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3. METHODOLOGY
3.1 Sampling aim
The aims of the sampling plan were to obtain the labels of 2.5% of all retail packaged food
products available in Australia and New Zealand, and to select labels which were a
representative sample of all food products and brand types (see section 3.2.2).
3.2 Sample stratification
3.2.1 Food categories
For the purpose of this survey, foods were grouped into 14 major food categories using a
food classification system similar to that used in Standard 1.3.1 Food Additives of the new
Code as outlined below:
1. dairy products;
2. edible oils & oil emulsions;
3. ice cream & edible ices;
4. fruit & vegetables;
5. confectionery;
6. cereals & cereal products;
7. breads & bakery products;
8. meat & meat products;
9. fish & fish products;
10. egg & egg products;
11. sugar, honey & related products;
12. foods intended for particular dietary uses;
13. non alcoholic beverages; and
14. mixed foods.
Major food categories were further divided into minor food categories based on the grouping
of food products with similar regulatory requirements (e.g. by individual food product
standards within a category or separated by additive permissions):
e.g. Dairy was divided into the following six minor food categories:
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1.1 milk;
1.2 cream;
1.3 dried milk products;
1.4 cheese;
1.5 dips; and
1.6 yoghurt.
In order to represent and distinguish between products with different storage and shelf life
requirements, minor food categories were then divided according to their processing
conditions:
e.g. 7.3 Cakes, muffins and pastries were divided into the following sub-minor food
categories:
7.3.1 fresh / ambient;
7.3.2 chilled;
7.3.3 frozen; and
7.3.4 mixes (eg. dry packet mixes).
The categorisation of foods in this manner ensured that all food product groups subject to the
labelling provisions of the new Code were covered by the survey. Sampling within these
categories was by quota sampling per food category.
The categories which were sampled are fully detailed in Table 1.
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Table 1 Food product categories used for the survey
Major product
category Minor product category Minor sub category
1. Dairy 1.1 Milk (including flavoured milks) 1.1.1 Fresh - full fat
(excludes butter) Fresh – includes pasteurised & unpasteurised 1.1.2 Fresh - reduced fat/ no fat
1.1.3 Long life - full fat
Long life – includes UHT, canned*, evaporated and
condensed) 1.1.4 Long life - reduced fat/ no fat
1.2 Cream 1.2.1 Fresh
Fresh – includes pasteurised & unpasteurised 1.2.2 Sour cream
Long life - includes UHT and canned* 1.2.3 Long life
1.3 Dried milk products 1.3.1 Full fat milk
1.3.2 Reduced fat/no fat milk
1.3.3 Other (non milk dairy powders e.g. cheese powders)
1.4 Cheese
1.5 Dips (predominately dairy based)
1.6 Yoghurt 1.6.1 Fresh
(including cultured milk drinks) 1.6.2 Powdered mix
2. 2.1 Edible oils
2.2 Butter
2.3 Margarine
Edible oils & oil
emulsions
2.4 Dairy spreads
3. 3.1 Ice cream 3.1.1 Frozen
3.1.2 Powdered mix
3.2 Ice confectionery 3.2.1 Ambient
3.2.2 Chilled
Ice cream & edible
ices
3.3 Frozen yoghurt
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Table 1 Food product categories used for the survey (cont’d)
Major Product
Category Minor Product Category Minor Sub Category
4. 4.1 Canned* fruits
4.2 Fresh packaged fruit
(includes peeled, cut, treated fruits and fresh packed
salads)
Fruits & vegetables
(including fungi,
nuts, seeds, herbs
and spices)
4.3 Fresh packaged vegetables
(includes peeled, cut, treated vegetables and fresh
packed salads)
4.4 Canned* vegetables
4.5 Nuts & seeds
4.6 Jams & spreads
(fruit, vegetable including peanut butter, vegetable
extracts and nut-based spreads)
4.7 Herbs & spices 4.7.1 Ambient (dried)
4.7.2 Chilled (fresh)
4.8 Dried/candied fruits
4.9 Dried vegetables
4.10 Pickled fruit
4.11 Pickled vegetables
4.12 Frozen fruit
4.13 Frozen vegetables
5. 5.1 Chocolate & cocoa products 5.1.1 Beverage
5.1.2 Confectionery
5.2 Sugar confectionery – includes candy coated
chocolate
Confectionery
5.3 Chewing gum
6. 6.1 Unprocessed cereals
(whole and broken grains)
6.2 Flours
6.3 Processed cereals
(including breakfast cereals)
6.4 Cereal bars
(including muesli bars, cereal based bars)
Cereal & cereal
products
6.5 Noodles & pasta 6.5.1 Shelf stable
6.5.2 Frozen
6.5.3 Chilled
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Table 1 Food product categories used for the survey (cont’d)
Major Product
Category Minor Product Category Minor Sub Category
7. 7.1 Breads 7.1.1 Shelf stable
7.1.2 Chilled
Bread & bakery
products (including bread, fruit loaf, English muffins,
crumpets) 7.1.3 Frozen
7.1.4 Bread mix
7.2 Biscuits 7.2.1 Savoury
7.2.2 Sweet
7.2.3 Biscuit mix – ambient
7.2.4 Biscuit mix – chilled
7.2.5 Biscuit mix – frozen
