8 Other Labelling issues
8.1. Labelling issues of concern
8.2. Any changes observed to the way allergens are listed on food labels
8.3. Suggested improvements to food labels
8.1 Labelling issues of concern (Q31)
Respondents were first asked whether there were any labelling issues that were of particular concern to them in selecting different food products for the person with the allergy, and then given the opportunity to comment in a spontaneous manner (Q31). Their responses were then coded and the results are presented in section 8.1.1.
Following this, respondents were then presented with a list of comments about labels and asked to indicate how often each of them happens when they are assessing the suitability of a food product (Q32). Results for this prompted measure are presented in section 8.1.2.
8.1.1 Spontaneous (Q31)
Two thirds of respondents (66%) said there were labelling issues that had caused them concern in attempting to identify foods that are suitable for the person(s) with the food allergies; more likely for those who belonged to a support group (76% versus 55% who did not).
Those respondents who did say they were concerned about labelling issues were then asked to describe what these were. Results are shown in Table 8.1.1.
Table 8.1.1 Issues with food labels (spontaneous)
Q31b What problems do you encounter when trying to identify foods that are suitable for the person(s) with an allergy?
The issues that appear to be of most concern were under the following themes:
- lack of understanding on the part of the consumer about specific things on food labels, such as emulsifiers and code numbers (food additives);
- the use of 'may contain' statements whereby respondents said the statements were not clear or were overused, and their use unnecessarily restricted food choices for those with allergies;
- the derivation of various ingredients such as 'vegetable' oil, and the use of the terms 'flavours' and 'spices';
- manufacturers issues that included unlabelled ingredients or changes to ingredients without notice, and also the issue of manufacturers avoiding the responsibility for labelling what is in their products; and
- labelling issues including the varied location of information on labels. The desire for percentage labelling and the belief that imported products are not subject to the same labelling laws as Australian / New Zealand produced items. It should be noted however, that imported foods in Australia and New Zealand are required to conform to the food labelling standards contained in the Code.
8.1.2 Prompted (Q32)
The results of the prompted measure are shown in Table 8.1.2.
Table 8.1.2 Problems encountered with labels
| Product used many times safely suddenly lists ingredient | Different names on label for the ingredients I need to avoid | Sometimes 'spices' and 'natural flavours' include the ingredient I need to avoid | Reaction to product that did not have problem ingredient listed | Different sized packages of the same product have different ingredients listed | Outside label varies from individual inside labels | Ingredient is in product but not listed on label | Product inside is different to what label says |
base: all respondents ( n) | (n=510) | (n=510) | (n=510) | (n=510) | (n=510) | (n=510) | (n=510) | (n=510) |
| % | % | % | % | % | % | % | % |
31 | 25 | 18 | 7 | 7 | 4 | 2 | 1 | |
Sometimes happens | 38 | 39 | 24 | 30 | 24 | 19 | 18 | 8 |
Seldom happens | 12 | 12 | 12 | 14 | 15 | 21 | 23 | 26 |
Never happens | 13 | 12 | 23 | 41 | 30 | 33 | 47 | 56 |
Don't know | 4 | 10 | 21 | 7 | 22 | 21 | 8 | 8 |
Not answered | 1 | 2 | 2 | 1 | 2 | 2 | 2 | 1 |
The boxes indicate the combined results reported in the text below.
Several of the issues relating to food labels were experiencedoftenorsometimesby around two thirds of respondents. These were:
- a product that has been used safely many times, suddenly has the ingredient of concern listed (69%); and
- there are different names on the label for the ingredients that need to be avoided (64%).
Three issues were experiencedoftenorsometimesby around a third of respondents:
- 'spices' or 'natural flavours' sometimes include the ingredient that needs to be avoided (42%);
- there was a reaction to the product even when it did not have the potential allergen listed in the ingredient list (37%); and
- different sized packages of the same product have different ingredients listed (31%).
Around one in five experience the following events often or sometimes:
- the outside label on a product differs from what is on individual inside labels (23%); and
- the ingredient is in the product but not listed on the label (20%).
