Demographics
What is your name?
Name
Michele Walton
If you answered yes to the question above, please provide your organisation's name.
Organisation
Australian Food and Grocery Council
Demographics (continued)
Where do you live, or where is your organisation based? Please select one item.
Please select one item
(Required)
NSW
Victoria
Queensland
Western Australia
South Australia
Tasmania
Ticked
ACT
Northern Territory
Outside of Australia
What is your background/interest group?
Please select one item
(Required)
General public
Consumer group
Government
Ticked
Industry
Public Health
Other
General Questions
Do you support nutrient reformulation as a public health measure?
Please select one item
(Required)
Ticked
Yes - please add comments and evidence
No - please add comments and evidence
Please provide details
See earlier responses to this consultation as copied and pasted below:
The AFGC supports reformulation as a public health measure where:
• There is evidence of a significant impact on health outcomes at a population level
• Targets are developed and agreed in collaboration with the relevant manufacturers to ensure they are feasible, achievable and flexible enough to accommodate the diversity across products, portfolios and businesses
• It remains voluntary
• Efforts by businesses, both large and small are acknowledged and rewarded
• Previous and ongoing reformulation activity is recognised and rewarded and limitations on further change are accepted
• The role of product development and the nutrient profile of new products in shaping the food supply is recognised
• Australians continue to have access to a diverse and wide ranging variety of products that meets their preferences and contributes to their social and nutritional needs, health and well-being
• There is a process, where possible, to engage manufacturers of imported products to ensure the competitiveness of Australian made products is not disadvantaged
• Reporting is meaningful and the burden on industry is manageable
• There is opportunity to reformulate within the usual business cycles of product renovation and renewal of labels.
The AFGC recognises the work that has gone into the current draft targets and thanks the Healthy Food Partnership Reformulation Working Group for their time and effort.
However, the AFGC is not able to support the current nutrient reformulation proposal as a public health measure, because consultation with members to inform this submission has highlighted many issues that need to be addressed. While the AFGC will be providing examples of some of the problems with the current proposal, comprehensive, detailed feedback on the draft definitions or targets for all the products in scope will not be provided. Individual companies, know their products and processes best and are better positioned to provide the detail regarding their specific products and portfolios.
AFGC recommends that a collaborative, targeted consultation process with industry, be undertaken to co-design category definitions, targets and timeframes that have the necessary flexibility to make them feasible and achievable.
Many of the draft category definitions are not appropriate and the draft targets and timeframe are not feasible. The problems have arisen because the methodology used is not fit for purpose. Unlike the methodology used by the former Food and Health Dialogue (FHD), that resulted in the achievement of significant sodium reductions1, the current process has not consulted those who understand the most about the individual products and the necessary business and technical processes, and who will be required to implement the targets. It has instead resulted in category definitions, targets and expectations that have not recognised the diversity of:
• importance of the targeted nutrients in determining the consumer experience
• functional roles that the targeted nutrients play in manufacturing
• production processes and the different ways that similar products are manufactured
• characterising ingredients and the importance of these to product quality and consumers’ perception of that quality
• current levels of targeted nutrients and the size of the change required to reach the target
• consumers’ expectations and preferences (both of product characteristics and of price point)
• iconic, historical or signature products and consumer resistance to change
• size of portfolios and the resources required to reformulate and revalidate all products
• sales volume and role of products in portfolios (i.e. the feasibility of directing resources towards reformulation of lower volume, minor parts of the portfolio may vary)
• the completed reformulation of products to date, in response to changing consumer demands and company and external commitments, and the limitations on further reformulation.
The current Healthy Food Partnership (HFP) proposal does not reflect a sufficient understanding of the new products that have come onto the market since the FHD definitions were agreed. It has not explored why some categories targeted under the FHD found it difficult to address the targets in the timeframe and what would make the targets more achievable.
AFGC’s submission will identify some of the technical challenges of the proposed targets, however individual companies’ submissions will address these in more detail. Where products are already reaching the limits of their capacity for reformulation, a partnership with Government to determine and approve solutions, for example funding for research, may be required.
