Healthy Food Partnership Voluntary Food Reformulation Targets - Public Consultation

DAA supports food reformulation as a public health measure to make healthier food choices easier and more accessible, noting it has been successfully
implemented in Australia [4,5], and in the past in several other countries [6-11].

DAA recognises that voluntary reformulation is a positive first step, however, supports mandating food reformulation in certain food categories would encourage
innovation in the food industry to find alternatives that consider both food safety and consumer acceptance [12, 13].

DAA views strong leadership from the government and non-government organisations, in combination with voluntary commitments from industry and ongoing
monitoring and evaluation, as key factors to successful food reformulation [13]. The penalty for those industry players who do not commit to meeting targets may
include negative publicity when evaluation results are published [14].

DAA understands that there is evidence to support an incremental roll-out of targets set with a specified timeframe [13, 15-17]. DAA encourages any food
reformulation initiative be made alongside Front-of Pack labelling, and long term, comprehensive public health messages and education programs [13,18], which
also include risk-factor treatment for high risk groups [19]. Appropriate education for consumers on the importance of food reformulation is important to ensure
reformulation products continue to be purchased and consumers are aware of the health benefits of food reformulation. DAA identifies that this has the potential
to preventing some consumers from adding extra fats, sugar or sodium back into their foods (e.g. sugar to cereals, and salt to meals).

DAA advises that reformulation should look at the whole nutrient profile of a food [13], and should encompass the addition of nutrients or ingredients that have
been identified as important for reducing the burden of disease.

DAA recognises consumption of foods high in saturated fat, added sugar and/or sodium are directly associated with chronic disease, overweight and obesity [1].

The latest Australian Health Survey data [2] shows that Australians are eating too much saturated fat, sodium and added sugar in the form of discretionary foods,
well exceeding the targets recommended by the WHO to improve population health [3].

References:

1. National Health and Medical Research Centre. Australian Dietary Guidelines [internet]. Canberra, ACT: 2013 [cited 18 Aug 11]. Available from:
https://www.nhmrc.gov.au/guidelines-publications/n55
2. Australian Bureau of Statistics. Australian Health Survey: consumption of added sugars, 2011-12 [internet]. Canberra, ACT: Australian Bureau of Statistics;
2016 April 27 [cited 2018 Aug 10]. 36 p. Cat no. 4364.0.55.011. Available from: http://www.abs.gov.au/ausstats/abs@.nsf/mf/4364.0.55.011.
3. World Health Organisation. Fact Sheets [internet]. Healthy Diet. World Health Organisation: Geneva, SWZ. 2018 Aug 24 [cited 2018 Sept 13]. Available from:
http://www.who.int/news-room/fact-sheets/detail/healthy-diet.
4. Trevena H, Neal B, Dunford E, Wu JH. An evaluation of the effects of the Australian food and health dialogue targets on the sodium content of bread, breakfast
cereals and processed meats. Nutrients. 2014; 6:3802–17.
5. Fear T, Gibbons C, Anderson S. The Heart Foundation’s ‘Tick’ Program. Driving innovation for a healthier food supply. Food Australia 2004; 56(12):599–600.
6. Chauliac M, Hercberg S. Changing the food environment: The French experience. Adv Nutr. 2012; 3:605S–610S.
7. Wyness LA, Butriss JL, Stanner SA. Reducing the population’s sodium intake: the UK Food Standards Agency’s salt reduction programme. Public Health Nutr.
2012;15:254–61
8. Hendry VL, Almíron-Roig E, Monsivais P, Jebb SA, Benjamin Neelon SE, Griffin SJ, et al. Impact of regulatory interventions to reduce intake of artificial
trans–fatty acids: A systematic review. Am J Public Health. 2015; 105:e32–42.
9. Combris P, Goglia R, Henini M, Soler LG, Spiteri M. Improvement of the nutritional quality of foods as a public health tool. Public Health. 2011; 125:717–24.
10. Dummer J. Sodium Reduction in Canadian Food Products with the Health Check Program. Can J Diet Prac Res 2012; 73(1):227–232.
11. Downs SM. The effectiveness of policies for reducing dietary trans-fat: a systemic review of the evidence [internet]. Bull World Health Organ: 2013 Feb 4
[cited 2018 sept 13]; 91:262-269H. doi: 10.2471/BLT.12.111468
12. Liem DG, Miremadi F, Keast RSJ. Reducing Sodium in Foods: The Effect on Flavour. Nutrients: 2011 [cited 2018 Sept 21]; 3(6):694-711. Available from:
https://search.proquest.com/docview/1537098421?accountid=34512
13. The Heart Foundation of Australia. Publications [internet]. Rapid review of the evidence: Effectiveness of food reformulation as a strategy to improve
population health [internet]. Canberra, ACT: The Heart Foundation of Australia. 2012 [cited 2018 Sept 20]. Available from:
https://www.heartfoundation.org.au/for-professionals/food-and-nutrition/improving-food-supply.
14. World Health Organisation. WHO Global Coordination Mechanism on the Prevention and Control of NCDs [internet]. Policy Brief: Reducing the use of sodium
in the food industry to lower sodium consumption. Geneva, SWZ: 2014 December [cited 2018 Sept 22]. Available from:
http://www.who.int/global-coordination-mechanism/working-groups/wg-3-1-private-sector-documents/en/
15. He FJ, Brinsden HC, Macgregor GA. Salt reduction in the United Kingdom: a successful experiment in public health. J Hum Hypertens, 2014; 28:345–52.
doi:10.1038/jhh.2013.105
16. Kilcast D, Angus F [eds]. In Reducing Salt in Foods—Practical Strategies. Sensory Issues in Reducing Salt in Food Products. Woodhead Publishing:
Cambridge, UK. 2007; pp. 195–199.
17. Hooper L, Bartlett C, Smith GD, Ebrahim S. Systematic review of long term effects of advice to reduce dietary salt in adults. BMJ. 2002: 325; 628.
18. Obesity Policy Coalition [internet]. Melbourne, Australia: Obesity Policy Coalition Tipping the Scales: Australian obesity prevention consensus; 2017 [cited
2018 Aug 10]. Available from: http://www.opc.org.au/downloads/tipping-the-scales/tipping-the-scales.pdf.
19. Murray CJ, Lauer JA, Hutubessy RC, et al. Effectiveness and costs of interventions to lower systolic blood pressure and cholesterol: a global and regional
analysis on reduction of cardiovascular-disease risk. Lancet 2003; 361 (9359):717–725.

