Public Consultation: Improving commercial foods for infants and young children

Closes 13 Sep 2024

This service needs cookies enabled.

Effectiveness of the proposed Options

11. Do you agree with the analysis of how well the proposed options would achieve the proposed objective? If not, please describe why and provide references with your response.
Please make sure your file is under 25MB
12. Which issues in this paper do you consider are more suitable to regulatory and non-regulatory approaches?
13a. Do you agree with the description of the possible benefits associated with the proposed options?

Benefits of each option.

 

Option 1: Satus Quo

Option 2: Non-regulatory Approaches

Option 3: Regulatory Approaches

Benefits to the community

Nil

Benefits to the community are dependent on widespread industry adoption of the non-regulatory approaches.

Reducing the total sugar content of commercial foods may have positive effects on dental carries.

Improving iron content of commercial foods for infants and young children may lead to improvements in iron status of infants and young children who regularly consume these foods. Based on the NZFF study where 23% of infants had sub-optimal iron, and 28% of infants (aged 7 to 10 months) frequently consume pouches, approximately 16,00018 infants in New Zealand may directly benefit if these changes are implemented by whole of industry.

Children who are regular consumers of commercial foods for infants and young children will directly benefit from improvements to those foods.


Reducing the total sugar content of commercial foods may have positive effects on dental carries.


Improving iron content of commercial foods for infants and young children may lead to improvements in iron status of infants and young children who regularly consume these foods. Based on the NZFF study where 23% of infants had sub-optimal iron, and 28% of infants (aged 7 to 10 months) frequently consume pouches, approximately 16,00019 infants in New Zealand may directly benefit if these changes are implemented by whole of industry.


The benefit would be greater than the non-regulatory approaches as all of industry is required to meet requirements.

Beneifts to Industry

A benefit of maintaining the status quo is no increase in costs.

Industry members who choose to voluntarily reformulate their products may benefit from the positive associations with making these foods healthier compared with their competitors.

Level playing field for industry.

Benefits to Government

No costs associated with administering voluntary or regulatory changes.

Ensuring good nutrition in the early years has the potential to translate into better health outcomes, resulting in savings for the health system. Improvements to dental health may result in savings related to the treatment of dental issues. These benefits can only be achieved if there is strong and widespread adoption of voluntary measures to improve commercial foods for infants and young children.

Better nutrient intake for children eating commercial foods in the early years has the potential to translate into better health outcomes, resulting in savings for the health system. Improvements to dental health may result in savings related to the treatment of dental issues.

Compared to Option 2, these benefits are more likely since this option ensures widespread adoption of improvements to foods for infants and young children.

 

13b. Are there additional benefits associated with all or some of the proposed options that have not been captured? Please provide data and references for your response.
Please make sure your file is under 25MB
14a. Do you agree with the assessment of the costs associated with the proposed options?

Costs of each option

  Option1: Status Quo Option 2: Non-regulatory Approaches Option 3: Regulatory Approaches
Costs to the community Costs to the community include the long-term costs associated with long term health and development outcomes if the status quo is maintained. Noting that there may be costs for reformulation and labelling changes, and these costs may be passed on to consumers. This may have unintended flow-on effects such as consumers having less money available to spend on other foods suitable for their family such as fruits and vegetables. Alternatively, increased product costs may shift purchasing away from commercial foods for infants and young children. Noting that there may be costs for reformulation and labelling changes, and these costs may be passed on to consumers. This may have unintended flow-on effects such as consumers having less money available to spend on other foods suitable for their family such as fruits and vegetables. Alternatively, increased product costs may mean that parents choose not to buy commercial foods for infants and young children.

However, sufficient transition periods can enable manufacturers to adopt the regulatory changes as part of otherwise scheduled labelling updates or product reformulations to reduce costs and impact on industry.

Other market considerations such as reduced competition from manufacturers choosing to leave the market instead of reformulating under option 3.
Costs to Industry Nil additional costs Costs to industry in product development and associated labelling changes. Non-regulatory options would only have costs to industry who voluntarily chose to participate. For example, there would be costs to manufacturers who chose to voluntarily reformulate their products as part of a voluntarily reformulation program.

It is not expected that there would be costs to food retailers associated with this option.		 Costs to industry in reformulation and associated labelling changes. If regulatory approaches are pursued, these costs would impact all manufacturers of infant and young child foods.

However, sufficient transition periods can enable manufacturers to adopt the regulatory changes as part of otherwise scheduled labelling updates or product reformulations to reduce costs and impact on industry.
It is not expected that there would be costs to food retailers associated with this option.
Costs to Government Maintaining the status quo will incur long-term costs related to chronic disease from poor dietary patterns. The medical costs due to childhood obesity has been estimated to be about $43 million (in 2015 AUD) per year [94]. The additional 3-year costs of healthcare for a child with obesity compared with healthy weight are estimated to be $825 for general patients and $1332 for concession card holders (in 2014 AUD)[95].

Costs to Government(s) would include the work involved in developing, operating, and monitoring a voluntary program.

There will also be costs associated with delivering industry education.

Costs to Government(s) would include the work involved in changing regulations and administrating and enforcing the regulations.

There will also be costs associated with delivering industry education.

 

14b. Are there additional costs associated with all or some of the proposed options that have not been captured? Please provide data and explain your rationale and your calculations.
15. What do you consider to be the preferred policy option(s) to recommend to Food Ministers? Please provide your rationale for your preference.
16. Please provide any other information on costs, timeframes, and feasibility for the options discussed in this consultation.
17. Please provide any other comments or points for consideration that may not have been addressed in this consultation.