While the Health Star Rating (HSR) cut-off points for the relevant HSR food categories were considered when determining the draft targets as an incentive for reformulation, if the targets are in fact feasible and achievable, manufacturers are likely to have already made the changes to gain the HSR benefits. Also, the current HSR review and subsequent possible changes to the HSR algorithm, have not been taken into account in determining the targets. Targets must be realistic and achievable rather than tipping points for the HSR algorithm.
The proposed targets do not provide a mechanism for companies to identify where there is the opportunity to reformulate appropriate products in their portfolios and to commit to percentage reductions, phased reductions, maximum or average levels or to targeting products with high sales volume. Nor do they recognise the role of product development going forward and that innovation is easier than renovation. It is also important to note that successful reformulation has often allowed the time that consumers need to adjust to less salty or sweet products.
The current approach implies 100% compliance by companies who would be judged on a pass or fail criteria. It is clearly not attractive for companies to engage with an initiative that is likely to attract criticism of both the companies involved and the HFP in general if some of their products do not meet the set targets within the set time frame. Consideration should be given to the New Zealand Heart Foundation’s Food Reformulation Programme that aims for 80% (by market share) of a food category to achieve the nutrient targets. This approach would also align with that taken by the former FHD.
The consultation paper acknowledges that the methodology used to determine the foods making the greatest contribution to Australians’ intake of sodium, saturated fat and total sugars, is limited. It is based on the nutrient profile of foods in 2011-12 Australian Health Survey (AHS) rather than current products. The FHD resulted in the achievement of significant sodium reductions1 and continued until 2014. The current methodology reflects FHD baseline or mid-term sodium values and does not recognise the significant effort that industry invested to achieve the results reported1. In fact the determination of which foods make the greatest contributions to the nutrients of interest does not acknowledge and reward any of the reformulation efforts made by companies since
2011-12. Current product nutrient profiles have been used through the FoodTrack database to determine the targets but it is not used to determine the scope of the categories.
The methodology also does not appear to have given any consideration to the nutrient dense foods, that are recommended within the dietary guidelines; rather a blanket approach to identifying product categories contributing to intakes of saturated fat, sugar and sodium has been taken that could lead to unintended consequences, such as reductions in the consumption of five food group foods.
Reformulation is likely to impact Australian made products more than imported products. Targets and timeframes need to ensure that consumers continue to be able to choose a wide range of Australian made products that meet their preferences.
A collaborative, targeted consultation process with industry, to co-design a scope, targets and timeframes that have the necessary flexibility to make them feasible and achievable is far more likely to engage more companies who would like to contribute to the success of this reformulation initiative in ways that recognise the diversity in both the food supply and across the industry. As part of this collaborative approach, any ongoing reformulation program needs to plan to monitor, evaluate and review targets to assess impact and continued feasibility. Prior to the launch of a reformulation program, industry consultation would also be required to determine the:
• Definition of the baseline values and opportunity for industry to check the data that relates to their products
• Form and content of the reporting and how industry would contribute
• Opportunities for industry to correct data about their products
• Nutrients that would be reported i.e. only the targeted nutrients or also other nutrients to monitor any unintended consequences.
Reformulation should also consider the addition and recognition of positive nutrients, where permitted by the Food Standards Code, rather than focusing only on the reduction of risk-associated nutrients.
1. Report on the Evaluation of the nine Food Categories for which reformulation targets were set under the Food and Health Dialogue https://www.health.gov.au/internet/main/publishing.nsf/Content/7BD47FA4705160A6CA25800C008088B9/$File/Healthy%20Food%20Partnership%20Evaluation%20Report_Heart%20Foundation.pdf
The AFGC supports reformulation as a public health measure where:
• There is evidence of a significant impact on health outcomes at a population level
• Targets are developed and agreed in collaboration with the relevant manufacturers to ensure they are feasible, achievable and flexible enough to accommodate the diversity across products, portfolios and businesses
• It remains voluntary
• Efforts by businesses, both large and small are acknowledged and rewarded
• Previous and ongoing reformulation activity is recognised and rewarded and limitations on further change are accepted
• The role of product development and the nutrient profile of new products in shaping the food supply is recognised
• Australians continue to have access to a diverse and wide ranging variety of products that meets their preferences and contributes to their social and nutritional needs, health and well-being
• There is a process, where possible, to engage manufacturers of imported products to ensure the competitiveness of Australian made products is not disadvantaged
• Reporting is meaningful and the burden on industry is manageable
• There is opportunity to reformulate within the usual business cycles of product renovation and renewal of labels.
