About You
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Council of Deans Nutrition and Dietetics, Australia and New Zealand
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Council of Deans of Nutrition and Dietetics, Australia and New Zealand (CDNDANZ) was established in 2015 with representation from all Universities currently offering qualifications in Nutrition and Dietetics across Australia and New Zealand that are recognised for dietetics practice by Dietitians Australia or the Dietitians Board New Zealand. The CDNDANZ aims to provide a forum for discussion, feedback, consultation and advocacy on issues relevant to nutrition and dietetics in Australia and New Zealand, independent of Dietitians Australia, Universities Australia, Dietitians Board New Zealand, Dietitians New Zealand and Universities New Zealand. The Terms of Reference of the CDND ANZ include providing advice and advocacy on standards required for the teaching, research and practice of Nutrition and Dietetics in Australia and New Zealand. In 2024 CDNDANZ represents 21 universities.
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Have you read the Consultation Paper: Improving commercial foods for infants and young children?
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Additional Evidence and Information
1. Are there additional studies on the consumption of commercial foods for infants and young children in Australia and New Zealand?
Please include references for any additional studies mentioned in your response.
The role of commercial processed baby foods in the diets of New Zealand toddlers by Anita Clouston https://ourarchive.otago.ac.nz/esploro/outputs/graduate/The-role-of-commercial-processed-baby/9926480121901891
Webb KL, Lahti-Koski M, Rutishauser I, et al. Consumption of ‘extra’ foods (energy-dense, nutrient-poor) among children aged 16–24 months from western Sydney, Australia. Public Health Nutrition. 2006;9(8):1035-1044. doi:10.1017/PHN2006970 https://www.cambridge.org/core/journals/public-health-nutrition/article/consumption-of-extra-foods-energydense-nutrientpoor-among-children-aged-1624-months-from-western-sydney-australia/27500A82010BE5590A6522AA8232E698
Castro TG, Gerritsen S, Teixeira JA, et al. An index measuring adherence to New Zealand Infant Feeding Guidelines has convergent validity with maternal socio-demographic and health behaviours and with children’s body size. British Journal of Nutrition. 2022;127(7):1073-1085. doi:10.1017/S0007114521001720
Webb KL, Lahti-Koski M, Rutishauser I, et al. Consumption of ‘extra’ foods (energy-dense, nutrient-poor) among children aged 16–24 months from western Sydney, Australia. Public Health Nutrition. 2006;9(8):1035-1044. doi:10.1017/PHN2006970 https://www.cambridge.org/core/journals/public-health-nutrition/article/consumption-of-extra-foods-energydense-nutrientpoor-among-children-aged-1624-months-from-western-sydney-australia/27500A82010BE5590A6522AA8232E698
Castro TG, Gerritsen S, Teixeira JA, et al. An index measuring adherence to New Zealand Infant Feeding Guidelines has convergent validity with maternal socio-demographic and health behaviours and with children’s body size. British Journal of Nutrition. 2022;127(7):1073-1085. doi:10.1017/S0007114521001720
2. Are there additional studies on the prevalence of iron deficiency in Australian children, including among Aboriginal and Torres Strait Islander children and children living in rural/or remote areas and other groups, including vulnerable populations?
Please include references for any additional studies mentioned in your response.
Zed K, Calogero N, Darssan D, Nicholl A, Deering K, O’Sullivan T. Iron deficiency and associated factors in Australian children aged 4–6 years. Proceedings of the Nutrition Society. 2023;82(OCE2):E170. doi:10.1017/S0029665123001799 https://www.cambridge.org/core/journals/proceedings-of-the-nutrition-society/article/iron-deficiency-and-associated-factors-in-australian-children-aged-46-years/3BA7853FF00196359E6F07EF4C50E282 (this paper is currently under review but we can provide manuscript if required)
3. Are there additional studies on the composition of commercial foods for infants and young children in Australia and New Zealand?
Please include references for any additional studies mentioned in your response.
