Demographics
What is your name?
Name
Katarnya Hickey
If you answered yes to the question above, please provide your organisation's name.
Organisation
Obesity Policy Coalition
Demographics (continued)
Where do you live, or where is your organisation based? Please select one item.
Please select one item
(Required)
NSW
Ticked
Victoria
Queensland
Western Australia
South Australia
Tasmania
ACT
Northern Territory
Outside of Australia
What is your background/interest group?
Please select one item
(Required)
General public
Consumer group
Government
Industry
Ticked
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
The Obesity Policy Coalition supports reformulation of high sugar products as a public health measure. Reformulation is an important part of a comprehensive approach to improving diets and reducing obesity in both adults and children. As the consultation paper notes, more than half of all Australians older than two years exceed the World Health Organization’s guideline on consumption of free sugar. Australians are consuming an average of 60g of added sugar per day, with 81% of this from discretionary food and drinks.
We strongly support the introduction of clear, specific nutrient reformulation targets, with a fixed timeframe for each target to be met. Ideally, reformulation goals should be backed by government regulation or co-regulation, which will enable action to be taken where food manufacturers fail to meet the targets. Targets must be aligned with the Australian Dietary Guidelines and complement the Health Star Rating System.
International experience shows us that reformulation measures that are strong and government-led can lead to meaningful change. The UK achieved success with its salt reduction strategy, achieving a reduction in salt consumption of 0.9g per day between 2005 and 2014 (Reference: Public Health England, National Diet and Nutrition Survey: assessment of dietary sodium Adults (19 to 64 years) in England, 2014, March 2016). Its sugar reduction program, by contrast, has not reached its targets at this stage. Some categories and products, however, have shown reductions in sugar content, and Public Health England advises that this is an early progress report and an updated progress report is due in 2019.
We strongly support the introduction of clear, specific nutrient reformulation targets, with a fixed timeframe for each target to be met. Ideally, reformulation goals should be backed by government regulation or co-regulation, which will enable action to be taken where food manufacturers fail to meet the targets. Targets must be aligned with the Australian Dietary Guidelines and complement the Health Star Rating System.
International experience shows us that reformulation measures that are strong and government-led can lead to meaningful change. The UK achieved success with its salt reduction strategy, achieving a reduction in salt consumption of 0.9g per day between 2005 and 2014 (Reference: Public Health England, National Diet and Nutrition Survey: assessment of dietary sodium Adults (19 to 64 years) in England, 2014, March 2016). Its sugar reduction program, by contrast, has not reached its targets at this stage. Some categories and products, however, have shown reductions in sugar content, and Public Health England advises that this is an early progress report and an updated progress report is due in 2019.
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.
dropdown list of nutrients
Please select one item
sodium
saturated fat
Ticked
sugars
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?
We do not support the application of portion size reduction to particular subcategories in place of reformulation targets for sugar reduction. We support an alternative approach where reformulation targets are set in addition to portion size reduction. We recommend clear and ambitious portion size reduction targets, requiring manufacturers to reduce the size of single serve products and bulk packs by a set percentage amount.
We are concerned that the proposed approach excludes a significant proportion of the free sugars consumed across the Australian population from reformulation targets – over 37% based on the figures provided in the discussion paper. As the discussion paper notes, more than half of Australians aged two years and older exceeded the WHO guideline for consumption of free sugars. This supports the need for reformulation of high sugar, discretionary products. We support portion size reduction as an important tool in improving diets, however it should be used in addition to, and not in place of, reformulation targets.
The consultation paper says that ‘For certain food categories where there is already significant product variation to enable consumer choice; both in product type, size and sugar content, seven food categories were determined to be best addressed by portion size reduction, and communication about the place of these (mainly discretionary) foods in total diet.’ As we outlined in our earlier response, we do not agree with this approach. In our view, the existence of significant product variation provides even further support for reformulation of existing high sugar options. This is because it shows that some consumers are still choosing high sugar options, even where there are a range of choices available. Those consumers stand to benefit from the reduction in sugar in the products they consume.
The portion size reduction consultation paper focuses on portion size reduction as a strategy to reduce energy intake and obesity; however, does not explain why reformulation targets could not be achieved for the various product categories. The paper notes that reformulation of fruit and vegetable juices to remove naturally occurring sugars is not possible other than by dilution, and we accept that. For other categories, however, the paper discusses the role of discretionary foods as adding variety, contributing to overall enjoyment of eating and as part of social activities and family or cultural celebrations. The paper says that ‘Rather than changing the taste of these products through reformulation, focusing on reducing portion sizes may therefore be a more appropriate strategy.’
We agree that some discretionary foods are often consumed as part of social activities and celebrations, and we accept that they will continue to be consumed by Australians. We know, however, that discretionary foods aren’t only consumed occasionally. As the consultation paper notes, Australians spend more than half of their food budget on discretionary foods.