7.3 Cakes/muffins/pastries 7.3.1 Fresh/ambient
7.3.2 Chilled
7.3.3 Frozen
(including cakes, muffins excluding English
style, sweet pastries, iced buns)
7.3.4 Mixes
8. 8.1 8.1.1 Chilled
Whole meat products including hams,
bacon, cooked chicken products 8.1.2 Frozen
8.2 Comminuted meat products 8.2.1 Chilled
(including hamburgers, sausages, manufactured
and processed meats, fermented meat products)
8.2.2 Frozen
Meat & meat
products (including
poultry & game)
8.3 Canned* meat
9. Fish & fish products 9.1 Packaged processed fish & fish fillets 9.1.1 Chilled
(including modified atmosphere packed fish
products, fish fingers, fish cakes, fish fillets)
9.1.2 Frozen
9.2 Semi preserved fish & fish fillets
(includes smoked, sugar cured, pickled fish)
9.3 Preserved fish products (canned)*
10. Eggs & egg products
11. 11.1 Sugar
(dry sugars and sugar syrups – e.g. corn syrup)
Sugar, honey &
related products
11.2 Honey (normal liquid & powders)
11.3 Tabletop artificial sweeteners
11.4 Royal jelly
11.5 Icing/frosting mixtures
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Table 1 Food product categories used for the survey (cont’d)
Major Product
Category Minor Product Category Minor Sub Category
12. 12.1 Infant formula products
12.2 Foods for infants
12.3 Formulated supplementary foods for young children
Foods intended for
particular dietary use
12.4 Formulated meal replacements
12.5 Formulated supplementary foods
12.6 Formulated supplementary sports foods
13. 13.1 Waters
(including packaged water and plain mineral water)
Non alcoholic
beverages
13.2 Fruit & vegetable juices 13.2.1 Shelf stable
(including concentrated fruit/vegetable juice powders and
syrups, coconut milk and plain soy beverage)
13.2.2 Chilled
13.3 Fruit & vegetable juice drinks 13.3.1 Shelf stable
(including flavoured soy drinks) 13.3.2 Chilled
13.4 Soft drinks
13.5 Formulated caffeinated beverages
13.6 Cordials
13.7 Electrolyte drink
13.8 Electrolyte drink base
13.9 Coffee
(including cream/coffee whiteners)
13.10 Tea
13.11 Herbal infusions
14. Mixed foods 14.1 Mixed non alcoholic drinks
(e.g. dry beverage bases and flavourings for milk shakes etc).
14.2 Desserts 14.2.1 Powdered mix
14.2.2 Chilled
14.2.3 Frozen
(including jelly, mousse, artificial cream)
14.2.4 Ambient
14.3 Mayonnaise & salad dressings
14.4 Sauces 14.4.1 Sweet shelf stable - liquid
14.4.2 Sweet shelf stable - powder
Sweet includes sauces, toppings and syrups
14.4.3 Sweet chilled
14.4.4 Savoury shelf stable - liquid
14.4.5 Savoury shelf stable - powder
Savoury includes sauces, salsa, gravy, condiments (e.g.
Mustard, pickle spread, chutney, tomato sauce), stocks
14.4.6 Savoury chilled
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Table 1 Food Product Categories Used For The Survey (cont’d)
Major Product
Category Minor Product Category Minor Sub Category
14.5 Soups 14.5.1 Canned
14.5.2 Chilled
14.5.3 Dry packet
14.6 Meat products 14.6.1 Frozen
(includes pies, pasties, sausage rolls, meat filled pasta) 14.6.2 Chilled
14.7 Pre-prepared meals 14.7.1 Frozen
14.7.2 Chilled
14.7.3 Canned
(includes complete breakfast meals and breakfast
drinks, frozen microwave meals, lunch kits)
14.7.4 Dry mix
14.8 Pizza 14.8.1 Chilled
14.8.2 Frozen
(complete pizza or base with sauce/herb coating)
14.8.3 Ambient
14.9 Snack foods 14.9.1 Ambient
(includes potato chips, gems and crisps etc, side dishes – e.g.
vegetable fingers, extruded snacks, corn chips, pretzels, snack
kits )
14.9.2 Frozen
* CANNED is in plastic, metal or pouch hermetic pack
3.2.2 Brand type categories
Retail packaged food products were categorised into four main, mutually exclusive brand
categories:
• nationally branded products – local retail products distributed in three or more
Australian States or Territories or in all regions of New Zealand (e.g. Nestle, Heinz,
Watties, Kraft); or any products imported into Australia or New Zealand;
• generic branded products – home brand, plain label and own brand retail products
(e.g. Farmland, Black and Gold, Pams, Homebrand);
• state specific products – retail products distributed in one or two Australian States or
Territories (e.g. dairy Rev and Big M flavoured milks from Victoria, bread products)
or, in only one region of New Zealand;
• specialty products – special interest products that did not fall into the other three
categories (e.g. special dietary foods such as gluten free foods, boutique products
such as propolis lollies, or specialised ethnic foods such as Kosher products).
Labels were also identified as local (i.e. manufactured in New Zealand or Australia) or
imported (i.e. manufactured outside of New Zealand or Australia), based on label
information.
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The purpose of this categorisation was to allow comparison of transition to, and consistency
with, labelling provisions of the new Code between these product categories.
