4. results & discussion · 2018-06-27 · 4. results & discussion the different...

FSANZ FOOD LABEL MONITORING SURVEY – PHASE 1 REPORT

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4. RESULTS & DISCUSSION

The different sub-sections of the ‘Results and Discussion’ section of this report cover the

assessment of each label element. Tables of results are provided with analysis by major food

categories for:

• label elements assessed for consistency against new Code labelling provisions; and

• baseline data on other labelling aspects (where applicable).

Minor food category result tables are detailed in the appendices of this report, where

appropriate.

4.1 Code used

Stage 1

Of the 1,266 labels sampled for Stage 1, 65% (818 labels) were assessed as being produced to

meet the requirements of the old Code. Thirty five percent of labels (448 labels) were fully

assessed (‘assessable’), of which, 27% were new Code and 8% were indeterminable but,

were assumed to have been produced to the new Code requirements. The use of old Code

labels varied between major food categories but, in the majority of cases, the proportion of

new Code labels was less than old Code labels (refer to Table 3 and Appendix 17).


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Table 3 Code used by major food category for Stage 1

Code Used

Indeterminable New Old Number fully

assessed

Major Food Category

Total

Number of

Products

Sampled Number (%) Number (%) Number (%) Number (%)

1. Dairy 116 1 (1) 41 (35) 74 (64) 42 (36)

2. Edible oils and oil emulsions 30 0 (0) 16 (53) 14 (47) 16 (53)

3. Ice cream and edible ices 40 0 (0) 7 (18) 33 (82) 7 (18)

4. Fruit and vegetables 160 30 (19) 35 (22) 95 (59) 65 (41)

5. Confectionery 76 1 (1) 17 (22) 58 (77) 18 (24)

6. Cereal and cereal products 75 1 (1) 14 (19) 60 (80) 15 (20)

7. Bread and bakery products 160 0 (0) 52 (33) 108 (67) 52 (33)

8. Meat and meat products 96 19 (20) 38 (40) 39 (41) 57 (61)

9. Fish and fish products 35 0 (0) 15 (43) 20 (57) 15 (43)

10. Eggs and egg products 8 0 (0) 3 (38) 5 (62) 3 (38)

11. Sugars, honey and related products 23 0 (0) 6 (26) 17 (74) 6 (26)

12. Food intended for particular dietary use 28 4 (14) 10 (36) 14 (50) 14 (50)

13. Non alcoholic beverages 134 38 (28) 20 (15) 76 (57) 58 (43)

14. Mixed foods 285 8 (3) 72 (25) 205 (72) 80 (28)

Overall Results 1266 102 (8) 346 (27) 818 (65) 448 (35)

Stage 2

Comparatively, the percentage of labels assessed as being produced to meet the requirements

of the old Code for Stage 2, was nine percent (109 of 1262 labels). This was substantially

different from Stage 1 however, differences were expected, as the new Code had been fully

implemented prior to the Stage 2 sampling period. Of the 1153 labels considered

‘assessable’, seven percent (85 of 1262 labels) were indeterminable, but assumed to have

been produced to the new Code requirements and, 85% (1068 of 1262 labels) were new Code

(refer to Table 4 and Appendix 18).


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Table 4 Code used by major food category for Stage 2

Code Used

Indeterminable New Old Number fully

assessed

Major Food Category

Total

Number of

Products

Sampled Number (%) Number (%) Number (%) Number (%)

1. Dairy 112 0 (0) 106 (95) 6 (5) 106 (95)

2. Edible oils and oil emulsions 30 0 (0) 29 (97) 1 (3) 29 (97)

3. Ice cream and edible ices 38 0 (0) 34 (89) 4 (11) 34 (89)

4. Fruit and vegetables 166 20 (12) 123 (74) 23 (14) 143 (86)

5. Confectionery 76 1 (1) 68 (90) 7 (9) 69 (91)

6. Cereal and cereal products 76 1 (1) 65 (86) 10 (13) 66 (87)

7. Bread and bakery products 161 0 (0) 143 (89) 18 (11) 143 (89)

8. Meat and meat products 98 17 (17) 78 (80) 3 (3) 95 (97)

9. Fish and fish products 35 0 (0) 31 (89) 4 (11) 31 (89)

10. Eggs and egg products 8 0 (0) 7 (87) 1 (13) 7 (87)

11. Sugars, honey and related products 23 5 (22) 16 (70) 2 (9) 21 (91)

12. Food intended for particular dietary use 27 2 (7) 20 (74) 5 (19) 22 (81)

13. Non alcoholic beverages 130 35 (27) 86 (66) 9 (7) 121 (93)

14. Mixed foods 282 4 (1) 262 (93) 16 (6) 266 (94)

Overall Results 1262 85 (7) 1068 (85) 109 (9) 1153 (91)

4.1.1 Code used based on brand category

Table 5 and Table 6 detail the Code used based on the brand category of the product for

Stage 1 and Stage 2 respectively. The percentage of assessable labels (new Code and

indeterminable labels) for each brand category varied between 33% and 42% in Stage 1 and

43% and 96% in Stage 2. As mentioned above, the percentage of ‘assessable’ labels was

expected to be higher in Stage 2 when compared to Stage 1, as the new Code had been fully

implemented prior to the Stage 2 sampling period. However, this did not apply to those labels

classified as ‘speciality ‘ products, where there was little change since Stage 1.

