19 July 2013 [12-13] Call for submissions – Qualifying criteria for nutrition content claims about dietary fibre Standard 1.2.7 – Nutrition, Health and Related Claims was gazetted in January 2013. In the Standard, the respective qualifying criteria for nutrition content claims about dietary fibre are 2 g, 4 g and 7 g dietary fibre per serving for source, good source and excellent source claims. In mid-2012, several breakfast cereal and bread manufacturers expressed concern that the qualifying criteria recommended for inclusion in Standard 1.2.7 were set above the criteria in the voluntary 1995 Code of Practice on Nutrient Claims in Food Labels and in Advertisements (CoPoNC) (National Food Authority, 1995), and that this would affect their ability to make nutrition content claims about dietary fibre. In response to this concern, FSANZ committed to considering this issue further during the three-year transition period for Standard 1.2.7. FSANZ is seeking stakeholder views and available evidence relating to the qualifying criteria for nutrition content claims about dietary fibre. To aid submitters in providing comments, questions are provided. Submitters are encouraged to use the response template provided at Attachment 2. All submissions will be published on our website. We will not publish material that is provided in-confidence, although that information might be subject to release under freedom of information laws. Submissions will be published as soon as possible after the end of the public comment period. Where large numbers of documents are involved, FSANZ will make these available on CD, rather than on the website. Under section 114 of the FSANZ Act, some information provided to FSANZ cannot be disclosed. More information about the disclosure of commercial- in-confidence information is available on the FSANZ website at ‘how to make a submission’. Submissions should be made in writing, be marked clearly with the word ‘Submission’, and quote, ‘Consultation Paper – Qualifying criteria for nutrition content claims about dietary fibre’. While FSANZ accepts submissions delivered in hard copy to our offices, it is more convenient to i
Transcript
19 July 2013[12-13]
Call for submissions – Qualifying criteria for nutrition content claims about dietary fibre
Standard 1.2.7 – Nutrition, Health and Related Claims was gazetted in January 2013. In the Standard, the respective qualifying criteria for nutrition content claims about dietary fibre are 2 g, 4 g and 7 g dietary fibre per serving for source, good source and excellent source claims.
In mid-2012, several breakfast cereal and bread manufacturers expressed concern that the qualifying criteria recommended for inclusion in Standard 1.2.7 were set above the criteria in the voluntary 1995 Code of Practice on Nutrient Claims in Food Labels and in Advertisements (CoPoNC) (National Food Authority, 1995), and that this would affect their ability to make nutrition content claims about dietary fibre. In response to this concern, FSANZ committed to considering this issue further during the three-year transition period for Standard 1.2.7.
FSANZ is seeking stakeholder views and available evidence relating to the qualifying criteria for nutrition content claims about dietary fibre.
To aid submitters in providing comments, questions are provided. Submitters are encouraged to use the response template provided at Attachment 2.
All submissions will be published on our website. We will not publish material that is provided in-confidence, although that information might be subject to release under freedom of information laws. Submissions will be published as soon as possible after the end of the public comment period. Where large numbers of documents are involved, FSANZ will make these available on CD, rather than on the website.
Under section 114 of the FSANZ Act, some information provided to FSANZ cannot be disclosed. More information about the disclosure of commercial-in-confidence information is available on the FSANZ website at ‘how to make a submission’.
Submissions should be made in writing, be marked clearly with the word ‘Submission’, and quote, ‘Consultation Paper – Qualifying criteria for nutrition content claims about dietary fibre’. While FSANZ accepts submissions delivered in hard copy to our offices, it is more convenient to receive submissions electronically through the FSANZ website via the link at ‘how to make a submission’. You can also email your submission directly to [email protected].
There is no need to send a hard copy of your submission if you have submitted by email or through the FSANZ website. FSANZ endeavours to formally acknowledge receipt of submissions within 3 business days.
DEADLINE FOR SUBMISSIONS: 6pm (Canberra time) 29 August 2013
Submissions received after this date will not be considered unless an extension had been given before the closing date. Extensions will only be granted due to extraordinary circumstances during the submission period. Any agreed extension will be notified on the FSANZ website and will apply to all submitters.
Questions about making submissions can be sent to [email protected].
