Information for Submitters
A Guide to Making Submissions
Why should I make a submission?
Making a submission is your chance to influence the development of a standard or variation to a standard in the Australia New Zealand Food Standards Code (the Code).
FSANZ invites comments from the public when considering new food standards or varying existing standards in order to ensure that decision-making is underpinned by as much information as possible. To achieve this, it welcomes input from the public, from industry and from health professionals. The requirement to consult with the public is built into FSANZ’s legislation.
Consultation assists FSANZ in its decision-making by providing alternative perspectives and opinions, and evidence in relation to the Proposal or Application being considered. It helps to ensure that differing views are considered, provides a broader view of the impacts and practicality of options, and facilitates a greater awareness of the circumstances that operate and support an understanding and cooperation between FSANZ and its stakeholders.
When can I make a submission?
When FSANZ is assessing applications or proposals to change the Code, there is generally at least one period, or for more complex matters, sometimes two or more periods, during which the public is asked to provide comments in the form of submissions.
Public submissions are formally invited via email alerts through our subscription service (accessible via http://www.foodstandards.gov.au/newsroom/subscriptionservice.cfm ),Food Standards News and on the FSANZ website. Any submitters will be kept fully informed on developments with specific applications or proposals.
You can also register your interest on being informed about a specific application or proposal, without making a submission, by contacting the Standards management Officer at standards.management@foodstandards.gov.au . Information about future calls for public submissions on current applications and proposals is always available in the Food Standards Work plan at http://www.foodstandards.gov.au/standardsdevelopment/standardsworkplan.cfm .
How do I prepare a submission?
Submissions must be in writing and should be sent by email where possible. They may simply state your views and opinions, or take the form of detailed scientific or technical documents or references that discuss or support your position in relation to the application or proposal.
It is important to FSANZ’s decision-making process that submissions address the objectives and the issues and questions that have been raised and provide, where possible, supporting information and facts. To do this you need to read the relevant assessment report carefully. You may provide comment and/or answer the questions raised in the paper. In all cases, your submission will be more effective if you provide supporting evidence of your views. Unsupported assertions often do not improve the debate.
FSANZ does not make its decisions based solely on the numbers of submissions ‘for’ or ‘against’ a particular course of action, but considers the issues that are raised and any supporting evidence that is provided in all submissions, in addition to its own assessment.
Where can I find an assessment report?
Assessment reports are available for viewing and downloading from the FSANZ website www.foodstandards.gov.au . Current matters out for comment can always be found at Documents for Public Comment located under ‘What’s new’ on the home page of the website.
How much time do I have to submit my comments?
All submissions must be received by FSANZ by the date identified on the website or the front cover of each report and as stated in the public notices published in those newspapers identified above.
Note that if an extension has been made to the closing date, due to the time constraints involved in advertising in the press, the Documents for Public Comment page will be the only place that the extended date will be advised.
If for some reason you cannot meet the deadline set for the receipt of public submissions, you will need to contact the Standards Management Officer - standards.management@foodstandards.gov.au - to see if an extension is possible. However, you should be aware that extensions will not be granted if it would be inequitable for all other submitters, or if a matter needs to be completed urgently.
What should I include in my submission?
Your submission to FSANZ should include:
- the number or the name of the application or proposal;
- your name and full contact details including: position, address, telephone number, fax and email address; and
- the level at which the submission was authorised in the case of organisations.
In addition, submissions might:
- identify and discuss any alternative options/solutions, apart from those already suggested;
- identify additional sectors, groups or individuals who may be affected and who should be consulted by FSANZ;
- provide factual information and data concerning the impact of proposed options on affected parties, i.e. benefits/costs of providing information on labels as a result of a proposed regulatory change;
- identify your preferred option; and
- provide any other relevant information e.g. scientific and technical, economic, international obligations, business and consumer information.
Your submission will have greater impact if it:
- is written with regard to the policy framework within which FSANZ is required to work;
- comments on the issues raised and possible options; and
- provides as much supporting evidence as possible.
Your submission should:
- be kept simple, clear and concise – your submission should be written in a style which is easy to read and which organises ideas and thoughts logically;
- be supported by relevant, reputable and current data where possible;
- use appropriate and specific case examples; and
- include a brief summary, especially if the submission is lengthy.
It is helpful, but not decisive, if submitters understand the role of FSANZ and its areas of responsibility. Many submissions are received that raise issues and concerns which FSANZ cannot address. It may be the case that these issues need to be raised with other Commonwealth agencies or State or Territory Governments or the New Zealand Government.
If in doubt, contact the Standards Management Officer for clarification at standards.management@foodstandards.gov.au
What happens to my submission?
When submissions are received, an acknowledgement from the Standards Management Officer will be sent within a day or so of receipt to let submitters know that their submission has been received.
The processes of FSANZ are open to public scrutiny, and any submissions received will ordinarily be placed on the public register of FSANZ and made available for inspection. It is planned that, in the future, all submissions will be placed on the FSANZ website.
If you wish that any information contained in a submission is to be treated as confidential by FSANZ, you should clearly identify the sensitive information and provide justification for treating it in-confidence. FSANZ is required to treat information as confidential if it identifies trade secrets relating to food and any other information relating to food, the commercial value of which would be or could reasonably be expected to be destroyed or diminished by disclosure. If FSANZ does not agree that the information meets these criteria, the author of the submission will be given an opportunity to withdraw the submission before it is made public.
All submissions and the relevant issues raised will be considered. The Draft and Final Assessment Reports should address the issues raised in the submissions. In some cases, they may be addressed individually in an Assessment Report and a response provided, or if a substantial number of submissions have been received, the issues raised might be summarised and a general response provided in the Report.
To whom should I send my submission?
FSANZ prefers that you lodge your submissions electronically through the FSANZ website using the ' Lodge a submission ' tab below or through Documents for Public Comment or under ‘What’s new’ on the home page of the website. This facility allows you to either attach electronic documents or to compose shorter submissions onscreen. If you have difficulties in lodging your submission, contact the Standards Management Officer as soon as possible.
FSANZ will also accept submissions emailed to standards.management@foodstandards.gov.au copies which should be addressed to the Standards Management Officer at PO Box 7186, Canberra BC ACT 2610.
Questions relating to making submissions or the application process should be directed to the Standards Management Officer by emailing standards.management@foodstandards.gov.au
Where can I obtain further information?
If you wish to be placed on a mailing list for future advice on a specific application or proposal, please contact the Standards Management Officer on standards.management@foodstandards.gov.au attaching this sheet with completed details or phoning +61 2 6271 2280.
If you want to hear about applications and proposals that FSANZ are developing and want to be included in the regular subscribers list then register on-line to our free Subscription Service . For assistance in registering on-line contact FSANZ Information Officer on +61 2 6271 2241.
Further information about FSANZ can be obtained from the FSANZ website at: www.foodstandards.gov.au or from the Information Officer in Australia email: info@foodstandards.gov.au ; or in New Zealand email: info@foodstandards.govt.nz
- Please Note: You should not provide ‘commercial-in-confidence’ material through the website