The AFGC recognises the work that has gone into the current draft targets and thanks the Healthy Food Partnership Reformulation Working Group for their time and effort.
However, the AFGC is not able to support the current nutrient reformulation proposal as a public health measure, because consultation with members to inform this submission has highlighted many issues that need to be addressed. While the AFGC will be providing examples of some of the problems with the current proposal, comprehensive, detailed feedback on the draft definitions or targets for all the products in scope will not be provided. Individual companies, know their products and processes best and are better positioned to provide the detail regarding their specific products and portfolios.
AFGC recommends that a collaborative, targeted consultation process with industry, be undertaken to co-design category definitions, targets and timeframes that have the necessary flexibility to make them feasible and achievable.
Many of the draft category definitions are not appropriate and the draft targets and timeframe are not feasible. The problems have arisen because the methodology used is not fit for purpose. Unlike the methodology used by the former Food and Health Dialogue (FHD), that resulted in the achievement of significant sodium reductions1, the current process has not consulted those who understand the most about the individual products and the necessary business and technical processes, and who will be required to implement the targets. It has instead resulted in category definitions, targets and expectations that have not recognised the diversity of:
• importance of the targeted nutrients in determining the consumer experience
• functional roles that the targeted nutrients play in manufacturing
• production processes and the different ways that similar products are manufactured
• characterising ingredients and the importance of these to product quality and consumers’ perception of that quality
• current levels of targeted nutrients and the size of the change required to reach the target
• consumers’ expectations and preferences (both of product characteristics and of price point)
• iconic, historical or signature products and consumer resistance to change
• size of portfolios and the resources required to reformulate and revalidate all products
• sales volume and role of products in portfolios (i.e. the feasibility of directing resources towards reformulation of lower volume, minor parts of the portfolio may vary)
• the completed reformulation of products to date, in response to changing consumer demands and company and external commitments, and the limitations on further reformulation.
The current Healthy Food Partnership (HFP) proposal does not reflect a sufficient understanding of the new products that have come onto the market since the FHD definitions were agreed. It has not explored why some categories targeted under the FHD found it difficult to address the targets in the timeframe and what would make the targets more achievable.
AFGC’s submission will identify some of the technical challenges of the proposed targets, however individual companies’ submissions will address these in more detail. Where products are already reaching the limits of their capacity for reformulation, a partnership with Government to determine and approve solutions, for example funding for research, may be required.
While the Health Star Rating (HSR) cut-off points for the relevant HSR food categories were considered when determining the draft targets as an incentive for reformulation, if the targets are in fact feasible and achievable, manufacturers are likely to have already made the changes to gain the HSR benefits. Also, the current HSR review and subsequent possible changes to the HSR algorithm, have not been taken into account in determining the targets. Targets must be realistic and achievable rather than tipping points for the HSR algorithm.
The proposed targets do not provide a mechanism for companies to identify where there is the opportunity to reformulate appropriate products in their portfolios and to commit to percentage reductions, phased reductions, maximum or average levels or to targeting products with high sales volume. Nor do they recognise the role of product development going forward and that innovation is easier than renovation. It is also important to note that successful reformulation has often allowed the time that consumers need to adjust to less salty or sweet products.
The current approach implies 100% compliance by companies who would be judged on a pass or fail criteria. It is clearly not attractive for companies to engage with an initiative that is likely to attract criticism of both the companies involved and the HFP in general if some of their products do not meet the set targets within the set time frame. Consideration should be given to the New Zealand Heart Foundation’s Food Reformulation Programme that aims for 80% (by market share) of a food category to achieve the nutrient targets. This approach would also align with that taken by the former FHD.