2.1 DEVELOPMENT OF QUALIFYING CRITERIA FOR NUTRITION CONTENT CLAIMS ABOUT DIETARY FIBRE.............................32.2.1 Consideration of qualifying criteria by the Australian National Food Authority................................32.2.2 Consideration of qualifying criteria by FSANZ (Proposal P293 – Nutrition, Health & Related Claims)
42.2 INDUSTRY PRACTICE WITH CLAIM CONDITIONS IN COPONC...............................................................................52.3 AMOUNT OF DIETARY FIBRE IN FOOD.............................................................................................................62.4 QUALIFYING CRITERIA FOR NUTRITION CONTENT CLAIMS ABOUT DIETARY FIBRE IN OTHER JURISDICTIONS.....................6
3 QUESTIONS FOR STAKEHOLDERS........................................................................................................... 9
3.1 INDUSTRY DATA – IMPACT OF QUALIFYING CRITERIA IN STANDARD 1.2.7 ON FOODS CARRYING NUTRITION CONTENT CLAIMS ABOUT DIETARY FIBRE...................................................................................................................................93.2 STAKEHOLDER VIEWS AND EVIDENCE............................................................................................................11
4 NEXT STEPS......................................................................................................................................... 11
REFERENCES........................................................................................................................................................11ATTACHMENT 1: AMOUNT OF DIETARY FIBRE IN SELECTED FOODS...........................................................................13ATTACHMENT 2: SUBMISSION TEMPLATE...........................................................................................................15
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1 IntroductionStandard 1.2.7 – Nutrition, Health and Related Claims was gazetted in January 2013. In the Standard, the respective qualifying criteria for nutrition content claims about dietary fibre are 2 g, 4 g and 7 g dietary fibre per serving for source, good source and excellent source claims. These qualifying criteria were developed during Proposal P293 – Nutrition, Health and Related Claims, following two rounds of public consultation (see section 2.2.2).
Before the gazettal of Standard 1.2.7, there were no qualifying criteria for nutrition content claims about dietary fibre in the Australia New Zealand Food Standards Code (Code), however a voluntary code of practice, the 1995 Code of Practice on Nutrient Claims in Food Labels and in Advertisements (CoPoNC) (National Food Authority, 1995), was available in Australia which included qualifying criteria for dietary fibre (see Table 1). The New Zealand Food Regulations (1984) included qualifying criteria for good source claims only (4 g dietary fibre per serving), however these regulations were revoked in 2002.
In mid-2012, several bread and breakfast cereal manufacturers asked FSANZ to review the qualifying criteria for nutrition content claims about dietary fibre. Their main concern was that the qualifying criteria proposed for inclusion in Standard 1.2.7 were set above the qualifying criteria in CoPoNC and that this would affect their ability to make nutrition content claims about dietary fibre on their foods. The concern was primarily about the ‘loss’ of claims, in particular that foods previously meeting good source would now only meet source criteria. The manufacturers suggested that the qualifying criteria for nutrition content claims about dietary fibre in Standard 1.2.7 should be the same as those in CoPoNC.
Table 1: Qualifying criteria for nutrition content claims about dietary fibreDescriptors for the
dietary fibre nutrition content claim
CoPoNC qualifying criteria
Standard 1.2.7 qualifying criteria
g dietary fibre per servingSource 1.5 2Good source 3 4Very high or Excellent source 6 7
In response to this request, FSANZ indicated in the Review Report for Standard 1.2.71 that further consideration would be given to the qualifying criteria for nutrition content claims about dietary fibre during the three-year transition period for the Standard (January 2013 – January 2016).
FSANZ is seeking views of stakeholders and information about the extent of food reformulation or changes to the labelling of dietary fibre on food labels in response to the qualifying criteria for dietary fibre nutrition content claims in Standard 1.2.7. FSANZ is aware that some food businesses have already commenced changing labels/food formulations in response to the qualifying criteria in Standard 1.2.7 and seeks information on such changes as part of this consultation. Information provided by submitters will assist FSANZ in identifying issues involved with the change from the previous CoPoNC qualifying criteria for dietary fibre nutrition content claims to those now in Standard 1.2.7.
2 Background2.1 Development of qualifying criteria for nutrition content claims
about dietary fibre
Table 2 summarises the evolution of qualifying criteria for nutrition content claims about dietary fibre prior to, and during the development of, Standard 1.2.7.
