Healthy Food Partnership Voluntary Food Reformulation Targets - Public Consultation

Response submitted previously

Woolworths is committed to helping our customers make healthier choices and providing clear guidance around portion size on pack. As part of our broader health commitments which includes product reformulation, Woolworths is currently reviewing and improving the serving size information provided across the Woolworths branded food range to make it clearer and more consistent for customers.

Woolworths recommends the Healthy Food Partnership provides clear guidance for standard serving sizes for industry as part of this review, so that this information is consistently provided to consumers across similar foods. Industry wide initiatives have the potential to have a much greater impact for consumers compared to those adopted by individual companies alone. A good example of this is the Health Star Rating which is consistently applied by all participating manufacturers.

Woolworths supports the concept of portion size reduction to help consumers manage their energy intake and recommends portion size goals are implemented on a voluntary basis with clear targets for industry to work towards. Woolworths currently offers a variety of portion sizes and individual portion controlled snacks to give customers choice. Woolworths understands portion size reduction may not always be feasible across all product types (at least in the short term) and blanket targets need to be mindful not to limit product innovation and range (e.g. celebration cakes such as birthday cakes and seasonal products).

For the subcategories proposed, Woolworths has identified the below challenges. While these challenges are not insurmountable, they should still be considered when developing portion size goals for food industry -

Chocolate and non chocolate confectionery:
Most confectionery sold in share bags is not individually packaged and reducing the total pack size may have little impact on consumption. Consumers may simply switch to other brands which have larger pack sizes available. Woolworths considers other strategies which show consumers how many lollies or pieces constitute a single serve to be a more effective strategy for these foods. Woolworths is also committed to reducing plastic packaging usage and addressing products in our range that are over-packaged. This adds an additional challenge if smaller or individually packaged products are required as part of the Healthy Food Partnerships portion size goals.

Frozen milk products:
Woolworths is aware there are only a limited number of Australian suppliers for single serve ice creams and ice confection, all of which use a standard mould for regular and mini sized ice creams and cones. Woolworths would therefore encourage industry wide adoption of smaller portion sizes in specific categories such as frozen milk products to ensure the investment in new equipment is cost effective and efficient for manufacturers.

Large share tubs of ice cream are sold by volume (e.g. 1L or 2L tubs) and Woolworths does not feel portion size reduction for these larger products will have the desired impact. Woolworths instead supports providing clear serving size guidance on these foods to help consumers understand how much they are eating.

All other subcategories designed for sharing:
Woolworths is uncertain if portion size reduction across products designed to share or entertain will translate into the consumption of smaller portions by consumers and instead, Woolworths advocates for providing clear serving size / portion size guidance on these foods. One of the most important considerations for consumers when making food choices is value for money and because it is often cheaper to buy larger products / or food in bulk, reducing portion size or introducing more individually wrapped (portion controlled) items may make some products less affordable, especially for budget conscious families.

Woolworths understands there is a multitude of other determinants of food intake including how a product is served, packaged, labelled, advertised and behavioural influences that impact the portion size consumed. Woolworths is also aware the literature review by the Healthy Food Partnership found the strongest evidence that suggests restricting portion size of discretionary foods and drinks reduces consumption relates to public sector settings such as childcare centres, schools and universities, rather than in the home environment where the amount served on a plate is determined by the consumer. This supports our view that portion size reduction goals should focus on single serve items in retail settings.