The consultation paper acknowledges that the methodology used to determine the foods making the greatest contribution to Australians’ intake of sodium, saturated fat and total sugars, is limited. It is based on the nutrient profile of foods in 2011-12 Australian Health Survey (AHS) rather than current products. The FHD resulted in the achievement of significant sodium reductions1 and continued until 2014. The current methodology reflects FHD baseline or mid-term sodium values and does not recognise the significant effort that industry invested to achieve the results reported1. In fact the determination of which foods make the greatest contributions to the nutrients of interest does not acknowledge and reward any of the reformulation efforts made by companies since
2011-12. Current product nutrient profiles have been used through the FoodTrack database to determine the targets but it is not used to determine the scope of the categories.
The methodology also does not appear to have given any consideration to the nutrient dense foods, that are recommended within the dietary guidelines; rather a blanket approach to identifying product categories contributing to intakes of saturated fat, sugar and sodium has been taken that could lead to unintended consequences, such as reductions in the consumption of five food group foods.
Reformulation is likely to impact Australian made products more than imported products. Targets and timeframes need to ensure that consumers continue to be able to choose a wide range of Australian made products that meet their preferences.
A collaborative, targeted consultation process with industry, to co-design a scope, targets and timeframes that have the necessary flexibility to make them feasible and achievable is far more likely to engage more companies who would like to contribute to the success of this reformulation initiative in ways that recognise the diversity in both the food supply and across the industry. As part of this collaborative approach, any ongoing reformulation program needs to plan to monitor, evaluate and review targets to assess impact and continued feasibility. Prior to the launch of a reformulation program, industry consultation would also be required to determine the:
• Definition of the baseline values and opportunity for industry to check the data that relates to their products
• Form and content of the reporting and how industry would contribute
• Opportunities for industry to correct data about their products
• Nutrients that would be reported i.e. only the targeted nutrients or also other nutrients to monitor any unintended consequences.
Reformulation should also consider the addition and recognition of positive nutrients, where permitted by the Food Standards Code, rather than focusing only on the reduction of risk-associated nutrients.
1. Report on the Evaluation of the nine Food Categories for which reformulation targets were set under the Food and Health Dialogue https://www.health.gov.au/internet/main/publishing.nsf/Content/7BD47FA4705160A6CA25800C008088B9/$File/Healthy%20Food%20Partnership%20Evaluation%20Report_Heart%20Foundation.pdf
Are you aware of any general public health risks associated with reformulation of select nutrients (i.e. sodium, saturated fat, sugars)?
Please select one item
(Required)
No
Ticked
Yes - (If yes, please indicate which food category and nutrient (s); and provide details and supporting evidence.
Portion size reduction and use of healthier oils
Are there any subcategories for these product types where a portion size reduction may not be feasible? If so, can you suggest an alternative approach to achieve a similar outcome?
If so, can you suggest an alternative approach to achieve a similar outcome?
AFGC recommends that the consistent terminology recommended by the Healthy Food Partnership Portion Size Working Group (PSWG) be adopted by the Healthy Food Partnership Reformulation Working Group (RWG) to ensure that the different activities with the Healthy Food Partnership have an internal consistency and support and reinforce each other.
The PSWG recommends that (1):
• If the size or the amount of food is determined/selected by the manufacturer/business/home cook or host then use the term ‘serving’.
• If size or amount of food is determined/selected by the person eating then use the term ‘portion’.
• The term ‘serve’ should only be used in reference to the Australian Dietary Guidelines reference serves.
AFGC strongly recommends that greater clarity be provided with regard to the specific intended impact of the serving size reduction. For example, is a specific nutrient reduction or energy intake reduction the primary focus? What is the expected impact on population intake as modelled by the methodology used by the RWG? Also, more detail is required about what changes are being proposed.
It is important to note that a secondary analysis(2) of data from the 2011-12 Australian Health Survey shows that for some of the subcategories (sweet biscuits, chocolate, lollies, jelly), the median portion size of Australian adults is already similar to or less than a serve size of a discretionary food in the Australian Guide to Healthy Eating.
Also, the targets should consider the significant work already completed in this area, by individual companies who have reduced the serving sizes of some of their existing product range and introduced new products that are appropriately sized. How would serving size reductions already completed be captured in the reporting? Would baseline data allow for this work to be included and if not how is it intended that this work is also positively communicated?