Table 2: Evolution of qualifying criteria for nutrition content claims about dietary fibreDescript
or for nutrition content claim (or synony
m)
New Zealand
Food Regulatio
ns(1984)
(revoked in 2002)
Proposed qualifying criteria for Proposal
P18 – Nutrient Claims(early
1990’s)
CoPoNC Standard 1.2.7 (Proposal P293)
Draft (1993)
Final (199
5)
Draft Assessment Report(2005)2
Preliminary
Assessment Report (2007), Final
Assessment Report (2008)3
and Review report (2012)4
Minimum amount of
dietary fibre per serving
Minimum amount of
dietary fibre per 100g
Minimum amount of dietary fibre per serving
Source Not prescribed
1.5 2 1.5 2 2
Good source
4 4 4 3 4 4
Very highORExcellent source
Not prescribed
10 6 6 NA 7
2.2.1 Consideration of qualifying criteria by the Australian National Food Authority
In the early 1990s, the then National Food Authority began developing qualifying criteria for nutrition content claims about dietary fibre and other food components under Proposal P18 – Nutrient Claims, for possible inclusion in the Australian Food Standards Code. At that stage, based on consideration of the dietary fibre content of a wide range of foods, it was proposed that the respective qualifying criteria for source, good source and excellent source nutrition content claims be 1.5 g, 4 g and 10 g dietary fibre per 100 g food. 5
2 P293- Draft Assessment Report - 7 December 20053 P293 - Preliminary Final Assessment Report4 P293 - Review Report5 Historical information sourced from documents prepared for the 22nd meeting of the National Food Authority (1994)
In 1993, it was decided to manage nutrition content claims by way of a voluntary code of practice instead of a food standard. Consequently, P18 was abandoned and CoPoNC6 (National Food Authority, 1995), was developed. In response to submissions from the Council of Australian Food Technology Associations (CAFTA) and other stakeholders, the National Food Authority changed the basis for dietary fibre claim criteria to per serving as it was recognised that dietary fibre quantities per 100g would unfairly advantage certain dry foods while disadvantaging fruits and vegetables. The 1.5 g, 4 g, 10 g dietary fibre per 100 g criteria were converted to 2 g, 4 g, 6 g dietary fibre per serving as these were considered to most closely reflect the previous per 100 g criteria, taking into account the levels of dietary fibre in a wide range of food and typical serving sizes.
At that time, CAFTA generally supported the criteria of 1.5 g, 3 g and 6 g dietary fibre per serving, for source, good source and excellent source claims, respectively, as they considered that:
whole wheat grain products should be the benchmark for allowing a good source claim since white bread was a major source of dietary fibre in the diet, it should be possible
to refer to white bread as a source of dietary fibre.
Most white breads were able to meet the figure of 1.5 g dietary fibre per serving at that time if the serving size was 2 slices, but not 2 g dietary fibre per serving. The final version of CoPoNC was released in 1995 and included the qualifying criteria of 1.5 g, 3 g and 6 g dietary fibre per serving, for source, good source and excellent source claims, respectively.
2.2.2 Consideration of qualifying criteria by FSANZ (Proposal P293 – Nutrition, Health & Related Claims)
Proposal P293 – Nutrition, Health & Related Claims commenced in 2003. In the Draft Assessment Report (2005)7, FSANZ first proposed that the qualifying criteria for source and good source claims be increased from 1.5 g to 2 g per serving and from 3 g to 4 g per serving, respectively. The key reasons for proposing these changes were:
1.5 g per serving and 3 g per serving were equivalent to only 5% and 13.3% of the regulatory reference value for dietary fibre of 30 g8, respectively. In comparison, for vitamins, minerals and protein, 10% and 25% of the reference value were required to make a source and good source claim, respectively. Therefore it was considered appropriate to increase the qualifying criteria for dietary fibre.
alignment with Canada’s approach for source and good source claims (see Table 3) the 2 g and 4 g of dietary fibre per serving would still allow a variety of foods to make
claims (noting that at present some white breads, particularly toast slices, have more than2 g dietary fibre per serving).
Qualifying criteria for a very high claim were not proposed in the Draft Assessment Report. One of the reasons for this was concern expressed by submitters with the practice of food manufacturers adding dietary fibre to processed foods.
6 CoPoNC was a voluntary code of practice that was developed by the National Food Authority (now FSANZ) and managed by the Food Code Management Committee that comprised representatives from industry and the community. A large number of nutrition content claims were self-regulated through the guidance provided in CoPoNC. CoPoNC did not apply in New Zealand.7 P293- Draft Assessment Report - 7 December 20058 The dietary fibre regulatory reference value of 30 g per day is based on a year 2000 nutrition target recommended in Towards better health for Australians published by the Commonwealth Department of Health in 1987.