Stage 1

Table 5 Code used based on brand category for Stage 1

Code Used

Indeterminable New Old

Brand Category

Total Number

of Products

Sampled Number (%) Number (%) Number (%)

Generic 106 10 (9) 35 (33) 61 (58)

National 966 74 (8) 261 (27) 631 (65)

Speciality 44 4 (9) 14 (32) 26 (59)

State Specific 150 14 (9) 36 (24) 100 (67)

Overall Results 1266 102 (8) 346 (27) 818 (65)


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Stage 2

Table 6 Code used based on brand category for Stage 2

Code Used


Brand Category

Total Number

of Products


Generic 194 15 (8) 170 (88) 9 (5)

National 958 58 (6) 826 (86) 74 (8)

Speciality 30 4 (13) 9 (30) 17 (57)

State Specific 80 8 (10) 63 (79) 9 (11)

Overall Results 1262 85 (7) 1068 (85) 109 (9)

4.1.2 Code used based on country of manufacture

Stage 1

Table 7 details the Code used based on imported status, determined by country of origin

information. There was very little difference between local and imported products, with 35%

of both local and imported products being assessed. Three labels were not included in the

total of 1263 labels in this categorisation, as their country of origin was indeterminable. Two

of these labels were new Code, and one was old Code.

Table 7 Code used based on imported status for Stage 1

Code Used


Imported Status

Total Number

of Products


Imported 164 21 (13) 37 (23) 106 (65)

Local 1099 81 (7) 307 (28) 711 (65)

Overall Results 1263 102 (8) 344 (27) 817 (65)

In terms of country of manufacture, the only countries where there were a sufficient number

of products manufactured to enable inter-country comparisons were Australia and New

Zealand (631 and 468 respectively). The total percentage of assessable labels (new and

indeterminable Code labels) was very similar for these countries (36% Australia and 34%

New Zealand).


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Stage 2

For Stage 2, a greater percentage of local products were fully assessed to the requirements of

the new Code (94%, 1025 of 1093 labels) in comparison to imported products (74%, 114 of

153 labels) (refer to Table 8). This was different to Stage 1 where the percentage of

‘assessable’ labels was the same for imported and local products. Country of origin status

was indeterminable for 16 labels in Stage 2. Of these labels, three were indeterminable for

Code used, 11 were assessed as being produced to the requirements of the new Code, and two

to the old Code.

Table 8 Code used based on imported status for Stage 2

Code Used


Imported Status

Total Number

of Products


Imported 153 13 (8) 101 (66) 39 (25)

Local 1093 69 (6) 956 (87) 68 (6)

Overall Results 1246 82 (7) 1057 (85) 107 (9)

As with Stage 1, only Australia and New Zealand had large enough sample sizes to allow

inter-country comparisons. Six hundred and seventy-three labels in Stage 2 were

manufactured in Australia of which 635 were fully ‘assessable’ (94%). Similarly, labels

manufactured in New Zealand were fully assessable in 93% of cases (390 of 420 labels).

4.2 Overall label consistency

Only labels determined ‘assessable’ were fully assessed against the labelling requirements of

the new Code for the label elements of interest, as detailed in the following sections. Of the

448 Stage 1 labels fully assessed, 15% (65 labels) were consistent with all the requirements

of the new Code assessed in this survey (refer to Table 9 for analysis by major food

categories, Appendix 19 by minor food categories). Consistency of labels in Stage 2 was

lower than Stage 1, with 5% of ‘assessable’ labels consistent with the requirements of the

new Code (56 of 1153 labels) (refer to Table 10 for analysis by major food categories,

Appendix 20 by minor food categories).


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The labels that were consistent in both Stages were all labels for products not requiring and,

subsequently not providing a Nutrition Information Panel (NIP), for example meat and meat

products, fruit and vegetables, fish and fish products and non-alcoholic beverages.

Stage 1

Table 9 Consistency status of labels by major food category for Stage 1

Consistency Status

Consistent Inconsistent

Major Food Category

Total Number of

Labels Assessed

Number (%) Number (%)

1. Dairy 42 1 (2) 41 (98)

2. Edible oils and oil emulsions 16 0 (0) 16 (100)

3. Ice cream and edible ices 7 0 (0) 7 (100)

4. Fruit and vegetables 65 27 (42) 38 (58)

5. Confectionery 18 0 (0) 18 (100)

6. Cereal and cereal products 15 0 (0) 15 (100)

7. Bread and bakery products 52 0 (0) 52 (100)

8. Meat and meat products 57 10 (18) 47 (82)

9. Fish and fish products 15 2 (13) 13 (87)

10. Eggs and egg products 3 0 (0) 3 (100)

11. Sugars, honey and related products 6 0 (0) 6 (100)

12. Food intended for particular dietary use 14 0 (0) 14 (100)

13. Non alcoholic beverages 58 25 (43) 33 (57)

14. Mixed foods 80 0 (0) 80 (100)

Overall Results 448 65 (15) 383 (85)


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Stage 2

Table 10 Consistency status of labels by major food category for Stage 2

Consistency Status


Major Food Category

Total Number of

Labels Assessed


1. Dairy 106 0 (0) 106 (100)




5. Confectionery 69 0 (0) 69 (100)









14. Mixed foods 266 3 (1) 263 (99)

Overall Results 1153 56 (5) 1097 (95)

4.2.1 Overall label consistency based on label element

Stage 1

Of the 383 labels which were inconsistent with new Code labelling provisions in Stage 1, the

label element primarily responsible for inconsistency was the NIP (94%, 359 labels).

However, the degree or severity of inconsistency with the NIP varied. For standard NIPs for

example, virtually all the 346 inconsistent labels (99%) had minor inconsistencies when

compared to the prescribed format for the NIP in the new Code; 49% had intermediate

inconsistencies and 64% had major inconsistencies (see Section 4.10 for more details).

A large number of inconsistencies also resulted from:

• the characterising ingredient label element (35%, 135 of 383 labels);

• the date marking label element (28%, 108 of 383 labels);

• the storage instructions label element (9%, 35 of 383 labels); and

• the compound ingredient label element (6%, 21 of 383 labels).