8.2 Any changes observed to the way allergens are listed on food labels (Q33)
In order to facilitate the measurement in the follow-up survey of changes brought about by the allergen labelling requirements in Australia and New Zealand contained in the Code, a question was asked about changes that may have been observed to labels.
Almost two thirds (63%) of respondents said they had noticed some changes in the previous 12 months, with no variation by country. Respondents who belonged to support groups were significantly more likely than those who did not, to have noticed change (82% versus 44% respectively).
Respondents were then asked what changes they had noticed. This was an open-ended question. Results are shown in Table 8.2.
Table 8.2 Changes seen to labels
Q33b What sorts of things have you noticed?
| . | total | country | |
| . | Australia | New Zealand(b) | |
base: those who said they had seen a change to labels ( n) | (n=323) | (n=257) | (n=66) |
| %* | %* | %* |
'May contain' now appears on everything | 45 | 44 | 47 |
Bold print for allergens | 23 | b 20 | a 33 |
A lot more information now included | 14 | b 20 | a 33 |
All/more/most products have warnings about nuts | 14 | b 16 | a 6 |
Made on same product line / equipment[currently used] | 12 | b 14 | a 3 |
Blanket statements eg ‘contains dairy/seeds/eggs…’ | 9 | b 11 | a 0 |
'Made in the same factory …'[currently used] | 5 | 6 | 2 |
'Made in the same premises …'[currently used] | 5 | 5 | 4 |
More products are labelled / clearly labelled | 5 | b 3 | a 14 |
Source of ingredients now listed | 5 | 5 | 3 |
Subtotal of those currently USED | 16 | b 18 | a 6 |
ab Indicates categories where there was a significant difference between the results in each column (significance at the 95% confidence level )
* Exceeds 100% due to multiple responses.
Almost half of respondents (45%) indicated that they were aware of increasing use of the 'may contain' disclaimer.
A quarter (23%) mentioned the bold type for allergens, however, this comment was more likely to be made by New Zealand respondents than Australians (33% versus 20% respectively). New Zealanders were also significantly more likely than Australians to have noticed that a lot more information is now included(33% versus 20% respectively), and that more products are now labelled or more clearly labelled (14% versus 3% respectively).
On the other hand, Australians were significantly more likely than New Zealanders to say that they had noticed:
- all or more products had warnings about nuts (16% versus 6% respectively);
- the use of the 'made on the same product line or equipment' statement (14% versus 3% respectively); and
- the use of blanket statements about other allergens such as dairy, seeds, eggs, etc, not just nuts (11% versus 0%).
As shown in the sub-total, 16% nominated measures that are part of the Code – 18% of Australians and 6% of New Zealanders.
8.3 Suggested improvements to food labels (Q34)
Finally, respondents were asked whether they had any suggestions about how food labels might be improved to indicate the presence of allergens. Results are shown in Table 8.3.
Table 8.3 Suggested improvements to food labels
Q34 Are there any other things you'd like to see on food labels? Do you have any suggestions about how food labels can be improved to make it easier for you to both find products that contain the problem ingredient or locate products that do not contain that ingredient?
