P240 Review of Labelling Statements on Reduced Fat and … DA.pdf · 2018-06-26 · 2 EXECUTIVE...

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12 December 2001 06/02

DRAFT ASSESSMENT (FULL ASSESSMENT - S.23) PROPOSAL P240 LABELLING STATEMENTS ON REDUCED FAT AND CONDENSED MILKS

DEADLINE FOR SUBMISSIONS to the Authority in relation to this matter:6 FEBRUARY 2002 (See ‘Invitation for Public Submissions’ for details)

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EXECUTIVE SUMMARY Proposal 240, was raised in February 2001 to review labelling statements on reduced fat and condensed milk. In the existing Australian and New Zealand food regulations (the Food Standards Code, Volume 1 and the New Zealand Food Regulation, 1984) warning statements are required on skim, modified and condensed milks. The warning statements, which vary between the Australian and New Zealand regulations, have been retained and are included in Clause 3, Standard 1.1.3, Transitional and Temporary Standards of Volume 2. This clause will cease operation upon repeal of Volume 1 and the New Zealand Food Regulations 1984, and so must be reviewed before this occurs. The purpose of the review is to address the inappropriateness of feeding milk, condensed milk, evaporated milk, dried milk, soy and rice beverages with a reduced fat content (less than 2.5%) to children under two years of age; and to determine if labelling statements on these products are required. The first round of public comment in response to P240 Initial (Preliminary) Assessment Report, demonstrated strong support from public health and government organisations to delete the requirements for warning statements on specified milk products and develop one advisory statement for Australia and New Zealand. The Australian dairy industry opposed this option and supported deleting the requirement to include a warning/advisory statement on specified milk products and rely on education through the public health system and other means to advise of the unsuitability of using these products in infant feeding. Labelling statements combined with public health education programs would be more effective in getting the message across to consumers that the products are unsuitable for children under two. The reason for this is labelling statements are sustained whereas public health education programs are often not sustainable for long periods. Consideration of the regulatory impacts of using advisory statements on reduced fat milk, condensed milk, evaporated milk, dried milk and soy and rice beverages concludes that the benefits will accrue to consumers and government in protecting public health and safety and supporting government policy which will outweigh the costs to industry through the need to change labels. It is clear from the Dietary Guidelines in Australia and New Zealand that reduced fat milks and condensed milks are not suitable to be fed to children under two years of age as the primary source of milk. The consensus amongst public health groups is that feeding reduced fat milks to children under two years of age in this manner could lead to growth and development problems and therefore an advisory statement should be placed on these products. The advisory statement should be expanded to cover soy and rice beverages because anecdotal evidence from dietitians suggest these products are often fed to children in place of cows milk. The possible negative effects on dairy consumption of existing warning statements has been raised. An advisory statement is less prescriptive, which would allow industry to place more positive statements on their products to prevent effects on consumption levels.

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1. BACKGROUND As part of the review of food standards in Australia and New Zealand, the Australia New Zealand Food Authority (ANZFA) prepared Proposal P161 – Specific Labelling Statements. This proposal considered the need for warning1 and advisory2 statements on skim milk, modified milk and condensed milk. At Full Assessment, it was proposed to extend the current warning statement on skim milk, modified milk and condensed milk to include all mammalian milk and milk products. The rationale for this decision was that mammalian milk poses a health risk to infants under 12 months of age if used as the major source of fluids, that is, as a replacement for breast milk or infant formula. The proposed warning statement was subsequently amended to an advisory statement at Inquiry. As a result of additional consultation on this issue, the proposed advisory statement on all milk products was temporarily withdrawn. The Authority reconsidered the evidence supporting the inclusion of all mammalian milk in the statement, and decided that the matter of whether infants under 12 months of age should be fed cows milk as the primary source of fluids required further investigation. 1.1 Food Standards Code (Volume 2) Following the completion of an extensive review of the existing food regulations in Australia and New Zealand (the Food Standards Code, Volume 1; and the New Zealand Food Regulations 1984) the Australia New Zealand Food Standards Council adopted the new Australia New Zealand Food Standards Code (known as Volume 2 to the Food Standards Code) in November 2000. A two-year transition period was agreed by Ministers in which industry has the option of complying with either Volume 1 or Volume 2 in Australia, or Volume 1, Volume 2, or the New Zealand Food Regulations 1984, in New Zealand. After this phase-in period ends in December 2002, Volume 1 and the New Zealand regulations will be repealed and all food sold in Australia and New Zealand must comply with Volume 2 (see Attachment 1 for more information on Food Standard setting in Australia and New Zealand). As an interim measure, the current mandatory warning statements on skim milk, modified milk and condensed milk, as prescribed in the existing regulations of Australia and New Zealand have been retained and are included in Clause 3, Standard 1.1.3, Transitional and Temporary Standards of Volume 2 of the Code. This clause will cease operation upon repeal of Volume 1 and the New Zealand Food Regulations 1984, and so must be reviewed before this occurs.

1 Warning statement – is required ‘if the risk to health is life threatening and it can be reasonably assumed that the general population of the specific target group is unaware of the potential risk to their health and a statement is needed to alert them to the risk’. A warning statement has prescriptive wording and must appear in the label on or attached to a package in 3mm lettering (see Volume 1, Standard H1, H3 and H4; and New Zealand Food Regulations, 1984). 2 Advisory statement – is required ‘if the general public or the sub-population is exposed to a significant potential risk to health but the risk to health is not life threatening, or when guidance is required to protect public health and safety’. An advisory statement does not have prescriptive wording but the intent of the message must be conveyed clearly to the consumer. An advisory statement can be displayed in connection with the display of the food or can be provided verbally by the retailer (see Vol.2, Standard 1.2.3, Clause 2).

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Current Provisions The current provisions for the labelling of reduced fat and condensed milks in Australia and New Zealand are different with respect to the wording of the warning statements and the milk and milk products covered by these statements. Australia In Australia, the statement: ‘SEEK MEDICAL ADVICE BEFORE USE IN INFANT FEEDING’ or ‘UNSUITABLE FOR INFANTS EXCEPT ON MEDICAL ADVICE’ is required by Volume 1 to be declared on the label of: • skim milk (paragraph 13(c)) of Standard H1; and • modified milk with a milk fat content of less than 21g/kg (paragraph 14(g)) of

Standard H1; and The statement: ‘UNSUITABLE FOR INFANTS EXCEPT ON MEDICAL ADVICE’ is required by Volume 1 to be declared on the label of: • sweetened condensed milk, unsweetened or sweetened condensed skim milk,

unsweetened or sweetened condensed separated milk or reduced fat unsweetened condensed milk (clauses (4) and (7) of Standard H3); and

• dried skim milk or skim milk powder (paragraph 2(b)) of Standard H4. Under clause 3, Standard 1.1.3 of Volume 2, labels must comply with the requirements in Volume 1, set out above, or, for foods manufactured in New Zealand with the following New Zealand Food Regulations 1984, set out below. 1.2.2 New Zealand In New Zealand, the statement: ‘NOT SUITABLE AS A COMPLETE MILK FOOD FOR INFANTS’ This statement is required to be declared on the label of:

• skim and non-fat milk; • reduced-fat milk (1.5 to 2.5% milk fat content); • evaporated skim milk; • skim milk powder; and • skimmed sweetened condensed milk.