Dunford, E. K., Scully, M., & Coyle, D. (2024). Commercially-produced infant and toddler foods—How healthy are they? An evaluation of products sold in Australian supermarkets. Maternal & Child Nutrition, e13709. https://doi.org/10.1111/mcn.13709 https://onlinelibrary.wiley.com/doi/10.1111/mcn.13709
4. Are there additional studies on the texture of commercial foods for infants and young children in Australia and New Zealand?
Please include references for any additional studies mentioned in your response.
None that we are aware of.
Food Manufacturer Reformulation Activities
5. Food manufacturers - What reformulation or other activities have you undertaken to change/improve in the last 5 years related to commercial foods for infants and young children? What was the purpose of the activity?
Please explain any activities you have undertaken to change and/or improve commercial foods for infants and young children in the last 5 years.
N/A
Your Views
6. Do you agree with the proposed objective of this work? If not, what is your proposed alternative?
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If you do not agree with the proposed objectives, please propose alternatives below.
We agree with the Healthy Food Partnership Executive Committee that this issue is high priority, of a serious nature and require a systems approach. However we believe the objective of this work should be to ‘ensure alignment’ with the recommendations rather than achieve ‘better alignment’. There are clear inconsistencies between national infant feeding advice and how some commercial baby food and drink products are presented. We also suggest that marketing should be added to the proposed objective to better encompass the product packaging advertising and other marketing approaches used by industry.
We support alignment with the Australian and New Zealand feeding guidelines, which include:
• Special complementary foods or milks for toddlers are not required for healthy children” - Australian Infant Feeding Guidelines
• “Commercial baby foods are a convenient alternative to home-made baby food, but an over-reliance on these products may reduce the variety of flavours and textures in a baby’s diet” - Healthy Eating Guidelines for New Zealand babies and toddlers
As these guidelines do not give detailed guidance on commercial foods for infants and young children, we advise using international best practice (ie the World Health Organization European Office’s Nutrition Profile and Promotion Model).
An updated objective is proposed:
"To improve the composition, marketing, labelling and texture of commercial foods for infants and young children to ensure alignment with the recommendations in the Australian and New Zealand infant and toddler feeding guidelines and international best practice".
We support alignment with the Australian and New Zealand feeding guidelines, which include:
• Special complementary foods or milks for toddlers are not required for healthy children” - Australian Infant Feeding Guidelines
• “Commercial baby foods are a convenient alternative to home-made baby food, but an over-reliance on these products may reduce the variety of flavours and textures in a baby’s diet” - Healthy Eating Guidelines for New Zealand babies and toddlers
As these guidelines do not give detailed guidance on commercial foods for infants and young children, we advise using international best practice (ie the World Health Organization European Office’s Nutrition Profile and Promotion Model).
An updated objective is proposed:
"To improve the composition, marketing, labelling and texture of commercial foods for infants and young children to ensure alignment with the recommendations in the Australian and New Zealand infant and toddler feeding guidelines and international best practice".
7. Are there additional policy options that should be considered? Please provide a rationale and the benefits and risks of your suggested option.
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If yes, please provide details as requested in the question.
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Option 1: Status Quo
8. Are the risks and limitations associated with the status quo described appropriately?
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If no, please explain your reasoning.
The risks need to clearly reflect what is at stake if no action is taken. Many commercial foods for infants and young children are not supporting their health and development as parents believe they are. As noted in recent research (Scully et al 2024), these products often don’t meet international nutrition standards and fall short in terms of labelling and promotion. If we go with Option 1, this problem will continue. We need to make meaningful changes to the composition, labelling, and texture of these foods to improve the health of Australian children. For these changes to be effective, they need to be mandatory, with proper monitoring and enforcement.
Option 2: Non-regulatory Approaches
9a. Are the risks and limitations associated with Option 2 described appropriately?
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If no, please explain your reasoning.
