About You
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Organisation
SA Health
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Public health
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Australia
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New Zealand
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If we require further information regarding your submission, can we contact you?
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Have you read the Consultation Paper: Improving commercial foods for infants and young children?
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Privacy, Confidential Information and Permissions
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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.
An additional study on the composition of commercial foods for infants and young
children was undertaken in 2024 with concerning results: 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. Results from this study
could inform any FSANZ standards review or development processes.
children was undertaken in 2024 with concerning results: 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. Results from this study
could inform any FSANZ standards review or development processes.
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.
Noting the evidence that commercially available foods for infants and young children often do not support healthy developmental progression and are frequently marketed and labelled in a misleading manner, SA Health together with Preventive Health SA support the proposed objective: 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. Given that this policy concerns the health and well-being of young children, and evidence shows that early food preferences and behaviours influence lifelong health, a comprehensive approach with timely implementation should be prioritised.
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.
The scope of the consultation covers foods marketed for infants and young children up to the age of 3 years, including food currently captured by Standard 2.9.2 – Food for Infants and Division 4 of Standard 2.9.3 – Formulated supplementary food for young children; however, has explicitly excluded toddler milks. This scope encompasses a wide range of products designed for various developmental stages and needs. Consequently, certain distinct requirements for different product categories will be necessary, making it essential to establish clear definitions and specifications for each subcategory to ensure the policy's effectiveness and enforceability.
The products captured by this consultation are generally unnecessary, and occasionally harmful, yet are often marketed to parents and caregivers as beneficial for their child’s health and development. This is also true of toddler milks. As a subcategory of formulated supplementary food for young children, it is unclear why toddler milks have been excluded from the scope of this consultation. Given the need to determine some requirements based on the category of food, it would be logical to include toddler milks as one such category. Furthermore, excluding toddler milks may create the misleading impression that the concerns about composition and labelling do not apply to them, and that they are essential for a child's development, which is not the case.
The products captured by this consultation are generally unnecessary, and occasionally harmful, yet are often marketed to parents and caregivers as beneficial for their child’s health and development. This is also true of toddler milks. As a subcategory of formulated supplementary food for young children, it is unclear why toddler milks have been excluded from the scope of this consultation. Given the need to determine some requirements based on the category of food, it would be logical to include toddler milks as one such category. Furthermore, excluding toddler milks may create the misleading impression that the concerns about composition and labelling do not apply to them, and that they are essential for a child's development, which is not the case.
Option 1: Status Quo
8. Are the risks and limitations associated with the status quo described appropriately?
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Yes
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No
If no, please explain your reasoning.
Preventive Health SA suggests the risks and limitations associated with a non-regulatory approach, as described within the consultation paper, do not recognise the risk of commercial interests influencing the policy process and reducing the effectiveness of a potential policy response. For example, the Health Star Rating System (HSR) and Healthy Food Partnership Voluntary Reformulation Program are
two current voluntary, non-regulatory approaches which are not achieving the
desired outcomes due to food industry’s weak uptake. Lessons from this approach
should be considered in applying regulation in this area so delays in uptake are not
repeated.
two current voluntary, non-regulatory approaches which are not achieving the
desired outcomes due to food industry’s weak uptake. Lessons from this approach
should be considered in applying regulation in this area so delays in uptake are not
repeated.
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.
SA Health does not support maintaining the status-quo or taking a non-regulatory
approach to improve the composition of commercial foods for infants and young
children. Although, as mentioned previously, there has been some progress through
the work of the Healthy Food Partnership Reformulation Program, industry
participation has been limited, indicating voluntary initiatives are insufficient to
address the identified issues.
approach to improve the composition of commercial foods for infants and young
children. Although, as mentioned previously, there has been some progress through
the work of the Healthy Food Partnership Reformulation Program, industry
participation has been limited, indicating voluntary initiatives are insufficient to
address the identified issues.
9d. What kinds of voluntary measures could be introduced to maximise industry uptake?
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Although a regulatory approach is supported for most elements discussed in the consultation paper, some aspects of improving the composition and labelling of foods for infants or young children might be more effectively managed through nonregulatory approaches. For example, guidance for industry to address the
appropriate introduction of common allergens could be developed with the purpose of encouraging manufacturers to include these in some of their products, in line with the Australian Society of Clinical Immunology and Allergy Guidelines.
appropriate introduction of common allergens could be developed with the purpose of encouraging manufacturers to include these in some of their products, in line with the Australian Society of Clinical Immunology and Allergy Guidelines.