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Mandatory advisory statements and ingredient declarations both represented less than one

percent of label inconsistencies (refer to Table 11).

It should be noted, that in a number of instances, labels were inconsistent for more than one

label element.

No labels were inconsistent for the following label elements:

• product name;

• usage instructions; and

• allergen labelling.

Only one label was assessed for genetically modified foods and ingredients and this label was

consistent. No labels were assessed for products that were irradiated or contained irradiated

ingredients (refer to Table 11).

Table 11 Overall label inconsistencies by label element assessed for Stage 1

Label Element Assessed Number of Labels

Inconsistent

Percentage of Total

Number of Inconsistent

Labels Assessed*

Product Name 0 0

Date Marking 108 28

Storage Instructions 35 9

Usage Instructions 0 0

Allergen Information 0 0

Mandatory Advisory Statements 2 less than 1

Nutrition Information Panel 359 94

Ingredient Declaration 1 less than 1

Characterising Ingredient Declaration 135 35

Compound Ingredient Declaration 21 6

Genetically Modified Foods or Ingredients 0 0

Irradiated Foods or Ingredients 0 0

* Total number of inconsistent labels = 383. Labels may be inconsistent for more than one label element.


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Stage 2

In Stage 2, the reasons labels were assessed as inconsistent with the new Code in regards to

label elements were similar to those in Stage 1. Again, the label element with the highest

percentage occurrence of inconsistent labels was the NIP (98%, 1078 of 1097 labels). As

with Stage 1, the severity of NIP inconsistencies varied. For standard NIPs for example,

virtually all the 1063 inconsistent labels (100%) had minor inconsistencies when compared to

the prescribed format for the NIP in the new Code; 45% had intermediate inconsistencies and

51% had major inconsistencies (see Section 4.10 for more details).

Other common reasons for inconsistency in Stage 2 were:

• the characterising ingredient label element (25%, 277 of 1097 labels);

• the date marking label element (18%, 197 0f 1097 labels); and

• the storage instructions label element (6%, 61 of 1097 labels).

Although at very low percentages, inconsistencies also occurred for the product name, usage

instructions, ingredient declaration and compound ingredient declarations label elements

(refer to Table 12). This was different to Stage 1 where no labels were inconsistent for the

product name and usage instructions label elements.

There were no inconsistencies in Stage 2 as a result of:

• allergen information; and

• mandatory advisory statements.


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Table 12 Overall label inconsistencies by label element assessed for Stage 2


Inconsistent

Percentage of Total

Number of Inconsistent

Labels Assessed*

Product Name 3 Less than 1

Date Marking 197 18


Usage Instructions 1 Less than 1


Mandatory Advisory Statements 1 Less than 1


Ingredient Declaration 13 1

Characterising Ingredient Declaration 277 25

Compound Ingredient Declaration 8 1



* Total number of inconsistent labels = 1097. Labels may be inconsistent for more than one label element.

4.2.2 Overall label consistency based on brand category

Based on brand category, there were some minor differences observed in overall label

consistency (refer to Table 13 and Table 14), with generic products being more consistent

than other types in Stage 1 and specialty products being more consistent in Stage 2. However,

the number of speciality products fully assessed in each Stage was small compared to the

total sample.

Stage 1

Table 13 Consistency status of labels based on brand category for Stage 1

Consistency Status


Major Food Category

Total Number of

Labels Assessed


Generic 45 9 (20) 36 (80)

National 335 46 (14) 289 (86)

Speciality 18 3 (17) 15 (83)

State Specific 50 7 (14) 43 (86)


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Stage 2

Table 14 Consistency status of labels based on brand category for Stage 2

Consistency Status


Major Food Category

Total Number of

Labels Assessed


Generic 185 10 (5) 175 (95)

National 885 38 (4) 847 (96)

Speciality 13 2 (15) 11 (85)

State Specific 70 6 (9) 64 (91)

4.2.3 Overall label consistency based on country of manufacture

There was little difference in the level of label consistency between local and imported

products in Stage 1 (15% and 14% of products respectively were consistent), compared to the

overall label consistency of 15% (refer to Table 9 and Table 15). Comparably, in Stage 2, the

consistency of local and imported labels was four percent and eight percent respectively, with

overall label consistency being 5% (refer to Table 10 and Table 16)

Stage 1

Table 15 Consistency status of labels based on imported status for Stage 1

Consistency Status


Imported Status

Total Number of

Labels Assessed


Imported 58 8 (14) 50 (86)

Local 390 57 (15) 333 (85)

Stage 2

Table 16 Consistency status of labels based on imported status for Stage 2

Consistency Status


Imported Status

Total Number of

Labels Assessed*


Imported 114 9 (8) 105 (92)

Local 1025 44 (4) 981 (96)

* Some labels could not be assessed as imported or local.

4.3 Overall label legibility

In assessing food labels for legibility, each label element was assessed separately. If any one

label element was deemed not legible, the overall label was inconsistent for legibility.


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Stage 1

Of the 448 labels fully assessed in Stage 1, 92% were legible (refer to Table 17 for analysis

by major food categories and Appendix 21 by minor food categories).

Table 17 Consistency status of legibility by major food category for Stage 1

Consistency Status


Major Food Category

Total Number of

Labels Assessed


1. Dairy 42 36 (86) 6 (14)




5. Confectionery 18 18 (100) 0 (0)









14. Mixed foods 80 76 (95) 4 (5)

Overall Results 448 410 (92) 38 (8)

Table 18 outlines the reasons why labels were not legible by label element (38 labels not

legible), with date marking and NIPs being the main label elements that were not legibile.

Details of legibility for each label element section and label element sub-section will be

discussed separately under each label element in the relevant sections of the report.