In the Draft Assessment Report it was also proposed that voluntary declaration of dietary fibre in the nutrition information panel would be permitted without requiring the food to meet the conditions for a source claim. This meant that the dietary fibre content of foods that did not meet the qualifying criteria for source claims could still be provided in the NIP thereby providing consumers with information. This provision was included in the consequential amendments to Standard 1.2.8 – Nutrition Information Requirements at the time Standard 1.2.7 was gazetted.
In the Preliminary Final Assessment Report (2007)9, which was the last opportunity for stakeholders to specifically comment on the qualifying criteria for nutrition content claims about dietary fibre, FSANZ continued to propose that the qualifying criteria be 2 g (6.67% of reference value), 4 g (13.3% of reference value) and also included 7 g (23.3% of reference value) per serving for an excellent source claim. There was a mixed response from submitters with some industry and public health stakeholders supporting the proposed approach while others opposed the approach. Key reasons for supporting the approach included the desirability of moving towards a percentage of the reference value consistent with the qualifying criteria for nutrition content claims about vitamins, minerals and protein, and consistency with international regulations. Submitters who opposed the approach cited the following reasons:
the regulatory reference value of 30 g/day was too high because it aligned with the NHMRC reference value for men aged 19 years and over
there is no evidence that raising the levels was necessary or would increase dietary fibre intakes
serving sizes may be manipulated in order to meet the higher criteria foods such as wheat biscuits would be unable to make good source claims despite
being almost 100% wholegrain the criteria were not aligned to Codex or to the European Union (EU) requirements consumers may be confused if foods carrying existing claims were reformulated or
claims were removed.
In the Final Assessment Report (2008)10, FSANZ maintained the higher levels for the qualifying criteria for the reasons provided at Draft Assessment, namely, that the CoPoNC criteria were too low relative to the regulatory reference value of 30 g and the criteria for claims about vitamins, minerals and protein, and the criteria would still allow a variety of foods to make claims.
In 2008 when the COAG Legislative Forum on Food Regulation (the Forum) asked FSANZ to review Standard 1.2.7, the issue of qualifying criteria for dietary fibre claims was not included in the review request and therefore was not given further consideration as part of the Review.
2.2 Industry Practice with claim conditions in CoPoNC
Data collected in 2001, 2003 and 2005 has indicated that food businesses in Australia have tended to follow the claim conditions in the voluntary CoPoNC (Williams et al. 2003, FSANZ 2005, FSANZ 2007). An independent study of compliance with CoPoNC carried out in Australia in 2001 found that the level of compliance in a sample of 6662 foods was 85% for the 3194 claims covered by CoPoNC (Williams et al. 2003).
9 P293 - Preliminary Final Assessment Report10 P293 - Final Assessment Report
The FSANZ Label Monitoring Survey carried out in 2003 found that, of the 721 labels sampled in Australia, 153 labels carried 220 claims that were covered by CoPoNC (FSANZ 2005). Ninety-seven per cent of the claims were found to be consistent with the labelling conditions in CoPoNC. Findings from the 2005 FSANZ Label Monitoring Survey (FSANZ 2007), suggested an increase in the use of nutrition content claims about dietary fibre on labels compared with that reported in the 2003 survey. Of the 746 labels sampled in Australia in 2005, 244 labels carried 369 claims that were covered by CoPoNC. Eighty-six per cent of the claims were found to be consistent with the labelling conditions in CoPoNC. Of the claims that were inconsistent with CoPoNC (n=51), 80% were due to dietary fibre claims not meeting either source or good source criteria. Current compliance with claim conditions in CoPoNC by food businesses is not known. In addition there are no data available on the compliance with CoPoNC in New Zealand.
2.3 Amount of dietary fibre in food
In the 2008–09 National Nutrition Survey, the main sources of dietary fibre in the diets of New Zealanders (aged 15 years and over) were reported to be (in decreasing amounts) breads, vegetables, potatoes, kumara and taro, fruits, grains and pasta, breakfast cereals and bread-based dishes (University of Otago and Ministry of Health, 2011). Similarly in Australia, breads, vegetables, fruits, potatoes, cereal-based foods and breakfast cereals, were the main sources of dietary fibre reported in the 1995 National Nutrition Survey (Australian Bureau of Statistics 1998).
Attachment 1 shows typical levels of dietary fibre in a range of foods. Note that not all foods eligible to carry voluntary nutrition content claims about dietary fibre do so, hence the need to collate information on foods currently carrying nutrition content claims about dietary fibre from food businesses as part of this consultation.
