesity problem in Australia.
To guide the development of appropriate FOPL, the following research findings should be
taken into consideration:
     1)     The text has to be of a large enough font to comfortably read (EUFIC,2005)
     2)     Consumers fully appreciate the benefits of nutritious, healthy eating but feel the
            language used on food labels is complex and technical and somehow removed
            from eating which is, by contract immediate and simple. (EUFIC, 2005)
     3)     Studies from the UK and Europe have shown that use of colours to indicate „high‟
            or „low‟ levels of nutrients is well understood by consumers (Synovate, 2005b)

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?
     The information which should be available at food service includes:
   1) source of ingredients
   2) farming method used
   3) allergies identified (gluten, dairy, nuts, eggs etc)

Q28. To what degree should the Food Standards Code address food advertising?

AECL believes further clarification is required regarding the definition of „food
advertising‟ and the elements this covers. Significant advancement in technology means
information about brands can be shared in a variety of ways and it is currently unclear
how far the definition of advertising stretches and therefore whether the requirements of
the Food Standards Code apply. Further clarity is required in relation to information
directed at other audiences other than consumers, for example, information provided
about foods to health professionals is currently not considered „food advertising‟
however this may be interpreted differently by different organisations and food
marketers. Further clarity is also required regarding whether information provided about
unbranded foods constitutes food advertising or whether this is considered educational
Q29. In what ways can consistency across Australia and New Zealand in the
     interpretation and administration of food labelling standards be improved?
Standards need to be National Standards not driven by each individual State or Territory.

Q30. In what ways can consistency, especially within Australia, in the enforcement of
     food labelling standards be improved?

    Define the rules of labelling.
    Educate the rules of labelling.
    Regulators need to be given power to prosecute.

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?

The strength is consistency on a national basis in each country. It provides a unified
     management approach, rationalised resources such as administration and
     implementation vehicles such as enforcement.

     The AECL see‟s no weakness in taking this path.

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 should be a national agency which is transparent, has the required resources,
      expertise, knowledge and capability to manage the enforcement of all requirements
      as they relate to food labelling.

Q33. If such an approach was adopted, what are appropriate mechanisms to deal with the
     constitutional limits to the Commonwealth‟s powers?

Q34. What are the advantages and disadvantages of retaining governments‟ primary
     responsibility for administering food labelling regulations?
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?

AECL believes that in the case of the egg industry, self regulation would work well, the QA
program has been well accepted and over 80% of eggs produced within Australia follow the
labelling guidelines as set by this program. Government is unlikely to achieve the same rate
as adoption as an industry run body will.

Q36. In what ways does such split or shared responsibility strengthen or weaken the
     interpretation and enforcement of food labelling requirements?

 If the government or separate agency would be used in a form to back up/support the
existing QA program and could perhaps assist in dispute resolutions, it would be looked upon
favourable by the egg industry.

Q37. What are the strengths and limitations of the current processes that define a product
     as a food or a complementary medicine?

Q38. What are the strengths and weaknesses of having different approaches to the
     enforcement of food labelling standards for imported versus domestically produced

This does not effect the egg industry as no fresh hen eggs are imported into Australia.

Q39. Should food imported through New Zealand be subject to the same AQIS
     inspection requirements?

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