Q1. to What Extent Should the Food Regulatory System Be Used to Meet Broader Public Health

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

If the food system is healthy and people are eating optimally then the government saves money on health. It also makes education easier if children are well fed and we end up with a smarter populace. I think if the government thinks holistically about society then the food regulatory system needs to make sure that people have access to the healthiest food they can.

Since the best thing you can do for people’s health is to offer them fresh unadulterated food then the food regulatory system should be used to enable people to find the least adulterated foods. Specific public-health objectives (dealing with heart disease, diabetes, obesity) should be dealt with through education not food marketing. They would also not be such a drain on resources if people were better educated.

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 website)?

All information needs to be present on the label. Is it GM? Does it involve nano technology or irradiation. Is it dipped in ammonia? Any and all information should be available on the label. A national government register of GM foods would only be ‘ok’. I currently use an iphone app while I am instore to determine the GM status of food, it’s cumbersome and tricky when also wrangling children. Please label all GM food.

Q3. How can accurate and consistent labelling be ensured?

By having clear guidelines for companies to follow.

Q4. What principles should guide decisions about government intervention on food labelling?

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

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Q6. Is this a satisfactory spectrum for labelling requirements?

All ingredients derived fully or partly from GM crops or processes need to be labelled. This includes refined products such as oils, sugars, starches, honey, additives and enzymes, and animal products derived fully or partly from GM feed, which currently escape labelling. GM animal feed needs to be labelled. This is "process-based" labelling. We reject suggestions that GM food becomes 'normal unlabelled food', with our usual food being labelled instead as "GM free".

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

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

Disallow marketing to children, who should not be making purchasing decisions; as they have no regard for health or weight. they also do not yet possess the critical thinking skills necessary to question marketing (of course, neither do many adults)

Q9. In what ways can disclosure of ingredients be improved?

Ingredients should not be allowed to use a generic term like ‘sugar’. Is it palm sugar, cane sugar, HFCS, fructose, glucose, beet sugar? This is a serious problem for the growing number of people in the community with fructose malabsorption.

I am in the final stages of setting up a catering company specialising in GM free, organic and free range menus. The market-research results were extremely positive as more and more people are worried about eating ethically and whether they can trust what is in their food. There are a number of these catering companies overseas especially in the UK. Over there it is less expensive to run a small-business like this because there is clear GM labelling.

I am finding that a lot of my time and therefore money is going into researching the background of ingredients and ascertaining which ones my company can use. If there was clear GM labelling then it would save my small business significant amounts of money and time.

The above also goes for any new means of production.

Q10. To what extent should health claims that can be objectively supported by evidence be permitted?

This is fine outside a designated government-label section. These things should not be included in the government reviewed label as this might confuse people. This should appear on the label as what it is – marketing.

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

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

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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?

It absolutely should. President Obama’s Cancer Council has come out swinging against all the chemicals in our modern lives. These may not be an immediate health threat but I think the government should also have the public’s long-term health at the core of its mission. ‘Absence of proof is not proof of absence’.

There have been too few independent studies to feel confident in the safety of GM foods. In fact, Doctors specialising in environmental medicine say there is a link between GM foods and illness. They state "several animal studies indicate serious health risks associated with GM food consumption". They include: allergy; gastrointestinal, liver and kidney changes; immune dysregulation; dysregulation of insulin and cholesterol response; accelerated ageing and reduced fertility. There have been no studies anywhere in the world to say whether GM food has been safe to eat or not. I reject the suggestion that GM is just a consumer concern that doesn't need labelling. GM food is not the same as non-GM food.

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

Business needs –

I am in the final stages of setting up a catering company specialising in GM free, organic and free range food. The market-research results were extremely positive as more and more people are worried about eating ethically and whether they can trust what is in their food. There are a number of these catering companies overseas especially in the UK. Over there it is less expensive to run a small-business like this because there is clear GM labelling.

