Food Label Monitoring Surveys
Food Standards Australia New Zealand (FSANZ) has been conducting label monitoring surveys to assess the progress on implementation of labelling changes on packaged food products since 20 December 2002. Correct labelling is considered an important aspect for FSANZ to achieve one of its objectives of ensuring consumers have adequate information on food labels to assist them to make an informed choice.
The 2002 and 2003 surveys examined food labels and compared the label information to key labelling requirements of the new Australian New Zealand Food Standards Code(the Code), focusing on those that had changed compared to the old Code. Transitional standards, such as 1.1A.2 Transitional Standard for Health Claims and 1.1A.3 Transitional Standard for Country of Origin Labelling, were not included as, at this time, no changes had been made to these standards.
During the survey period, 2002 and 2003, some foods manufactured complying with the old regulations were still available for purchase. This was because there was a 12 month stock-in-trade provision for foods manufactured prior to 20 December 2002 and a 24 month provision for long life foods (shelf life greater than 12 months). Foods manufactured directly in-store were allowed to continue being labelled as before for twelve months from 20 December 2002.
The pleasing news is that the 2002 and 2003 surveys showed high levels of consistency on products manufactured to the new Code for key labelling requirements. These key requirements were declarations of allergens, usage instructions, ingredients lists, product name and overall legibility of labels. Levels of consistency for other key labelling requirements that were not quite so high but did improve from 2002 to 2003 were: date marking, storage instructions and labelling of characterising ingredients (percentage labelling).
However, the surveys did show that some food manufacturers were still having problems with the correct presentation of the nutrition information panel, as required in the Code. This panel shows the amount of energy, protein, fat, saturated fat, carbohydrate, sugar and sodium (salt) in a product. The reported problems ranged from those assessed as minor ones that were not considered to affect consumer understanding of the information presented, for example, the use of upper case font rather then lower case or missing borders, to those assessed as major inconsistencies, such as panels not indicating that the values given were averages, incorrect values, missing headings or on occasion, nutrients missing or in the wrong order on the panel.
Nutrition information panels are an important public health tool as they enable consumers to make an informed choice about the nutrient content of the product that they are purchasing. It is important that the information on food labels, in particular the nutrition information panel, is correct and in a readable format. FSANZ’s previous research with consumers on labelling issues shows that consumers often use nutrition panel information to verify nutrition claims.
Food manufacturers can check the accuracy of their nutrition panels by referring to the fact sheets and user guides on the FSANZ website or by running the information through the nutrition panel calculator at http://www.foodstandards.gov.au/mediareleasespublications/nutritionpanelcalculator/. |
What were the new food labelling changes?
The new Food Standards Code, which was gazetted in December 2000 and came into full force for any food sold in Australia and New Zealand after 20 December 2002 (excluding the stock-in-trade provisions), made a number of changes to the labelling of packaged foods. These included:
- Mandatory nutrition information panels on nearly all packaged foods showing average energy content, protein, fat, saturated fat, carbohydrates and sugars, and sodium (salt). The only exceptions to this are very small packages, and foods that have minimal nutrition such as single herbs or spices and tea or coffee.
- The major food allergens, such as eggs, milk, fish, peanuts and other nuts, sesame, soybeans, and cereals containing gluten (eg wheat) and their products must be labelled however small the amount.
- Date marking was clarified to ‘Use By’ dates, which mean the food cannot be legally sold or consumed after that date for public health and safety reasons, and ‘Best Before’ dates, where the food may still be sold after the date but may not retain some of the specific qualities for which any claims are made on the product.
- Ingredients must be listed in descending order (by ingoing weight). If the product contains added water, it also must be listed in the ingredients list according to its ingoing weight (making an allowance for any water lost in processing, for example by evaporation or from reconstitution), except when the water makes up less than 5% of the finished product.
- The percentage of the main or ‘characterising’ ingredient must be listed in the ingredients list, for example the percentage of strawberry in a strawberry yoghurt.
Existing labelling requirements were also retained. These were:
- Labels must be legible and in English.
- Foods must be labelled with an accurate name or description, for example a ‘strawberry’ yoghurt must actually contain strawberries.
- Labels must have the name and business address in Australia or New Zealand of the supplier (manufacturer or importer), as well as the lot identification of the food for food recall purposes.