On the whole, we are not satisfied that there is any fundamental difference in the nature of these products as compared to others, such that they cannot or should not be reformulated (other than 100% fruit juice). We don’t accept that the taste of these products should never be changed or that reformulation must necessarily change their taste to a significant extent. We also do not accept that the product variation within these categories is any different from the variation within other categories.
We are also concerned that where portion size reduction is highlighted as appropriate, there are currently no targets set to determine how much reduction is required. If portion size reduction is adopted as a strategy across these product categories, we recommend clear, ambitious targets, requiring manufacturers to reduce the size of single serve products and bulk packs by a set percentage amount. We are also concerned about the effectiveness of changing the displayed serving size and number of servings in multi-serve packs. While we agree that consumers should be provided with accurate information on appropriate serving sizes, we do not think changing this information is likely to have a meaningful impact on consumption. To the greatest extent possible, portion size reduction should be implemented by reducing the actual size of the product sold, whether it is in a single serve or a multipack.
We are concerned that the proposed approach excludes a significant proportion of the free sugars consumed across the Australian population from reformulation targets – over 37% based on the figures provided in the discussion paper. As the discussion paper notes, more than half of Australians aged two years and older exceeded the WHO guideline for consumption of free sugars. This supports the need for reformulation of high sugar, discretionary products. We support portion size reduction as an important tool in improving diets, however it should be used in addition to, and not in place of, reformulation targets.
The consultation paper says that ‘For certain food categories where there is already significant product variation to enable consumer choice; both in product type, size and sugar content, seven food categories were determined to be best addressed by portion size reduction, and communication about the place of these (mainly discretionary) foods in total diet.’ As we outlined in our earlier response, we do not agree with this approach. In our view, the existence of significant product variation provides even further support for reformulation of existing high sugar options. This is because it shows that some consumers are still choosing high sugar options, even where there are a range of choices available. Those consumers stand to benefit from the reduction in sugar in the products they consume.
The portion size reduction consultation paper focuses on portion size reduction as a strategy to reduce energy intake and obesity; however, does not explain why reformulation targets could not be achieved for the various product categories. The paper notes that reformulation of fruit and vegetable juices to remove naturally occurring sugars is not possible other than by dilution, and we accept that. For other categories, however, the paper discusses the role of discretionary foods as adding variety, contributing to overall enjoyment of eating and as part of social activities and family or cultural celebrations. The paper says that ‘Rather than changing the taste of these products through reformulation, focusing on reducing portion sizes may therefore be a more appropriate strategy.’
We agree that some discretionary foods are often consumed as part of social activities and celebrations, and we accept that they will continue to be consumed by Australians. We know, however, that discretionary foods aren’t only consumed occasionally. As the consultation paper notes, Australians spend more than half of their food budget on discretionary foods.
On the whole, we are not satisfied that there is any fundamental difference in the nature of these products as compared to others, such that they cannot or should not be reformulated (other than 100% fruit juice). We don’t accept that the taste of these products should never be changed or that reformulation must necessarily change their taste to a significant extent. We also do not accept that the product variation within these categories is any different from the variation within other categories.
We are also concerned that where portion size reduction is highlighted as appropriate, there are currently no targets set to determine how much reduction is required. If portion size reduction is adopted as a strategy across these product categories, we recommend clear, ambitious targets, requiring manufacturers to reduce the size of single serve products and bulk packs by a set percentage amount. We are also concerned about the effectiveness of changing the displayed serving size and number of servings in multi-serve packs. While we agree that consumers should be provided with accurate information on appropriate serving sizes, we do not think changing this information is likely to have a meaningful impact on consumption. To the greatest extent possible, portion size reduction should be implemented by reducing the actual size of the product sold, whether it is in a single serve or a multipack.
What type of changes are required to business practices and infrastructure, (rather than recipes) to effect a portion size reduction?
Please provide details
Not applicable
What lead time is considered appropriate to prepare for these changes, for business preparedness ahead of the implementation time period beginning?
Suggested leadtime
We do not support the provision of any lead time on top of the implementation period. The purpose of the implementation period is to allow manufacturers time to prepare and plan for product reformulation or portion size reduction. It is unclear why an additional time period would be required in the context of portion size reduction.
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
In our view, any portion size reduction could take place in a reduced time period, for example a two year implementation period with a progress report after one year. Unlike reformulation targets, portion size reduction does not require work to develop reformulated recipes. Changes to manufacturing processes and packaging would be required, however in our view this could be achieved in less than four years.
From a business perspective, is there any benefit in having the timeframe for nutrient reformulation targets overlap with the change to healthier oils?
Please provide details
Not applicable
Do you have any suggested changes to the inclusions / exclusions of the draft definitions?
Please provide details
The draft definitions provided are broad and do not generally list specific inclusions and exclusions as has been done for the categories that have reformulation targets. We support broadly defined categories to capture as many discretionary food products as possible.