Proposal P240 - Labelling Statements On Reduced Fat And Condensed Milks
FINAL ASSESSMENT REPORT (INQUIRY - SECTION 24)
July 2002 (Corrected version)
EXECUTIVE SUMMARY
Evidence indicates that the consumption of reduced fat milk, modified milks and milk alternatives, as the main source of milk, by children under two years is a public health concern.
The Australian (Draft) and New Zealand Dietary Guidelines suggest that reduced fat milks and skim milks with a fat content of no more than 2.5% are unsuitable as the main source of milk for children under two years of age. The possible effects on health of children under two consuming reduced fat milks or milk alternatives include growth failure and chronic non-specific diarrhoea.
There is a risk that existing information is not sufficient for carers of young children to make appropriate choices about the feeding of reduced fat milks and milk alternatives to their children at the point of purchase.
The objectives of this review are to:
1. Ensure carers have accurate and adequate information available to them to make informed choices about the feeding of reduced fat milks, modified milks and milk alternatives to their children.
2. To develop a harmonised approach to the requirements between Australia and New Zealand, if labelling statements are required.
The options proposed at Draft Assessment were:
1. maintain the status quo and continue to have different warning statements on reduced fat and condensed milk products in Australia and New Zealand; or
2. delete the current prescriptive requirements for warning statements on specified milk products and develop an advisory statement for Australia and New Zealand. The statement would be required on:
a. milk with a fat content of no more than 2.5%; or
b. milk, condensed milk, evaporated milk and dried milk with a fat content of no more than 2.5%; or
c. milk, condensed milk, evaporated milk, dried milk, soy beverages with a fat content of no more than 2.5%; or
d. milk, condensed milk, evaporated milk, dried milk, soy and rice beverages with a fat content of no more than 2.5%.
3. delete the requirement to include a warning/advisory statement on specified milk products and rely on education through the public health system and other means to advise on the unsuitability of feeding these products to children (less than 2 years).
The impacts indicate that an advisory statement will be beneficial to consumers in reducing the consumption of reduced fat milks and milk alternatives by children under two years of age. An advisory statement will also allow harmonisation of labels between Australia and New Zealand whilst allowing industry to place the statements on their labels in such a way as to not discourage the provision of other milks to children under two years, and milks more generally to older children. The initial costs of labelling changes to industry will be outweighed by a potential reduction of growth and development problems in children.
ANZFA undertook two rounds of public consultation for this proposal as outlined in Section 21 of the ANZFA Act. At each stage of consultation ANZFA received 17 submissions (17 at Initial Assessment and 17 at Draft Assessment). (See Attachment 2 for summary of submissions received at Draft Assessment).
ANZFA convened an External Advisory Group after the first round of public consultation (Initial Assessment) consisting of representatives of the dairy industry, government, public health and consumer groups to:
1. identify evidence that may support or refute the options proposed by ANZFA; and
2. consider submissions, with regard to harmonising labelling statements on reduced fat (no more than 2.5%) milks, modified milks and milk alternatives (soy and rice beverages) between Australia and New Zealand.
The preferred option is 2d, with the removal of the requirement for an advisory statement on condensed milks.
After further consideration, condensed milk should not be required to carry an advisory statement because the use of the product has changed with advances in milk technology. Condensed milk is no longer used as a substitute for milk and is not marketed as such by manufacturers. Therefore, as it is unlikely to make up a major proportion of a child's diet it would be unnecessary to warn carers of the risks associated with consuming reduced fat versions.
This option will assist to reduce the consumption of reduced fat milk, modified milks and milk alternatives as the main source of milk by children under two years of age. This option is superior because it provides carers with information on a wider range of reduced fat products, reducing the potential for growth and development problems in children under two years of age.
Option 2d with the removal of condensed milk will address the risk that existing information is not sufficient for carers of young children to make appropriate choices about milks, modified milks and milk alternatives at the point of purchase by providing labelling information. Qualitative evidence suggests that consumers use labelling information to determine product choice and in pregnant women and parents with young children this increases.
This option will ensure that statements between Australia and New Zealand will be harmonised and allow manufacturers to place positive statements on their products.
Recommendation and Statement of Reasons
ANZFA's reasons for the decision are as follows:
The current labelling provisions in Australia and New Zealand require a mandatory warning statement on skim milk, modified milk and condensed milk. The warning statements in Australia and New Zealand are different with respect to wording and the milk and milk products covered by the statements need to be reviewed before the repeal of the existing regulations (December 2002).
The External Advisory Group agreed that the scope of the Proposal should be to address the inappropriate feeding of milks, modified milks and milk alternatives (soy and rice beverages) with a fat content of no more than 2.5% to children under two years of age as the main source of milk. The scope was expanded to include soy and rice beverages because anecdotal evidence from health professionals suggests they are being fed to children.
Qualitative evidence suggests that consumers use labelling information to determine product choice and this practice increases for pregnant women and parents with young children. While there is no evidence specifically on the use of labelling statements on milk this suggests they may be useful in alerting carers to the risk of feeding reduced fat milks, modified milks and milk alternatives to their children.
Dietary Guidelines in Australia and New Zealand suggest that reduced fat milk and skim milk with a fat content of no more than 2.5% are unsuitable for children under two years of age.
Evidence from the National Health and Medical Research Council (NHMRC) indicates the possible effects on health of children under two consuming reduced fat milk products as the main source of milk include growth failure and chronic non-specific diarrhoea.
An advisory statement to address the issue of the inappropriate feeding is consistent with ANZFA principles for labelling statements and the Coalition of Australian Government principles of minimum effective regulation.
Consideration of the impacts indicate that an advisory statement will be beneficial to consumers in reducing the consumption of reduced fat milks, modified milks and milk alternatives by children under two of age as the main source of milk. An advisory statement will also allow harmonisation of labels between Australia and New Zealand whilst allowing industry to place positive statements on their labels.
Condensed milk should not be required to have an advisory statement because with advances in milk technology the use of the product has changed and it is no longer used as a substitute for milk. This is reflected by the marketing of the product that indicates it is designed for use in recipes and cooking. Therefore, as it is unlikely to make up a major proportion of a child's diet it would be unnecessary to warn carers of the risks associated with consuming reduced fat versions.
In light of the available evidence, with due consideration ANZFA has recommended that an advisory statement be placed on reduced fat milks, modified milks and milk alternatives to protect consumers by alerting carers of young children to the issue and to cover those products which could lead to growth and development problems if fed to children under the age of two as the main source of milk.