Alternative approaches:
Woolworths suggests companies are also encouraged to adopt other strategies to assist consumers determine an appropriate serving size. These strategies could be implemented through a Code of Practice or industry guide and build on the existing Australian Food & Grocery Council (AFGC) serving size principles. Examples include -
- For products sold as individual units, include the number of units in a serving as part of the nutrition information panel information (currently part of the AFGC guidance)
- Include pictorial images or visual guidance where appropriate, especially for foods which are not individual units e.g. X cm wide slice of banana bread, 1 scoop of ice cream.
- Provide pre-cut portions where possible
- Provide a range of product sizes to give consumers choice including mini and regular varieties of muffins, cupcakes, donuts and stick ice creams. Woolworths currently offers mini sized options in sweet bakery, sweet biscuits, frozen milk products, dishes where sugar is the main ingredient (such as petite pavlovas and mini meringues) and fruit and vegetable juices in single serve tetra packs. Woolworths customer research consistently shows consumers prefer supermarkets to offer choice and support to help them make healthier choices rather than limiting the type of foods they can buy.
- Offering resealable packaging where possible. Belgium research (De Bondt, Van Kerckhove & Geuens, 2017) has shown that when snack foods (i.e. skittles and jelly beans) are packaged in a resealable bag, consumers eat less. This suggests that people may be better able to self-regulate their consumption of energy dense foods when there is the option to save food for later. Companies would need to assess the impact of resealable packaging on the finished product cost.
- Wider adoption of Percent Daily Intake (%DI) labelling. This provides consumers with the context of energy and other nutrients in a single serve.
- Implementing an education campaign which focuses on educating consumers on appropriate portion sizes and how discretionary foods can fit into a healthy balanced diet. Woolworths Food & Health Survey Report (2018) found smaller portion sizes was a top priority for 28% of customers surveyed, showing consumers are consciously eating less in an effort to be healthier. This indicates the portion size of main meals and food over the whole day is equally important to consumers as the portion size of discretionary foods. A holistic campaign which focused on the five core food groups, portion sizes and how foods translate to energy requirements could be beneficial.

For all subcategories, companies will need to determine if a reduction in portion size is commercially viable as consumers should not be expected to pay the same price for smaller products. Portion size reduction goals also need to consider whether targets are based on kilojoule content or gram weight / volume as some subcategories will differ depending on the type of product e.g. light and fluffy cakes vs. dense fruit cakes, wafer biscuits vs. chocolate cookies and solid chocolate vs. hollow or aerated chocolate. Woolworths is aware some companies already have portion size goals in place which relate to calorie content and this may be better suited to certain foods. For example, Unilever has committed to its entire adult single-serve ice cream range to contain 250 calories or fewer in the UK. This has meant a recipe change for some products and a size reduction for others. Woolworths total own brand range of single serve ice creams meet this target already, including both regular and mini size varieties which indicates such a commitment is achievable.

Changes to business practices and infrastructure will differ by product category and Woolworths recommends targets to reduce portion size consider both cost to suppliers and consumer acceptance.

Woolworths would like to highlight the following challenges to business practices and infrastructure -
- the development and production of a smaller product may require significant investment in factory equipment (smaller trays, tins, moulds).
- smaller products may require changes to packaging size and type
- the size of food products is often predetermined by cost efficiencies including the volume of product that can be produced per hour, the type of packaging a supplier is already using and the physical capabilities of the factory.
- reducing portion size to an extent that reduces factory efficiency may mean a product is no longer commercially viable. For suppliers manufacturing the same type of product (e.g. same size but different recipe) for multiple companies, portion size reductions which are voluntary may be impractical if they are not adopted by all companies.

Portion size can be the defining factor for the purchase of many products. There is a risk that shrinking portion sizes would increase the cost of production and therefore the shelf price - meaning consumers will be paying more for less. As an alternative option, if the portion size of a product is not reduced, companies can still educate consumers about smaller portions by implementing smaller ‘serve sizes’. As part of Woolworths product development process, all Woolworths branded products must be taste tested and approved by our customer panel prior to launch. Woolworths products are not only benchmarked on quality, taste and nutrition but also on price per unit to ensure we are competitive.

Woolworths recommends if the Healthy Food Partnership progresses with portion size reduction, a communications strategy is implemented to ensure portion size reduction is seen as a commitment to public health and not for profit reasons. As an example, in 2014 Nestle halved the size of their Allen's Killer Python to ‘treat size’ (47g to 24g). Martin Brown, the General Manager of Confectionary at Nestle said “when we halve the sizeRedacted text While people may buy more of the smaller products, it is not enough to make up for the loss in weight”. This change was also met with considerable customer criticism with many complaining that how much they eat should not be dictated by a large corporation. Companies who participate in the Healthy Food Partnership initiatives must be publicly recognised by the Government for their efforts to combat similar criticism.

Special consideration would also need to be given to products sourced internationally as well as the impact to products sold in both Australia and New Zealand.

It is difficult for Woolworths to estimate the required lead time to prepare for these changes without knowing how many products would require portion size reduction or the capability of our current supply base to make the required changes. As a minimum however, Woolworths would suggest at least 12 months lead time ahead of the implementation time period beginning.

