Public Consultation: Improving commercial foods for infants and young children

Closes 13 Sep 2024

Option 2: Non-regulatory Approaches

Description
Under this option, the Australian and New Zealand Governments could work with industry to voluntarily improve commercial foods for infants and young children so those foods will better align with Australian and New Zealand Infant and Toddler Feeding Guidelines regarding composition, texture, and labelling.

Approaches to working with industry could range from providing guidance that industry could follow, to a more rigorous code of practice which industry can voluntarily commit to and report on. These voluntary approaches could be incorporated into existing initiatives such as the Healthy Food Partnership in Australia and New Zealand Heart Foundation Reformulation Program, and/or through establishing a new trans-Tasman initiative.

Industry led activities could also be applied through this option. A broader range of issues could be incorporated into a non-regulatory approach compared to regulatory approaches and these can also be tailored to specific issues or product types.

Information for health professionals and caregivers could also be improved and promoted.

9a. Are the risks and limitations associated with Option 2 described appropriately?

Option 2 - Risks and Limitations

Risks and limitations

  • Success of this approach is dependent on industry uptake of the voluntary program to have the intended impact. Voluntary recommendations and targets may not receive sufficient industry uptake to make significant improvements to commercial foods for infants and young children.
  • No obligations for industry to adopt or adhere to targets or guidance developed.
  • Current voluntary programs such as the Healthy Food Partnership Reformulation Program and Health Star Rating labelling system have not had widespread industry uptake which indicates that an additional voluntary program may also not be widely adopted by industry. However, smaller, and more targeted voluntary initiatives for specific foods or issues may have more success.
  • Voluntary measures do not create a level playing field, potentially penalising those that do participate by way of increased costs both via implementing the changes needed to amend products, and increased costs associated with higher iron ingredients.
  • Consumers may not be able to identify whether a product has improved its composition for nutrients that are not part of the standard declarations in the Nutrition Information Panel (NIP).
  • Success of educational resources is contingent on effective dissemination to relevant target audiences.
  • Education interventions can have limited reach and may not benefit all populations.
9b. Are there particular approaches in this option that should be further considered?

More information on Non-regulatory approaches

Composition
Governments could work with industry to voluntarily improve the composition of commercial foods for infants and young children with a focus on iron, sugars, and sodium.

Approaches for consideration include:

  • Establishing guidance for ingredient use in ready to eat meals for infants and toddlers. For example: use of iron rich ingredients and their minimum iron content, removal of fruit from savoury infant foods (pouches or cans), encouraging use of allergens in formulation.
  • Establishing sugar and sodium targets for infant and toddler foods under the Australian Healthy Food Partnership Reformulation Program or New Zealand Heart Foundation Reformulation Program (funded by Health New Zealand). There are already targets established for sugar and sodium in these programs for other foods which has led to improvements in the composition of the food supply. For example, in the first two years of the Healthy Food Partnership Reformulation Program participating companies have removed approximately 208 tonnes of table salt, 261 tonnes of sugar and 470 tonnes of saturated fat from the food supply[92, 93]. Despite these positive results, there is low company participation in the reformulation program.
  • Development of trans-Tasman Industry Code of Practice to promote a wider range of foods that align with dietary guidance for infants and young children.

Labelling
Governments could work with industry to voluntarily improve the labelling of commercial foods for infants and young children. Industry –led approaches could also be adopted. Texture of products and appropriateness for different ages would also be considered through labelling approaches.

This could include implementing guidance for ingredients in product names to be listed in the order of prominence reducing the number of claims made on products to provide more useful information to consumers on the appropriateness of the product. There could also be guidance to industry about use of characters on food packages.

Education and Information
Improve information for health professionals and caregivers on nutritional requirements for infants and young children. This should include regular updates to guidelines and education campaigns to highlight the importance of good nutrition for infants and young children.

Approaches for consideration include:

  • Improving trans-Tasman information for health professionals and consumers on nutritional requirements for infants and young children.
  • Developing plain English and translated (and tailored) resources for Culturally and Linguistically Diverse (CALD) groups, including Māori, Aboriginal and Torres Strait Islander people.
9c. Food manufacturers- How likely are you to be involved in a voluntary reformulation or labelling program? What would be a suitable time frame for this option to be implemented in your organisation?
9d. What kinds of voluntary measures could be introduced to maximise industry uptake?
9e. What implementation issues need to be considered for this option?