The risks and limitations of Option 2 underestimate the seriousness of the potential outcomes associated with relying on voluntary approaches. We strongly advise against this option, as it is unrealistic and unwise to expect that the industry will voluntarily take actions that go against its fundamental profit-driven objectives. Non-regulatory approaches to food labelling, such as voluntary industry initiatives, consumer education, and third-party certifications, have shown mixed results in terms of effectiveness. Research consistently shows that corporations prioritise their financial interests, even when it conflicts with public health goals. "Part of the Solution": Food Corporation Strategies for Regulatory Capture and Legitimacy - PMC (nih.gov)
In addition, there is no substantial evidence, either within Australia or internationally, that non-regulatory approaches to reformulation and labelling are effective. Non-regulatory strategies have consistently fallen short of delivering significant improvements, particularly in sectors involving vulnerable populations like infants and young children. This is illustrated by the World Health Organization (WHO) International Code of Marketing of Breast-milk Substitutes in 1981.
The theory mentioned in the Consultation RIS around "smaller, more targeted voluntary initiatives for specific foods or issues" also lacks a track record of effectiveness, especially when it comes to protecting the health and nutrition of children. Instead of taking a chance on an unproven method, we should rely on strategies that have demonstrated success—namely, regulatory approaches.
In addition, there is no substantial evidence, either within Australia or internationally, that non-regulatory approaches to reformulation and labelling are effective. Non-regulatory strategies have consistently fallen short of delivering significant improvements, particularly in sectors involving vulnerable populations like infants and young children. This is illustrated by the World Health Organization (WHO) International Code of Marketing of Breast-milk Substitutes in 1981.
The theory mentioned in the Consultation RIS around "smaller, more targeted voluntary initiatives for specific foods or issues" also lacks a track record of effectiveness, especially when it comes to protecting the health and nutrition of children. Instead of taking a chance on an unproven method, we should rely on strategies that have demonstrated success—namely, regulatory approaches.
9b. Are there particular approaches in this option that should be further considered?
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If yes, please outline the options that should be further considered.
No we do not support any voluntary industry approaches due to a lack of evidence that these are effective. See response above 9a
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?
Please input your response below.
See response in 9a,b. We do not support a voluntary industry approach.
9d. What kinds of voluntary measures could be introduced to maximise industry uptake?
Please input your response below.
See response in 9a,b. We do not support a voluntary industry approach.
9e. What implementation issues need to be considered for this option?
Please input your response below.
See response in 9a,b. We do not support a voluntary industry approach.
Option 3: Regulatory Approaches
10a. Are the risks and limitations associated with Option 3 described appropriately?
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If no, please explain your reasoning.
There is a risk that if regulations are based solely on minimal guidelines from Australia and New Zealand, Australian standards may continue to fall short of international best practice. We recommend that action is taken to ensure alignment with international best practice.
On the assumption that Option 3 may require a lengthy implementation period – the health of Australian and New Zealand children is important and should not be compromised to make the implementation period more acceptable to food industry. We believe a reasonable implementation period for regulatory approaches is two years, consistent with country-of-origin labelling and other changes (eg mandatory folic acid fortification).
Developing relevant sub-categories is not a limitation. The World Health Organisation has already completed substantial work in creating detailed definitions and specifications for product sub-categories. Analysis of Australian and New Zealand products against this model demonstrates that products in these markets can be effectively sub-categorised, with the existing definitions and specifications proving to be both relevant and applicable.
We disagree with the concern about consumers struggling to understand labelling changes. Labelling would align with national recommendations and ensure consistency of messaging and reduce confusion Implementing labelling changes would make product names more accurate and ensure that foods are labelled and marketed with greater transparency and honesty. Compared to the current situation, this approach would reduce the need for consumers to navigate complex or misleading labels and claims, thereby lowering the associated risks.
On the assumption that Option 3 may require a lengthy implementation period – the health of Australian and New Zealand children is important and should not be compromised to make the implementation period more acceptable to food industry. We believe a reasonable implementation period for regulatory approaches is two years, consistent with country-of-origin labelling and other changes (eg mandatory folic acid fortification).
Developing relevant sub-categories is not a limitation. The World Health Organisation has already completed substantial work in creating detailed definitions and specifications for product sub-categories. Analysis of Australian and New Zealand products against this model demonstrates that products in these markets can be effectively sub-categorised, with the existing definitions and specifications proving to be both relevant and applicable.