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Table 18 Overall label illegibility by label element assessed for Stage 1


Not Legible

Percentage of Total

Number of Labels Not

Legible

Product Name 0 0

Date Marking 25 66




Mandatory Advisory Statements 0 0





Stage 2

Ninety-one percent of labels in Stage 2 were consistent for the legibility label element (refer

to Table 19 for analysis by major food categories and Appendix 22 by minor food

categories). Reasons for legibility inconsistencies are detailed in Table 20 and will be

discussed for each label element section and label element sub-section below.


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Table 19 Consistency status of legibility by major food category for Stage 2

Consistency Status


Major Food Category

Total Number of

Labels Assessed


1. Dairy 106 97 (92) 9 (8)




5. Confectionery 69 57 (83) 12 (17)









14. Mixed foods 266 246 (92) 20 (8)

Overall Results 1153 1051 (91) 102 (9)

Table 20 Overall label illegibility by label element assessed for Stage 2


Not Legible*

Percentage of Total

Number of Labels Not

Legible

Product Name 3 3

Date Marking 80 78




Mandatory Advisory Statements 0 0





*Labels could be illegible for more than one label element

4.4 Product name

Stage 1

With respect to the product name label element, all 448 Stage 1 labels were assessed as

legible and therefore, consistent with the labelling requirements of the new Code. Additional

data collected indicated that 95% of labels fully assessed in Stage 1 had product names that

were a true reflection of the nature of the food (refer to Table 21).


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Table 21 Product name and description reflect true nature of product by major

food category for Stage 1

Product Name/Description Reflects True Nature

Yes No

Major Food Category

Total Number of

Labels Assessed


1. Dairy 42 40 (95) 2 (5)




5. Confectionery 18 16 (89) 2 (11)









14. Mixed foods 80 74 (91) 6 (9)


Stage 2

Three labels were assessed as inconsistent for legibility in Stage 2 and consequently, with the

requirements of the new Code for this label element. The reasons these labels were assessed

as inconsistent for legibility are a result of the product name and/or description not being:

• indelible (one of three labels);

• distinct from label decoration (one of three labels); and

• in English (one of three labels).

Ninety four percent of product names and descriptions in Stage 2 were assessed as truly

reflecting the nature of the food (refer to Table 22).


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Table 22 Product name and description reflect true nature of product by major

food category for Stage 2

Product Name/Description Reflects True Nature

Yes No

Major Food Category

Total Number of

Labels Assessed


1. Dairy 106 103 (97) 3 (3)




5. Confectionery 69 64 (93) 5 (7)









14. Mixed foods 266 249 (94) 17 (6)

Overall Results 1153 1082 (94) 71 (6)

Comparison of additional data for product name and description in Stage 1 and Stage 2

For Stage 1, the principal reasons that the name or description did not reflect the true nature

of the product for the 24 inconsistent labels were a result of the product name or description:

• not describing what the food was (38%, nine of 24 labels);

• being in a different field of vision2 (17%, four of 24 labels);

• not indicating that the product was a concentrate or dry mix (13%, three of 24 labels);

or

• being deceptive (46%, 11 of 24 labels).

Labels could be inconsistent for more than one reason.

2 Field of vision requirements are not given in the new Code, but refer to requirements in the Australian Trade

Measurements Act. The name of the food or brand required under Trade Measurement legislation may not

necessarily be the same as that used in order to comply with the new Code. For the purposes of this assessment

it was decided that customers should be presented with primary facts in one field of vision and they should not

have to search packs for information such as the name, description or weight.


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Reasons that the name and/or description did not reflect the true nature of the product were

the same in Stage 2, though the percentage occurrence of these reasons was different between

the Stages.

The reasons that the product name and/or description did not reflect the true nature of the

product in Stage 2 were, the product name and description:

• did not describe what the food was (17%, 12 of 71 labels);

• were in a different field of vision² (15%, 11 of 71 labels);

• was deceptive (65%, 46 of 71 labels); or

• did not indicate that the product was a concentrate or dry mix (six percent, four of 71

labels).


The product name or description on the label of a food product was considered to be

deceptive when the product named or described an ingredient that was not present in the

product (e.g. ‘strawberry fruit bars’ with no indication that the product did not contain

strawberries but was merely strawberry flavoured).

4.5 Date marking

Eighty six percent (387 labels) of the 448 labels fully assessed in Stage 1 were required to

provide date marking whilst, eighty seven percent (1006 labels) of the 1153 labels fully

assessed in Stage 2 were required to provide date marking. Those labels that were exempt

from providing date marking statements were assessed as such for this label element in the

overall label assessment, and therefore were not fully assessed for this label element.

For the minor food categories of fresh milk full fat, fresh milk reduced fat, chilled whole

meat products and chilled comminuted meat products, it was deemed for the purpose of this

survey, that date marking should be given as a ‘use by’ date for health and safety reasons.

Stage 1


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Seventy two percent of the labels fully assessed for this label element in Stage 1, were

consistent with the Code (refer to Table 23). The following major food categories had the

highest proportion of inconsistent labels for this label element:

• edible oils and emulsions (seven of 16 labels);

• ice cream and edible ices (four of 7 labels);

• non alcoholic beverages (16 of 39 labels);

• cereal and cereal products (six of 15 labels);

• bread and bakery products (15 of 52 labels);

• meat and meat products (15 of 56 labels); and

• sugars, honey and related products (two of two labels).

Table 23 Consistency status of date marking by major food category for Stage 1

Consistency with date marking requirement

Consistency Inconsistent

Major Food Category

Total Number of

Labels Assessed


1. Dairy 41 32 (78) 9 (22)




5. Confectionery 18 15 (83) 3 (17)









14. Mixed foods 79 57 (72) 22 (28)

Overall Results 387 279 (72) 108 (28)

Stage 2

The percentage of labels consistent with the Code in Stage 2 was similar to that of Stage 1,

with 80% of labels fully assessed being consistent (refer to Table 24). In Stage 2, the

following major food categories had the highest proportion of inconsistent labels for this

label element:


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• meat and meat products (40 of 90 labels);

• eggs and egg products (five of seven labels); and

• sugars, honey and related products (four of 10 labels).