2.4 Qualifying criteria for nutrition content claims about dietary fibre in other jurisdictions
Table 3 compares the qualifying criteria for nutrition content claims about dietary fibre in Standard 1.2.7 with international regulations and guidance.
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Table 3: Qualifying criteria for dietary fibre in Standard 1.2.7, CoPoNC and international regulations and guidanceDescriptors for dietary
fibre nutrition content claims
Standard 1.2.7 2013
CoPoNC1995
Canada2003
EU2006
Codex20091
USA2008
Source 2 g per serving(6.7% of reference value (30g))
1.5 g per serving 2 g per reference amount and serving of stated size2
3 g/100g or1.5 g/100 kcal
3 g/100g or1.5 g/100kcal or10% of dietary reference value per serving3
10-19% of Dietary Reference Value (25g) per prescribed RACC4
(for good source, contains or provides claims)
Good source or high
4 g per serving(13.3% of reference value (30g))
3 g per serving 4 g per reference amount and serving of stated size
(‘high’ is used, ‘good’ is not permitted)
6 g/100g or3 g/100 kcal
6 g/100g or3 g/100kcalor20% of dietary reference value per serving4
Excellent source or very high
7 g per serving(23.3% of reference value (30g))
6 g per serving 6 g per reference amount and serving of stated size
(‘very high’ is used, ‘excellent’ is not permitted)
Not permitted Not permitted 20% of Dietary Reference Value (25g) per prescribed RACC4
(for high, rich, excellent claims)
1 Codex Alimentarius: Guidelines for use of nutrition and health claims (CAC/GL-1997). Countries may choose which approach to use.2 For example, the reference amount for bread is 50g and the permitted serving size for bread ranges from 25 to 70g. This means that if the chosen serving size for bread was 40g and it carried a source claim, the bread would need to contain 2g dietary fibre per 40g bread. (reference amounts are at http://laws-lois.justice.gc.ca/eng/regulations/C.R.C.,_c._870/page-368.html#h-371). Serving sizes are at http://www.inspection.gc.ca/english/fssa/labeti/guide/ch6e.shtml#tab6-3. 3 Serving size and dietary reference values to be determined at national level4 RACC - Reference Amounts Customarily Consumed Per Eating Occasion (reference amounts are at http://www.accessdata.fda.gov/scripts/cdrh/cfdocs/cfcfr/CFRSearch.cfm?fr=101.12). Reference amounts are used to determine whether a food meets the criteria for nutrient content claims. If the serving size declared on the food label differs from the reference amount, and the food meets the criteria for the claim only on the basis of the reference amount, the claim must be followed by a statement that states the basis on which the claim is made.
As indicated in Table 3, the way in which qualifying criteria are expressed differs among the various jurisdictions. Examples are provided in Tables 4 and 5 to facilitate comparison. It is clear that the qualifying criteria in Standard 1.2.7 are similar to those prescribed in Canada and, for foods with a serving size of 67 g or higher, they are also similar to the EU criteria and to the criteria in the Codex Guideline. The approach taken in the USA (same criteria used for good source, contains or provides claims) differs from that taken in other jurisdictions.
