Public Consultation: Improving commercial foods for infants and young children

Under the Overarching Strategic Statement for the Food Regulatory System, the aims of the food regulatory system are:

1. Protecting the health and safety of consumers by reducing risks related to food. 
2. Enabling consumers to make informed choices about food by ensuring that they have sufficient information and by preventing them from being misled. 
3. Supporting public health objectives by promoting healthy food choices, maintaining, and enhancing the nutritional qualities of food and responding to specific public health issues. 
4. Enabling a strong sustainable food industry to assist in achieving diverse, affordable food supply and general economic benefit.

Improving commercial foods for infants and young children is related to the first three objectives of the Food Regulatory System. 

This work currently falls under Priority 2 of the Food Regulatory System to support the public health objective to reduce chronic disease related to overweight and obesity. 

Considering the description of the problem outlined above and the aims of the food regulation system, FRSC proposes the objective of this work is as follows:
"To improve the composition, labelling and texture of commercial foods for infants and young children to better align with the recommendations in the Australian and New Zealand infant and toddler feeding guidelines". 

Three policy options to achieve the objective of this work have been identified and are summarised below. These options are not mutually exclusive, and more than one option could be recommended to Food Ministers to address concerns relating to commercial foods for infants and young children.

Option 1 - Status Quo
Current regulations include requirements and restrictions for the composition and labelling of some categories of commercial foods for infants, with fewer requirements for the range of foods aimed at young children. Regulations do not cover texture of commercial foods for infants and young children.

Option 2 - Non-regulatory approaches
This option could include establishing guidance to support industry to voluntarily improve the composition and labelling of foods for infants and young children, by developing voluntary codes, resources, and guidance for industry. This may also include expanding existing reformulation programs in Australia and New Zealand to include commercial foods for infants and young children. Under this option, industry led approaches may also be applied. This option could also include the development of consumer information and education materials to be distributed to parents and caregivers by health professionals such as GPs or maternal and child health nurses. A package of voluntary activities could make positive changes to the foods targeted to infants and young children and support parents’ and caregivers’ ability to select foods suitable for their child. However, success of this option is dependent on strong and widespread industry uptake of the voluntary measures. Current industry adoption of other voluntary labelling and compositional initiatives (for example the Health Star Rating or Healthy Food Partnership Reformulation Program) have not had widespread industry adoption suggesting that a different non-regulatory approach may be required to achieve changes in this product category. There are risks that through voluntary approaches the issues identified in the market of foods for infants and young children will remain.

Option 3 - Regulatory approaches
Under this option, Government could review, develop and/or enhance compositional and labelling regulations for commercial foods for infants and young children. Under a regulatory approach, all relevant food products would be required to adhere to the requirements on labelling and composition, therefore increasing the reach and impact of improvements to foods for infants and young children. This option achieves consistent adoption of the regulations and a level playing field because it is not dependent on industry voluntarily changing their products. A regulatory approach supports parents and caregivers who purchase these foods to provide infants and young children with foods that better align with infant and toddler feeding guidelines.