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1.2.3 Codex Alimentarius There are no requirements under Codex Alimentarius for reduced fat milk and skim milk etc. to be labelled with advisory or warning statements. 1.2.4 United States There are no requirements within the Food and Drug Administration labelling provisions for reduced fat and skim milk etc. to be labelled with advisory or warning statements. 1.2.5 United Kingdom Skimmed milk products containing non-milk fat solids must carry a warning that they are unfit for, or not to be used as, food for babies. 1.3 Proposal P240 Proposal P240, was raised in February 2001 to review labelling statements on reduced fat and condensed milk before the repeal of Volume 1 (December 2002). Following the first round of public comment it was clear that there was divided opinion as to the preferred option. As a result, an External Advisory Group was convened to provide expert opinion on this matter. 2. PROBLEM The Australian3 and New Zealand4 Dietary Guidelines suggest that reduced fat milk and skim milk with a fat content of less than 2.5% are unsuitable for children under two years. Comprehensive data on the prevalence of reduced fat milk consumption by children under two years of age in Australia and New Zealand is not available. The 1995 Australian National Nutrition Survey only collected information on children two years and older, and the New Zealand National Nutrition Survey only collected information on people 15 years and older. A children’s nutrition survey is currently being undertaken in New Zealand but as yet no results are available. However, qualitative evidence suggests that the problem of children (less than 2 years) consuming reduced fat milks is quite prevalent in both countries, while the consumption of reduced fat soy and rice beverages also appears to be an increasing issue. The possible effects on health of children under two consuming reduced fat milks, as the main source of milk are outlined in Section 6 and include growth failure and chronic non-specific diarrhoea. Whilst it is an existing requirement, it has been claimed by industry that statements on reduced fat milks alerting carers to their inappropriateness as the main milk source for children under two may have a negative impact on the consumption of other dairy products by children in general. There is no evidence to support this, and any potential negative impacts of such statements need to be weighted against the positive impacts, such as the health of children under two, and the sustainability of a labelling statement to convey this information, as opposed to other methods of informing carers. 3 National Health and Medical Research Council. Dietary Guidelines for Children and Adolescents. Australian Government Publishing Service, Canberra, 1995. 4 Ministry of Health. Food and Nutrition Guidelines for Healthy Infants and Toddlers (Aged 0-2 Years).

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The purpose of this review is to assess the inappropriateness of feeding: • milk, condensed milk, evaporated milk, dried milk; • soy beverages; • and rice beverages; with a fat content of less than 2.5% to children under two years of age. This must occur before the end of the transition period for Volume 2 (December 2002). The following issues are not considered part of this review and will be considered by ANZFA separately: 1. the unsuitability of cows milk as the sole dietary liquid source for infants (<1 year); and 2. whether there should be advisory statements on milk and milk products other than those

identified above.

3. OBJECTIVE The objective of this review is to determine the most cost effective regulatory mechanism for managing the risk of the inappropriate feeding of: • milk, condensed milk, evaporated milk, dried milk; • soy beverages; and • rice beverages; with a fat content of less than 2.5% to children under two years of age. 4. OPTIONS The Initial Assessment (Issues paper) circulated for public comment on this matter in June 2001 outlined three potential options. These options were limited to milk and milk products with a fat content of less than 2.5%. The External Advisory Group for this review agreed that labelling statements should also cover other reduced fat products (<2.5% fat content) similar to milk on a nutritional basis. For example, soy beverages. They also concluded that rice beverages should be included because anecdotal evidence indicates that an increasing number of mothers were feeding this product to children in replacement of cow’s milk. Therefore, the regulatory options have been expanded to include soy and rice beverages. The proposed options at this time are: 1. maintain the status quo and continue to have different warning statements on reduced

fat and condensed milk products in Australia and New Zealand; or 2. delete the current prescriptive requirements for warning statements on specified milk

products and develop an advisory statement for Australia and New Zealand. The statement would be required on:

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a. milk with a fat content of below 2.5%; or b. milk, condensed milk, evaporated milk and dried milk with a fat content below

2.5%; or c. milk, condensed milk, evaporated milk, dried milk, soy beverage with a fat

content below 2.5%; or d. milk, condensed milk, evaporated milk, dried milk, soy and rice beverages with a

fat content below 2.5%. 3. Delete the requirement to include a warning/advisory statement on specified milk

products and rely on education through the public health system and other means to advise the unsuitability of feeding these products to children (less than 2 years).

5. IMPACT ANALYSIS 5.1 Identification of Affected Parties

1. Consumers in Australia and New Zealand. 2. Producers and manufacturers of dairy products and soy and rice beverages. 3. Governments in Australia and New Zealand. Option 1 – To maintain the status quo and continue to have different warning statements on milk products in Australia and New Zealand. CONSUMERS Costs

• no additional costs. • consumers in Australia and New Zealand

will continue to receive different information.

• possibility of different statements on the same products.

• children who consume rice and soy beverages may be at risk if carers education is inadequate∗ .

• existing negative statements may deter the consumption of other dairy products.

Benefits • assist in reducing the level

of inappropriate feeding of these products to infants and young children.

PRODUCERS and MANUFACTURERS Dairy industry

• no additional costs. • continued labelling costs. • lack of harmonisation of labelling between

Australia and New Zealand.

• no additional labelling costs.

GOVERNMENT Commonwealth, New Zealand Health Depts, State/Territory Health Depts

• no additional costs. • reduced enforcement costs

∗ The External Advisory Group advised that anecdotal evidence from dietitians suggests that increasing numbers of children under 2 years are consuming soy and rice beverages.

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Option 2 a - delete the current prescriptive requirements for warning statements on specified milks products and develop an advisory statement for Australia and New Zealand to be placed on milks with a fat content of below 2.5%. CONSUMERS Costs

• may discourage the use of dairy products for children more generally.