Table 4: Comparison of minimum amounts of dietary fibre (g per serving) required for source and good source/high claims for bread*, across a number of jurisdictionsDescriptor
s for dietary
fibre nutrition content claims
Standard 1.2.7 2013
CoPoNC1995
Canada2003
EU2006
Codex2009
USA2008
Source 2 g per serving
1.5 g per serving
2.8 g per serving(reference amount is 50g, permitted serving size 25-70g)
2.1 g per serving
2.1 g per servingor3 g per serving
2.5 g per 50 g RACC1
(Dietary Reference Value is25 g dietary fibre per day)
Good source or high
4 g per serving
3 g per serving
5.6 g per serving(reference amount is 50g, permitted serving size 25-70g)
4.2 g per serving
4.2 g per servingor6 g per serving
*serving size 70g (typical serving size declared by manufacturers in Australia and New Zealand)1 RACC - Reference Amounts Customarily Consumed Per Eating Occasion
Table 5: Comparison of minimum amounts of dietary fibre (g per serving) required for source and good source/high claims for breakfast cereal*, across a number of jurisdictionsDescriptor
s for dietary
fibre nutrition content claims
Standard 1.2.7 2013
CoPoNC1995
Canada2003
EU2006
Codex2009
USA2008
Source 2 g per serving
1.5 g per serving
2 g per serving(reference amount is 30g, permitted serving size 20-45g)1
1.2 g per serving
1.2 g per servingor3 g per serving
2.5 g per 30 g RACC2,3
(Dietary Reference Value is25 g dietary fibre per day)
Good source or high
4 g per serving
3 g per serving
4 g per serving(reference amount is 30 g, permitted serving size20-45g)
2.4 g per serving
2.4 g per servingor6 g per serving
*serving size 40g (typical serving size declared by manufacturers in Australia and New Zealand)1 For ready-to-eat breakfast cereals, puffed and coated, flaked, extruded, without fruit or nuts (20 g to 42 g per 250 ml), very high fibre cereals (with 28 g or more dietary fibre per 100 g)2 RACC - Reference Amounts Customarily Consumed Per Eating Occasion 3 For breakfast cereals, ready-to-eat weighing 20 g or more but less than 43 g per cup; high fibre cereals containing 28 g or more of dietary fibre per 100 g
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3 Questions for stakeholders3.1 Industry data – impact of qualifying criteria in Standard 1.2.7
on foods carrying nutrition content claims about dietary fibre
A range of foods in the marketplace currently carry nutrition content claims about dietary fibre such as breakfast cereals; breads; muesli bars; breakfast drinks; canned, chilled and frozen vegetable products; fruit products; wholegrain rice and wholegrain pasta. FSANZ is seeking information on the extent to which foods currently carrying nutrition content claims about dietary fibre will no longer be able to continue carrying the same claims following the end of the transition period for Standard 1.2.7 in January 2016. We would appreciate information on the costs of changing labels and/or product formulations in order to meet the present qualifying criteria in Standard 1.2.7 as well as information on any technical issues associated with increasing the amount of dietary fibre in foods.
FSANZ is aware that some food businesses have made, or are in the process of making, label and/or product changes in response to the qualifying criteria for nutrition content claims about dietary fibre in Standard 1.2.7 and therefore FSANZ is interested in receiving information on changes that have already been made.
PLEASE REFER TO ATTACHMENT 2 FOR A SUBMISSION TEMPLATE
Part A of template – For food industry
Question 1
What foods do you sell that currently carry nutrition content claims about dietary fibre (e.g. claims such as source, good source, and excellent source of dietary fibre or synonyms of these descriptors) and do not meet the relevant qualifying criteria in Standard 1.2.7? Please provide the following information for these foods:
food name, dietary fibre claim on label, serving size, g dietary fibre per serving
Please also provide:
the number of foods and stock-keeping units (SKUs)11 currently carrying nutrition content claims about dietary fibre that do not meet the qualifying criteria in Standard 1.2.7
the total number of foods and SKUs currently carrying nutrition content claims about dietary fibre.
11 SKU - refers to a stock-keeping unit, a unique identifier for each distinct product that can be purchased in business.
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Question 2
If you were to change or remove nutrition content claims about dietary fibre on labels in response to the present qualifying criteria in Standard 1.2.7 for any of the foods listed in Question 1, what would be the cost of such label changes? Please provide the following information:
number of SKUs affected for each type of packaging material used direct cost of making a change (which could include cost of label design, label
production, proofing, package redesign, labour) indirect cost of making a change (which could include label write-off and managerial
costs (including marketing and advertising)) marginal cost of label changes if such changes could be combined with any other label
changes during the transition period for Standard 1.2.7.
Question 3
If you were to reformulate any of the foods listed in Question 1 in order to meet the present qualifying criteria in Standard 1.2.7, what would be the cost of such reformulation? Please provide the following information:
the number of foods you might reformulate and the estimated total cost of reformulation a description of any technical issues associated with increasing the amount of dietary
fibre in foods, with reference to any specific foods.
Question 4
Have you already made any changes to nutrition content claims about dietary fibre on food labels in response to the qualifying criteria in Standard 1.2.7? If ‘yes’ please provide the following information:
number of SKUs for which you have already made labelling changes and the cost of making a change for each type of packaging material used.
Question 5
Have you already reformulated any foods in order to meet the present qualifying criteria in Standard 1.2.7? If ‘yes’, please provide the following information:
the number of foods you have reformulated and the total cost of reformulation.
Question 6
What would be the commercial impact if the qualifying criteria for claims about dietary fibre in Standard 1.2.7 were changed to the criteria in CoPoNC? Please provide detail.