Table 24 Consistency status of date marking by major food category for Stage 2

Consistency with date marking requirement

Consistency Inconsistent

Major Food Category

Total Number of

Labels Assessed


1. Dairy 104 83 (80) 21 (20)




5. Confectionery 66 54 (82) 12 (18)









14. Mixed foods 217 193 (89) 24 (11)

Overall Results 1006 809 (80) 197 (20)

Of the labels inconsistent for date marking, three reasons for inconsistency were identified,

with some labels being inconsistent for more than one reason:

• date marking not provided on food product labels;

• date marking not legible; and

• incorrect or inappropriate use of date marking statement.

These three categories are discussed in detail below.

4.5.1 Date marking not provided on food product labels

Ninety one percent (352 of 387 labels) of labels required to provide date marking in Stage 1

were consistent in providing these date marking statements (refer to Table 25). This figure was

higher in Stage 2, with 98% (989 of 1006 labels) of labels providing date marking statements

when required (refer to Table 26).

Stage 1


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Table 25 Consistency status for provision of date marking by major food category for

Stage 1

Consistency Status


Major Food Category

Total Number of

Labels Assessed*


1. Dairy 41 40 (98) 1 (2)




5. Confectionery 18 16 (89) 2 (11)









14. Mixed foods 79 65 (82) 14 (18)


*Total number of labels requiring date marking = 387


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Stage 2

Table 26 Consistency status for provision of date marking by major food category for

Stage 2

Consistency Status


Major Food Category

Total Number of

Labels Assessed*


1. Dairy 104 103 (99) 1 (1)




5. Confectionery 66 66 (100) 0 (0)









14. Mixed foods 217 215 (99) 2 (1)

Overall Results 1006 989 (98) 17 (2)

*Total number of labels requiring date marking = 1006

Comparison of date marking statement provision in Stage 1 and Stage 2

When comparing results for Stage 1 and Stage 2, it is noted that for some major categories, the

difference in terms of percentage consistency for date marking provision is reasonably large.

This is particularly true for edible oils and oil emulsions where 69% of labels requiring date

marking statements in Stage 1 were consistent in providing these statements, whilst in Stage 2

93% were consistent. Other major food categories where this difference was considered

reasonably large include:

• ice cream and edible ices (71% in Stage 1 and 91% in Stage 2);

• confectionery (89% in Stage 1 and 100% in Stage 2);

• cereal and cereal products (88% in Stage 1 and 100% in Stage 2);

• fish and fish products (82% in Stage 1 and 100% in Stage 2); and

• mixed foods (82% in Stage 1 and 99% in Stage 2).


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4.5.2 Date marking not legible

Stage 1

Of the 352 labels providing date marking in Stage 1, 93% (327 labels) were assessed as

consistent with legibility provisions.

Although 25 labels were assessed as inconsistent against legibility provisions, it was still

possible to ascertain if the date marking statement was correct or appropriate in all but two of

these labels (see below).

A lack of colour contrast with background affected date marking legibility. In nine of the 25

labels assessed as inconsistent for legibility, date markings were not placed on the label, but

located on the side of the lid or the body of the container. The lids, containers or product (if

container transparent) were often dark coloured or patterned, causing the date marking

printing to be illegible. The fact that the date markings were often printed onto the container

rather than the label, also contributed to date markings lacking indelibility (nine of the 25

inconsistent labels), as the print did not appear to adhere as well to these surfaces. As date

mark information is often printed on food packs at high line speeds it is noted that it is

difficult for the food industry to control legibility in all cases.

In addition, labels were inconsistent for the lack of:

• noticeability (four of the 25 labels);

• visibility (four of 25 labels); and

• prominence (one of 25 labels).

Stage 2

In Stage 2, 92% (909 of 989 labels) of labels providing date marking were consistent with

legibility requirements.

As with Stage 1, it was still possible to assess date marking statements for correctness and

appropriateness in all but seven of the 80 labels inconsistent for legibility.


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The reasons for inconsistency with respect to date marking legibility in Stage 2, were more

numerous than that of Stage 1.

The prime reason for date marking illegibility in Stage 2 was a lack of indelibility, affecting

37 of the 80 inconsistent labels. Other reasons for date marking illegibility were due to date

marking not being:

• visible (12 of 80 labels);

• aligned appropriately (11 of 80 labels);

• in contrast with background (nine of 80 labels);

• a distinct text (five of 80 labels);

• in an easy to read font (three of 80 labels);

• in an easy to read case (two of 80 labels);

• placed appropriately (two of 80 labels);

• prominent (two of 80 labels);

• distinct from decorations (one of 80 labels);

• distinct or ‘standing out’ (one of 80 labels); and

• sized to fit date marking box (one of 80 labels).

It should be noted that in both Stage 1 and 2, some labels were inconsistent for legibility for

more than one reason.

4.5.3 Incorrect or inappropriate use of date marking statement

Stage 1

Table 27 details the consistency of the date marking statement used (i.e. ‘use by’ or ‘best

before’) against the labelling provisions for Stage 1 labels. Of the 352 labels providing date

markings, 84% of labels were consistent, with 15% inconsistent, and two labels (1%)

indeterminable (due to total illegibility of the date marking).