Option 3: Regulatory Approaches
10a. Are the risks and limitations associated with Option 3 described appropriately?
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Yes
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No
If no, please explain your reasoning.
While a regulatory approach is supported, it is acknowledged that regulation alone is
insufficient to improve nutrition outcomes for infants and young children. Targeted
communication and education will need to accompany implementation to ensure
consumer understanding and enhance effectiveness.
insufficient to improve nutrition outcomes for infants and young children. Targeted
communication and education will need to accompany implementation to ensure
consumer understanding and enhance effectiveness.
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.
A regulatory approach to improving composition should be considered. Currently, Standard 2.9.2 – Food for Infants requires certain foods to meet compositional related requirements for iron, sodium and monosaccharide and disaccharide content, while Division 4, Standard 2.9.3 – Formulated supplementary foods for young children sets minimum composition limits for energy, protein and vitamins and minerals. SA Health and Preventive Health SA supports extending compositional requirements, with specific consideration of energy, iron, free sugars, sodium, fat and protein, to other categories of commercial foods for infants and young children as appropriate.
Standard 2.9.2 – Food for infants currently requires captured foods to display a label indicating the consistency of the food. It is recommended that this regulation is extended to other commercial infant and toddler foods with the addition of a statement indicating the appropriateness of the texture for various developmental stages.
Standard 2.9.2 – Food for infants currently requires captured foods to display a label indicating the consistency of the food. It is recommended that this regulation is extended to other commercial infant and toddler foods with the addition of a statement indicating the appropriateness of the texture for various developmental stages.
10e. What implementation issues need to be considered for this option?
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The enforceability of any regulatory approach must also be considered. Currently,
jurisdictions vary in their approach to monitoring and enforcing compliance with
labelling and composition requirements of the Food Standards Code. The
implications for an increased compliance burden on regulators should also be
considered.
jurisdictions vary in their approach to monitoring and enforcing compliance with
labelling and composition requirements of the Food Standards Code. The
implications for an increased compliance burden on regulators should also be
considered.
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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12. Which issues in this paper do you consider are more suitable to regulatory and non-regulatory approaches?
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A regulatory approach for labelling as well as composition is supported to help parents and caregivers make more informed choices about the food they provide for their children, enabling easier comparison between similar products.
As mentioned above, a regulatory approach to labelling for texture is supported; however, a non-regulatory approach may be more effective in improving the texture of the foods themselves. This could involve guidance for industry to provide products of varying textures and educational material to parents to encourage the introduction of various textures as necessary for their child’s development.
As mentioned above, a regulatory approach to labelling for texture is supported; however, a non-regulatory approach may be more effective in improving the texture of the foods themselves. This could involve guidance for industry to provide products of varying textures and educational material to parents to encourage the introduction of various textures as necessary for their child’s development.
15. What do you consider to be the preferred policy option(s) to recommend to Food Ministers? Please provide your rationale for your preference.
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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)
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SA Health supports, in principle, a regulatory approach to improve commercial foods for infants and young children; however, notes some elements under consideration, such as texture, may be better managed through non-regulatory initiatives.
17. Please provide any other comments or points for consideration that may not have been addressed in this consultation.
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Evidence demonstrates that the packaging of commercial infant and toddler food products in Australia contain up to 21 different claims (average 6.7 claims)1. SA Health and Preventive Health SA supports a review of these claims to eliminate potentially misleading or unnecessary nutrient content or health claims, including consideration of minimum requirements in nutritional quality for specific claims to be permitted.
Currently, foods captured by Standard 2.9.2 and Standard 2.9.3 are excluded from the HSR; however, general foods targeted at young children over 12 months of age are still eligible to display a HSR. Considering the likelihood of the HSR being mandated in the future, and the distinct nutritional needs of young children, ensuring changes to labelling for commercial foods for infants and young children are aligned with the HSR will support parents and caregivers to make suitable choices for their children's nutritional requirements.
Currently, foods captured by Standard 2.9.2 and Standard 2.9.3 are excluded from the HSR; however, general foods targeted at young children over 12 months of age are still eligible to display a HSR. Considering the likelihood of the HSR being mandated in the future, and the distinct nutritional needs of young children, ensuring changes to labelling for commercial foods for infants and young children are aligned with the HSR will support parents and caregivers to make suitable choices for their children's nutritional requirements.