DAA do not identify any subcategories where portion size reductions would not be feasible, however acknowledge that there may be challenges in achieving these reductions for some categories. DAA has highlighted these below, and provides some evidence and suggested strategies to reducing portion sizes.

DAA support that portion size reduction is favourable in the listed categories, with the aim to reduce total dietary energy intake (specifically, via the reduction of discretionary food intake). DAA recognises that additional strategies are needed to support portion size reduction to ensure it translates into consumption of smaller portions in the Australian Population.

A recent review by Lee and Lewis [1] identified and assessed a number of strategies to reduce portion size. This review identified six broad types of portion size intervention: interventions changing/restricting the portion size offered, interventions changing the dishware used, interventions targeting food and drink labelling, interventions involving product reformulation, interventions targeting unit pricing and other ‘novel’ interventions. A number of the strategies described below are based upon information from this review.

DAA identify that one of the six interventions identified in this review, product reformulation, has been covered in depth in the previous two rounds of food reformulation submissions, where there was an aim to reduce sodium, added sugar and saturated fat content of foods. DAA are supportive of food reformulation to reduce energy density of foods of processed foods.

DAA recognises that there are a number of strategies that could be adopted to reduce portion size. The following strategies could be used to reduce the portion size in products within these categories:
• Reduce the portion size (weight) of items sold individually
• Reduce the suggested serving size (weight) in the NIP on bulk products
• Package the product into smaller serve sizes and sell in a multi pack
• Reduce overall weight of items sold to share
• Reduce suggested serving size of the food if sold to share.
• Allowing discretionary foods to be of any size/weight provided they align with the serve sizes or kilojoule content outlined in the Australian Dietary Guidelines [2].
Further comments on some of these strategies are included below.

Reducing the portion size (weight) of items sold individually:

DAA support the strategy to reduce weight of food items that are intended to be one serve only (e.g. an individual chocolate bar). DAA highlights that this strategy is already being implemented in some places across Australia, such as the NSW Ministry of Health school canteen resources [3, 4], which (among other things) recommend maximum portions for individual items (and use easy-to-follow references such as golf balls vs tennis balls). DAA recognise that changes to portion sizes may reduce consumer’s perceived value for money and consideration to pricing must be given. Additionally, there is a risk that consumers may consume more than one serving if they perceive the portion size to be inadequate, which highlights the necessity to combine these changes with long term public health messaging on the benefits of food reformation and portion control.

Reducing the suggested serving size (weight) in the NIP:

DAA support the use of Nutrition Information Panels (NIPs) to reduce portion sizes in packaged foods in combination with comprehensive and long-term public health messaging. DAA recognises there are challenges associated with this, including the reliance on individual consumers to read and understand labels, and then make a decision to adhere to the guidance provided on the NIP about serving sizes. There is evidence to suggest changing NIP labelling to compare foods to a reference serving size alone is ineffective [1]. DAA strongly support the coupling of this strategy with adequate consumer education and public awareness raising, via a social marketing campaign.