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3.2 Stakeholder views and evidence
It has been six years since stakeholders were asked to comment on the qualifying criteria for nutrition content claims about dietary fibre (Proposal P293 Preliminary Final Assessment Report 2007)12. FSANZ therefore invites comments from all stakeholders and encourages submitters to provide documented evidence to support viewpoints. Several submitters to the Preliminary Final Assessment Report suggested that increasing the qualifying criteria for nutrition content claims about dietary fibre could cause consumer confusion as consumers may believe that the dietary fibre content of certain foods had been reduced. FSANZ is keen to hear if this issue is still of concern and whether there are any studies that have investigated this issue.
Part B of template – For all stakeholders
Question 7
Do you think the qualifying criteria for nutrition content claims about dietary fibre in Standard 1.2.7 should be changed to the levels in CoPoNC? Please provide documented evidence to support your view.
Question 8
Do you think consumers could be confused if nutrition content claims about dietary fibre that currently comply with the qualifying criteria in CoPoNC are changed in response to the qualifying criteria in Standard 1.2.7? If so, please provide any research studies that have investigated the extent to which consumers understand the difference between foods carrying different levels of dietary fibre claims, that is, source, good source, and excellent source claims. Any information on changes in purchasing patterns in response to a change in the labelling of a dietary fibre claim is also of interest.
4 Next stepsFollowing the close of the consultation period, FSANZ will collate and evaluate the information provided by submitters. FSANZ appreciates that this current consultation process raises some uncertainty for industry in relation to the qualifying criteria. With this in mind, FSANZ will endeavour to resolve the issue as quickly as possible. Should FSANZ consider there is merit in changing the qualifying criteria for nutrition content claims about dietary fibre in Standard 1.2.7, a proposal will be prepared to assess this change and further public consultation undertaken.
References
Australian Bureau of Statistics (1998) National Nutrition Survey. Nutrient Intakes and Physical Measurements Australia 1995. Catalogue Number 4805.0
FSANZ (2005) On-going food label monitoring survey in Australia and New Zealand. Report on the Re-assessment of 2003 Labels for Nutrition, Health and Related Claims (Phase 2, Part C). Evaluation Report Series No. 14. Food Standards Australia New Zealand, Canberra, ACT
FSANZ (2007) On-going food label monitoring survey in Australia and New Zealand. Report on the Assessment of 2005 Labels for Nutrition, Health and Related Claims. Evaluation Report Series No 16. Food Standards Australia New Zealand, Canberra, ACT
NUTTAB (2010) FSANZ Nutrient Tables. http://www.foodstandards.gov.au/science/monitoringnutrients/nutrientables/nuttab/Pages/NUTTAB-2010-electronic-database-files.aspx Accessed 10 July 2013
University of Otago and Ministry of Health (2011) A Focus on Nutrition: Key findings of the 2008/09 New Zealand Adult Nutrition Survey. Wellington: Ministry of Health
Williams P, Yeatman H, Zakrzewski S, Aboozaid B, Henshaw S, Ingram K, Rankine A, Walcott S. and Ghani F (2003) Nutrition and related claims used on packaged Australian foods – implications for regulation. Asia Pacific J Clin Nutr, 12 (2): 138-150
Attachments
Attachment 1: Amount of dietary fibre in selected foodsAttachment 2: Submission template
Rice and PastaRice, brown, raw 50 (1/4 cup) 1.6Pasta, white, with egg, dry 40 (1/4 cup) 1.0Pasta, wholemeal, dry 50 (1/4 cup) 5.9
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Attachment 1
14
Attachment 1
Table 1 continued: Amount of dietary fibre in selected foods (NUTTAB, 2010)Food Typical serving
size (g unless otherwise
stated)
Dietary fibre (g) per serving
Fruits and VegetablesApple, dried 25 2.3Apple, royal gala, unpeeled, raw 140 2.9Apricot, dried 35 2.9Banana, cavendish, peeled, raw 100 2.4Bean, broad, raw 50 3.6Bean, green, raw 50 1.6Beetroot, canned 80 3.1Broccoli, fresh, raw 50 1.8Brussels sprout, fresh, raw 50 2.4Carrot, mature, peeled, raw 50 2.0Potato, red skin, peeled, boiled 80 1.9Sweetcorn, kernels, canned 50 1.8Nuts and LegumesBaked beans, canned in tomato sauce 200 10.4Beans, mixed, canned, drained 60 3.7Bean, red, kidney, canned 60 3.9Nut, almond, with skin 20 1.8Nut, cashew, raw 20 1.2Nut, hazelnut, raw 20 2.1Nut, peanut, without skin, roasted, with oil, salted 20 1.2Nut, walnut, raw 20 1.3
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Attachment 2
Attachment 2: Submission template
To assist us in compiling submissions, please complete the tables below.