Within the quota for each food category or sub-category, the appropriate proportion of each
brand type category was determined and convenience sampling used to obtain samples.
3.3 Sample size
To determine the appropriate sample size, stock keeping unit (SKU) lists were obtained from
supermarket and retail outlets across Australia and New Zealand (refer to Appendices 4 and
5). These SKU lists were analysed and grouped according to their inter-company
relationship. From these lists, the total size in terms of the variety of products available in
each pre-determined sub-minor food category was estimated. The cross over between
Australia and New Zealand SKUs (i.e. the number of SKUs available in both countries) was
estimated as 30% of the total number of SKUs available in Australia. In order to account for
this, the number of required samples for Australian food categories were reduced to 70% of
that initially calculated.
Two and a half percent of the total SKUs for any given sub-minor food category was chosen
as a sampling quota. In cases where a sub-minor food category was small (less than 100
SKUs), a minimum of two samples was taken. The total number of samples to be taken was
calculated as 1284: 733 from Australia and 551 from New Zealand. In Stage 1 however, due
to the unavailability of some samples (e.g. royal jelly in New Zealand), the total number of
samples purchased was 1273 (99% of the target). Of these, a total of 1,266 labels were
assessed, as some products with the same product brand and product name were purchased in
both New Zealand and Australia (99% target). In Stage 2, a total of 1,262 labels were
assessed (98% of the target). As with Stage 1, the target sample size was unobtainable due to
the variability of samples and some products being purchased in both Australia and New
Zealand. The quotas for sampling within each food category are detailed in the attached
Australian and New Zealand sampling plans in Appendices 6 and 7.
For products to be sampled within Australia, the most extensive SKU data supplied by any
one chain were used to estimate the proportion of specialty, generic, and state specific brands
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available in each sub-minor food category to ensure that a representative sample of brand
type was obtained. The SKU data received for New Zealand were not as extensive as that
from Australia and thus, analysing for brand types proved difficult. Therefore, to ensure the
sampling of a variety of brand types (namely national and generic), sampling was undertaken
in both the North and South Islands and split between the three principle supermarket chains.
SKU data were not comprehensive enough to allow categorisation of products in terms of
specificity to either the North or South Island.
Once the sample quota for each brand type per sub-minor food category had been established
as above, individual foods for inclusion in the survey were chosen by convenience sampling
(non-random). However, samples from as many different manufacturers as possible were
chosen, without consideration for their market share within each category. For example, for
the minor food category of edible oils, it was observed that there are a number of
manufacturers, but the market is dominated by a small number of manufacturers whose brand
name is associated with a variety of SKUs (oil types and pack sizes) that were likely to have
been labelled in the same manner. Sampling products made by a range of manufactures
rather than proportional to the number of SKUs provided a wide range of food labels to
assess for consistency with the new Code in that minor food category.
3.4 Sample collection
Samples within food categories were selected off store shelves, purchased and recorded in
sampling lists. Food products were collected until the quota for any given food category was
filled.
3.4.1 Sample collection in Australia
A large proportion of samples were initially purchased in metropolitan Victoria, the majority
of which were nationally branded and generic branded products.
For state specific products in Australia, samplers purchased products within this brand type
category in Victoria, New South Wales, Queensland, South Australia, Western Australia and
Tasmania. All samplers received a state specific product list for their respective state. This
list indicated the number of products the sampler was to purchase within each sub-minor food
category and the state specific brands that were to be chosen from. For example, for the
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minor food category of cheese, a single sample of the following state specific brands could be
purchased in South Australia:
• Cosmo Dairy;
• Farmers Union;
• Watsonia Dairy;
• Capel Dairy; and
• Kangaroo Island.
Samplers were asked to purchase those state specific brands/products that were easy to find
within local supermarket/s. Where products were hard to find, supermarkets were contacted,
and asked if any of the listed state specific products were stocked at nearby stores. If state
specific brands were stocked, samplers were asked to purchase a specific state specific brand
at the alternative store.
In addition to a state specific product list, samplers received a sampling list to record
products purchased, and prompt sheets to assist in the purchasing of products considered
difficult or confusing to identify (e.g. formulated supplementary foods).
Specialty products were sought from retail outlets chosen for their ethnic product range, their
specialized product range, their wide range of product lines or their innovative product lines.
In Australia, these types of products were generally purchased within metropolitan Victoria.
The remainder of products (including imported products) to be sampled within Australia,
were primarily purchased from metropolitan Victoria and New South Wales.
3.4.2 Sample collection in New Zealand
Samplers were recruited in both the North and South Island, and a sampling list and prompt
sheet were provided. Sampling was undertaken in metropolitan Auckland and Christchurch,
and in surrounding rural areas of Ashburton, Methven and Timaru. Sampling was split
between the three principle supermarket chains.
Due to the limited information provided for New Zealand SKUs, guidance in terms of ‘state
or regional specific’ products was not given as it was not possible to assess the status of
products for this brand type category for New Zealand.
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3.5 Determination of food standard used for product manufacture
The determination of the regulations used for the manufacturing and labelling of a food
product was based on the format of the Nutrition Information Panel (NIP) used, as the new
Code differs markedly from previous regulations. This assessment looked at whether the
format was consistent with the new Code or the old Code requirements as of June 2002 (up to
and including Amendment 60). The new Code prescribes that most manufactured foods
should provide a NIP on the label and include the following nutrients:
• Energy;
• Protein;
• Fat;
• Fat, saturated;
• Carbohydrate;
• Sugars; and
• Sodium.