• children who are fed reduced fat condensed milk, soy or rice beverages may continue to be at risk if carers education is inadequate.

• potential increase in cost of the above products if industry change labels.

Benefits • reinforces government

policy as reflected in the Dietary Guidelines in both Australia and New Zealand.

• assist in reducing the level of inappropriate feeding of these products to infants and young children.


• potential cost in changing labels for the dairy industry. The dairy industry would have the option of keeping the text of the warning statement because the advisory statement is less prescriptive. If industry decide to change to an advisory statement they could absorb these changes into routine label changes; costs should therefore be minimal.

• may place the dairy industry at a competitive disadvantage compared to producers of soy and rice beverages, fruit juices, fruit drinks and carbonated drinks.

• harmonisation of labelling on milks between Australia and New Zealand.

• will have the freedom to use their own words on labels, provided the intent of the message is conveyed clearly to consumers.


• increased enforcement costs • less prescriptive regulation.

• reinforces government policy.

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Option 2 b - delete the current prescriptive requirements for warning statements on specified milk products and develop an advisory statement for Australia and New Zealand to be placed on milk, condensed milk, evaporated milk and dried milk with a fat content below 2.5%. CONSUMERS Costs


• children who are fed reduced fat soy and rice beverages maybe at risk.


Benefits • reinforces government

policy as reflected in the Dietary Guidelines in both Australia and New Zealand.



• potential cost in changing labels for the dairy industry. The dairy industry would have the option of keeping the text of the warning statement because the advisory statement is less prescriptive. If industry decide to change to an advisory statement they could absorb these changes into routine label changes; costs should therefore be minimal.

• may place the dairy industry at a competitive disadvantage compared to producers of soy and rice beverages, fruit juices, fruit drinks and carbonated drinks.

• harmonisation of labels between Australia and New Zealand.

• will have the freedom to use own words on the label provided the prescribed effect is maintained.


• increased enforcement costs. • less prescriptive legislation.

• reinforces government policy.

Option 2 c - delete the current prescriptive requirements for warning statements on specified milks products and develop an advisory statement for Australia and New Zealand to be placed on milk, condensed milk, evaporated milk, dried milk and soy beverage with a fat content below 2.5%. CONSUMERS Costs



Benefits • consumers who use non-dairy

products will receive important information that is not currently available on food labels.

• reinforces government policy as reflected in the Dietary Guidelines in both Australia and New Zealand.


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PRODUCERS and MANUFACTURERS Dairy industry Soy beverage industry

• initial cost in changing labels for soy beverage industry. potential cost in changing labels for the dairy industry. The dairy industry would have the option of keeping the text of the warning statement because the advisory statement is less prescriptive. If industry decide to change to an advisory statement they could do absorb these changes into routine label changes; costs should therefore be minimal.

• may place the dairy and soy beverage industries at a competitive disadvantage compared to producers of fruit juices, fruit drinks and carbonated drinks.

• harmonisation of labelling between Australia and New Zealand.

• will have the freedom to use their own words on labels provided prescribed effect is maintained.


• costs associated with the revision of existing public health, health promotion material to incorporate information on soy beverages.

• increased enforcement costs.

• less prescriptive regulation. • reinforces government policy.

Option 2 d - delete the current prescriptive requirements for warning statements on specified milks products and develop an advisory statement for Australia and New Zealand to be placed on milk, condensed milk, evaporated milk, dried milk and soy and rice beverages with a fat content below 2.5%. CONSUMERS Costs



Benefits • consumers who use non-dairy

products will receive important information that is not currently available on food labels.

• reinforces government policy as reflected in the Dietary Guidelines in both Australia and New Zealand.


PRODUCERS and MANUFACTURERS Dairy industry Soy and rice beverage industry

• initial cost in changing labels for soy and rice beverage industry. potential cost in changing labels for the dairy industry. The dairy industry would have the option of keeping the text of the warning statement because the advisory statement is less prescriptive. If industry decide to change to an advisory statement they could do absorb these changes into routine label changes; costs should therefore be minimal.

• may place the dairy, soy and rice and beverage industries at a competitive disadvantage compared to producers of fruit juices, fruit drinks and carbonated drinks.


• will have the freedom to use their own words on labels provided prescribed effect is maintained.


• costs associated with the revision of existing public health, health promotion material to incorporate information on soy beverages.

• increased enforcement costs.

• less prescriptive regulation. • reinforces government policy.

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Option 3 – delete the requirement to a include a warning/advisory statement on specified milk products and rely on education by the public health system and other support services to advise of the unsuitability of feeding these products to children (less than 2 years). CONSUMERS Costs

• increased risk to health of children under two years of age if education and delivery of messages is inadequate.

• potential increase in cost of milk products if industry change labels.

• potential increase in health care costs if these milks are fed to infants and toddlers.

Benefits • no additional benefits.

PRODUCERS and MANUFACTURERS Dairy industry Soy and rice beverage industry

• initial cost in changing labels for the dairy industry if they want to change labels before other routine changes.

• less prescriptive regulations.


GOVERNMENT Commonwealth, New Zealand Health Departments, State/Territory Health Departments

• increased cost of education to parents. • potential increase in public health care costs

if education is inadequate.

• reduced enforcement costs.

6. THE EVIDENCE FOR ADVISORY STATEMENTS In the draft National Health and Medical Research Council (NHMRC) Dietary Guidelines5

for Children and Adolescents and Infant Feeding Guidelines, reduced fat milks are not recommended for pre-school aged children. These recommendations are based on the fact that limited fat intake from milk in infants may interfere with optimal energy intake and hence affect growth and development including neurological development. 6.1 Consequences of low fat intake The NHMRC5 indicates that unsupervised restriction of dietary fat can lead to growth failure and to chronic non-specific diarrhoea in infants and young children. 6.2 Growth and Energy Deficiency In infants, growth and tissue replacement requires 30 percent of energy intake compared to only 5 percent in adults5. Thus, even a small energy deficit during this period of rapid growth in the first two years of life may affect growth rate. 6.3 Other Evidence A study comparing the growth of a group of toddlers consuming reduced fat milk compared to those consuming full fat milk found no significant differences in growth6. 5 National Health and Medical Research Council. Dietary Guidelines for Children and Adolescents and Infant Feeding Guidelines (Draft) 2001.

