Public Consultation: Improving commercial foods for infants and young children

Closes 13 Sep 2024

Option 3: Regulatory Approaches

Description

Under this option, Ministers could request FSANZ to review, develop and /or enhance compositional and labelling requirements for commercial foods for infants and young children, so that diets based on these foods will better align with Australian and New Zealand Infant and Toddler Feeding Guidelines.

Consideration could be given to aligning any new regulations with international regulations to reduce barriers to trade and minimise costs to both food importers and exporters noting this is already part of the food standards development process.

10a. Are the risks and limitations associated with Option 3 described appropriately?

Option 3: Risks and limitations

Risks and limitations

  • Potential for long implementation period but a more permanent solution.
  • There are several relevant product sub-categories within young child foods this approach would require detailed definitions and specifications for each product sub-category and evidence would be required to justify a prescriptive approach. Any standards would have to nuance requirements by category as appropriate.
  • Labelling changes require some level of consumer understanding to achieve intended outcome.
  • Potential to create a more complex regulatory environment by changing the NIP requirements for a specific subset of foods.
  • As the dietary guidance is reviewed and updated there may be a need to be update requirements where relevant.
  • Potential to create barriers to trade, however, a technical barrier to trade application can be made to the World Trade Organisation if required to address this issue.
10b. Are there particular approaches in this option that should be further considered?

More information on Regulatory Approaches

Composition
Review and develop regulatory compositional requirements for commercial foods for infants and young children. This should include, but not be limited to:

  • Extending minimum iron levels to further categories of foods targeted to infant and young children.
  • Extending maximum sugar and sodium content to further categories of foods targeted to infant and young children.

Labelling
Review and enhance labelling requirements for commercial foods for infants and young children, in consultation with consumer law regulators as appropriate. This could include, but not be limited to:

  • Reviewing the Nutrition Information Panel (NIP) to ensure it is fit for purpose for this age group, such as requiring the declaration of iron content.
  • Reviewing claim permissions (e.g. nutrition content claims) to ensure claims enable carers to make informed choice and do not mislead, such as restrictions on added sugar claims (if not addressed by P1062) or the number of claims permitted on pack.
  • Reviewing marketing aspects of foods for young children, including use of characters on packaging and provision of toys.
  • Reviewing the naming requirements for foods to ensure current regulations enable informed consumer choice. This could include requiring product names to list ingredients in the order of prominence.
  • Require pouch products with a spout to include a statement that indicates the food should not be consumed by sucking from the package (spout) and should be decanted into a bowl or onto a spoon prior to consumption.
  • Require foods packaged in pouches with spouts to include a statement that these products are not suitable for consumption for children over 12 months.

Texture

  • Including labelling information about the appropriateness of the texture of the food and a child’s developmental stage.
10c. Food manufacturers- please provide information on the impact of potential composition options. What would be a suitable time frame for these options to be implemented in your organisation.
10d. Food manufacturers- how would the labelling options impact you? What would be a suitable time frame for these options to be implemented in your organisation?
10e. What implementation issues need to be considered for this option?