We disagree with the concern about consumers struggling to understand labelling changes. Labelling would align with national recommendations and ensure consistency of messaging and reduce confusion Implementing labelling changes would make product names more accurate and ensure that foods are labelled and marketed with greater transparency and honesty. Compared to the current situation, this approach would reduce the need for consumers to navigate complex or misleading labels and claims, thereby lowering the associated risks.
10b. Are there particular approaches in this option that should be further considered?
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If yes, please outline the options that should be further considered.
To effectively address the sugar and sweetness levels in foods for babies and toddlers, for nutrition and dental health reasons, we need to go beyond simply setting maximum sugar content thresholds for specific categories. We recommend the following:
- Avoid the use of added sugars (as defined in the Food Standards Code) and concentrated fruit ingredients in all foods for infants and young children up to 3 years of age. (NB concentrated fruit ingredients include all fruit forms other than pureed fruit and whole, cut, or chopped dried fruit – includes fruit juice, fruit paste, fruit gel, fruit powder, fruit pulp, concentrated fruit puree etc). These concentrated fruit ingredients fall under the 'free sugars' category (Swan GE et al., 2018).
- Impose limits on using fruit to sweeten foods for infants and young children, following the World Health Organization’s Nutrient and Promotion Profile Model guidelines. These guidelines restrict the use of fruit in savory foods, dairy products, cereals, and snacks.
- Prohibit the use of non-sugar sweeteners in foods for infants and young children, as defined by the World Health Organization (WHO, 2023). Some studies suggest that consuming non-sugar sweeteners might lead to overcompensation, and there is limited research on their long-term effects on infants and young children (young children have different metabolic processes, and their developing bodies may react differently to these sweeteners). Brown, R. J., de Banate, M. A., & Rother, K. I. (2010). Artificial Sweeteners: A systematic review of metabolic effects in youth. International Journal of Pediatric Obesity, 5(4), 305–312. https://doi.org/10.3109/17477160903497027
- Except for water and unflavoured milk, prohibit other drinks, except those regulated by Standards 2.9.2 and 2.9.3 of the Food Standards Code, for marketing towards infants and young children.
We also recommend reform around snack foods. As noted in reference 64 of the Consultation document, over a third of foods marketed for infants and young children are snack foods. We recommend discretionary are not to be specifically marketed towards babies or young children, for the reasons below.
- In comparison to other countries, Australia has a high prevalence of snacking (over 95%), and where snacking provides one-third of our children’s total energy intake (Wang D, van der Horst K, Jacquier EF, Afeiche MC, Eldridge AL. Snacking Patterns in Children: A Comparison between Australia, China, Mexico, and the US. Nutrients. 2018 Feb 11;10(2):198. doi: 10.3390/nu10020198. PMID: 29439472; PMCID: PMC5852774.)
- As per the Australian and NZ dietary guidelines, discretionary foods are not recommended as snacks for this age group. Despite this, high energy, low nutrient, highly processed snack foods have seen significant growth in recent years, as noted in the Consultation document.
- These snack foods include highly processed products. Highly processed, often low fibre, foods can contribute to digestive problems such a constipation in children and poorer gut health. When children consume highly palatable, highly processed foods, they are less likely to eat whole, nutrient-dense foods like fruits, vegetables, and lean proteins. This displacement effect can lead to nutritional deficiencies, which can impair growth, cognitive development, and affect overall health. Consumption of many highly processed foods is associated with increased obesity with dose-response effect across different countries and cohorts (da Costa Louzada et al, 2021 https://doi.org/10.1590/0102-311X00323020 ; ); Castro TG et al; Br J Nutr 2022;127(7):1073-1085. DOI: https://doi.org/10.1017/S0007114521001720; Castro, TG et al; Matern Child Nutr, 18, e13402. https://doi.org/10.1111/mcn.13402).
- The convenience, long shelf life, and wide variety of highly processed, discretionary foods, including organic and gluten-free options, attract many consumers. However, ultra-processed foods negatively impact health by reducing cooking confidence, decreasing family meals, shortening meal times, and encouraging constant snacking and screen-time, which undermines positive behaviour modelling and weakens family bonds. (Khandpur et al; Ann Nutr Metab 2020; 76 (2): 109–113. https://doi.org/10.1159/000507840)
In terms of names of food products, we recommend that regulations enable informed consumer choice. This can be done by products listing ingredients in the order of prominence, and by not permitting fruits and vegetables in the name of foods where fruits and vegetables are either not in their whole form, or in their whole form but do not make up at least half of the product.