A market assessment was conducted byRedacted text (member of the DAA Food Regulatory and Policy Committee) on Wednesday 17 October 2018, at Redacted textin Concord, NSW. It was identified that several sweet bakery products (freshly baked) did not have NIPs. This creates a barrier to achieving product-wide reduced serving sizes.
Package the product into smaller serves sizes and sell in a multi-pack

DAA is unsure if this strategy is always effective at reducing intake of discretionary foods, as consumers still have a choice to consume more than one serving if there is a multi-pack available to them.

DAA is concerned with the potential environmental impact that packaging of portion-controlled share packs may have. Discretionary foods are currently significant contributors to diet-related environmental impacts [5, 6]. DAA supports that packaging is important for food safety and to provide consumers’ information on shelf-life, nutrition information and allergies, however DAA encourages new and innovative strategies to reduce the impact of single-use plastics on the environment. This may include a shift towards bio-degradable packaging, or more novel technologies such as edible packaging. DAA acknowledges there is no simple solution and manufacturers will face many challenges, but highlights investment into research in this area by government and industry is the first step to positive change. Parallel to this, long-term public health messaging is required to invoke change in consumer behaviour and beliefs.

Reducing weight of items sold to share:

DAA recognises it is possible to reduce the weight of products designed to share between several individuals. An example of this are baking mixes, which are part of the sweet bakery and sweet biscuit categories. However, DAA highlights that it is important to determine whether this will actually result in reduce portions at an individual level. Despite the presence of guidance on the NIPs and recipe methods, these portion sizes are still ultimately determined by the consumer during serving.
DAA highlights that consumers should continue to have the option to purchase products sold to share, as they are likely purchased for different reasons including cost-savings [7], and environmental considerations [5, 6]. As above, DAA has highlighted its concerns with increased packaging on the environment. Items sold to share are a way of minimising this impact.

Portion control in line with Australian Dietary Guideline serve sizes and kilojoule contents:

A market assessment was conducted by Redacted text (member of the DAA Food Regulatory and Policy Committee) on Wednesday 17 October 2018, at Redacted textin Concord, NSW. A large variation in serving sizes and the number of kilojoules (kJ) per serve was identified within and across the proposed food categories highlighted in the Consultation document. DAA are able to provide complete data from this market research upon request. Overall, the average energy per serve ranged from 174-1930kJ for a total 62 food items. This included sweet bakery products (range 506-1930kJ/serve; n= 12), sweet biscuits (range 231-795kJ/serve; n= 8), chocolate or chocolate-based confectionary (range 390-1100kJ/serve; n= 14), confectionery (non-chocolate) (range 250-871kJ/serve; n= 8), frozen milk products (range 174-1010kJ/serve; n= 10), dishes with sugar as the main ingredient (range 330-1783.75kJ/serve; n= 3) and fruit and vegetable juices (range 214-495kJ/serve; n= 7). DAA highlights that similar findings have been identified in the literature [8, 9], supporting the need for regulated portion control targets in Australia.

Research based on the Australian Health Survey data found that portion sizes for many commonly consumed discretionary foods have increased, and sizes were consistent across age, gender and SES groups [8]. Given the role of food reformulation to reduce energy intake, DAA encourage the alignment of serve sizes within these food categories with the recommended serve sizes outlined in the Australian Dietary Guidelines [2]. These guidelines recommend a serve size of 600kJ for discretionary foods/drinks. Fruit and vegetable juices would be excluded from this as they are not a discretionary food [10].

Overall, DAA are supportive of strategies to reduce portion sizes and as with any reformulation activities, they should be supported by public health messaging and consumer education. A multi-faceted approach is essential to reduce the over consumption of discretionary foods and energy in Australia.

A comment on portion size vs serving size:

DAA highlight the interchangeable language used when discussing ‘serving sizes’ and ‘portion sizes’. Though these terms mean similar things, consumer market research may also be useful to determine what Australians understand by the terms and to mould education campaigns to be designed with appropriate language in mind. Market research would also be useful to understand how Australians use bulk share bags.

