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Technical Evaluation for Labelling Review Recommendation 43: Perceptible Information Principle

​(September 2013)

Executive Summary

In 2009, the then Australian and New Zealand Ministerial Council for Food Regulation (now known as the Australia and New Zealand Ministerial Forum on Food Regulation (Forum)) agreed to a comprehensive independent review of food labelling law and policy. An expert panel, chaired by Dr Neal Blewett, AC, undertook the review and the panel’s final report, Labelling Logic: Review of Food Labelling Law and Policy (2011) (Labelling Logic) was publicly released in January 2011.

Recommendation 43, one of several recommendations relating to presentation of information on food labels in Labelling Logic states: That the Perceptible Information Principle be used as a guide for labelling presentation to maximise label comprehension among a wide range of consumers.
 
In the government response to Recommendation 43, the Forum asked FSANZ to undertake a technical evaluation and provide advice on the application of the Perceptible Information Principle to the presentational aspects of food labels, as well as whether the Perceptible Information Principle as a tool to aid food label design has benefits over other tools.
 
In response to the Forum’s request for technical evaluation and advice, FSANZ has:
  • commissioned a literature review on the impact of format/presentation on consumer use and understanding of label information and the application of the Perceptible Information Principle to presentational aspects of information on food labels
  • considered the requirements in the Australia New Zealand Food Standards Code (the Code) and any guidance provided by industry and jurisdictions relating to the presentation of mandatory food label information
  • compared requirements in Canada, the United States of America (USA) and the European Union (EU) relating to the presentation of mandatory food label information with those in the Code
  • evaluated the suitability and effectiveness of requirements/guidance, the Perceptible Information Principle and any other tools for presentational aspects of mandatory information on food labels.
The Perceptible Information Principle  is one of seven principles of universal design developed in 1997 from the disability rights movement in the USA. To date, the principles have not been widely adopted by the design community and have not been explicitly applied to food labelling. In addition, only guidelines and not specific recommendations for optimising design are provided. Nonetheless, the Perceptible Information Principle can be applied to the format and presentation of mandatory information on food labels.
 
Two of the five guidelines associated with the Perceptible Information Principle refer to legibility and contrast. Legibility and contrast are covered in Standard 1.2.9 – Legibility Requirements of the Code in general terms and to a greater extent in the FSANZ user guide for Standard 1.2.9. Guidance on allergen labelling is also available from the Australian Food and Grocery Council.
 
The remaining three guidelines are not specifically covered in the Code but can be applied to food labelling. These guidelines include the use of more than one mode of providing information, such as pictorial and textual modes together, differentiation of information and the use of computer technology. However, the intent of the guidelines could be applied to the provision of mandatory label information, both via the label and by other means, through developing further guidance, if required.
 
No other tools similar to the Perceptible Information Principle have been identified. However, best practice advice/guidance is available which can assist with the presentation of information on food labels. Although the current evidence base is limited, there are a number of factors relating to the presentation of information on food labels identified in the literature that are considered to be helpful in attracting consumers’ attention and also in aiding knowledge acquisition. Many of these factors are not encompassed by the Perceptible Information Principle, for example grouping and consistency of information, but have been included in guidance documents available for use in other countries. The effectiveness of such guidance documents in improving the format and presentation of mandatory label information is unknown.
 
Food regulations in Canada, the USA and the EU include detailed requirements relating to legibility and format of mandatory information on food labels in contrast with the general legibility criteria in the Code. Reasons for having general legibility criteria in the Code include the recognition that legibility can be optimised using a number of effective combinations of criteria and that regulations should be no more prescriptive than is necessary to protect public health and safety while providing maximum flexibility for food businesses.
 
In conclusion, the Perceptible Information Principle can be applied to the format and presentation of mandatory information on food labels but has not been explicitly applied to date. The Perceptible Information Principle is chiefly about principles of good design and does not provide any degree of detail or prescription that assists designers to meet the principles. Some aspects of the Perceptible Information Principle are covered in the Code and an associated user guide. No other tools similar to the Perceptible Information Principle have been identified, however, some best practice advice/guidance is available both locally and overseas. The best practice advice/guidance includes factors relating to the presentation of information on food labels identified in the literature review to be helpful for consumers. The effectiveness of the best practice advice/guidance is unknown.
 

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