The Consultation document notes acknowledges that multiple claims on products have the potential to cause consumer confusion about how healthy the product is for babies and young children. There has also been more research about the impact of claims on parent and caregivers’ perceptions, preferences and purchasing intentions. The World Health Organization recommends no health, nutrition, or marketing claims on food for infants and young children (with limited exceptions), and we strongly feel this approach should be mandated in Australia and New Zealand. Just as infant formula products are not permitted to carry nutrition content or health claims (Standard 1.2.7 of the Food Standards Code), neither should foods for babies and young children. There are many examples of misleading claims in our supermarkets (eg ‘free from preservatives and additives’ gives parents a false representation of a healthful product, even though the product is over half sugar).
- A recent study showed that “every commercially produced infant and toddler food product available in Australian supermarkets in 2022 failed to meet World Health Organization recommendations for product promotion” (Dunford, E. K., Scully, M., & Coyle, D. (2024). Commercially-produced infant and toddler foods—How healthy are they? An evaluation of products sold in Australian supermarkets. Maternal & Child Nutrition, e13709. https://doi.org/10.1111/mcn.13709)
- The same study showed that “up to 21 different claims were found on product packaging, with products on average displaying 6.7 claims” – this can be overwhelming for parents and send the wrong message about the health of the product
We recommend that no child-directed marketing (such as using TV characters on product packaging) be allowed on foods for babies and young children. This should be part of the policy reforms to improve commercial foods for this age group, given the effect of this type of product advertising on purchasing habits of families.
We recommend that pouch products should include two front-of-pack statements, one that indicates the food should not be consumed by sucking from the package (spout) but should be fed via a spoon; and another to state that they are for ages 6 to 9 months. This is because:
- purees are inappropriate textures of food for babies over 9 months
- sucking from pouches encourages overconsumption of the product
- sucking from pouches does not support normal oral motor development that occurs with eating foods with a variety of textures. Poor exposure to texture variety is associated with later risk of fussy eating and lower intakes of fruit and vegetables later in childhood (Koletzko et al. Complementary foods in baby food pouches: position statement from the Nutrition Commission of the German Society for Pediatrics and Adolescent Medicine. Mol Cell Pediatr. 2019 Mar 6;6(1):2. doi: 10.1186/s40348-019-0089-6. PMID: 30840172; PMCID: PMC6403273.)
Maximum Saturated fat and minimum total protein are set for foods and align with national guidelines. However, changes to limits sugar content and reformulation of products must ensure that limits on other macronutrients are considered. As outlined in the RIS, work needs to take place on policy options to address energy density limits, sweet flavour profiles and serving sizes.
- Avoid the use of added sugars (as defined in the Food Standards Code) and concentrated fruit ingredients in all foods for infants and young children up to 3 years of age. (NB concentrated fruit ingredients include all fruit forms other than pureed fruit and whole, cut, or chopped dried fruit – includes fruit juice, fruit paste, fruit gel, fruit powder, fruit pulp, concentrated fruit puree etc). These concentrated fruit ingredients fall under the 'free sugars' category (Swan GE et al., 2018).
- Impose limits on using fruit to sweeten foods for infants and young children, following the World Health Organization’s Nutrient and Promotion Profile Model guidelines. These guidelines restrict the use of fruit in savory foods, dairy products, cereals, and snacks.
- Prohibit the use of non-sugar sweeteners in foods for infants and young children, as defined by the World Health Organization (WHO, 2023). Some studies suggest that consuming non-sugar sweeteners might lead to overcompensation, and there is limited research on their long-term effects on infants and young children (young children have different metabolic processes, and their developing bodies may react differently to these sweeteners). Brown, R. J., de Banate, M. A., & Rother, K. I. (2010). Artificial Sweeteners: A systematic review of metabolic effects in youth. International Journal of Pediatric Obesity, 5(4), 305–312. https://doi.org/10.3109/17477160903497027
- Except for water and unflavoured milk, prohibit other drinks, except those regulated by Standards 2.9.2 and 2.9.3 of the Food Standards Code, for marketing towards infants and young children.