The changes in serving size that manufacturers are already implementing are often also supported by serving size and portion size information on the label. Some examples are included below:
https://www.nestlechoosewellness.com.au/your-wellbeing/nestle-launches-innovative-a-new-portion-device/
https://cdn.aigroup.com.au/Submissions/General/2018/Senate_Obesity_inquiry_Ai_Group_July_2018.pdf
(Also refer to the Ai Group Confectionery Sector Submission for this Consultation.)
The product range within each subcategory identified by the RWG is very broad and serving size reductions may not be feasible for all items within a company’s portfolio for a variety of reasons including:
• Serving size reduction can be complex and incur significant costs to a company when considering the changes required to manufacturing processes, packaging production line, packaging, relabelling, resizing within vending machines and consumer information and messaging.
• While some products are individually wrapped, others are not, or they are intended as family size or share packs (such ice-cream tubs or packets of sweet biscuits). Introducing new packaging of products into individual servings may not be acceptable to consumers. There is a growing concern regarding the environmental impact of increased packaging. An alternate approach is to support the serving size label information already available, with consumer education about portion size. A consumer education strategy is one of the recommendations from the PSWG.
Recommendation 1 Better Awareness: develop and implement a communications strategy and campaign to promote appropriate sizes of portions, using agreed terminology, to address consumer perceptions about portion (1)
• Additionally, reducing serving size may not meet consumer expectations where they perceive a decrease in value for money. Consumers may also respond to smaller servings of products by increasing the number of servings they consume and their overall portion size.
AFGC recommends that this approach would be better placed with the activities of the Portion Size Working Group (PSWG) due to the PSWG’s understanding and consideration of the broader implications. Targeted consultation with key industry could be implemented within the roll out of the PSWG’s recommendations.
Implementation of specific serving size changes should also be accompanied by a concurrent consumer education strategy as recommended by the PSWG (1).
The Portion Size Reformulation Working Group has made specific recommendations for industry that include:
Recommendation 2 Better Choices: develop and implement an industry engagement strategy to adopt voluntary activities to support healthier sizes of portions and sizes of servings.
This strategy would involve the following three key activities:
1. Encourage stakeholders to adopt activities which contribute to the priority areas relating to the sizes of portions.
These activities should be embedded into the broader Healthy Food Partnership implementation plan. For example, the Portion Size Working Group voluntary activities can be combined with the draft pledges developed by the Food Service Working Group, and targets set by the Reformulation Working Group, to result in a suite of pledges for implementation across different sectors.
2. Develop voluntary goals for sizes of servings of key discretionary foods and drinks.
These goals should build on existing resources, recognise that a range is likely to be more appropriate than one amount, and be developed and launched over the next two years.
A content-specific group should be convened to develop draft goals, commissioned by the Department of Health.
3. Develop and implement an Industry Best Practice Guide.
This should provide guidance and support to food companies to incorporate nutrition as a key driver in labelling decisions regarding the size of servings and the size of food and drinks offered.
A content-specific group should be convened to develop this guidance, commissioned by the Department of Health.
For food service products, serving size reduction is best placed within the context of the Food Service Pledge Better Choices Theme: Food and Beverage Sizes (3) in collaboration with the activities of the Portion Size Working Group.
(1)http://www.health.gov.au/internet/main/publishing.nsf/Content/D1303EA4560AC170CA257FAD00823954/$File/Portion%20Size%20Working%20Group%20report.pdf
(2) https://www.nature.com/articles/srep19596
(3)http://www.health.gov.au/internet/main/publishing.nsf/Content/E398A923DDAA5FF5CA257FAD00823955/$File/Food%20Service%20Working%20Group-%20final%20Rationale%20%20MAY%202018.pdf
The PSWG recommends that (1):
• If the size or the amount of food is determined/selected by the manufacturer/business/home cook or host then use the term ‘serving’.
• If size or amount of food is determined/selected by the person eating then use the term ‘portion’.
• The term ‘serve’ should only be used in reference to the Australian Dietary Guidelines reference serves.