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Table 27 Consistency status of date marking statement used by major food category for

Stage 1

Consistency Status

Consistent Inconsistent Indeterminable

Major Food Category

Total Number

of Labels

Assessed* Number (%) Number (%) Number (%)

1. Dairy 40 34 (85) 6 (15) 0 (0)

2. Edible oils and oil emulsions 11 9 (82) 2 (18) 0 (0)

3. Ice cream and edible ices 5 3 (60) 1 (20) 1 (20)

4. Fruit and vegetables 34 30 (88) 4 (12) 0 (0)

5. Confectionery 16 15 (94) 1 (6) 0 (0)

6. Cereal and cereal products 13 11 (84) 2 (15) 0 (0)

7. Bread and bakery products 50 42 (84) 8 (16) 0 (0)

8. Meat and meat products 54 43 (80) 11 (20) 0 (0)

9. Fish and fish products 9 8 (89) 1 (11) 0 (0)

10. Eggs and egg products 3 3 (100) 0 (0) 0 (0)

11. Sugars, honey and related products 2 0 (0) 2 (100) 0 (0)

12. Food intended for particular dietary use 14 12 (86) 2 (14) 0 (0)

13. Non alcoholic beverages 36 26 (72) 9 (25) 1 (3)

14. Mixed foods 65 60 (92) 5 (8) 0 (0)

Overall Results 352 296 (84) 54 (15) 2 (1)

* Total number of labels providing date marking only

Of the 54 Stage 1 labels assessed as being inconsistent for the date marking statement used,

the three main reasons were:

• the statement used being incorrect or inappropriate (22 of 54 labels) as a result of:

o ‘best before’ provided where a ‘use by’ statement was necessary (seven of 22

labels);

o statement other than ‘best before’ or ‘use by’ given (e.g. ‘best by’, ‘best before

end’, ‘exp’) (15 of 22 labels);

• provision of a date only, with no accompanying statement given (15 of 54 labels); or

• the date itself was not placed with the statement, with no indication given of its

location (12 of 54 labels).

A few inconsistencies also occurred due to incorrect date format (four labels) and use of

multiple statements (four labels) (e.g. ‘use by’ and ‘best before’). The date marking

statement used could be inconsistent for more than one reason.

Stage 2


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For Stage 2, the consistency status of date marking statements used was similar to that of

Stage 1, with 88% (875 of 989 labels) of labels consistent, 11% (107 of 989 labels)

inconsistent, and less than one percent (seven of 989 labels) indeterminable due to illegibility

(refer to Table 28).

Table 28 Consistency status of date marking statement used by major food category for

Stage 2

Consistency Status


Major Food Category

Total Number

of Labels


1. Dairy 103 88 (85) 15 (15) 0 (0)




5. Confectionery 66 62 (94) 4 (6) 0 (0)


7. Bread and bakery products 141 122 (87) 18 (13) 1 (Less than 1)







14. Mixed foods 215 208 (97) 4 (2) 3 (1)

Overall Results 989 875 (88) 107 (11) 7 (Less than 1)

* Total number of labels providing date marking only

The reasons for inconsistency in terms of date marking statement used for the 107

inconsistent Stage 2 labels were:

• the statement used being incorrect or inappropriate (74 of 107 labels) as a result of:

• ‘best before’ provided where a ‘use by’ statement was necessary (40 of 74 labels);

• statement other than ‘best before’ or ‘use by’ given (e.g. ‘best by’, ‘best before

end’, ‘exp’) (34 of 74 labels);

• provision of date only, with no accompanying statement given (14 of 107 labels);

• the use of multiple terms (e.g. ‘best before’ and ‘use by’) (nine of 107 labels);

• the use of incorrect date format (nine of 107 labels); and

• the date itself not placed with statement, with no indication given of its location (five

of 107 labels).


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As with Stage 1, the date marking statement used in Stage 2 could be inconsistent for more

than one reason.

Tables 29 and 30 detail the date marking statement types used in the major food categories

for Stage 1 and 2 respectively.

Table 29 Date marking statement type used by major food category for Stage 1

Date Marking Statement Used

Best Before Use By Other Date but no

Statement

Indeterminable*

Major Food Category

Total

Number of

Labels

Assessed# Number (%) Number (%) Number (%) Number (%) Number (%)

1. Dairy 40 21 (53) 18 (45) 1 (2) 0 (0) 0 (0)

2. Edible oils and oil emulsions 11 9 (82) 0 (0) 2 (18) 0 (0) 0 (0)

3. Ice cream and edible ices 5 3 (60) 0 (0) 0 (0) 1 (20) 1 (20)

4. Fruit and vegetables 34 25 (74) 5 (15) 2 (6) 2 (6) 0 (0)

5. Confectionery 16 15 (94) 0 (0) 0 (0) 1 (6) 0 (0)

6. Cereal and cereal products 13 10 (77) 2 (15) 1 (8) 0 (0) 0 (0)

7. Bread and bakery products 50 38 (76) 9 (18) 2 (4) 1 (2) 0 (0)

8. Meat and meat products 54 14 (26) 36 (67) 1 (2) 3 (5) 0 (0)

9. Fish and fish products 9 4 (45) 4 (44) 0 (0) 1 (11) 0 (0)

10. Eggs and egg products 3 3 (100) 0 (0) 0 (0) 0 (0) 0 (0)

11. Sugars, honey and related

products

2 2 (100) 0 (0) 0 (0) 0 (0) 0 (0)

12. Food intended for particular

dietary use

14 6 (43) 6 (43) 2 (14) 0 (0) 0 (0)

13. Non alcoholic beverages 36 23 (64) 5 (14) 3 (8) 4 (11) 1 (3)

14. Mixed foods 65 40 (62) 22 (33) 1 (2) 2 (3) 0 (0)

Overall Results 352 213 (61) 107 (30) 15 (4) 15 (4) 2 (1)

# Number of products requiring date marking only

* Indeterminable due to date mark not being legible


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Table 30 Date marking statement type used by major food category for Stage 2