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Whilst there were lower intakes of total fat and saturated fat in the group consuming reduced fat milk, total energy intake was not reduced. 6.4 NHMRC Recommended targets for fat intake during infancy and childhood7 Birth to Two Years During the first year of life breast milk or infant formulae should be the major milk feed because of its lower saturated fat and higher iron content compared to cow’s milk. Fat intake should comprise approximately 50 percent of energy intake by breast fed and formula fed infants aged 0-6 months. In the later part of the first year of life and during the second year of life, the target is approximately 40 percent energy as fat. The fat content of milk becomes less important with age, because other foods that contribute fats and oils are eaten. However, skim milk (less than 0.5 percent fat) and reduced fat milk (1.5 percent – 2.5 percent fat) should not be given to children under two years of age. 6.4.2 Two to five years A gradual increase in the proportion of energy from carbohydrate will occur, with a gradual reduction in the proportion of energy from fat. As children in this age group are already consuming a diet containing 33 percent fat a target of 30 percent is recommended with no more than 10 percent from saturated fat. Reduced fat milks are suitable but skim milk should not be used for children less than five years. 7. CONSULTATION ANZFA received a total of 17 submissions in response to P240 Initial Assessment Report. In general, the dairy industry were opposed to the proposal whilst government, public health and consumer organisations were supportive. A summary of the submissions is at Attachment 3. Of the 17 submissions: • five submissions supported the proposed approach in the proposal; • five submissions supported the proposal in principle but disagreed with one or more

issues raised in the proposal and provided alternative views; and • seven submissions disagreed with the proposal. 7.1 Issues Arising from Public Submissions 7.1.1 Appropriateness of milk fat content Of the ten submitters that supported the proposal, two (one from industry and one from a public health organisation) commented that an advisory statement should cover all milks with

6 Wosje, K.S. Specker, B. L. Giddens, J. No differences in growth or body consumption from age 12 to 24 months between toddlers consuming 2% milk and toddlers consuming whole milk. JAMA: 101;1. 2001. 7 National Health and Medical Research Council. Dietary Guidelines for Children and Adolescents and Infant Feeding Guidelines (Draft) 2001.

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a milk fat content of below 3 percent. The remaining eight submitters supported the proposed milk fat level of below 2.5 percent. 7.1.2 Warning vs. advisory statement Of the ten submitters that supported the proposal, one consumer organisation commented that the wording of the statement should be prescribed so that the message is consistent and is not open to misinterpretation. The remaining nine submitters supported the use of an advisory statement, rather than a warning statement. 7.1.3 Types of milks to be covered by the statements Of the ten submitters that supported the proposal, two commented that the statement should be extended to cover reduced fat milk substitutes such as soy beverages. The remaining eight submitters agreed that the statement should cover milk, condensed milk and milk products with a milk fat content of less than 2.5%. Other Comments 7.1.4 Wording of Advisory Statement Two submitters commented that the wording of the advisory statements should be to the effect that the product ‘ is not suitable as a complete milk food for infants’ or ‘not suitable as a primary beverage’. The rationale for this is that reduced fat and skim milk products are suitable for use in food preparation and cooking. 7.1.5 Opposition to the proposal Opposition to the proposal (7 submissions) was from dairy industry organisations and was based on the following arguments: o No scientific evidence to suggest that consumption of reduced fat milk present a public

health risk for toddlers in the context of the total diet. o The use of a labelling statement may discourage the consumption of dairy products in

children and lead to an increase in the consumption of fruit drinks and carbonated beverages.

o Positive public health outcomes have been achieved through public health education programs.

o Condensed milk is only marketed for use in recipes, not infant feeding. o The use of the term ‘milk products’ is too broad. o Requiring labelling statements for milk and not milk substitutes is anti-competitive and

places milk at a market disadvantage compared to the soy and rice beverage industry. o Codex does not require such labelling statements, therefore Australian and New

Zealand export products may be disadvantaged. 7.2 External Advisory Group The External Advisory Group (see membership at Attachment 3) advised that there were two distinct issues when considering labelling statements on milk:

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1. the unsuitability of cows milk as the sole dietary source for infants (< 1 year); and 2. the inappropriateness of feeding milk, condensed milk, evaporated milk, dried milk, soy

beverages and rice beverages with a fat content of less than 2.5% to children under two years.

The External Advisory Group agreed after considering submissions that: • the Purpose of P 240 should be limited to addressing the latter point, i.e. the

inappropriateness of feeding milk, condensed milk, evaporated milk, dried milk, soy and rice beverages with a fat content of less than 2.5% to children under two years;

• condensed milk (less than 2.5% fat) should be included because even though these

products are marketed for use in recipes they are not suitable to be fed to children under two years of age;

• labelling statements combined with public health education programs would be more

effective in getting the message across to consumers that the products are unsuitable for children under two. The reason for this is labelling statements are sustained whereas public health education programs are often not sustainable for long periods;

• reduced fat soy and rice beverages should be included as part of the review because

anecdotal evidence from dietitians suggest these products are often fed to children in place of cows milk. Therefore carers feeding these products to their children need to be informed of the risk. In the case of rice beverages this is particular important because the product is nutritionally inferior to milk; and

• if an advisory statement is the preferred option to be used on the above products, then it

should be a positive statement rather than a negative statement because it would prevent carers from avoiding the above products and leading to an increase in the consumption of fruit drinks and carbonated beverages. For example, the group agreed that the warning statement as set out in the New Zealand Food Regulations 1984 ‘Not suitable as a complete milk food for infants’ is more positive than the statements ‘Seek medical advice before use in infant feeding’ or ‘Unsuitable for infants except on medical advice’ in Volume 1 of the Food Standards Code.

It must be noted that advisory statements are not prescriptive and industry is able to give positive messages as long as the meaning of the message remains unchanged. 8. CONCLUSIONS It is clear from the Dietary Guidelines3,4 in Australia and New Zealand that reduced fat milks and condensed milk are not suitable to be fed to children under two years of age. The consensus amongst public health groups is that feeding reduced fat milks to children under two years could lead to growth and development problems and therefore an advisory

3 National Health and Medical Research Council. Dietary Guidelines for Children and Adolescents. Australian Government Publishing Service, Canberra, 1995. 4 Ministry of Health. Food and Nutrition Guidelines for Healthy Infants and Toddlers (Aged 0-2 Years).