Previously, the provision of NIPs was not mandatory however, when provided, NIPs for food
produced in Australia, were to include the following nutrients:
• Energy;
• Protein;
• Fat;
• Carbohydrate;
• Sugars;
• Sodium; and
• Potassium.
In New Zealand, Regulation 13a(12) of the New Zealand Food Regulations 1984 required
energy, protein, fat and carbohydrate to be declared but did not prescribe the order. In both
countries, if a claim was made about an additional nutrient it was also required to be declared
on the NIP. Thus, the point of reference for the Code used when NIPs were provided, was the
presence or absence of saturated fat as potassium could still be used in new Code NIPs when
making salt claims. If the product was exempt under the new Code from carrying an NIP (for
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example because of small package size or other specific exemptions within the new Code),
the Code status of the food was considered to be ‘indeterminable’. For the purposes of this
survey, these ‘indeterminable’ labels were assumed to have been produced to the new Code
requirements. If no NIP was provided, but no exemption for the provision of the NIP is
included in the new Code, the food label was assumed to have been produced to meet the old
Code requirements where provision of NIPs was not mandatory.
Figure 1 outlines the process for determining which set of regulations were used.
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Figure 1 Process for determination of food code used for product manufacture
NEW CODE LABEL
NO
Is a nutritioninformation panelpresent on food
product label
YES
Is “Fat, Saturated”declared in nutrition
information panel
NO
YES
YES
Is the product exempt fromproviding a nutrition
information panel in thenew Code
INDETERMINABLECODE LABEL
NO
OLD CODE LABEL
ASSUMED TO BE
3.6 Assessment of label elements
Only those labels deemed as being manufactured to the new Code, including indeterminable
labels, were further assessed for the label elements of interest in the survey.
For the purposes of this survey, interpretation of the new Code, including the depth and scope
of label assessments, was determined in consultation with FSANZ Staff and the Project
Team.
Figure 2 details the assessment process for labels.
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Figure 2 Assessment process for FSANZ Food Label Monitoring Survey
DETERMINE FOOD CODEUSED AS PER FIGURE 1
NO FURTHER ASSESSMENTCONDUCTED
SAMPLES COLLECTED AS PERSAMPLING PLAN (APPENDICES 6
AND 7)
ASSESS LABEL ELEMENTS FORCONSISTENCY WITH THE NEW
CODE; AND/OR COLLECT OTHERINFORMATION ON LABEL OF
INTEREST
ANALYSE DATA FROMASSESSMENTS OF LABELS
OLD CODE
NEW CODE ORINDETERMINABLE
Two types of further assessment occurred for those labels assessed as new Code labels
(including indeterminable labels), as follows:
• assessment for consistency with new Code labelling requirements; and
• additional data collection on the use of non-mandatory label aspects.
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Results for the overall assessment of consistency of food labels with the new Code labelling
provisions were also reported against brand type and the place of production (local or
imported).
3.6.1 Assessment of consistency with mandatory requirements
Where the new Code mandated specific provisions for labelling requirements, labels were
assessed for consistency against the new Code for each label element of interest. A total of 12
label elements were assessed. In some cases, the information on a single label element was
complex and needed to be broken down into sections or sub-sections for assessment
purposes. Definitions of the terms ‘label element’, ‘label element section’ and ‘label element
sub-section’ are provided in the Glossary to this report. For every food label, each label
element sub-section was assessed for consistency and deemed consistent, inconsistent,
indeterminable, exempt or not applicable. Then each label element section was assessed for
consistency based on these results, followed by each label element and finally the whole
label.
Figure 3 provides an example of the hierarchy of assessment.