Personal need -

If the public feels it is in their interest (eg GM) then that should be sufficient.

For ingredients the fact that that ingredient exists in the food should be sufficient. In my house I have nut and egg allergy (anaphylactic), moderate pea allergy and an intolerance to linseed, puy lentils, chickpeas, avocado, citrus, tomatoes, strong cheese, some preservatives, some artificial sweetners and some food colouring. If I can’t trust the label to include all these ingredients then I can’t buy it. Therefore we need to make sure that all ingredients appear on the label.

We also avoid GM at home and would like this to be made easier. GM companies argue that farmers should have the choice to buy GM seeds if they wish. Why doesn’t this choice extend to the consumer? Why don’t I have the choice to avoid it if I wish?

Q15. What criteria should determine which, if any, foods are required to have country of origin labelling?

If it is a food then we should know where it comes from. There may be health or ethical issues which mean we need to know where our food comes from. The current need to label food as imported at least goes halfway as it is a signal not to buy it because there isn’t enough information on which to base a decision to purchase.

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

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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?

Words that promise a certain means of production (organic, free range, halal) definitely need clear definitions. Nebulous words like ‘fresh’ and ‘natural’ can be left to the marketeers. Education should teach people that if it’s in a packet it’s not fresh or natural even if it once was.

Q18. What criteria should be used to determine the legitimacy of such information claims for the food label?

If the guidelines are clear on the means of production necessary to warrant a label then use the guidelines/definition.

Undefined words belong in marketing and there needs to be more education to teach the population the difference between actual guideline words and marketing.

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?

GM processes should be highlighted at every stage of production. It is done in Europe, I don’t understand why we can’t do it here. I would be very disappointed if we introduced a labelling system 12 years behind the UK. I think the panel should investigate the EU and how they manage to label GM. If the companies behind these technologies don’t want the labelling we really need to ask why. If GM food is the same as normal food then why can they patent it? The same goes for nano and irradiation.

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?

Yes.

Q21. Should minimum font sizes be specified for all wording?

Yes, I’m sure there are accessibility guidelines developed by the government that should help with these decisions.

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

I’m sure that an objective group could be formed to check food labels for legibility as part of the process of getting a food a barcode. If you wanted to simplify it you could just send them a photo of the label at actual size. Then someone could check it against the packet when it is manufactured.

Q23. How best can the information on food labels be arranged to balance the presentation of a range of information while minimising information overload?

Limit the amount of space for marketing. If the marketeers complain remind them how successful the ipod has been with its minimalist packaging, the product should speak for itself.

There does need to be part of the packet that can be trusted to be free of marketing (including the heart foundation tick which while at times helpful can be misleading in the case of sugars). A section of the packet that consumers can trust to only contain government regulated information. It needs to be clear and easy to find and understand.

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

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

I think icons are great, used effectively. there needs to be a sanctioned part of the packet for government icons (GM free, nano free etc) and the rest can do what they like but the consumer needs to know they can trust the icons within the designated government regulated label section.

Q26. What objectives should inform decisions relevant to the format of front-of-pack labelling?

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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?

Given the alarming rise in food allergies amongst kids it is imperative to have clear labelling in any place where kids have to attend (schools, pre-schools, kindergartens, hospitals).

Places that are attended by choice (restaurants, take-away, fetes) are not as necessary. As the mother of a severely egg allergic child I only attend restaurants where I can trust the person telling me what ingredients go into the food. This means avoiding restaurants that use a lot of pre-packaged food. In general I avoid a lot of restaurants but I think it is better than crippling small restaurants with paperwork.

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

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Q29. In what ways can consistency across Australia and New Zealand in the interpretation and administration of food labelling standards be improved?

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

There must be an easy way for members of the community to prosecute companies that lie on their labels. It should also be possible for the community to request the government carry out tests on food as the community doesn’t have access to the scientific means necessary to do the testing.

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?

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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?