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statement should be placed on these products. The advisory statement should be expanded to cover soy and rice beverages as anecdotal evidence from dietitians suggest these products are often fed to children in place of cows milk. Consideration of the regulatory impacts of advisory statements on milk concludes that the benefits which will accrue to consumers and government in protecting public health and safety and supporting government policy will outweigh the costs to industry through the need to change labels. The possible negative effects on dairy consumption of negative warning statements has been raised as an issue. An advisory statement is less prescriptive which would allow industry to place more positive statements on their products to prevent effects on consumption levels. 9. RECOMMENDATION It is recommended that Option 2d be supported and advisory statements be placed on milk, condensed milk, evaporated milk, dried milk, soy and rice beverages subject to the following conditions: • statements be limited to products with a fat content of less than 2.5%; and • statements target children under two years of age. The proposed drafting for an amendment to the Food Standards Code (Vol 2) is at Attachment 2. 10. WORLD TRADE ORGANIZATION (WTO) NOTIFICATION During the ANZFA assessment process, comments are also sought internationally from other Members of the World Trade Organization (WTO). As members of the WTO, Australia and New Zealand are signatories to the agreements on the Application of Sanitary and Phytosanitary Measures (SPS Agreement) and on Technical Barriers to Trade (TBT Agreements). In some circumstances, Australia and New Zealand have an obligation to notify the WTO of changes to food standards to enable member countries of the WTO to make comment. Amending the Food Standards Code to change the existing warning statements on milk and milk products to advisory statements may raise a potential Technical Barrier to Trade and therefore will be notified to the WTO. 11. FOOD STANDARDS SETTING IN AUSTRALIA AND NEW ZEALAND The Governments of Australia and New Zealand entered an Agreement in December 1995 establishing a system for the development of joint food standards. On 24 November 2000, Health Ministers in the Australia New Zealand Food Standards Council (ANZFSC) agreed to adopt the new Australian New Zealand Food Standards Code. The new Code was gazetted on 20 December 2000 in both Australia and New Zealand as an alternate to existing food regulations until December 2002 when it will become the sole food code for both countries. It aims to reduce the prescription of existing food regulations in both countries and lead to greater industry innovation, competition and trade.

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Until the joint Australia New Zealand Food Standards Code is finalised the following arrangements for the two countries apply: • Food imported into New Zealand other than from Australia must comply with either

Volume 1 (known as Australian Food Standards Code) or Volume 2 (known as the joint Australia New Zealand Food Standards Code) of the Australian Food Standards Code, as gazetted in New Zealand, or the New Zealand Food Regulations 1984, but not a combination thereof. However, in all cases maximum residue limits for agricultural and veterinary chemicals must comply solely with those limits specified in the New Zealand (Maximum Residue Limits of Agricultural Compounds) Mandatory Food Standard 1999.

• Food imported into Australia other than from New Zealand must comply solely with

Volume 1 (known as Australian Food Standards Code) or Volume 2 (known as the joint Australia New Zealand Food Standards Code) of the Australian Food Standards Code, but not a combination of the two.

• Food imported into New Zealand from Australia must comply with either Volume 1

(known as Australian Food Standards Code) or Volume 2 (known as Australia New Zealand Food Standards Code) of the Australian Food Standards Code as gazetted in New Zealand, but not a combination thereof. Certain foods listed in Standard T1 in Volume 1 may be manufactured in Australia to equivalent provisions in the New Zealand Food Regulations 1984.

• Food imported into Australia from New Zealand must comply with Volume 1 (known

as Australian Food Standards Code) or Volume 2 (known as Australia New Zealand Food Standards Code) of the Australian Food Standards Code, but not a combination of the two. However, under the provisions of the Trans-Tasman Mutual Recognition Arrangement, food may also be imported into Australia from New Zealand provided it complies with the New Zealand Food Regulations 1984.

• Food manufactured in Australia and sold in Australia must comply with Volume 1

(known as Australian Food Standards Code) or Volume 2 (known as Australia New Zealand Food Standards Code) of the Australian Food Standards Code but not a combination of the two. Certain foods listed in Standard T1 in Volume 1 may be manufactured in Australia to equivalent provisions in the New Zealand Food Regulations 1984.

In addition to the above, all food sold in New Zealand must comply with the New Zealand Fair Trading Act 1986 and all food sold in Australia must comply with the Australian Trade Practices Act 1974, and the respective Australian State and Territory Fair Trading Acts. Any person or organisation may apply to ANZFA to have the Food Standards Code amended. In addition, ANZFA may develop proposals to amend the Australian Food Standards Code or to develop joint Australia New Zealand food standards. ANZFA can provide advice on the requirements for applications to amend the Food Standards Code.

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12. INVITATION FOR PUBLIC SUBMISSIONS The process for amending the Australia New Zealand Food Standards Code (the Code) is prescribed in the ANZFA Act 1991. Open and transparent consultation with interested parties is a key element in the process involved in amending or varying the Code. Any individual or organization may make an ‘application’ to the Australia New Zealand Food Authority (the Authority) seeking to change the Code. The Authority itself, may also seek to change the Code by raising a ‘proposal’. In the case of both applications and proposals there are usually two opportunities for interested parties to comment on proposed changes to the Code during the assessment process. This process varies for matters that are urgent or minor in nature. Following the initial assessment of an application or proposal the Authority may decide to accept the matter and seek the views of interested parties. If accepted, the Authority then undertakes a draft assessment including, preparing a draft standard or draft variation to a standard (and supporting draft regulatory impact statement). If a draft standard or draft variation is prepared, it is then circulated to interested parties, including those from whom submissions were received, with a further invitation to make written submissions on the draft. Any such submissions will then be taken into consideration during the final assessment, which the Authority will hold to consider the draft standard or draft variation to a standard.

Comment opportunities in the usual assessment process to change the Australia New Zealand Food Standards Code

(Note: this process may vary for matters that are urgent or minor)

Content of Submissions Written submissions containing technical or other relevant information which will assist ANZFA in undertaking an assessment on matters relevant to the application, including consideration of its regulatory impact, are invited from interested individuals and organizations. Information providing details of potential costs and benefits of the proposed change to the Code from stakeholders is highly desirable. Claims made in submissions should be supported wherever possible by referencing or including relevant; studies, research findings, trials, surveys etc. Technical information presented should be in sufficient detail to allow independent scientific assessment. Submissions may provide more general comment and opinion on the issue although those framing their submissions should bear in mind ANZFA’s regulatory role specifically relates to food supplied for human consumption in Australia and New Zealand. The ANZFA Act 1991

Scoping Stage

Initial Assessment Stage

Draft Assessment Stage

Final Assessment Stage Comment period 2

Comment period 1

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sets out the objectives of the Authority in developing food regulatory measures and variations of food regulatory measures as:

(a) the protection of public health and safety; and (b) the provision of adequate information relating to food to enable consumers to make informed choices; and (c) the prevention of misleading or deceptive conduct.

