Front of pack labelling – an update from the AFGC


Geoffrey Annison, deputy chief executive of the Australian Food and Grocery Council (AFGC), provides an update on the progress surrounding front of pack nutrition labelling, arguing there's still more work to be done.

The Blewett Review of food labelling reported in 2011 recommending a national, uniform front of pack nutrition labelling (FoPL) scheme to assist consumers in selecting foods and constructing healthy diets.

The Council of Australian Government responded by requesting that the [then] Department of Health and Ageing bring together representatives of industry, public health, consumers and the food regulatory agencies to develop a new FoPL system. The new labelling was to include an interpretive element (i.e. a ‘health mark’ or ‘health rating’) and build on existing systems used by industry.

A FoPL Project Committee of stakeholders has been developing the methodology for assessing foods based on their levels of nutrients and aggregating the data into a ranking or score as well as practical considerations such as the design of the label itself. It has also considered the implementation of the labelling scheme and its promotion to consumers.

Progress to date has been substantial. Proposals include:

  1. An interpretive food rating system based on a modified form of the Nutrient Profile Scoring Criterion system currently used for Standard 1.2.7 Nutrition health and related claims of the ANZ Food Standards Code. Foods receive a score appearing on the food label as a Health Star Rating (a half to a five star scale with half star increments);
  2. The levels of nutrients including energy are to be shown to assist consumers seeking specific information which may be important to them – the Australian Food and Grocery Council (AFGC) proposes that its Daily Intake Guide (DIG), which currently appears on over 7,200 products, can be carried forward to fulfil this function for the new FoPL scheme;
  3. Implementation of the FoPL scheme to comprise an AFGC managed voluntary industry code with specialist committees of stakeholders providing advice on different aspects of the management of the scheme; and
  4. A government funded social marketing campaign explaining and promoting the use of the new scheme to the public.

Notwithstanding this progress further work is required before the system can be finalised and implemented.

The AFGC, a key participant in developing the new FoPL scheme, considers that any new system must:

  1. Be scientifically and technically sound providing guidance to consumer choice aligned with current nutritional wisdom;
  2. Be understandable to consumers so they are assisted in making appropriated choices and healthy diet selections;
  3. Be practical for industry to implement with minimal cost impost; and
  4. Be supported by well resourced social marketing promoting the use of the scheme.

The AFGC has argued for a Regulatory Impact Statement to be conducted to demonstrate that the considerable costs which industry will bear in making label changes, if they adopt the new FoPL, is justified by substantial benefits passing through to consumers.

In a welcome move, the Coalition  government   has decided to conduct a cost benefit analysis with full industry consultation – thereby for the first time giving a proper examination of the costs of the system and if it will achieve its public health objectives. Further research is also to be conducted to confirm the effectiveness of the Health Star Rating labels in helping consumers make healthy diet selections.

Despite the considerable progress, in addition to these key aspects of the proposed FoPL system (confirmation of which remains outstanding) there are a number of other issues which need to be worked through. These include:

  1. Finalising the guidance provided to industry on how to implement the proposed labelling –  the integrity of the system will rely on a consistent yet flexible approach which reflects the great variability of food packaging sizes and formats;
  2. Agreeing on the core messages to consumers regarding use of the labelling to assist choice – the key paradigm of variety, moderation and balance as the bedrock of healthy eating must be supported and not inadvertently undermined;
  3. Providing appropriate transition arrangements so that companies can have time to implement the labelling within reasonable time frames; and
  4. Establishing effective monitoring and surveillance of the program to confirm, whether or not it is effective in communicating to consumers and assisting in their food choices.

The AFGC remains committed to the process, but is not naïve to the fact that these are major hurdles which must be negotiated before implementation can be agreed on and initiated.

The food industry is expected to carry the $200 million cost of implementing this scheme, which is a substantial regulatory burden. If industry is going to make this investment in a new front of pack system, it must be scientifically credible, meaningful to consumers and practical and attractive for industry to implement from the outset. Otherwise we risk consumers losing confidence in a “work in progress” labelling system, thereby undermining the whole purpose of the exercise of encouraging consumers to construct healthy diets.