Date Marking Statement Used

Best Before Use By Other Date but no

Statement

Indeterminable*

Major Food Category

Total

Number of

Labels

Assessed# Number (%) Number (%) Number (%) Number (%) Number (%)

1. Dairy 103 77 (75) 22 (21) 3 (3) 1 (1) 0 (0)

2. Edible oils and oil emulsions 27 23 (85) 0 (0) 2 (7) 1 (4) 1 (4)

3. Ice cream and edible ices 29 26 (90) 1 (3) 0 (0) 1 (3) 1 (3)

4. Fruit and vegetables 91 74 (81) 8 (9) 7 (8) 2 (2) 0 (0)

5. Confectionery 66 61 (92) 1 (2) 2 (3) 2 (3) 0 (0)

6. Cereal and cereal products 59 52 (88) 3 (5) 3 (5) 1 (2) 0 (0)

7. Bread and bakery products 141 112 (79) 14 (10) 12 (9) 2 (1) 1 (1)

8. Meat and meat products 87 34 (39) 52 (60) 1 (1) 0 (0) 0 (0)

9. Fish and fish products 24 11 (46) 9 (38) 2 (8) 1 (4) 1 (4)

10. Eggs and egg products 7 6 (86) 0 (0) 0 (0) 1 (14) 0 (0)

11. Sugars, honey and related

products

10 7 (70) 1 (10) 1 (10) 1 (10) 0 (0)

12. Food intended for particular

dietary use

22 17 (77) 3 (14) 2 (9) 0 (0) 0 (0)

13. Non alcoholic beverages 108 88 (81) 12 (11) 7 (6) 1 (1) 0 (0)

14. Mixed foods 215 192 (89) 15 (7) 5 (2) 0 (0) 3 (1)

Overall Results 989 780 (79) 141 (14) 47 (5) 14 (1) 7 (1)

# Number of products requiring date marking only

* Indeterminable due to date mark not being legible

Comparison of date marking statements used in Stage 1 and Stage 2

In Stage 1 and Stage 2, meat and meat products was the only major food category to

predominantly use ‘use by’ for date marking statements.

For Stage 1, the use of ‘best before’ and ‘use by’ statements were equally predominant for the

following categories:

• dairy;

• fish and fish products; and

• food intended for particular dietary use.

The percentage usage of date marking statements was different in Stage 2, where the only

major food category where the use of ‘best before’ and ‘use by’ were equally prominent was

fish and fish products.


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In both Stages, the majority of products in the other major food categories used ‘best before’

for date marking statements.

Overall for Stage 1, 61% of labels providing date marking statements used ‘best before’

statements, 30% used ‘use by’ statements, four percent each used other statements and

4%just provided a date without a qualifying statement. The remaining one percent were

indeterminable as labels were not legible.

In 13 of the 15 cases where other date marking statements were used on food product labels,

the other statements were variations on ‘Best Before’ and included:

• ‘Best Before End’ (eight of the 15 labels);

• ‘B/B’ (one of 15 labels);

• ‘BB’ (two of 15 labels); and

• ‘Best By’ (two of 15 labels).

Additional statements used were ‘exp’ or ‘Exp’ (one of 15) and one label used multiple

terms.

For Stage 2, labels providing date marking statements used ‘best before’ in 79% of cases, and

‘use by’ in 14% of cases. Other date marking statements were used for five percent of the

989 labels providing date marking statements, whilst one percent of labels provided a date

with no qualifying statement.

The majority of other date marking statements used in Stage 2, were also variations on ‘best

before’ and included:

• ‘Best Before End’ (six of 47 labels);

• ‘BB’ (five of 47 labels);

• ‘BBE’ (three of 47 labels);

• ‘B.Before’ (one of 47 labels);

• ‘B/B’ (two of 47 labels);

• ‘B/Before’ (one of 47 labels);

• ‘Baked’ (one of 47 labels);

• ‘Best’ (one of 47 labels);


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• ‘Best Bef’ (one of 47 labels);

• ‘Best Before By’ (one of 47 labels);

• ‘Best Before Frozen’ (one of 47 labels);

• ‘BKD’ (one of 47 labels);

• ‘Baked Before’ (four of 47 labels); and

• ‘Baked on’ (two of 47 labels).

There were however, some variations on the term ‘use by’ in Stage 2, and these included:

• ‘UBD’ (one of 47 labels); and

• ‘Use By Date’ (one of 47 labels).

The remaining ‘other’ statements used were:

• ‘EXP’ (four of 47 labels);

• ‘EX Date’ (one of 47 labels);

• ‘Expiration date’ (one of 47 labels); and

• ‘Expiry’ (one of 47 labels).

Additionally, eight labels in Stage 2 used multiple terms.

4.6 Storage instructions

Stage 1

Where a product requires storage instructions after opening, the Code does not specify the

type of products to which this applies. In theory, single serve products should not require

storage instructions. However, for the purposes of this survey, where it was considered likely

that such products could be stored in the refrigerator after opening, labels were assessed as

inconsistent if such storage instructions were not given.

Fifty four percent (243 of 448 labels) of Stage 1 labels required storage instructions. Of the

205 labels not requiring storage instructions, 32% (65 labels) voluntarily provided these

instructions. Therefore, a total of 308 labels were included for consistency assessment in

this label element for Stage 1.


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Of the 308 labels requiring or voluntarily providing storage instructions in Stage 1, 89% (273

labels) were consistent with the new Code requirements (refer to Table 31). The proportion

of labels that were inconsistent with Code requirements was higher in the following major

food categories:

• fish and fish products (eight of 15 labels);

• ice cream and edible ices (two of seven labels);

• mixed foods (13 of 61 labels); and

• fruits and vegetables (seven of 32 labels).