In developing food regulatory measures and variations of food regulatory measures The Authority must also have regard to the following:

(a) the need for standards to be based on risk analysis using the best available scientific evidence;

(b) the promotion consistency between domestic and international food standards; (c) the desirability of an efficient and internationally competitive food industry; (d) the promotion of fair trading in food.

Submissions addressing the issues in the context of the objectives of the Authority as set out in the ANZFA Act 1991 will be more effective in supporting their case. Written submissions containing technical or other relevant information which will assist the Authority in undertaking a final assessment on matters relevant to the application, including consideration of its regulatory impact, are invited from interested individuals and organisations. Technical information presented should be in sufficient detail to allow independent scientific assessment. Submissions providing more general comment and opinion are also invited. The Authority's policy on the management of submissions is available from the Standards Liaison Officer upon request. Following its draft assessment of the application the Authority may prepare a draft standard or draft variation to a standard (and supporting draft regulatory impact statement), or decide to reject the application/proposal. If a draft standard or draft variation is prepared, it is then circulated to interested parties, including those from whom submissions were received, with a further invitation to make written submissions on the draft. Any such submissions will then be taken into consideration during the inquiry, which the Authority will hold to consider the draft standard or draft variation to a standard. Transparency The processes of ANZFA are open to public scrutiny, and any submissions will ordinarily be placed on the public register of ANZFA and made available for inspection. If you wish any confidential information contained in a submission to remain confidential to ANZFA, you should clearly identify the sensitive information and provide justification for treating it in confidence. The Australia New Zealand Food Authority Act 1991 requires ANZFA to treat in confidence trade secrets relating to food and any other information relating to food, the commercial value of which would be or could reasonable be expected to be destroyed or diminished by disclosure. Contact details for submitters are recorded so that the Authority can continue to keep them informed about progress of the application or proposal.

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Deadlines The deadlines for submissions are clearly indicated in the advertisements calling for comment and in the relevant Assessment Reports. While the Authority often provides comment periods of around 6 weeks, the periods allowed for comment may vary and may be limited to ensure critical deadlines for projects can be met. Unless the Project Manager has given specific consent for an extension, the Authority cannot guarantee that submissions received after the published closing date will be considered. Delivery of Submissions Submissions must be made in writing and should be clearly marked with the word ‘Submission’ and quote the correct project number and title. Submissions may be sent by mail, fax or email to one of the following addresses: Australia New Zealand Food Authority Australia New Zealand Food Authority PO Box 7186 PO Box 10559 Canberra BC ACT 2610 The Terrace WELLINGTON 6036 AUSTRALIA NEW ZEALAND Tel (02) 6271 2258 Tel (04) 473 9942 Fax (02) 6271 2278 Fax (04) 473 9855 email: [email protected] email: [email protected] Submissions should be received by the Authority by: 6 FEBRUARY 2002 Submissions may also be sent electronically through the submission form on the ANZFA website www.anzfa.gov.au. Electronic submissions should also include the full contact details of the person making the submission on the main body of the submission so that the contact details are not separated. Further Information Further information on this and other matters should be addressed to the Standards Liaison Officer at the Australia New Zealand Food Authority at one of the above addresses. Assessment reports are available for viewing and downloading from the ANZFA website or alternatively paper copies of reports can be requested from the Authorities Information Officer at [email protected]. ATTACHMENTS 1. Food Standards-setting in Australia and New Zealand 2. Draft Variations to the Food Standards Code 3. Statement of Reasons 4. Summary of Submissions 5. External Advisory Group

mailto:[email protected]


http://www.anzfa.gov.au/


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ATTACHMENT 1 FOOD STANDARDS-SETTING IN AUSTRALIA AND NEW ZEALAND The Governments of Australia and New Zealand entered an Agreement in December 1995 establishing a system for the development of joint food standards. On 24 November 2000, Health Ministers in the Australia New Zealand Food Standards Council (ANZFSC) agreed to adopt the new Australian New Zealand Food Standards Code. The new Code was gazetted on 20 December 2000 in both Australia and New Zealand as an alternate to existing food regulations until December 2002 when it will become the sole food code for both countries. It aims to reduce the prescription of existing food regulations in both countries and lead to greater industry innovation, competition and trade. Until the Australia New Zealand Food Standards Code is the sole Code between Australia and New Zealand, the following arrangements for the two countries apply: • Food imported into New Zealand other than from Australia must comply with

either Volume 1 (previously known as Australian Food Standards Code) or Volume 2 (also known as the Australia New Zealand Food Standards Code) of the Food Standards Code, as gazetted in New Zealand, or the New Zealand Food Regulations 1984, but not a combination thereof. However, in all cases maximum residue limits for agricultural and veterinary chemicals must comply solely with those limits specified in the New Zealand (Maximum Residue Limits of Agricultural Compounds) Mandatory Food Standard 1999.

• Food imported into Australia other than from New Zealand must comply solely

with Volume 1 (previously known as Australian Food Standards Code) or Volume 2 (also known as the Australia New Zealand Food Standards Code), of the Food Standards Code, but not a combination of the two.

• Food imported into New Zealand from Australia must comply with either Volume 1

(previously known as Australian Food Standards Code) or Volume 2 (also known as the Australia New Zealand Food Standards Code) of the Food Standards Code, as gazetted in New Zealand, but not a combination thereof. Certain foods listed in Standard T1 in Volume 1 may be manufactured in Australia to equivalent provisions in the New Zealand Food Regulations 1984.

• Food imported into Australia from New Zealand must comply with Volume 1

(known as Australian Food Standards Code) or Volume 2 (known as Australia New Zealand Food Standards Code) of the Food Standards Code, but not a combination of the two. However, under the provisions of the Trans-Tasman Mutual Recognition Arrangement, food may also be imported into Australia from New Zealand provided it complies with the New Zealand Food Regulations 1984.

• Food manufactured in Australia and sold in Australia must comply solely with

Volume 1 (previously known as Australian Food Standards Code) or Volume 2 (also known as the Australia New Zealand Food Standards Code), of the Food Standards Code, but not a combination of the two. Certain foods listed in Standard T1 in Volume 1 may be manufactured in Australia to equivalent provisions in the New Zealand Food Regulations 1984.

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In addition to the above, all food sold in New Zealand must comply with the New Zealand Fair Trading Act 1986 and all food sold in Australia must comply with the Australian Trade Practices Act 1974, and the respective Australian State and Territory Fair Trading Acts. Any person or organisation may apply to ANZFA to have the Food Standards Code amended. In addition, ANZFA may develop proposals to amend the Food Standards Code or to develop joint Australia New Zealand food standards. ANZFA can provide advice on the requirements for applications to amend the Food Standards Code.