We also recommend reform around snack foods. As noted in reference 64 of the Consultation document, over a third of foods marketed for infants and young children are snack foods. We recommend discretionary are not to be specifically marketed towards babies or young children, for the reasons below.
- In comparison to other countries, Australia has a high prevalence of snacking (over 95%), and where snacking provides one-third of our children’s total energy intake (Wang D, van der Horst K, Jacquier EF, Afeiche MC, Eldridge AL. Snacking Patterns in Children: A Comparison between Australia, China, Mexico, and the US. Nutrients. 2018 Feb 11;10(2):198. doi: 10.3390/nu10020198. PMID: 29439472; PMCID: PMC5852774.)
- As per the Australian and NZ dietary guidelines, discretionary foods are not recommended as snacks for this age group. Despite this, high energy, low nutrient, highly processed snack foods have seen significant growth in recent years, as noted in the Consultation document.
- These snack foods include highly processed products. Highly processed, often low fibre, foods can contribute to digestive problems such a constipation in children and poorer gut health. When children consume highly palatable, highly processed foods, they are less likely to eat whole, nutrient-dense foods like fruits, vegetables, and lean proteins. This displacement effect can lead to nutritional deficiencies, which can impair growth, cognitive development, and affect overall health. Consumption of many highly processed foods is associated with increased obesity with dose-response effect across different countries and cohorts (da Costa Louzada et al, 2021 https://doi.org/10.1590/0102-311X00323020 ; ); Castro TG et al; Br J Nutr 2022;127(7):1073-1085. DOI: https://doi.org/10.1017/S0007114521001720; Castro, TG et al; Matern Child Nutr, 18, e13402. https://doi.org/10.1111/mcn.13402).
- The convenience, long shelf life, and wide variety of highly processed, discretionary foods, including organic and gluten-free options, attract many consumers. However, ultra-processed foods negatively impact health by reducing cooking confidence, decreasing family meals, shortening meal times, and encouraging constant snacking and screen-time, which undermines positive behaviour modelling and weakens family bonds. (Khandpur et al; Ann Nutr Metab 2020; 76 (2): 109–113. https://doi.org/10.1159/000507840)
In terms of names of food products, we recommend that regulations enable informed consumer choice. This can be done by products listing ingredients in the order of prominence, and by not permitting fruits and vegetables in the name of foods where fruits and vegetables are either not in their whole form, or in their whole form but do not make up at least half of the product.
The Consultation document notes acknowledges that multiple claims on products have the potential to cause consumer confusion about how healthy the product is for babies and young children. There has also been more research about the impact of claims on parent and caregivers’ perceptions, preferences and purchasing intentions. The World Health Organization recommends no health, nutrition, or marketing claims on food for infants and young children (with limited exceptions), and we strongly feel this approach should be mandated in Australia and New Zealand. Just as infant formula products are not permitted to carry nutrition content or health claims (Standard 1.2.7 of the Food Standards Code), neither should foods for babies and young children. There are many examples of misleading claims in our supermarkets (eg ‘free from preservatives and additives’ gives parents a false representation of a healthful product, even though the product is over half sugar).
- A recent study showed that “every commercially produced infant and toddler food product available in Australian supermarkets in 2022 failed to meet World Health Organization recommendations for product promotion” (Dunford, E. K., Scully, M., & Coyle, D. (2024). Commercially-produced infant and toddler foods—How healthy are they? An evaluation of products sold in Australian supermarkets. Maternal & Child Nutrition, e13709. https://doi.org/10.1111/mcn.13709)
- The same study showed that “up to 21 different claims were found on product packaging, with products on average displaying 6.7 claims” – this can be overwhelming for parents and send the wrong message about the health of the product
We recommend that no child-directed marketing (such as using TV characters on product packaging) be allowed on foods for babies and young children. This should be part of the policy reforms to improve commercial foods for this age group, given the effect of this type of product advertising on purchasing habits of families.