AFGC strongly recommends that greater clarity be provided with regard to the specific intended impact of the serving size reduction. For example, is a specific nutrient reduction or energy intake reduction the primary focus? What is the expected impact on population intake as modelled by the methodology used by the RWG? Also, more detail is required about what changes are being proposed.
It is important to note that a secondary analysis(2) of data from the 2011-12 Australian Health Survey shows that for some of the subcategories (sweet biscuits, chocolate, lollies, jelly), the median portion size of Australian adults is already similar to or less than a serve size of a discretionary food in the Australian Guide to Healthy Eating.
Also, the targets should consider the significant work already completed in this area, by individual companies who have reduced the serving sizes of some of their existing product range and introduced new products that are appropriately sized. How would serving size reductions already completed be captured in the reporting? Would baseline data allow for this work to be included and if not how is it intended that this work is also positively communicated?
The changes in serving size that manufacturers are already implementing are often also supported by serving size and portion size information on the label. Some examples are included below:
https://www.nestlechoosewellness.com.au/your-wellbeing/nestle-launches-innovative-a-new-portion-device/
https://cdn.aigroup.com.au/Submissions/General/2018/Senate_Obesity_inquiry_Ai_Group_July_2018.pdf
(Also refer to the Ai Group Confectionery Sector Submission for this Consultation.)
The product range within each subcategory identified by the RWG is very broad and serving size reductions may not be feasible for all items within a company’s portfolio for a variety of reasons including:
• Serving size reduction can be complex and incur significant costs to a company when considering the changes required to manufacturing processes, packaging production line, packaging, relabelling, resizing within vending machines and consumer information and messaging.
• While some products are individually wrapped, others are not, or they are intended as family size or share packs (such ice-cream tubs or packets of sweet biscuits). Introducing new packaging of products into individual servings may not be acceptable to consumers. There is a growing concern regarding the environmental impact of increased packaging. An alternate approach is to support the serving size label information already available, with consumer education about portion size. A consumer education strategy is one of the recommendations from the PSWG.
Recommendation 1 Better Awareness: develop and implement a communications strategy and campaign to promote appropriate sizes of portions, using agreed terminology, to address consumer perceptions about portion (1)
• Additionally, reducing serving size may not meet consumer expectations where they perceive a decrease in value for money. Consumers may also respond to smaller servings of products by increasing the number of servings they consume and their overall portion size.
AFGC recommends that this approach would be better placed with the activities of the Portion Size Working Group (PSWG) due to the PSWG’s understanding and consideration of the broader implications. Targeted consultation with key industry could be implemented within the roll out of the PSWG’s recommendations.
Implementation of specific serving size changes should also be accompanied by a concurrent consumer education strategy as recommended by the PSWG (1).
The Portion Size Reformulation Working Group has made specific recommendations for industry that include:
Recommendation 2 Better Choices: develop and implement an industry engagement strategy to adopt voluntary activities to support healthier sizes of portions and sizes of servings.
This strategy would involve the following three key activities:
1. Encourage stakeholders to adopt activities which contribute to the priority areas relating to the sizes of portions.
These activities should be embedded into the broader Healthy Food Partnership implementation plan. For example, the Portion Size Working Group voluntary activities can be combined with the draft pledges developed by the Food Service Working Group, and targets set by the Reformulation Working Group, to result in a suite of pledges for implementation across different sectors.
2. Develop voluntary goals for sizes of servings of key discretionary foods and drinks.
These goals should build on existing resources, recognise that a range is likely to be more appropriate than one amount, and be developed and launched over the next two years.
A content-specific group should be convened to develop draft goals, commissioned by the Department of Health.
3. Develop and implement an Industry Best Practice Guide.
This should provide guidance and support to food companies to incorporate nutrition as a key driver in labelling decisions regarding the size of servings and the size of food and drinks offered.
A content-specific group should be convened to develop this guidance, commissioned by the Department of Health.
For food service products, serving size reduction is best placed within the context of the Food Service Pledge Better Choices Theme: Food and Beverage Sizes (3) in collaboration with the activities of the Portion Size Working Group.