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Figure 3 Label Assessment Levels
P R O D U C T N A M E IN G R E D IE N T D E C L A R A T IO N
D A T E M A R K IN G
A L L E R G E N IN F O R M A T IO N
S T O R A G E IN S T R U C T IO N S
U S A G E IN S T R U C T IO N S
C H A R A C T E R IS IN G IN G R E D IE N T S
C O M P L E X IN G R E D IE N T S
F o o d C o n ta in s A lle rg e n T y p e S ta te m e n ts
A lle rg e n s D e c la re d In in g re d ie n t L is t
M a y C o n ta in A lle rg e n T y p e S ta te m e n ts
M A N D A T O R Y A D V IS O R Y S T A T E M E N T S
C a ffe in e A d v is o ry S ta te m e n ts
G u a ra n a A d v is o ry S ta te m e n ts
P h y to s te ro l E s te r A d v is o ry S ta te m e n ts
N U T R IT IO N IN F O R M A T IO N P A N E L (N IP )
S ta n d a rd N IP
E x p a n d e d N IP
E x p a n d e d N IP - F a t T y p e
E x p a n d e d N IP - C a rb o h y d ra te T y p e
E x p a n d e d N IP - S a lt T y p e
S p e c ia l N IP
F o rm u la te d C a ffe in a te d B e v e ra g e s
F o rm u la te d S u p p le m e n ta ry F o o d s
F o rm u la te d M e a l R e p la c e m e n ts
In fa n t F o rm u la P ro d u c ts
In fa n t F o o d s
E le c tro ly te D rin k s
G E N E T IC A L L Y M O D IF IE D F O O D S /IN G R E D IE N T S
G e n e tic a lly M o d ifie d F o o d
G e n e tic a lly M o d if ie d In g re d ie n t
IR R A D IA T E D F O O D S /IN G R E D IE N T S
Irra d ia te d F o o d s
Irra d ia te d In g re d ie n ts
L A B E L E L E M E N T S A S S E S S E D
P re s e n c e o f N IP
L e g ib ility o f N IP
E X A M P L E O F S E C T IO N S O F L A B E L E L E M E N T A S S E S S E D - S ta n d a rd N IP
G e n e ra l N IP E le m e n ts
N IP B o rd e rs
N IP H e a d in g
S e rv in g In fo rm a tio n
N IP C o lu m n s
N u tr ie n ts
V a lu e s
U n its
O th e r
P re s e n c e
E X A M P L E O F S U B S E C T IO N S O F S E C T IO N S A S S E S S E D - N IP H e a d in g
P o s it io n A lig n m e n t C a s e W o rd in g
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3.6.2 Additional data collection on the use of non-mandatory label elements
Additional data were collected for some label elements, which were not mandated by the
labelling provisions of the new Code (e.g. ‘may contain’ allergen statements) or, not deemed
to be able to be objectively judged from a label only (e.g. usage instructions). Data were also
collected on the ways that information was presented and the reasons for label element sub-
section, label element section and label element inconsistencies. This information was
recorded and categorised to provide useful baseline data for future analysis of usage,
provision or approach taken for these label elements.
The label information examined under this component of the survey was not included in the
consistency assessments for label element sub-sections, label element sections, label elements
and overall label consistency.
Appendix 15 details the assessment protocol used for the survey, which includes a list of the
additional data collected. The rationale behind the assessment approach undertaken, and the
reasons for inclusion are detailed below under each label element.
3.6.3 Tools used for assessment
To aid in the assessment of labels, a Standard Check List was designed to conduct label
assessments (refer to Appendix 8). For products with special NIPs, a special NIP Checklist
was developed for each type. These are detailed in Appendices 9 – 14.
A Microsoft Access database was designed to record all data.
3.6.4 Data security and confidentiality
Data were stored in an Access database and Excel spreadsheets on a secure network, and
were accessed only by employees of Silliker Microtech. Whilst it is possible to access brand
names and product names in the database forms, these names do not transfer to the queries
and subsequently the data itself cannot be linked to these brand or product names and thus, to
any manufacturers.
Labels were stored in numerical order in a secure warehouse. Again these labels were only
accessed by employees of Silliker Microtech.
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3.6.5 Label legibility
In the new Code, mandatory text font size requirements were removed. As a consequence, it
was considered that legibility is a key label element for assessment, especially given the
additional requirements for information in the new Code. Each label element of a label was
assessed separately for legibility against the guidelines in Table 2 below:
Table 2 Legibility assessment classifications
Classification Definition
Prominent Distinct contrast to background
Indelible Printing has not faded, run or rubbed off
Distinct Decorations and embellishments do not interfere with legibility of words on label
Text not printed on complex/pictorial or multicoloured background
Easy to read Text is easy to read e.g. font size not too small to read
Text case is suitable for ease of reading e.g. font style hard to read
Stand Out Words, statements, expressions and designs are easily seen
Placing Information Related information placed in same field of vision
Information Noticeable Important information highlighted by using contrasting colour, border, larger print size, other
distinctive print, use of line spacing, type justification or segmenting of text
English All information required by new Code is in English
Visibility Visible without opening pack, removing stickers or breaking seams
The legibility classifications were based on the FSANZ User Guide to Standard 1.2.9
Legibility Requirements. The visibility classification was not covered in the user guide but
was added to cover the issue of information not being visible to consumers without opening
or damaging the packaging.
Additional data were collected on the reasons why each label element was not legible and
also, on the reasons why labels were inconsistent for legibility overall.
3.6.6 Product Name
The assessment of consistency of the product name label element with the new Code
labelling provisions was based on legibility only.
Additional data were collected on whether or not the product name was an appropriate
description of the food product in question. Baseline data were also collected on the reasons
for concluding that product names or descriptions did not appear to reflect the food’s true
nature. The product name was assessed to determine if removal of compositional
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requirements for a number of products under the new Code had impacted on how well
product names and descriptions reflected the true nature of the food concerned. Whilst the
new Code requires that a product’s name or description is a true reflection of that product, it
was considered difficult to objectively assess this. Field of vision requirements are not
specified in the new Code. For the purposes of this assessment, requirements in the Trade
Measurements Act were used to assess whether information such as the name, description or
weight were in one field of vision.
3.6.7 Date Marking
Date marking was assessed with respect to whether it was provided where required and
whether the date marking statement used matched the requirements of Standard 1.2.5 of the
new Code. Consistency assessment for this label element was therefore conducted on the
basis of provision, legibility and appropriateness of date marking statements used.
Additional data were also collected on the date marking statements chosen, alternative date
marking statements used, and reasons why labels were inconsistent for this label element.
