Moves in Australia and New Zealand to agree on the type of front-of-pack nutrition labels have yet to come to a conclusion and demonstrate the divisive nature of the issue. In part three of just-food’s management briefing on nutritional labelling, Ben Cooper outlines the debate Down Under.


One of the persuasive arguments for self-regulation and voluntary industry action over mandated regulation is speed, and the painstaking approach the Australian government has taken on front-of-pack (FOP) nutritional labelling arguably underlines that advantage.

However, the way the government has addressed the issue of front-of-pack labelling over the last year or so has ensured that the principal issues regarding an issue of great importance have once again been debated openly and thoroughly.

Once again, the issue of front-of-pack labels has divided opinion between the food industry on one hand and public health professionals and campaigners on the other, along similar lines as seen in the UK and the US.


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In Australia and New Zealand, the debate over front-of-pack nutritional labelling over the last couple of years has been conducted in the context of a wide-ranging review of food labelling led by former Health Minister Neal Blewett. The Blewett review was published in January 2011, but it was only at the end of November that the Australian government announced its policy intentions around front-of-pack labelling in light of the Blewett recommendations.

The Blewett recommendations on FOP nutritional labelling

Front-of-pack nutritional labelling was one element of the wide-ranging Blewett food labelling review which was published in the form of a report, entitled Labelling Logic, in January last year. 

The report covered a diverse range of food labelling issues. On front-of-pack nutritional labelling it made the following recommendations, crucially including the recommendation of a multiple traffic lights system:-

That an interpretative front-of-pack labelling system be developed that is reflective of a comprehensive Nutrition Policy and agreed public health priorities. 

That a multiple traffic lights front-of-pack labelling system be introduced. Such a system to be voluntary in the first instance, except where general or high-level health claims are made or equivalent endorsements/trade names/marks appear on the label, in which case it should be mandatory.

That government advice and support be provided to producers adopting the multiple traffic lights system and that its introduction be accompanied by comprehensive consumer education to explain and support the system.

That ongoing monitoring and evaluation of the multiple traffic lights system be undertaken to assess industry compliance and the effectiveness of the system in improving the food supply and influencing consumers’ food choices.

That chain food service outlets across Australia and New Zealand be encouraged to display the multiple traffic lights system on menus/menu boards. Such a system be mandatory where general or high-level health claims are made or equivalent endorsements/trade names/marks are used.

That any beverages containing alcohol be exempt from nutrition-related front-of-pack labelling requirements.

The Australian government response

The official government responses to the Blewett recommendations were published at the end of November by the Legislative and Governance Forum on Food Regulation (FoFR), convening as the Australia and New Zealand Food Regulation Ministerial Council. 

The FoFR supported the first Blewett recommendation regarding the development of an interpretative front-of-pack labelling system, and said this should be introduced within a two-year timeframe.

However, it noted that the question of whether the format should be interpretive, as recommended by the review panel, or non-interpretive continues to be an issue on which stakeholder views “are polarised”. 

It also noted the launch in 2008 of a voluntary industry system by the Australian Food and Grocery Council (AFGC), known as the Daily Intake Guide (DIGs), which is non-interpretive, and that this system has been implemented by many major manufacturers and retailers and is generally supported by the food industry.

Stakeholder views are also polarised in relation to the role of government, the FoFR stated, with industry backing voluntary measures, while “many public health and consumer stakeholders believe that government should mandate a multiple traffic lights system without further delay”.

While it noted that there was consensus on some other issues, such as support for some form of front-of-pack labelling, it proposed that, as there had been no government-led discussion in Australia and New Zealand regarding the scope and detail of possible interpretive approaches and given the divergence of views on that question, government should lead “a collaborative process that brings polarised views together to build on existing common ground”.

In that process, the following issues should be considered:-

  • whether front-of-pack labelling should be non-interpretive to allow consumers to apply information as they see fit, or interpretive to help consumers to understand, interpret and apply information
  • minimising the potential for unintended or undesirable consequence
  • interpreting and building on the existing evidence base about the ability of front-of-pack labelling to drive changes in consumer behaviour.

“The key objective will be to move away from the current divisive debate and polarised views by building on the common ground among stakeholders. The collaborative design process will focus on addressing issues of concern, exploring new approaches and exploring possibilities for building on existing schemes,” the FoFR summary stated.

The FoFR proposed that the Food Regulation Standing Committee (FRSC) work with the Australian Health Ministers’ Advisory Council (AHMAC) to manage the collaborative process, utilising consultant technical expertise where necessary. “Mechanisms will be established for stakeholders to provide policy and technical input to the process. The overall aim will be to work through the issues in a way that solves problems and builds consensus,” FoFR continued. Given the history of this debate in Australia and elsewhere, that is a bold aim.

The FoFR requested that Food Regulation Standing Committee provide a substantial progress report on the development of a front-of-pack labelling system in June 2012, with a view to having it developed by December.

“The likely next steps will depend on the level of stakeholder consensus. If major points of difference are or can be resolved, consistent voluntary implementation by industry will be encouraged, supported by consumer education initiatives by government. Alternatively, depending on the level of consensus, either a pilot of the model interpretive system (if one is agreed) or a market-based comparative trial conducted by government, may be the next step.”

The FoFR’s official response to the remaining five recommendations was that government action would have to be “on hold” until the proposed action on the first recommendation had been carried out. Crucially, this means the key recommendation that a multiple traffic lights front-of-pack labelling system be introduced is also ‘on hold’. 

“The implementation and monitoring of any front-of-pack labelling system cannot commence until the type of system is agreed,” the FoFR stated. “The multiple traffic lights system is only one approach to interpretive front-of-pack labels, and all other approaches need to be considered before recommendations 51 to 55 [the remaining five recommendations on front-of-pack labelling] can be considered.”

Stakeholder response

Given that both the Blewett review and FoFR analysis includes an observation about the differing views between the industry and public health on this issue, it was entirely predictable that the FoFR response should itself elicit a mixed response.

The Australian Food and Grocery Council welcomed the government response, including the decision “to reject traffic light labels”, and said the food and grocery manufacturing industry would be “happy to work with the Forum on Food Regulation to look at global evidence on developing a preferred approach to a single, front-of-pack food labelling system”.

The supposition that placing this ‘on hold’ is a de facto rejection of traffic lights may seem to be a rather convenient misreading of the government’s response but in fact campaigners interpreted the response in exactly the same way.

The Obesity Policy Coalition, said “corporate wealth” had won over “consumer health” on the issue. “The Federal Government has bowed to food industry pressure by rejecting traffic light labels in its response to the Labelling Logic review,” Jane Martin, senior policy adviser for the Obesity Policy Coalition, said.

The Dieticians Association of Australia (DAA) said it welcomed the government’s decision to begin work on developing a single front-of-pack system. While the DAA said it supported a single mandatory front-of-pack labelling system, it believes “the best way to do this is still unclear”.

Looking ahead

The fact that such a thorough process as has been seen in Australia and New Zealand – the Blewett review itself received 449 submissions – is yet to produce a definitive outcome not only underlines that the wheels of government do turn slowly, but also speaks to the complexity of the issue and intractability of a debate which appears to polarise industry and campaigners in every market where it is discussed.

The central point of that debate – the question of whether a front-of-pack system labels should be interpretive or simply based around a numeric level or percentage of recommended daily intake – is discussed further in the final section of this briefing.