(1)http://www.health.gov.au/internet/main/publishing.nsf/Content/D1303EA4560AC170CA257FAD00823954/$File/Portion%20Size%20Working%20Group%20report.pdf
(2) https://www.nature.com/articles/srep19596
(3)http://www.health.gov.au/internet/main/publishing.nsf/Content/E398A923DDAA5FF5CA257FAD00823955/$File/Food%20Service%20Working%20Group-%20final%20Rationale%20%20MAY%202018.pdf
What type of changes are required to business practices and infrastructure, (rather than recipes) to effect a portion size reduction?
Please provide details
Industry has identified that significant changes would be required to production processes, labelling, packaging, vending machines, consumer education and messaging as a result of product serving size reduction. There may also be a significant financial impact if consumers perceive products to be lower value for money or that, due to the use of increased packaging resources, this strategy is misaligned with other business objectives to reduce packaging and the environmental footprint. Greater detail about the specific serving size reductions being proposed is needed to provide more specific feedback on the type of changes required.
The necessary flexibility is also required to ensure companies have the capacity to nominate products more appropriate for serving reduction within a company’s portfolio.
Again AFGC recommends that this activity would be best placed within the activities of the Portion Size Working Group in consultation with key industry to ensure the broader implications of product serving reductions are considered.
http://www.health.gov.au/internet/main/publishing.nsf/Content/D1303EA4560AC170CA257FAD00823954/$File/Portion%20Size%20Working%20Group%20report.pdf
The necessary flexibility is also required to ensure companies have the capacity to nominate products more appropriate for serving reduction within a company’s portfolio.
Again AFGC recommends that this activity would be best placed within the activities of the Portion Size Working Group in consultation with key industry to ensure the broader implications of product serving reductions are considered.
http://www.health.gov.au/internet/main/publishing.nsf/Content/D1303EA4560AC170CA257FAD00823954/$File/Portion%20Size%20Working%20Group%20report.pdf
What lead time is considered appropriate to prepare for these changes, for business preparedness ahead of the implementation time period beginning?
Suggested leadtime
Without more detail about the intended impact of the serving size changes it is not possible to identify specific changes that would be effective and feasible, nor the lead time to prepare for them. For example, the timing would depend on the type of change that had to be implemented – large scale manufacturing changes would take significantly longer than on pack communication. In some cases serving size reductions may take longer than simple reformulation due to the required investment in infrastructure and other elements of production. More information about the specific serving size reductions being proposed is needed to provide more specific feedback on the lead time required.
Regarding the use of healthier oils, some products will require longer timeframes to investigate the possibility of using different oils and experimentation. Further targeted consultation with individual companies would help clarify which products will require longer timeframes than others due to technical complexities and the resulting implications. These might include existing agreements and contracts, expenditure needed for new equipment and machinery, research into the suitability of different oil blends and ways to account for any impact on flavour and texture as well as implications for manufacturing processes.
AFGC again recommends that serving size changes be implemented with the Portion Size Reformulation Working Group (PSWG) recommendations and also further targeted consultation with key industry regarding both serving size changes and the use of healthier oils be undertaken.
http://www.health.gov.au/internet/main/publishing.nsf/Content/D1303EA4560AC170CA257FAD00823954/$File/Portion%20Size%20Working%20Group%20report.pdf
Regarding the use of healthier oils, some products will require longer timeframes to investigate the possibility of using different oils and experimentation. Further targeted consultation with individual companies would help clarify which products will require longer timeframes than others due to technical complexities and the resulting implications. These might include existing agreements and contracts, expenditure needed for new equipment and machinery, research into the suitability of different oil blends and ways to account for any impact on flavour and texture as well as implications for manufacturing processes.
AFGC again recommends that serving size changes be implemented with the Portion Size Reformulation Working Group (PSWG) recommendations and also further targeted consultation with key industry regarding both serving size changes and the use of healthier oils be undertaken.
http://www.health.gov.au/internet/main/publishing.nsf/Content/D1303EA4560AC170CA257FAD00823954/$File/Portion%20Size%20Working%20Group%20report.pdf
Nutrient reformulation targets have a suggested four year implementation period, with a report on progress after two years. Is a similar timeframe suitable for portion size reduction? For changing to healthier oils?