3.6.8 Storage instructions
The new Code requires the mandatory inclusion of storage instructions where required to
ensure food safety and that a food product will keep for the specified period indicated in the
‘use-by’ or ‘best-before’ date. Where a product requires storage instructions after opening to
meet these requirements, the Code does not specify the types of products to which this
applies. For the purposes of this survey, it was assumed that the storage instructions after
opening applied to all products including single serve products.
This label element was assessed to determine the level of understanding of ‘before’ and
‘after’ opening requirements. Consistency for this section was assessed using Standard 1.2.5
Clause 6, Standard 1.2.6 and Standard 2.9.2 Clause 11 of the new Code and was based on
provision and legibility of storage instructions where these instructions were required under
the new Code.
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Additional data were also collected on the voluntary provision of storage instructions. If
storage instructions were voluntarily provided, these were assessed for legibility and included
for the consistency assessment of this label element.
If a product was retailed under frozen, refrigerated or ambient conditions, these were deemed
to be its storage requirements prior to opening. However, the retail storage conditions were
not used for assessment purposes if the retailer had stored the product under conditions other
than:
• those advised on the label; or
• technically accepted storage conditions (e.g. industry codes of practice or industry
standards) for that product type.
3.6.9 Usage instructions
The provision of usage instructions was a new requirement in the new Code under Standard
1.2.6 of the new Code and was therefore assessed to measure the level of adoption by food
manufacturers of this new requirement.
The assessment of consistency of the usage instruction label element with the new Code
labelling provisions was based on legibility only.
Additional data collected related to whether or not usage instructions were provided as the
assessment of the reasons why usage instructions were required was considered to be
subjective.
3.6.10 Allergen labelling
Whilst declaration of allergens on food labels is mandatory, manufacturers have two options
for the declaration:
• ‘food contains allergen’ statements; and/or
• declaration in the ingredients list.
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The ingredients list was assessed as a label element in it own right, therefore, the assessment
of allergen labelling consistency with the new Code labelling provisions was based on
legibility of ‘food contains allergen’ statements only.
A statement indicating the potential presence of allergens not directly added to a food product
may have been present on food labels in the form of a ‘may contain allergen’ statement, as a
result of other food products containing the allergen being manufactured in the same facility.
‘May contain’ allergen statements are optional statements not covered by the new Code.
The reasons for assessing this label element were to determine, in addition to the consistency
assessment:
• how allergens were currently declared; and
• the prominence given to allergen statements (e.g. placement, font size and style).
Additional data were therefore collected on the terminology used to name specific allergens
(i.e. common or lay terminology, as opposed to technical ingredient names, such as milk
protein as opposed to whey protein concentrate). Data were also collected on ‘may contain
allergen’ statements, categorised by the approach and format taken. The kinds of allergens
named, using each of the three methods above of providing information about the presence or
potential presence of allergens, were also assessed for data collection.
In summary, data were collected for the following sections for this label element, for each of
the three statement types:
• statement type used;
• terminology used;
• placement of statement;
• font size; and
• font type.
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The terminology used to declare allergens in the ingredients list was categorised according to
the following:
• common name; or
• ingredient name.
Placement of allergen statements was grouped into the following categories:
• near ingredient list;
• near NIP;
• between ingredient list and NIP; or
• other.
Font size of allergen statements was compared to the ingredient list and categorised as:
• smaller;
• larger; or
• the same.
Font type of allergens declared in ingredients list or allergen statement was categorised as:
• bold; or
• roman (standard).
3.6.11 Mandatory advisory statements
Mandatory advisory statements were targeted for provision of statements and correctness of
statement intent for three product groups:
• kola beverages with caffeine;
• food containing guarana and guarana extract; and
• foods containing phytosterol esters.
These product groups were selected as examples of mandatory advisory statements under
Standard 1.2.3 Clause 2 of the new Code.
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For these three groups the provision, legibility and correct intent of required statements were
assessed for consistency with Standard 1.2.3 Clause 2 of the new Code. Additional data were
collected on the reasons for inconsistency for this label element for each group.
3.6.12 Nutrition information panel
Substantial changes occurred to the required format of the NIP in the new Code. These
changes included mandatory provision of NIPs for most packaged food products and the
inclusion of a statement of saturated fat content within the NIP.
The following is an excerpt from Clause 5 of Standard 1.2.8 Nutrition Information
Requirements providing further details regarding the new requirements.
5 Prescribed declarations in a nutrition information panel
(1) A nutrition information panel must include the following particulars -
(a) the number of servings of the food in the package; and (b) the average quantity of the food in a serving expressed, in the case of a
solid or semi-solid food, in grams or, in the case of a beverage or other liquid food, in millilitres; and
(c) the unit quantity of the food; and (d) the average energy content, expressed in kilojoules or both in kilojoules and
in calories (kilocalories), of a serving of the food and of the unit quantity of the food; and
(e) subject to clause 12, the average quantity, expressed in grams of, protein, fat, saturated fat, carbohydrate and sugars, in a serving of the food and in a unit quantity of the food; and
(f) the average quantity, expressed in milligrams or both milligrams and millimoles, of sodium in a serving of the food and in the unit quantity of the food; and
(g) the name and the average quantity of any other nutrient or biologically active substance in respect of which a nutrition claim is made, expressed in grams, milligrams or micrograms or other units as appropriate, that is in a serving of the food and in the unit quantity of the food;
set out, unless otherwise prescribed in this Code, in the following format –
NUTRITION INFORMATION
Servings per package: (insert number of servings) Serving size: g (or mL or other units as appropriate)
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Quantity per Serving Quantity per 100g (or 100mL)
Energy kJ (Cal) kJ (Cal)
Protein g g
Fat, total - saturated
g g
g g
Carbohydrate sugars
g g
g g
Sodium mg (mmol) mg (mmol)
(insert any other nutrient or biologically active substance to be declared)
g, mg, µg (or other units as appropriate)
g, mg, µg (or other units as appropriate)
(2) A nutrition information panel must clearly indicate that –
(a) the average quantities set out in the panel are average quantities; and (b) any minimum and maximum quantities set out in the panel are minimum
and maximum quantities.