References:

1. Lee A, Lewis M. A Rapid Review of the Evidence - Effective Portion Size Strategies [internet]. The Australian Department of Health and the Australian Prevention Partnership Centre. 2017 Jun [cited 2017 Oct 03]; 21 p. Available from: https://preventioncentre.org.au/resources/evidence-reviews/effective-portion-size-strategies/

2. National Health and Medical Research Council. The Australian Dietary Guidelines [internet]. Canberra: NHMRC. 2013 [cited 2018 Oct 01]; 53 p. Available from: https://www.eatforhealth.gov.au/guidelines

3. NSW Ministry of Health. The NSW Health School Canteen Strategy Food and Drink Benchmark [internet]. Sydney: NSW Ministry of Health. 2017 Feb [Cited 2018 Oct 23]; 22 p. Available from: https://www.health.nsw.gov.au/heal/Pages/healthy-school-canteens.aspx

4. NSW Department of Education. The NSW Healthy School Canteen Strategy - Food and Drink Criteria [Internet]. Third Edition. Sydney: NSW Ministry of Health. 2017 Dec [Cited 2018 Oct 23]; 42 p. Available from: www.healthykids.nsw.gov.au

5. Hadjikakou M. Trimming the excess: environmental impacts of discretionary food consumption in Australia. Ecological Economics. 2017; 131:119-128.

6. Hendrie GA, Baird D, Ridoutt B, Hadjikakou M, Noakes M. Overconsumption of energy and excessive discretionary food intake inflates dietary greenhouse gas emissions in Australia. Nutrients. 2016 Oct 31; 8(11):E690.

7. Griffith, R. Leibtag, E. Leicester, A. Nevo, A. 2009. Consumer shopping behaviour: How much do consumers save? Journal of Economic Perspectives, 23:2, 99-120.

8. Haskelberg, H. Neal, B. Dunford, E. Flood, V. Rangan, A. Thomas, B. Cleanthous, X. Trevena, H. Zheng, J.M. Louie, J.C.Y. Gill, T. Wu, J.H.Y. 2016. High variation in manufacturer-declared serving size of packaged discretionary foods in Australia. British Journal of Nutrition, 115: 1810-1818. doi: 10.1017/S0007114516000799.

9. Zheng M, Rangan A, Meertens B, Wu J. Changes in typical portion sizes of commonly consumed discretionary foods among Australian adults from 1995 to 2011-2012. Nutrients. 2017; 9 (6): E577.

10. National Health and Medical Research Council. Eat for Health. What are discretionary food choices? [Internet]. Updated 2017 June 05 [cited 2018 Oct 23]. https://www.eatforhealth.gov.au/food-essentials/discretionary-food-and-drink-choices.

DAA are not a manufacturer and therefore cannot advise on changes required to business practices and infrastructure to effect a portion size reduction. DAA have identified concerns with potential increases in packaging and the environmental impact in Question 1.

DAA does advocate for the employment of APDs in food industry to assist companies to address these issues.

DAA also considers there should be one set of standards that all food manufacturers should abide by no matter where food is sold, be it supermarket or café. This is because many similar products are sold across different outlets, and without regulation, size and ingredient variety causes challenges for consumers in meeting portion guidelines.

DAA support incremental introductions of changes to portion and healthy fats and oils regulation. DAA are not a manufacturer and therefore cannot advise specific timeframes.

DAA suggest consulting with industry to understand a feasible timeframe to allow successful reformulation of nutrients or product sizes without compromising product safety, quality and consumer acceptance. The change in portion size and use of healthier oils should be accompanied by consumer awareness and education campaigns.

DAA support incremental introductions of changes. DAA are not a manufacturer and therefore cannot advise a timeframe. DAA suggest consulting with industry to understand a feasible timeframe to allow successful reformulation of nutrients or portion sizes without compromising product safety, quality and consumer acceptance.

DAA highlight the important role that APDs can play in food reformulation, and encourage industry to employ the services of APDs when developing new recipes and strategies to make these changes.

DAA supports reformulation that encourages changes to healthier oils, and has provided consultation on this is previous Food Reformulation submission rounds in October 2018.

DAA acknowledges there are some challenges that manufacturers may encounter when switching to healthier oils, due to different properties, however fully support their implementation. DAA encourages manufacturers to look into new and innovative ways to develop products that meet the reformulation targets and use healthier oils, as this will hopefully improve the health and nutrition of the Australian population. DAA advocate for long-term public health messages highlighting the importance and benefits of food reformulation.

DAA are not a manufacturer and therefore cannot advise a timeframe. DAA suggest consulting with industry to understand a feasible timeframe to allow successful reformulation without compromising product safety, quality and consumer acceptance.

A market assessment was conducted by Redacted text (DAA Food Regulatory and Policy Committee member) on Wednesday 17 October 2018, at Redacted textin Concord NSW.
DAA highlight that the food category ‘dishes with sugar as the main ingredient’ incorporates several other food items that could be included in other categories (e.g. baking mixes, individual crème caramel/rice puddings). DAA encourage clear definitions of food categories to avoid cross-over and potential confusion for manufacturers when trying to meet portion targets. DAA are able to provide this market assessment upon request.