Submitter name:
Part A - Questions for food industry
Table 1 (response to Question 1): Foods carrying nutrition content claims about dietary fibre that do not meet the relevant qualifying criteria in Standard 1.2.7 (please add more rows as required)
Food Dietary Fibre claim on label Serving size (g) g dietary fibre per serving
Table 2 (response to Question 1): Number of foods (and SKUs) carrying nutrition content claims about dietary fibre that do not meet the relevant qualifying criteria in Standard 1.2.7 and total number of foods (and SKUs) carrying nutrition content claims about dietary fibre
Item Number of foods(as of July 2013)
SKUs(as of July 2013)
A. Foods carrying nutrition content claims about dietary fibre that do not meet the relevant qualifying criteria in Standard 1.2.7
B. All foods carrying nutrition content claims about dietary fibre
Percentage (A/B X 100)
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Attachment 2
Table 3 (response to Question 2): Cost of future labelling changes in response to qualifying criteria for nutrition content claims about dietary fibre in Standard 1.2.7
Item
Packaging materialFlexible Fibre Plastic Metal Glass
Pouch/bagLiquid
paperboard carton
Corrugated carton
Folding carton Tub Bottle Jar Aluminium
canSteel can Jar Bottle
Number of SKUs that will need the label to be changed (for each type of packaging material)
Direct cost of making a label change1
Indirect cost of making a label change2
Can the labelling changes be made at the same time as other labelling changes during the transition period for Standard 1.2.7? Indicate YES or NO for each type of packaging materialIf YES for above item, what would the marginal cost be for making the change to nutrition content claims about dietary fibre (in addition to the cost of the other label changes)?
1 Direct costs could include cost of label design, label production, proofing, package redesign, labour2 Indirect costs could include label write-off and managerial costs (including marketing and advertising)
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Attachment 2
Table 4 (Response to Question 3):Item Response
Number of foods you might reformulate (from those listed in Table 1)Estimated total cost of reformulation
$
Describe any technical issues associated with increasing the amount of dietary fibre in foods, with reference to any specific foods.
18
Attachment 2
Table 5 (response to Question 4): Cost of labelling changes already incurred in response to meeting the qualifying criteria for nutrition content claims about dietary fibre in Standard 1.2.7
Item
Packaging materialFlexible Fibre Plastic Metal Glass
Pouch/bagLiquid
paperboard carton
Corrugated carton
Folding carton Tub Bottle Jar Aluminium
canSteel can Jar Bottle
Number of SKUs for which you have already made labelling changes (for each type of packaging material)
Direct cost of making a label change1
Indirect cost of making a label change2
1 Direct costs could include cost of label design, label production, proofing, package redesign, labour2 Indirect costs could include label write-off and managerial costs (including marketing and advertising)
Table 6 (Response to Question 5)Item Response
Have you already reformulated any foods in order to meet the present qualifying criteria in Standard 1.2.7 (YES/NO)If ‘YES’, please provide the number of foods you have reformulatedIf ‘YES’, please provide the total cost of reformulation $
19
Attachment 2
Table 7 (Response to Question 6)Item Response
What would be the commercial impact if the qualifying criteria for claims about dietary fibre in Standard 1.2.7 were changed to the criteria in CoPoNC? Please provide detail.
20
Attachment 2
Part B – Questions for all stakeholders
Table 8 (Response to Question 7)Item Response
Do you think the qualifying criteria for nutrition content claims about dietary fibre in Standard 1.2.7 should be changed to the levels in the CoPoNC? (YES/NO)Please provide documented evidence to support your view.
21
Attachment 2
Table 9 (Response to Question 8)Item Response
Do you think consumers could be confused if nutrition content claims about dietary fibre that currently comply with the qualifying criteria in CoPoNC are changed in response to the qualifying criteria in Standard 1.2.7? (YES/NO)If YES, please provide any research studies that have investigated the extent to which consumers understand the difference between foods carrying different levels of dietary fibre claims, that is, source, good source, and excellent source claims.
Any information on changes in purchasing patterns in response to a change in the labelling of a dietary fibre claim is also of interest.