Editorial note: ‘Average quantity’ is determined in accordance with the definition set out in clause 2 of Standard 1.1.1. Average quantities may be indicated, for example, by inserting the word ‘Average’ or an abbreviation for average at the beginning of ‘Quantity per Serving’ and the ‘Quantity per 100 g (or 100 mL)’ columns, or including a note at the end of the panel stating that all specified values are averages. No format is prescribed for the indication of minimum and maximum quantities. They may be indicated, for example, by inserting the bracketed abbreviations ‘(min)’ and ‘(max)’ immediately after the relevant quantities in the Quantity per Serving column and the Quantity per 100 g (or 100 ml) column. Clause 12 explains when minimum and maximum quantities may be indicated.
(3) The word ‘serving’ may be replaced in the nutrition information panel by -
(a) the word ‘slice’, ‘pack’ or ‘package’; or (b) the words ‘metric cup’ or ‘metric tablespoon’ or other appropriate word or
words expressing a unit or common measure.
Because of the detailed nature of NIPs, the consistency of each different section of the NIP
was assessed. The level of severity of inconsistencies was also assessed in terms of their
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impact on consumer understanding. Severity was categorised as one of the following three
levels:
• minor;
• intermediate; or
• major.
The severity rating was based on the assessment criteria detailed in Appendix 16. These
assessment criteria were developed in consultation with FSANZ staff and the Project Team.
These criteria were used for standard NIPs (which contain data on the seven nutrients that
must be included in all NIPs), expanded NIPs (those NIPs where additional nutrients or
biologically active substances are included) and special NIPs (such as those required on
packages of infant formula).
Assessment of the NIP was split into the following label element sections:
• presence;
• legibility;
• general reasons;
• borders;
• panel heading;
• serving information;
• columns;
• nutrients;
• values;
• units; and
• other (anything not coverable under these label element sections and that deems the
NIP format as inconsistent with that prescribed in the new Code).
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The label element sub-sections within the label element section were assessed for
consistency. Consistencies for standard NIPs and the expanded NIP section, were assessed
using Standard 1.2.8 of the new Code.
Expanded NIP sections were assessed separately as three categories:
• expanded due to inclusion of information on types of fat (e.g. omega fatty acids);
• expanded due to inclusion of information on types of carbohydrate (e.g.lactose); and
• expanded due to a label claim about salt or sodium content.
Overall consistency of expanded type NIP sections was based on the consistency assessment
of these three expanded type NIPs. Specific claims about added vitamins and minerals were
not assessed separately.
For products with special NIP requirements, the following standards in the new Code were
used for consistency assessment:
• electrolyte drinks/bases Standard 2.6.2 Clause 7;
• formulated caffeinated beverages Standard 2.6.4 Clause 3 (2);
• infant formula Standard 2.9.1 and the Transitional Standard;
• infant foods Standard 2.9.2 Clause 9;
• formulated meal replacements Standard 2.9.3 Clause 3; and
• formulated supplementary foods Standard 2.9.3 Clauses 5 & 7.
For the overall label assessment, the NIP was assessed as consistent if all the requirements
for a standard or special NIP were met and, where appropriate, if those for the expanded NIP
section were also met. Additional data were collected on the voluntary provision of NIPs on
products exempt from the mandatory provision of NIPs and the nature of the inconsistency
for label element sub-sections, label element sections and for each NIP.
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3.6.13 Percentage daily intake information
Additional data were collected for provision of percentage daily intake information and usage
of the daily intake information column within NIPs. Reference was made to Standard 1.2.8
of the new Code.
Claims about biologically active substances that may have referred to recommended daily
intakes were considered outside the scope of this survey.
3.6.14 Ingredient declaration
The ingredient declaration was assessed against Standard 1.2.4 of the new Code (FSANZ
2002) to determine that it was provided where required.
Consistency for this label element was assessed for provision and legibility of the ingredient
declaration.
3.6.15 Characterising Ingredients
The declaration of percentages of characterising ingredients is a new provision in the new
Code. This label element was assessed to determine whether or not these declarations were
consistent with Standard 1.2.10 of the new Code, whether the appropriate characterising
ingredient was selected for declaration and the extent of declarations given.
Determining what is a characterising ingredient on a food label is subjective. Three sources
of information were considered to determine the presence of a characterising ingredient in a
food product:
• product name;
• product description; and
• ingredients in pictures or graphics.
Consistency with this label element was assessed for these three sources.