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ATTACHMENT 2 DRAFT VARIATION TO THE FOOD STANDARDS CODE To commence: On gazettal [1] Standard 1.1.1 of Volume 2 of the Food Standards Code is varied by omitting the definition of warning statement in clause 2, substituting –

warning statement means a statement required by to be expressed in the text as so prescribed in this Code, in –

(a) clause 3 of Standard 1.2.3; and (b) clause 3 of Standard 2.6.3; and (c) subclauses 15(1), 15(3) and 27(1) of Standard 2.9.1; and (d) paragraph 5(3)(c) and subclause 6(2) of Standard 2.9.2; and (e) subclauses 3(3) and 3(4) of Standard 2.9.4.

[2] Standard 1.1.3 of Volume 2 of the Food Standards Code is varied by omitting clause3. [3] Standard 1.2.3 of Volume 2 of the Food Standards Code is varied by - [3.1] inserting in the Table to clause 2 - Milk, condensed milks, evaporated milks, dried milks and beverages made from soy or rice, where these foods contain no more than 2.5% m/m fat after being diluted, as appropriate, for consumption

Statement to the effect that the product is not suitable as a complete milk food for children under the age of two years

[3.2] omitting the Editorial Note immediately following the Table to clause 2, substituting

Editorial note: 'Milk' is defined in Standard 2.5.1. ‘Condensed milks’, ‘dried milks’ and ‘evaporated milks’ are defined in Standard 2.5.7.

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ATTACHMENT 3 STATEMENT OF REASONS PROPOSAL P240 LABELLING STATEMENTS ON REDUCED FAT AND CONDENSED MILKS The Australia New Zealand Food Authority (ANZFA) has before it a proposal (P240) to review the current regulations relating to the labelling of reduced fat and condensed milk with warning statements. Proposal P240 aims to determine the most cost effective regulatory mechanism for managing the risk of the inappropriate feeding of milk, condensed milk, evaporated milk, dried milk, soy and rice beverages with a fat content of less than 2.5% to children under the age of two. ANZFA recommends the adoption of the draft variations to Standards 1.1.3 and 1.2.3 of Volume 2 of the Food Standards Code, as amended for the following reasons: 1. Consideration of the regulatory impacts of advisory statements on milks concludes that

the benefits which will accrue to consumers and governments in protecting public health and safety and supporting government policy, will outweigh the costs to industry through the need to change labels.

2. An advisory statement is less prescriptive than a warning statement and would allow

industry to place more positive statements on their products. 3. An advisory statement should cover soy and rice beverages because anecdotal evidence

from dietitians suggest that these products are being fed to children in place of cows milk.

4. A labelling statement to the effect that the product is not suitable as a complete milk

food for children under two years of age is consistent with the Australian and New Zealand Dietary Guidelines.

The Draft Assessment report of P240 recommends variations to Standards 1.1.3 and 1.2.3 of Volume 2 of the Food Standards Code. The report recommends deleting Clause 3 of Standard 1.1.3 to amend the requirement for mandatory warning statements on reduced fat and condensed milk; and amending the table to Clause 2 of Standard 1.2.3 to require an advisory statement on milk; evaporated milk; condensed milks, dried milk; and beverages made from soy or rice, where these products have a fat content of less than 2.5%. World Trade Organization (WTO) Notification Amending the Food Standards Code to change the existing warning statements on milk and milk products to advisory statements may raise a potential Technical Barrier to Trade and therefore will be notified to the WTO. DRAFT VARIATION TO THE FOOD STANDARDS CODE To be inserted here

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ATTACHMENT 4 Summary of First Round of Public Consultation List of Submitters Australian Dairy Corporation Australian Dairy Products Federation Inc. CSIRO Health Sciences and Nutrition Dairy Farmers Dietitians Association of Australia Food Technology Association (FTA) Victoria Inc. InforMed Systems Ltd Market Milk Federation of Australia, Incorporated Ministry of Health Murray Goulburn Co-operative Co. Limited National Council of Women National Foods Nestlé Australia Ltd New Zealand Dairy Board New Zealand Dairy Foods Limited Office of Regulation Review Royal New Zealand Plunket Society (Inc.) University of Otago

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Submitter Support or

Oppose Preferred Option

Comments

INDUSTRY Australian Dairy Corporation

Oppose Previous submissions by ADC to P161 in May and August 2000 are appropriate to P240. Supports current NHMRC Dietary Guidelines regarding the use of reduced fat milk for children under 2 years of age. Insufficient scientific data to suggest that consumption of low and reduced fat milks present a public health risk for children under 5 years of age. In the absence of such data, a labelling statement may negatively impact on the consumption of dairy products and calcium intake. Consideration should be given to existing public health education programs rather than food labelling. Consumer research indicates food labelling alone may be ineffective in securing consumer understanding and safeguarding public health. Any advisory statement must be based on sound scientific evidence and be integrated with public health promotional activities. A positive statement may be more appropriate rather than a negative statement.

Australian Dairy Products Federation Inc

Oppose Preferred option is Option 3, on the following basis: Implementation of Dietary Guidelines is through public education not labelling requirements. Labelling statements may deter parents from providing dairy products to young children, impacting on calcium intake and bone development. Also, parents may replace milk with fruit drinks and carbonated beverages which have high sugar content. Labelling statements required for milk and not for milk substitutes is anti-competitive and places milk at a market disadvantage. Little evidence is available on total dietary fat intake for toddlers to conclude that skim milk and reduced fat milks don’t provide adequate energy from fat to support normal growth. No scientific evidence to support 2.5% milk fat cut-off level as opposed to 2.1% for labelling statements. Changing the level to 2.5% means Australian manufacturers need to adjust their educational/labelling material. Advisory statement should not be required on condensed milk as it is used in ingredients in recipes and marketed as such. Also, all reducing sugars contribute to dental caries, not just sucrose. Reference to the development of a sweet tooth is unsubstantiated in the paper. Low fat and reduced fat milks are not unsuitable for infants and toddlers, provided they are not the sole nutrient source. ANZFA has not provided a definition of ‘milk and milk products’. This requires further clarification. Codex does not require labelling statements on milk and milk products – this could disadvantage Australian export products.

