Food Regulation Standing Committee Consultation: Policy guideline on information requirements for prepackaged food sold online

FRSC propose to develop a policy guideline on information requirements for prepackaged food sold online to achieve the desired outcome. This consultation will inform the development and content of such a guideline and Ministers' decisions on whether to adopt the policy guideline.

A policy guideline is the established process in the Food Regulation system for Food Ministers to issue their policy expectations. Policy guidelines provide guiding principles for addressing significant food issues.

FSANZ must have regard to any written policy guidelines by Food Ministers when developing or reviewing food regulatory measures and variations of food regulatory measures. Policy guidelines need to be clear, comprehensive and consistent but should not be too prescriptive. A policy guideline does not trigger regulatory action.

Many consumers are shopping for food online. To ensure these consumers have access to the information needed to make an informed choice, the information requirements for prepackaged food sold online will likely need to be considered, including potentially through the future FSANZ work on nutrition labelling. A policy guideline on information requirements for prepackaged food sold online ensures that any future food regulatory measures are fit for purpose and met the expectations of Ministers.

Benefits of a policy guideline on information requirements for prepackaged food sold online are:

• Sets clear policy expectations on information to be provided online when food required to bear a label is offered for retail sale online.
• Promotes consistency with international guidance from Codex Alimentarius.
• Inform any future work on information requirements for prepackaged food sold online. This could include the future work by FSANZ on nutrition labelling where concerns have been raised about nutrition labelling not being provided online.
• Whilst not the primary purpose of a policy guideline, this could provide industry with guidance on what information they should provide online when selling food.

We are seeking your views on the draft policy guideline

FRSC has developed a draft policy guideline on information requirements for prepackaged food sold online for your feedback. This is provided in full on the next page and then by section (aim, context, scope and policy principles) with specific questions.

In line with the desired outcome, the policy guideline focuses on the provision of information required on the food label as this has been deemed as essential for safety and to inform consumers purchasing decisions. This does not limit other information being provided online to consumers.

The draft FRSC policy guideline is similar to the Codex Guideline on the Provision of Food Information for Pre-packaged Foods to be Offered via E-commerce (CXG 104-2024), adopted in 2024. They both refer to:

• All information required on the physical label should be provided for prepackaged food sold online, except for date marking and lot identification.
• Consumers should be encouraged to check the information on the physical label before consumption.
• The information should be freely accessible to the consumer to inform their purchasing decision.
• Legibility of the information.

Unlike the Codex guideline, the draft policy guideline does not specify that the information must be provided on the product information e-page. The policy guideline provides principle-based guidance that this information should be displayed prominently in connection with the food for sale online, so that this information is easily accessible and identifiable to consumers. This is to encompass the range of online platforms where food could be sold, such as webpages and applications, both now and in the future.