We recommend that pouch products should include two front-of-pack statements, one that indicates the food should not be consumed by sucking from the package (spout) but should be fed via a spoon; and another to state that they are for ages 6 to 9 months. This is because:
- purees are inappropriate textures of food for babies over 9 months
- sucking from pouches encourages overconsumption of the product
- sucking from pouches does not support normal oral motor development that occurs with eating foods with a variety of textures. Poor exposure to texture variety is associated with later risk of fussy eating and lower intakes of fruit and vegetables later in childhood (Koletzko et al. Complementary foods in baby food pouches: position statement from the Nutrition Commission of the German Society for Pediatrics and Adolescent Medicine. Mol Cell Pediatr. 2019 Mar 6;6(1):2. doi: 10.1186/s40348-019-0089-6. PMID: 30840172; PMCID: PMC6403273.)
Maximum Saturated fat and minimum total protein are set for foods and align with national guidelines. However, changes to limits sugar content and reformulation of products must ensure that limits on other macronutrients are considered. As outlined in the RIS, work needs to take place on policy options to address energy density limits, sweet flavour profiles and serving sizes.
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.
Please input your response below.
N/A
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?
Please input your response below.
N/A
10e. What implementation issues need to be considered for this option?
Please input your response below.
We recommend a two year implementation period for regulatory approaches, consistent with some previous labelling changes.
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.
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If no, please describe why you don't agree and provide references below.
We do not agree that Option 2 has ‘some potential to meet the objective’ in relation to each component: composition, labelling, texture and feasibility. We believe ‘the option is unlikely to meet the objective’ for each component as Option 2 is very unlikely to significantly change the current position and will therefore not achieve the proposed objective.
As per our response to Question 10, a comprehensive range of reforms are required to ensure that all commercial foods for infants and young children align with the Australian and New Zealand infant and toddler feeding guidelines and international best practice.
As per our response to Question 10, a comprehensive range of reforms are required to ensure that all commercial foods for infants and young children align with the Australian and New Zealand infant and toddler feeding guidelines and international best practice.
12. Which issues in this paper do you consider are more suitable to regulatory and non-regulatory approaches?
Please input your response below.
We believe that the issues mentioned here are all suitable for regulatory approaches. We do not recommend non-regulatory approaches based on previous evidence.
13a. Do you agree with the description of the possible benefits associated with the proposed options?
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Please provide your reasoning below.
We disagree that Option 2 would result in benefits or savings for the health system. Voluntary approaches are highly unlikely to result in widespread changes that would make a meaningful difference.
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 input your response below.
We believe Option 3 is that this is the only option that would result in meaningful benefits for babies and young children.
14a. Do you agree with the assessment of the costs associated with the proposed options?
Please select one item
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Yes
Radio button:
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No
Please provide your reasoning below.
We disagree that there will be any significant costs in industry under Option 2 as it is unlikely that voluntary approaches will be acted on in any meaningful manner.
15. What do you consider to be the preferred policy option(s) to recommend to Food Ministers? Please provide your rationale for your preference.
Please select one item
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Option 1: Status Quo
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Option 2: Non-regulatory approach
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Option 3: Regulatory approach
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Combination (please elaborate below)
Please input your response below.
Rationale provided above
17. Please provide any other comments or points for consideration that may not have been addressed in this consultation.
Please input your response below.
Improving commercial foods for babies and young children requires more than just this objective. We also recommend the following factors are considered:
• A regular national nutrition survey for infants and young children
• More transparent labelling of key ingredients and naming of products
• Structural factors such as adequate paid parental leave that enables parents and carers to have the time to prepare and feed non-commercial family foods
• State/territory Food Authorities do not currently have a strong remit or adequate budget to police claims. FSANZ at state level need to be better equipped to monitor and enforce regulations.
• A regular national nutrition survey for infants and young children
• More transparent labelling of key ingredients and naming of products
• Structural factors such as adequate paid parental leave that enables parents and carers to have the time to prepare and feed non-commercial family foods
• State/territory Food Authorities do not currently have a strong remit or adequate budget to police claims. FSANZ at state level need to be better equipped to monitor and enforce regulations.