Australian Food Industry Calls for a Single Front of Pack Labelling System

The Daily Intake Guide approach is the system preferred by the European Union, following a great deal of research into consumer understanding. This system was adapted for Australia, bringing it into line with Australian nutrition information panels, which will remain mandatory on all products.

25/03/09 The Australian Food and Grocery Council (AFGC) is calling on government to support a single front of pack labelling system that includes information about energy, fat, sugar, salt and serve sizes.

AFGC Chief Executive Kate Carnell said that there is already a front of pack labelling system in the market place that provides this information.

The Daily Intake Guide is on more than 1100 products and is used by major manufacturers and retailers including Woolworths, Coles, IGA, Franklins, ALDI and McDonalds. It is being progressively rolled out and will be on most products over the next two years.

The Daily Intake Guide approach is the system preferred by the European Union, following a great deal of research into consumer understanding. This system was adapted for Australia, bringing it into line with Australian nutrition information panels, which will remain mandatory on all products.

“It only makes sense that the government should adopt the system that is already being used by consumers everyday to make decisions on putting together a balanced diet,” Ms Carnell said. 

Two-thirds of people in a recent Newspoll survey of 1200 people said they found it easy to understand and more than one third reported using it to make purchasing decisions.

The AFGC strongly recommends that the final decision on front of pack labelling should be part of the overall review on labelling currently being conducted as part of the COAG initiatives. 

“It is essential that labelling be national, consistent and understood by the consumers. The purpose of the COAG initiative is to provide a holistic approach to labelling and avoid the problems that have been caused by piecemeal approaches to decision making in the past,” Ms Carnell said.

Effective front of pack labelling (FOPL) using an internationally established approach already operates in Australia and New Zealand in the form of the Daily Intake Guide (DIG) labelling scheme. One of a number of possible approaches considered by the food industry, the DIG labelling was assessed as well-suited to the needs of Australians being information based linking food product nutrients to consumers nutritional requirements. The DIG scheme, as ‘thumbnail’ icons, is now on over 1000 products in Australia and New Zealand and is used by almost 60 company/brands (manufacturers, retailers and quick service restaurants). It is supported by a website, community service announcements and a compliance program.

The AFGC is concerned that the Consultation Paper has failed to clearly describe this policy consultation for what it is – namely a debate about the merits of introducing traffic light labelling, or retaining the well established DIGscheme. Any mandated traffic light labelling scheme will need full regulatory justification. Definitive and convincing evidence will be required demonstrating that any change will lead to a substantially better system than the DIG scheme.

The AFGC has long advocated for clear policy guidelines on food labelling. Given the comprehensive Independent Review of Food Labelling to be undertaken in 2009, the current development of a policy guideline on FOPL is premature. To proceed risks misalignment of policies, misalignment of policy with regulation, and misalignment of policy with well established FOPL schemes, such as the ‘Heart Tick’ and the DIG scheme.

The AFGC supports policies and regulations which are evidence-based addressing well defined issues with clear objectives. Whilst there is agreement on the need to provide consumers with information there is no clear evidence regarding on how effective FOPL is, or might be, in achieving this aim, despite numerous studies reviewing different forms of FOPL. Consequently the AFGC considers a non-prescriptive FOPL Policy Guideline is the best approach.

For providing general information about food which is applicable across the healthy adult population the AFGC considers non-interpretative approaches – such as the DIG scheme are better than interpretive approaches. They reflect the nutritional wisdom that all foods can be incorporated into healthy diets and the maxim of moderation, balance and variety – and importantly underscore that all foods do contribute to diets.

More over, the DIG scheme goes beyond labels of food packages. The scheme supports consumers understand the labelling and how to use it through:

• guidance on the intent of the program and format of label icons (thumbnails) giving a common look to the scheme and confidence to consumers in the information;
• active enforcement through market surveillance and complaints resolution procedures;
• promotion to industry to ensure its widespread use; and
• education of consumers regarding use of the labels through:
o community service announcements encouraging use of the thumbnails;
o point of sale education material (in preparation) providing detailed information on how the thumbnails should be used; and
o web support to assist consumer determine their nutritional needs and further information on constructing healthy diets.

The AFGC reported that consumer research in 2008 confirmed awareness of the DIG scheme is high and being transferred into purchasing decisions.

In contrast the AFGC considers interpretive schemes such as ‘traffic lights’ ill-suited to helping consumers construct health diets as they:
• fail to reflect the nutritional wisdom of the importance of variety, balance and moderation;
• risk the health of consumers by
o implying that ‘green’ foods can be consumed without restraint; and
o dismissing the importance of nutrient density, and particularly of micronutrients despite evidence that many Australians have suboptimal intakes.
• unscientifically focus on individual foods, rather than the need to construct healthy diets;
• simplistically approach a complex problem, doing nothing to encourage consumers to eat to their requirements;
• create hard boundaries, based on nutrient content, suggesting that very small changes can profoundly effect on the nutritional value of a product – which is not scientific;
• are ineffective for some cultural groups less familiar with symbols such as traffic lights; and
• fail to distinguish between some foods e.g. margarine and butter.

Interpretive labelling schemes such as ‘traffic lights’ promulgate the falsehood that some foods are inherently ‘healthy’ and some are ‘unhealthy’. This is unscientific and a poor basis for food policy or regulation; nutritional wisdom only recognises ‘healthy’ and ‘unhealthy’ diets.

The AFGC supports the majority of the policy aims, and draft policy principles identified – except those which infer that foods can be classified as health or unhealthy. The AFGC proposes the following additional policy principles for inclusion in the Policy Guideline:

• consistency with all other food regulatory policies, including the foreshadowed Food Labelling Policy which will result from the independent Review of Food Labelling;
• accommodation of both voluntary industry codes and full regulation working together for the most effective outcome; and
• flexibility to provide information which helps consumers chose diets which meet all their nutritional needs for energy, macronutrients, micronutrients and nutritive substances.

At this time, the AFGC supports Policy Option 1 – Status Quo. The FOPL Policy Guideline should await the outcome of the Independent Review of Labelling.

Should a Policy Guideline be developed the AFGC considers Policy Option 2 appropriate. It should support non-prescriptive, voluntary schemes recognising that this model is already well established in the form of the DIG scheme. Policy Options 3 and 4 threaten to undermine current well established FOPL schemes including the Heart Tick and the DIG scheme.

The DIG scheme has gained the support of consumers where it counts – in the shopping aisles of supermarkets. It did so in the absence of a formal Policy Guideline, but in a manner largely consistent with draft policy aims and principles in the consultation papers, the AFGC reported.