| . | total sample | country | |
| . | Australia | New Zealand | |
base: all respondents ( n) | (n=510) | (n=413) | (n=97) |
| %* | %* | %* |
Should use plain English | 12 | 12 | 14 |
Need more detail about meaning of things | 7 | 6 | 9 |
Should say what ingredient is derived from | 5 | 5 | 5 |
Different words for same thing / should be uniform | 5 | b 6 | a 1 |
'Flavours', 'spices', 'colours' not explicit enough | 4 | b 3 | a 9 |
Additive Code numbers are meaningless | 4 | 4 | 6 |
Need to know what type of ‘nuts’ | 4 | b 4 | a 0 |
'Dairy' has lots of other names (casein, whey, etc) | 4 | 3 | 4 |
Need to know the source of vegetable oil | 3 | 3 | 3 |
SUBTOTAL1: Clarity or understanding | 42 | b 40 | a 52 |
Should be bold print or larger writing on labels | 16 | b 14 | a 23 |
Warning statement should be located near ingredient list | 5 | b 4 | a 11 |
Location of label information should be standard | 3 | b 2 | a 6 |
Comments about format of ingredients list | 3 | 3 | 4 |
SUBTOTAL1: Formatting | 27 | b 23 | a 44 |
Should say 'No nut / Nut free' | 11 | b 12 | a 4 |
Should say egg-free, dairy-free | 6 | b 4 | a 16 |
Symbols for 'free' or safe products | 6 | 6 | 3 |
SUBTOTAL1: Should say when substance not present | 23 | 23 | 23 |
Table 8.3 Suggested improvements to food labels (continued)
| . | total sample | country | |
| . | Australia | New Zealand | |
base: all respondents ( n) | (n=510) | (n=413) | (n=97) |
| %* | %* | %* |
Should say does or does not contain, not 'may' | 11 | 11 | 8 |
Manufacturers using 'may contain' to cover themselves | 5 | b 6 | a 1 |
The words 'may contain' increasingly overused | 4 | 4 | 2 |
Should substantiate 'may contain' statements | 3 | 4 | 1 |
SUBTOTAL1: 'May contain' statements | 22 | b 25 | a 12 |
All % should be listed (to ascertain level of ingredient in food and therefore assess risk) | 5 | 6 | 2 |
All ingredients should be listed | 4 | 4 | 6 |
SUBTOTAL1: Accuracy | 9 | 10 | 8 |
ab Indicates categories where there was a significant difference between the results in each column (significance at the 95% confidence level )
* Exceeds 100% due to multiple responses.
1 The subtotal is a count of respondents, not responses, i.e. respondents may have given more than one response in the category, and hence the sub-total is not the sum of all responses shown.
From the results, it seemed that food labelling was a salient issue for the respondents in this survey, as indicated by the number of responses recorded.
Major issues for respondents were those of clarity or understanding of the information on food labels:
- should use plain English;
- need more detail about meaning of things;
- 'dairy' has lots of other names (casein, whey, etc);
- 'flavours', 'spices', 'colours' not explicit enough;
- code (additives) numbers are meaningless;
- lots of different words for the same thing. Naming of ingredients should be uniform;
- need to know the source of ‘vegetable oil’;
- should say what an ingredient is derived from; and
- need to know what type of ‘nuts’.
In total, 42% of respondents made comments relating to these issues and the level recorded in the New Zealand sample were significantly higher than in the Australian sample (52% versus 40% respectively).
Another major concern was the 'may contain' statements, with many comments made in relation to this:
- manufacturers should substantiate 'may contain' statements;
- they should say does or does not contain, and not 'may contain';
- the 'may contain' statement is overused; and
- manufacturers are covering themselves legally.
When specific answers were combined, a total of 22% made a comment about the 'may contain' statements. Significantly more Australian respondents commented on the ‘may contain’ statements than the New Zealand respondents (25% versus 12% respectively).
And related to this, some respondents preferred products being labelled to indicate when the substance of concern was not present rather than that it 'may be' present:
- should say 'No nut’ or ‘Nut free';
- should say ‘egg-free’, or ‘dairy-free’; and
- use symbols for 'free' or ‘safe’ products.
In total, 23% respondents said products should be labelled to indicate when the substance of concern is not present, and the proportions who said this were similar in both countries.
The accuracy of labelling information was also a concern:
- all [ingredient] percentages should be listed (to ascertain level of ingredient in food and therefore assess risk); and
- all ingredients should be listed.
In this regard, one in ten (10%) respondents raised labelling information accuracy as an issue, to a similar degree in both New Zealand and Australia. It has been noted throughout the report that many of these potential problems have been addressed in the Code, for example in Standard 1.2.3 for the listing of components of compound ingredients and Standard 1.2.4 for specifying the source of cereals, starch, fats and oils. However, at the time of this survey, foods were still available for sale that had been labelled according to the old regulations, due to stock-in-trade provisions that were in force after December 2002.
Various formatting issues were also suggested for improvement:
- should use bold print or larger writing (font size) on labels;
- warning statements should be located near ingredient list;
- location of label information should be standard; and
- comments about format of ingredients list.
Twenty seven percent of respondents mentioned formatting issues, and again New Zealanders were more likely to mention this than Australians (44% versus 23% respectively).
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