Woolworths recommends gaining industry wide commitment and alignment in affected categories to enable easier and more streamlined implementation. If the whole industry acts at the same time, this could increase efficiencies for suppliers and speed to market. Woolworths would also like to understand whether any challenges uncovered during the lead time could be fed back into the Healthy Food Partnership and whether or not any targets could then be revised.

Key factors which may impact lead times include -
- Woolworths tender process which only occurs outside of contract dates.
- The ability to find suitable suppliers to produce the size required.
- Product quality testing and the extent of redevelopment required
- Consumer acceptance of the new product
- Artwork / packaging redesign

Woolworths is aware country of origin and supporting Australian manufacturers and producers is important to many of our customers and it is therefore important to understand the current manufacturing capabilities of Australian suppliers. Woolworths suggests industry is engaged early on to provide feedback on suggested targets and whether they are technically feasible from a manufacturing point of view. An industry roundtable format or stakeholder workshops would be welcomed once portion size reduction goals have been determined.

Portion Reduction:
Although a four year timeframe in isolation could be feasible, Woolworths is unsure if it is achievable in the current regulatory environment. Woolworths supports voluntary portion size reduction targets but is concerned with the number of potential changes to food labels and product formulation companies may need to implement in the next four years. This includes but is not limited to the Healthy Food Partnership reformulation targets, changes to sugar labelling on pack and changes to the Health Star Rating as part of the 5 year review. Health is a key focus for Woolworths business, however due to the amount of Woolworths food products and the resource required to manage product changes, portion size reduction could be challenging to prioritise amongst other business commitments.

To overcome these challenges, Woolworths recommends some consideration is given to whether all products in a companies portfolio are required to meet the targets or only a certain percentage. Woolworths also suggests focus is given to the categories which will have the most beneficial impact on consumers, for example sugar sweetened beverages.

Healthier oils:
Woolworths is committed to reducing saturated fat and eliminating artificial trans fat from Woolworths branded food range and is always looking for opportunities to use healthier oils (i.e. replacing oils higher in saturated fat with those lower in saturated fat). Woolworths supports a healthier oil commitment on a voluntary basis which gives companies the opportunity to nominate key lines to reformulate and transition products where it is commercially and technically feasible.

Moving to healthier oils may be challenging for Woolworths products if the type of oil used by a supplier is dictated by the type of oil already being used for other products. Introducing specific oils for Woolworths may add additional cost and reduce manufacturing efficiencies, especially for lower volume lines. Woolworths considers gaining industry wide commitment and alignment on targets in specific categories is the best approach for healthier oils so that suppliers can introduce changes in their factory across all products and maximise processing efficiencies. A good example of a collaborative approach is when industry took drastic steps to lower the trans-fatty acid content in processed food in the 1990s, largely by eliminating trans fat from margarine.

Other challenges with a healthier oil target is when foods use more than one oil type (e.g. an oil blend) or when companies may substitute the type of oil used from time to time depending on availability. These products may only list ‘vegetable oil’ in the ingredient list on pack rather than specifying the oil type to allow for this variation. This would make it difficult to monitor where healthier oils were being used. From a technical perspective, oil blends may be used in specific ratios to achieve a specific function or to provide a specific texture or melting point. This may prevent the use of healthier oils in recipes.

To overcome these challenges, Woolworths suggests the ‘healthier oils’ target focusses on oils used for frying, rather than targeting fats or oils which are used in a product recipe to achieve the required texture, taste or a specific function. For example for snacks which are baked and not fried, the oil within the product recipe could be excluded from the definition if used in only a small amount, for example low fat products with less than 3% fat. Where multiples oils are used in a food, Woolworths also suggests consideration is given to the percentage contribution of each oil to the final product and/or final saturated fat content of the food.

Woolworths considers having the time frame for nutrient reformulation overlap with the change to healthier oils could have advantages and disadvantages for manufacturers. The primary benefit would be that companies can implement the changes at the same time, potentially limiting the number of times a product must be touched from a formulation perspective. Companies could also see how the changes work together to ensure a quality, acceptable tasting product can be delivered.