- Where specific storage conditions are required in order for a product to keep until its ‘Best Before’ or ‘Use By’ date, manufacturers must include this information on the label, for example ‘this yoghurt should be kept refrigerated’.
- Food additives must be listed in the ingredients list by its class name followed by the prescribed number or specific name in brackets e.g. thickener (414 or gum Arabic).
- In Australia there must be a country of origin statement.
- A food must be labelled as genetically modified if it has altered DNA or protein in the final product. A food label must include the statement ‘genetically modified’ in association with the food or ingredient if it has DNA or protein in the final product
- A food that has been irradiated must be labelled as having been treated by irradiation (only herbs, spices, herbal infusions and some tropical fruits are currently permitted to be irradiated).
Food manufacturers can check the labelling requirements by referring to the fact sheets and user guides on the FSANZ website and the New Zealand Food Safety Authority (NZFSA) website. State authorities also provide labelling information. There is more information on the changes at http://www.foodstandards.gov.au/whatsinfood/foodlabelling.cfm A shoppers guide to food additives and labelling is also available in book stores for consumer use http://www.foodstandards.gov.au/mediareleasespublications/publications/shoppersguide/index.cfm And in New Zealand a Food Additives and a labelling booklet is available free on line at http://www.nzfsa.govt.nz/consumers/food-safety-topics/food-processing-labelling/food-additives/index.htm or by calling the NZFSA on 0800 69321. Other useful websites are given in the additional materials information sheet. |
Why has FSANZ conducted these surveys?
FSANZ carried out these surveys to assess progress of implementation of the new food labelling regulations in the Code, the first step being to collect baseline data on labelling on food products.
The surveys did not include an assessment of labelling requirements that had not changed in the Code at that time, such as those for country of origin labelling or use of nutrition and health claims.
What was surveyed?
The surveys aimed to examine the labels of 1200 items each year, selected from 14 food categories (approximately 2.5% of the product lines available) from a range of outlets including both supermarkets and small retailer. The food categories were:
- Dairy products
- Edible oils and emulsions
- Ice cream and edible ices
- Fruit and vegetables
- Confectionery
- Cereal and cereal products
- Bread and bakery products
- Meat and meat products
- Fish and fish products
- Egg and egg products
- Sugar, honey and related products
- Food intended for particular dietary uses
- Non-alcoholic beverages
- Mixed foods (eg sauces, dressings, desserts)
The sample was broadly representative of products available for sale in Australia and New Zealand and was based on the level of variety within each food category. There were an estimated 50,000 food product lines available in Australia and New Zealand at the time of the surveys, with different sizes of the same product being listed as separate product lines (70% products were available in both countries).
When were the surveys held?
The 1st stage was carried out in 2002 before the new regulations were mandatory as a benchmark for further measurement and the 2nd stage in 2003 while some long shelf life goods produced under the old regulations were still on the shelf.
What did the surveys find?
Stage 1 of the surveys was held in 2002 and Stage 2 in 2003 and examined labels of products manufactured to the new Code. The survey examined each label against twelve key labelling requirements in that Code. Thirty five percent of labels collected in 2002 (448 labels) and 91% labels collected in 2003 (1153 labels) were fully assessed. The main findings of surveys were:
Labelling requirement | Stage 1 Percent (%) labels consistent with labelling standards , for labels required to or voluntarily providing information | Stage 2 Percent (%) labels consistent with labelling standards, for labels required to or voluntarily providing information |
Overall label legibility | 92 | 91 |
Allergen declarations* | 100 | 100 |
Mandatory advisory statements* | 100 | 100 |
I ngredient declarations* | 99 | 99 |
Usage instructions* | 100 | 99 |
Product name* | 100 | 99 |
Storage instructions | 89 | 93 |
Date markings | 72 | 80 |
Compound ingredients | 71 | 70 |
Characterising ingredients | 38 | 57 |
Nutrition information panel (Standard NIP only)# | 36 major reasons 51 intermediate reasons 1 minor reasons | 49 major reasons 55 intermediate reasons 0 minor reasons |
*Based on legibility only
# The reasons an NIP may have been assessed as inconsistent were grouped into major, intermediate and minor, depending on the potential impact on consumer understanding of the information in the panel (ie major reasons were those NIP components that would have the most serious impact on consumer understanding of the NIP if labelled incorrectly). See below for explanation of results.