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Dairy Farmers Oppose Preferred option is Option 3, on the basis that the use of a labelling statement could be construed as a ‘warning’ and

therefore discourage milk consumption by children generally. Next preferred option is to support the use of a prescribed statement as follows: ‘NOT SUITABLE AS A COMPLETE MILK FOOD FOR INFANTS’. Do not agree that the word ‘toddlers’ should be used in the statement as many people use the term ‘toddlers’ to refer to children older than 2 years of age. Support the reference fat content of below 2.5%. Support the use of a statement on condensed milks in addition to reduced fat milks.

Food Technology Association Victoria Inc

Support Support all issues raised in the proposal.

InforMed Systems Ltd

Support with modification

Support the age range proposed of children under 2 years. Support the range of milks to be covered by the statement. Propose that the statement should cover milks with a fat level of below 3% as there is a possibility that reduced fat milks of below 3% fat could be introduced in New Zealand (currently none between 2.5 and 3% fat).

Market Milk Federation of Australia, Incorporated

Oppose Proposal will send wrong message to consumers and will affect consumption of all dairy products by toddlers, putting them at risk from obtaining required dietary intake of calcium and other essential elements. Support submissions by ADPF and ADC.

Murray Goulburn Co-operative Co. Ltd

Oppose Preferred option is Option 3, on the following basis: No demonstrated evidence that current milk consumption and practices are a significant public health risk to children under 2 years of age. Public health system can advise appropriate infant and toddler feeding practices. Negative statements on a few specified products have the potential to mislead consumers from all dairy foods. Many foods and beverages are not recommended for young children. It is unfair and anti-competitive for only some of these products to have a warning/advisory statement.

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National Foods Oppose Preferred option is Option 3 on the following basis:

Proposal lacks supporting scientific evidence to underpin the recommendations proposed. Evidence of a health and safety issue that requires regulatory intervention has not been provided. The Dietary Guidelines apply to the total diet and are intended as guidance for the Australian population. ANZFA has taken the rationale for an individual guideline and transferred this into a proposed labelling statement. An unintended consequence of the proposal could be to limit the variety of dairy foods available to infants and toddlers, as well as the use of reduced fat milks and milk products as ingredients in recipes in foods. In addition, there may be a greater use of milk alternatives such as soft drinks, fruit juices, cordial etc. This is likely to have greater potential risk to health on the energy, protein, calcium and mineral intake of infants and toddlers, than the use of reduced fat or modified milk. Fat modified dairy foods should not be negatively categorised in isolation – any statement should be consistently applied to other intrinsically low fat or modified fat foods. Positive public health outcomes cannot be achieved by a single advisory statement on a single category of dairy products. Evidence from the 1995 National Nutrition Survey suggests that existing public health messages are working, therefore an advisory statement on reduced fat dairy foods is not warranted. The proposal does not harmonise with Codex.

Nestlé Australia Ltd Oppose Preferred option is Option 3 on the following basis: Proposal does not address the use of milk replacers such as soy drink products, which may be reduced or low fat products. The health concern would relate equally to milk replacers. No scientific evidence of the development of a ‘sweet tooth’ in infants and toddlers and the development of dental caries due to consumption of condensed milk. Condensed milk should not require an advisory statement as it is only marketed as an ingredient for use in recipes, not for infant feeding. The use of the term ‘milk products’ is too broad and may capture products that are not intended to be included eg yoghurts and ice confection products containing milk. Also, it is unclear whether evaporated skim milk or reduced fat evaporated milk is to be covered by the proposed statement. An advisory statement may have unintentional consequences of excluding dairy products from the diet of children and toddlers. Nestle believes we should rely on a public health system to educate the public about the unsuitability of reduced fat products and condensed milks for infant feeding. Additional cost to manufacturers as some labels may have already been changed to the Volume 2 requirements. There will be no reduced costs of enforcement with the proposed change in wording. ANZFA has not provided evidence to determine whether the energy intake provided by fat is insufficient in the toddler age group. The proposed statement is considered to be a potential technical barrier to trade and would therefore need to be notified to the WTO.

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New Zealand Dairy Board Support with modification

Advisory statement should apply equally to other milks/milk substitutes that may replace cow’s milk in the diet. Whatever option is chosen, education by the public health system and other support services will play an important role in advising of the unsuitability of these products. Propose that the advisory statement should only apply to infants under 12 months as milk is not the only source of fat in a toddler’s diet i.e. children typically consume a mixed diet after the age of 1 year. Propose the following advisory statement ‘not suitable as a complete food for infants’ so the products can still be used in cooking/sauces etc without raising concern..

New Zealand Dairy Foods Limited


PUBLIC HEALTH/ GOVERNMENT

CSIRO Health Sciences and Nutrition

Support Support all issues raised in the proposal. Also state that reduced intake of Vitamin A from reduced fat fortified milk and fortified skim milk compared to whole milk should be taken into consideration.

Dietitians Association of Australia

Support Support all issues raised in the proposal. Also state: Need to reinforce previous comments that it is important not to discourage use of milk and milk products for children under 2 years. Alternative beverages may not provide the same nutritional benefits of milk. Advisory statement should not discourage use of modified milk products in food preparation and cooking. Healthy eating recommendations should be provided from sound nutrition education sources. Manufacturers should be encouraged to extend the ‘use by date’ to include a time period for use after the milk container is opened.

Ministry of Health Support with modification

Support all issues raised in the proposal but consider that the statement should be extended to cover milk substitutes eg soy products. Also, further consideration needs to be given to an advisory statement for all milks and milk products, and milk substitutes to the effect that they are unsuitable for infants under 12 months of age if used as the principal source of fluids.

University of Otago Support with modification

Support the age range proposed of children under 2 years. Support the use of an advisory statement but propose that the statement should cover all milks with a milk fat content of below 3 percent. The statement should be to the effect that the product is not suitable as a primary beverage. Definition of ‘milk and milk products’ needs clarification.

CONSUMERS National Council of Women of Australia

Support with modification

Support the age range proposed of children under 2 years. Support the range of milks to be covered by the statement. Support the reference fat content of below 2.5%. Consider that the wording of the statement should be prescribed so that the message is consistent and leaves no room for misinterpretation. Also, situation could be life threatening if a child is raised solely on reduced fat and condensed milks

Royal New Zealand Plunket Society Inc


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ATTACHMENT 5 SIGNAL Australian Dairy Products Federation Australian Dairy Corporation Dietitians Association of Australia New Zealand Nutrition Foundation National Health and Medical Research Council Australian Confederation of Paediatric and Child Health Nurses Royal and New Zealand Plunket Society Australian Consumer Association Women’s and Children’s Hospital New Zealand Dairy Corporation

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