In Response to the Current Food Labelling Review, I Hereby Provide My

In response to the current Food Labelling Review, I hereby provide my opinions as a concerned Australian citizen.

Q2. What is adequate information and to what extent does such information need to be physically present on the label or be provided through other means (eg education or website)?

All food labelling should be truthful, transparent, accurate, honest, informative and not a promotion. We need clear labelling. Using a supermarket "wand" to read a barcode or an "app" on an iphone to find out what is in a product is inadequate. We need to know what is in our food at home. What if a friend with a food allergy comes to visit? What about people with disabilities, the elderly, people for who English is not the first language? If companies want to sell us food they must be able to tell us what is in it. Otherwise it is deceptive.

Q3. How can accurate and consistent labelling be ensured?

If there is no national body to enforce labelling standards, this needs to change.

Q6. Is this a satisfactory spectrum for labelling requirements?

All ingredients derived from GM must be labelled. The report says GM is currently labelled (3.1) in fact oils, sugars, starches from GM crops, milk, eggs, meat from animals fed GM , honey, additives derived from GM, ARE NOT LABELLED. GM is new and needs labelling. Ordinary food should not be forced to be labelled "GM free". In Europe, foods produced from GM crops are labelled, irrespective of whether there is GM DNA or protein in the final product. Labs all over the world including Serbia, Brazil, Hungary and China can quantify GM in food. Australian labs are able to do the same but need certification.

Q13. To what extent should the labelling requirements of the Food Standards Code address additional consumer-related concerns, with no immediate public health and safety impact?

The public are tired of having genuine concerns about GM food ignored. Doctors specialising in environmental medicine say there is a link between GM foods and illness. They state "several animal studies indicate serious health risks associated with GM food consumption". They include: allergy; gastrointestinal, liver and kidney changes; immune dysregulation; dysregulation of insulin and cholesterol response; accelerated ageing and reduced fertility.

Q17. Is there a need to establish agreed definitions of terms such as ‘natural’, ‘lite’, ‘organic’, ‘free range’, ‘virgin’ (as regards olive oil), ‘kosher’ or ‘halal’? If so, should these definitions be included or referenced in the Food Standards Code?

Yes. Package-jargon has long confused and frustrated consumers, moreover it has become a labyrinthine nightmare for any sane person to navigate.

Recently it has been brought to my attention that foods labelled ‘Non-GM’ are permitted to contain elements of GM contaminant. This is blatantly misleading. All foods that do, or may contain any trace of GM ought to be labelled as such, not be covered in terms that confuse and deceive consumers. What would a rational public think if such an ambiguous approach were applied to peanuts? The potential hazards of GM are no less critical.

Consumers have a right to feel confident that labels convey substantiated information, not a riot of meaningless spin and classification loopholes.

Q19 In what ways can information disclosure about the use of these technological developments in food production be improved given the available state of scientific knowledge, manufacturing processes involved and detection levels?

New technologies – GM, nanotech and irradiation need labelling. The report (3.16) implies that labelling of GM, nanotech and irradiation will "inhibit" those technologies. We need to be very suspicious of technologies that need to be hidden from consumers. Everyone has to eat. We have a right to know what is in our food and to be cautious about technologies the food industry wants to sell us.

Q20. Should alcohol products be regulated as a food? If so, should alcohol products have the same labelling requirements as other foods (i.e., nutrition panels and list of ingredients)? If not, how should alcohol products be regulated?

Alcohol products should be regulated as a food.

Q21. Should minimum font sizes be specified for all wording?

Yes! The elderly and visually impaired ought to be given every opportunity, as with every Australian, to know what is in their food. Information that is too small to be read does not assist consumers in making informed decisions.

Q22. Are there ways of objectively testing legibility and readability? To what extent should objective testing be required?

There are ways, objective testing should be a standard requirement for all labelling. Minimum font sizes would assist in this regard.

Q24. In what ways can consumers be best informed to maximise their understanding of the terms and figures used on food labels?

Clear, concise definitions of terms ought to be available at the point of purchase, as well as online. Q27. What is the case for food label information to be provided on foods prepared and consumed in commercial (e.g., restaurants, take away shops) or institutional (schools, pre-schools, worksites) premises? If there is a case, what information would be considered essential?

Fast food restaurants should be obliged to inform consumers via clear, readily visible means whether their product contains GM ingredients or elements. Similarly, all commercial and institutional eateries should be obliged to complete transparency when met with customer inquiries in this regard.

Q29. In what ways can consistency across Australia and New Zealand in the interpretation and administration of food labelling standards be improved?

Serious dialogue with New Zealand would be unendingly beneficial. New Zealand’s stance on GM labeling far surpasses Australia’s on both ethical and moral ground, there is much Australia can learn from this example.

Q30. In what ways can consistency, especially within Australia, in the enforcement of food labelling standards be improved?

National standards. This issue transcends state differences.

Additional Notes.

-- Conflicts of interest with the Food Labelling Review. One of the five members of the review panel, Nick Goddard, is from the Australian Oilseeds Federation. This peak industry body has GM companies as members ie: Monsanto, Bayer Crop Science, Dow Agrosciences. Monsanto is the owner of the GM canola variety grown in Australia. Just over 50% of consumers say they would not buy GM if they could avoid it according to a 2007 Roy Morgan Research. Our food regulator, FSANZ, is expected to protect the health and safety of consumers AND promote an internationally competitive food industry (as stated in Section 10 of this report). Food regulators should ONLY be concerned with public health.

-- Monitoring and enforcement slips through the cracks. There is no national body to enforce labelling standards. FSANZ has conducted only one pilot study into the labelling laws in 2003. 22% of tested samples had GM DNA. None had labels. In contrast a NZ maker of soy sausages was prosecuted for labelling its sausages “non-GM” as they had 0.0088 percent GM present. The company pleaded guilty rather than face a legal bill of $63,000.

-- Threats to Australian food labelling. The Australian government is currently negotiating a free trade agreement with the Asia Pacific region. The public needs assurance that food labelling laws will not be part of the negotiation.