Note: Genetically modified (GM) ingredients were declared on one label in Stage 1 and on no labels in Stage 2. No labels in either stage declared treatment with ionising radiation.
The surveys showed significant progress made by industry in implementation of the key labelling requirements, such as declarations of allergens, usage instructions, ingredients lists, product name and overall legibility of labels. Levels of consistency for other key labelling requirements that were lower but improved from 2002 to 2003 were: date marking, storage instructions and labelling of characterising ingredients (percentage labelling).
The survey results also showed that the requirements in relation to the nutrition information panel had presented some problems. The panels were assessed against the prescriptive nutrition information panel labelling requirements in the Code, with inconsistencies classed as minor, intermediate or major. The type of inconsistency was determined by their potential impact on consumer understanding and on consumers’ ability to compare two different labels easily, noting that each label could be inconsistent for more than one category.
For standard nutrition information panels, virtually all inconsistent labels (99% of the 346 labels inconsistent for the nutrition information panel in Stage 1 and 100% of the 1063 labels inconsistent for the nutrition information panel in Stage 2) had minor inconsistencies, such as the use of upper case font instead of lower case, lack of borders or punctuation differences. There was an improvement in the proportion of labels with intermediate and major inconsistencies between Stage 1 and Stage 2. Comparing the two Stages, 49% (Stage 1) and 45% (Stage 2) had intermediate inconsistencies, such as incorrect position of a column of information within the nutrition information panel. In Stage 1, 64% panels had major inconsistencies, while in Stage 2, 51% had major inconsistencies, such as values not presented as averages, incorrect units, missing headings or missing nutrients or nutrients in the wrong order.
FSANZ had an agreement with the contractor that they must notify FSANZ immediately if a product was identified in the label monitoring survey that gave rise to public health and safety concerns, such as incorrect allergen labelling. FSANZ would then contact the relevant enforcement agency. This did not arise during the 2002 or 2003 surveys.
What will happen now?
FSANZ has initiated discussions with key food industry organisations in Australia on the best way to ensure all manufacturers have the correct information on labelling requirements. One of the outcomes of these discussions is a plan to hold a number of joint FSANZ/Australian Food and Grocery Council workshops on food labelling with members of the food industry during 2006. FSANZ will also undertake similar discussions with the NZFSA and the New Zealand food industry.
FSANZ will continue to monitor food labels in 2005 and 2006. The 3rd stage survey commenced in April 2005 when all packaged food must comply with the new rules and a further survey will be undertaken in 2006. The new surveys will include an assessment of nutrition and health claims on food labels as well as the twelve key labelling elements assessed in previous surveys.
These surveys are not intended for enforcement purposes as compliance and enforcement surveys are the responsibility of the Australian States and Territories and of New Zealand. However, if a trend of non-compliance becomes evident following the 2005 survey, and Australian State and Territory and New Zealand food agencies have not identified similar issues of non-compliance through enforcement activity, discussions between the jurisdictions and FSANZ will explore appropriate action, including consideration of the need to review the current labelling standards. FSANZ, in parallel with many jurisdictions and food industry organisations, is considering the best ways to assist manufacturers get helpful information on labelling requirements.
| Copies of the executive summary and full label monitoring report are now available on the FSANZ website at http://www.foodstandards.gov.au/mediareleasespublications/publications/evaluationreportseries/foodlabelmonitoringsurvey/index.cfm For further information please contact Janis Baines by phone (02 6271 2234) or email (janis.baines@foodstandards.gov.au). |
| A separate survey on the labelling of GM food published by FSANZ in 2004 found all those sampled complied with the Food Standards Code. The survey is available at http://www.foodstandards.gov.au/mediareleasespublications/publications/gmlabellingreviewrep2460.cfm In New Zealand a GM labelling Survey found one products to be non-compliant with the Food Standards Code. This was published in 2003 and is available at |
A food industry information sheet 'Results of Food Label Monitoring Surveys: Identifying Key Labelling Issues' is available 'here'
For further information please contact Janis Baines by phone (02 6271 2234) or email ( janis.baines@foodstandards.gov.au ).