CFA Submission on Consistency of Food Regulation

Cans of food stacked on a shelf in a grocery store

CFA’s recent submission on a consultation paper prepared by consultants on the Consistency of Food Regulatory Approaches in Australia and New Zealand identified labelling, food medicine, and health claims as the main areas of inconsistency.

The submission included the following points:

Labelling: The present requirements provide great scope for between jurisdiction inconsistencies in the assessment of compliance with the Code and result in some information being insufficiently legible and/or prominent for many consumers, especially those with impaired vision.

Examples of this include information on alcohol content (% by volume) and total standard drink information displayed on the labels of many alcoholic beverages.

Given the importance to consumers of being able to easily notice and read information labels in order to be able to make informed choices and to not be misled or deceived, this results in considerable consumer detriment and under achievement of food regulation objectives. It is also discriminates against consumers with disabilities.

Food-medicine: The current food-medicine interface results in anomalies and inconsistent approaches to different products of the same type and between jurisdictions. And, FSANZ is unable to provide interpretation.

Health Claims: The current arrangements result in inconsistent approaches between jurisdictions. Some jurisdictions are proactive in investigating claims, whereas others rely on a public complaint being made before acting. The same standards should apply to, and be complied with by, businesses across all states and territories and NZ.

The submission also said that:

  • Inconsistencies in the application of all types of regulatory requirements have negative impacts on consumers. The impacts are particularly severe in relation to safety, the food medicine interface, health and other claims, the provision of information aimed at informing consumers and facilitating informed choices, and how information is displayed.
  • Most consumers are time poor and do not want and should not have to spend time doing their own research on food products, checking that information is correct, or trying to compare information displayed inconsistently, and often inadequately, between products.
  • Improving the consistency of the interpretation and application of food regulations also improves the achievement of public food policy objectives because more consumers can make informed choices and avoid being misled or deceived.

Ian Jarratt, CFA’s representative on the Food Standards Australia and New Zealand’s Consumer and Public Health Dialogue.