Please select one item
Yes
Ticked
No
Don't know
Not applicable
Please provide details
Portion Size Reduction Timeframe
It would again be recommended that this activity be included in the implementation of the Portion Size Working Group (PSWG) recommendations. Targeted consultation with key industry could be implemented within the roll out of the PSWG’s recommendations.
http://www.health.gov.au/internet/main/publishing.nsf/Content/D1303EA4560AC170CA257FAD00823954/$File/Portion%20Size%20Working%20Group%20report.pdf
Use of Healthier Oils Timeframe
Changes in production processes to reduce oils and increase the use of healthier oils has already been undertaken by many individual companies.
However the disclosure of ongoing current work specific details is not considered appropriate within this forum due to commercial in-confidence issues.
The success of product reformulation and reduced portion sizing to date by individual companies, could be collated and presented, in a similar way to that of the Heart Foundations Tick program https://www.heartfoundation.org.au/healthy-eating/heart-foundation-tick/tick-achievements?_ga=2.14457079.179054458.1539229034-1460091540.1535609943
For food service products, changing to healthier oils is best placed within the context and implementation of the Food Service Pledge Better Ingredients Theme: Healthier oils and fats.
http://www.health.gov.au/internet/main/publishing.nsf/Content/E398A923DDAA5FF5CA257FAD00823955/$File/Food%20Service%20Working%20Group-%20final%20Rationale%20%20MAY%202018.pdf
It would again be recommended that this activity be included in the implementation of the Portion Size Working Group (PSWG) recommendations. Targeted consultation with key industry could be implemented within the roll out of the PSWG’s recommendations.
http://www.health.gov.au/internet/main/publishing.nsf/Content/D1303EA4560AC170CA257FAD00823954/$File/Portion%20Size%20Working%20Group%20report.pdf
Use of Healthier Oils Timeframe
Changes in production processes to reduce oils and increase the use of healthier oils has already been undertaken by many individual companies.
However the disclosure of ongoing current work specific details is not considered appropriate within this forum due to commercial in-confidence issues.
The success of product reformulation and reduced portion sizing to date by individual companies, could be collated and presented, in a similar way to that of the Heart Foundations Tick program https://www.heartfoundation.org.au/healthy-eating/heart-foundation-tick/tick-achievements?_ga=2.14457079.179054458.1539229034-1460091540.1535609943
For food service products, changing to healthier oils is best placed within the context and implementation of the Food Service Pledge Better Ingredients Theme: Healthier oils and fats.
http://www.health.gov.au/internet/main/publishing.nsf/Content/E398A923DDAA5FF5CA257FAD00823955/$File/Food%20Service%20Working%20Group-%20final%20Rationale%20%20MAY%202018.pdf
From a business perspective, is there any benefit in having the timeframe for nutrient reformulation targets overlap with the change to healthier oils?
Please select one item
Yes
No
Ticked
Don't know
Please provide details
For food service products, changing to healthier oils is best placed within the context and implementation of the Food Service Pledge Better Ingredients Theme: Healthier oils and fats.
http://www.health.gov.au/internet/main/publishing.nsf/Content/E398A923DDAA5FF5CA257FAD00823955/$File/Food%20Service%20Working%20Group-%20final%20Rationale%20%20MAY%202018.pdf
http://www.health.gov.au/internet/main/publishing.nsf/Content/E398A923DDAA5FF5CA257FAD00823955/$File/Food%20Service%20Working%20Group-%20final%20Rationale%20%20MAY%202018.pdf
Do you have any suggested changes to the inclusions / exclusions of the draft definitions?
Please select one item
Ticked
Yes
No
Please provide details
There is a need for greater transparency and clarity regarding the rationale and methodology underpinning the selection of subcategories and the intended impact of the serving size changes.
Also, the inclusions and exclusions for the current subcategories are broad and alignment with the draft nutrient reformulation targets definitions is recommended for greater clarity and consistency.
Also, the inclusions and exclusions for the current subcategories are broad and alignment with the draft nutrient reformulation targets definitions is recommended for greater clarity and consistency.