Woolworths considers in some categories, having the time frame overlap could be more challenging if -
- the nutrient being targeted is not saturated fat, for example, reducing salt and changing to a healthier oil at the same time could significantly impact taste
- the products current sodium/sugar/saturated fat is significantly higher than the proposed target as companies may need to approach reformulation in a stepwise approach.

To ensure manufacturers are consistently reducing the portion size of foods in priority categories identified by the Healthy Food Partnership, it is essential that the inclusion and exclusion definitions for each subcategory are clear. Woolworths has a large team which includes product developers, quality specialists and nutritionists and it is therefore critical to ensure the definitions are not open to interpretation as to what is included and what isn’t.

1) PORTION SIZE
Woolworths also recommends any further consultation in this area clearly determines whether portion size reduction targets will apply to share packs, single serve items or both. Woolworths preference is to include only single serve items as Woolworths considers these foods to be where the greatest influence can be had on consumption and therefore intakes of energy, saturated fat, sugar and salt by consumers.

Sweet bakery definition:
The current definition of sweet bakery is not clear. Woolworths suggests creating distinct subcategory inclusions and exclusions, similar to those provided in the reformulation target consultation. For example, the definition should clearly identify if pastry based products such as sweet pies, danishes and tarts are included, as well as puddings, cheesecakes, fruit scones and croissants.

Woolworths suggests that baking mixes that must be prepared with other ingredients are excluded from the definition. It is not clear how portion size reduction would be possible for these products aside from reducing the serving size provided on pack. The prepared product may also differ in size due to the customers preparation method or how closely the on pack recipe instructions are followed.

Woolworths recommends cookie mixes and cookie dough are excluded from the definition as it could be confusing whether the portion size target relates to the product ‘as sold’ or ‘as prepared’. The prepared product may also differ in size due to the preparation method or how closely the on pack recipe instructions are followed.

Dishes with sugar as the main ingredient definition:
Woolworths suggests this category is either revised or excluded. The current definition for dishes with sugar as the main ingredient is not clear “Sugar-based products where sugar is the main ingredient. Includes shelf-stable, frozen, ready-to-eat or products requiring reconstitution’. ‘Sugar as the main ingredient’ could be interpreted differently by companies for example as foods where sugar is the first ingredient, foods where sugar is among the top ingredients, or foods where sugar content is overall high. The word ‘dishes’ should also be replaced with ‘product’ as meringues and jelly are not dishes.

Woolworths prefers the definition used for the Australian Health Survey which states - “the Sugar products and dishes food group includes sugar, honey, syrups, jam, chocolate spreads and sauces and dishes and products other than confectionery where sugar is the major component e.g. pavlova and meringue”. Woolworths is however uncertain however if portion size reduction is appropriate for many of these foods (e.g. honey, syrups and spreads) as the serving size is generally 1 teaspoon. With pavlovas and meringue, Woolworths currently offers mini versions of these products, and larger products are generally used for entertaining and special occasions.

Woolworths recommends if this subcategory is to be kept, products requiring reconstitution are excluded from the definition, as it could be confusing whether the portion size target relates to the product as sold or as prepared. The prepared product may also differ in size due to the preparation method and how closely consumers follow instructions and/or deviate from the recipe listed on pack.

HEALTHIER OILS:
Woolworths recommends clear guidance is provided as to what constitutes a ‘healthier’ oil and in what applications the target is applicable to. As an example, are solid fats or partially solid fats included or only liquid oils.

Woolworths agrees with the suggestion of providing preparation instructions for baking rather than frying on product packaging to steer consumers towards healthier cooking methods. Woolworths considers this to be one of the best approaches to reduce saturated fat associated with crumbed and battered proteins and other foods which can be either baked or fried.

Savoury snacks definition:
Woolworths recommends the definition of snacks is limited to chips and snacks that are fried to ensure the frying medium is the primary focus of the reformulation as opposed to a small amount of oil which may be used as part of the product recipe.

Savoury biscuits definition:
Woolworths is not aware of any savoury biscuits that are fried (and not baked) and therefore questions the relevance of including this subcategory. Some savoury biscuits may also not be able to switch to oils lower in saturated fat due to the nature of their traditional recipes e.g. Woolworths puff pastry twists or Lavosh crackers which are made using butter.