Single ingredient products and products where the characterising ingredient was a flavour
were assessed as exempt. Foods with primarily one ingredient and only low-level additives
(e.g. less than one percent), were deemed consistent if the product was declared to contain
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100% of the primary ingredient, or exempt if nothing was declared (e.g. orange juice with
only Vitamin C added). If products had no characterising ingredients, the label was deemed
to be not applicable for this label element (e.g. cheddar cheese).
If the words ‘flavoured’ were used in conjunction with the product name or description then
the label was deemed as exempt (e.g. product name of ‘strawberry flavoured cake bars’).
The assessment of consistency of the characterising ingredients label element with the new
Code labelling provisions, was based on provision of information on the percentage content
of all characterising ingredients present in the food.
Additional data were collected for voluntary provision of ingredient percentages, where no
characterising ingredient was explicitly implied or, where the product was assessed as having
no characterising ingredients (e.g. brown sugar). Data were also collected on the reasons
why labels were inconsistent for the characterising ingredient label element.
3.6.16 Compound ingredients
Compound ingredients are those ingredients that are themselves comprised of two or more
ingredients (e.g. yoghurt in yoghurt coated muesli bars). Compound ingredients were
assessed as Standard 1.2.4 Clause 6 of the new Code introduced labelling requirements
relating to the situations under which the components of these compound ingredients must be
declared.
Declaration of all ingredients or, only food additives and allergens (as applicable based on
level of compound ingredient present), was assessed for consistency under Standard 1.2.4
Clause 6 of the new Code.
Additional data were also collected on the reasons for assessing labels as being inconsistent
for this label element.
3.6.17 Genetically modified foods and ingredients
The labelling provisions for genetically modified (GM) foods and ingredients are
requirements of the new Code. Therefore, statement provision and intent were of interest.
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Consistency assessment, using Standard 1.5.2 of the new Code, was based on provision,
legibility and intent of the statement required for genetically modified foods. For genetically
modified ingredients, the consistency assessment was based on provision and legibility of the
wording ‘genetically modified’, in conjunction with the genetically modified ingredient in the
ingredient declaration.
Additional data were also collected on the usage of ‘genetically modified (GM) free’ claims
and the types of ‘GM free’ statements made.
3.6.18 Irradiated foods and ingredients
The irradiated food and ingredient labelling provisions are new requirements of the new
Code. Therefore, provision of required statements and correctness of intent were of interest.
Consistency assessment was based on statement provision, intent and legibility for irradiated
foods. For irradiated ingredients, the consistency assessment was based on provision of
wording, in conjunction with the irradiated ingredient in the ingredient declaration.
Only those product labels for herbs, spices or herbal infusions, or those foods containing any
of these ingredients, were assessed for this label element as these were the only food types
permitted to be irradiated under Standard 1.5.3 (FSANZ 2002) for the period July 2002 –
December 2003. All other foods were categorised as not applicable.
3.7 Limitations of this survey
As the Code is a living document, with amendments being made on a regular basis, one of the
limitations of a survey of this kind is that the assessment of the consistency of food labels
against labelling provisions can be reported against a given point in time only. In this case,
all labels were assessed against labelling provisions in the Code as at June 2002, up to and
including Amendment 60. At the time of writing this report, some of these provisions have
been further amended, for example; Standard 1.2.3 Mandatory Warning and Advisory
Statements and Declarations.
Two main sources of bias have been identified in this survey:
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• retail packaged food product sampling; and
• measurement of label elements.
The non-random selection of retail packaged food products in this survey was intended to
increase the likelihood of sampling as many brand types and different products as possible
within a given food category or sub-category, as well as including as large a number of
manufacturers as practical. However, this sampling method also introduced the chance of
sample bias, as products were not sampled proportionally to the number of SKUs a
manufacturer had. Therefore, data obtained from this survey may not be a true representation
of foods available in the mainstream market place.
The measurement of label elements in this survey was undertaken by more than one person.
Given the subjectiveness of some aspects of label assessment, this may have resulted in
assessor bias (i.e. inconsistencies may have occurred in the way in which labels were
assessed).
Other limitations encountered in this survey included the sample size. Two and a half percent
is a small proportion of the Australian and New Zealand market place and thus, samples and
results gathered in this survey may not be a true representation of consistency with the new
Code in the wider market place in these countries. The small sample size also meant that it
was difficult for food products to be purchased from all types of retail outlets and ethnic
shops. Lastly, not all labels were produced to the new Code requirements so the number of
samples within food categories which were fully assessed was reduced further.
The methods used to minimise these bias are discussed in section 3.8 Quality assurance.
3.8 Quality assurance
Quality assurance measures were put in place to minimise data collection and recording
errors, and to reduce the chance of bias in this survey.
In order to ensure the reliability of label assessment, all assessors undertook a training
session run by the Project Co-ordinator. In addition to this, the initial assessments made by
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each assessor using the checklists were crosschecked by the project co-ordinator before being
entered into the database.
After assessments were entered into the database, data obtained were checked for any results
that appeared abnormal (e.g. the provision of storage instructions being entered as not
applicable for fresh full cream milk). When abnormal results were present, results were
traced back to the involved food categories and subsequent food product labels for
verification of correct assessment and data entry. If required, appropriate changes were made
to the database.
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