Table 31 Consistency status of storage instructions by major food category for

Stage 1

Consistency Status


Major Food Category

Total Number of

Labels Assessed*


1. Dairy 41 40 (98) 1 (2)




5. Confectionery 4 4 (100) 0 (0)









14. Mixed foods 61 48 (79) 13 (21)

Overall Results 308 273 (89) 35 (11)

* Includes all storage instructions, whether required or provided voluntarily

For this label element:

• ninety-nine percent of labels required to provide storage instructions before opening

were consistent in providing these instructions;

• thirty-nine percent of labels for single serve products deemed (for the purposes of this

survey) to require the provision of storage instructions after opening provided these

storage instructions; and


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• sixty-four percent of labels for multiple serve products required to provide storage

instructions after opening provided these instructions.

The reasons storage instructions were considered to be inconsistent were;

• storage instructions were not legible as the instructions were not visible (three of the

35 inconsistent labels);

• storage instructions required before opening were not provided (four of 35 labels);

• storage instructions deemed to be required after opening for single serve products (for

the purposes of this survey) were not provided (11 of 35 labels); and

• storage instructions required after opening for multiple serve products were not

provided (17 of 35 labels).

Of the four labels failing to provide storage instructions required before opening, one was a

frozen ice cream, one a frozen ice-confection, one a chilled comminuted meat and one a

frozen dessert.

Eleven single serve product labels deemed (for the purposes of this survey) to require the

provision of storage instructions after opening in order to maintain food safety and ensure the

product would keep for the specified ‘use by’ or ‘best before’ period, were inconsistent in

providing these instructions. For this label element sub-section there was one each for a

canned vegetable, dessert, and pre-prepared meal, three were canned soups and five were

canned fish products.

Seventeen labels for multiple serve products were assessed as inconsistent for not providing

storage instructions. These 17 labels included one each of pickled vegetable, infant food and

snack food, two canned fruits, three each of canned vegetables and canned fish, and six

sauces.

Stage 2

Of the 1153 labels fully assessed in Stage 2, 41% (474 labels) required storage instructions.

In addition, 355 labels voluntarily provided storage instructions and were included for

consistency assessments. Therefore, a total of 829 labels were assessed for consistency of


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storage instructions in Stage 2. Ninety three percent of these labels were assessed as

consistent with the requirements of the new Code (refer to Table 32).

Table 32 Consistency status of storage instructions by major food category for

Stage 2

Consistency Status


Major Food Category

Total Number of

Labels Assessed*


1. Dairy 105 103 (98) 2 (2)




5. Confectionery 10 10 (100) 0 (0)









14. Mixed foods 187 165 (88) 22 (12)


* Includes all storage instructions, whether required or provided voluntarily

For this label element;

• ninety-eight percent (363 of 370 labels) required to provide storage instructions

before opening were consistent in providing these instructions;

• thirty-nine percent of labels for single serve products deemed (for the purposes of this

survey) to require the provision of storage instructions after opening provided these

storage instructions; and

• fifty-two percent of labels for multiple serve products required to provide storage

instructions after opening provided these instructions.

The reasons storage instructions were assessed as inconsistent for Stage 2 were:

• storage instructions required before opening were not provided (seven of 61 labels);

• storage instructions deemed to be required after opening for single serve products (for

the purposes of this survey) were not provided (11 of 61 labels);


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• storage instructions required after opening for multiple serve products were not

provided (41 of 61 labels); and

• storage instructions were not legible (two of 61 labels) as a result of:

• storage instructions not being distinct from label decoration (one of two labels);

and

• storage instructions not being visible (one of two labels).

Of the labels inconsistent in providing storage instructions required before opening, there was

one each of a fresh yoghurt, chilled comminuted meat, butter, frozen ice cream, and chilled

dessert and two chilled whole meat products.

Single serve products assessed as inconsistent in providing storage instructions deemed to be

required after opening included one canned fruit, one canned pre-prepared meal, one dessert,

three preserved fish, and five canned soups.

Of the multiple serve products assessed as inconsistent in providing storage instructions after

opening, one was a pickled vegetable, one a pickled fruit, one a dessert, three canned meats,

five canned soups, seven canned fruits, seven preserved fish products, eight canned pre-

prepared meals, and eight canned vegetables.

Comparison of storage instruction consistency in Stage 1 and Stage 2

There was very little difference in the overall percentage consistency of storage instructions

between the two Stages (89% for Stage 1 and 93% in Stage 2). There was however some

differences in percentage consistency by major food category, the greatest being for ice

cream and edible ices, with 71% being assessed as consistent in Stage 1 and 97% assessed as

consistent in Stage 2. Other major food categories where there was a substantial increase in

percentage consistency were:

• fish and fish products (47% in Stage 1 and 68% in Stage 2); and

• mixed foods (79% in Stage 1 and 88% in Stage 2).

Three major food categories also had a reduction in percentage consistency from Stage 1 to

Stage 2, however these differences were not as great as those mentioned above.


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4.7 Usage instructions

In Stage 1, 33% (146 of 448 labels) of labels provided usage instructions (refer to Table 33).

All usage instructions provided were legible, thus the consistency for this label element was

100%. In Stage 2, fewer labels provided usage instructions (21%, 243 of 1153 labels) (refer

to Table 34). Furthermore, one label in Stage 2 was assessed as inconsistent as the usage

instructions were not legible due to them not being noticeable.

Table 33 Usage instructions provision by major food category for Stage 1

Provision of Usage Instructions

Provided Not Provided

Major Food Category

Total Number of

Labels Assessed


1. Dairy 42 4 (10) 38 (90)




5. Confectionery 18 1 (6) 17 (94)









14. Mixed foods 80 52 (65) 28 (35)

Overall Results 448 146 (33) 302 (67)


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Table 34 Usage instructions provision by major food category for Stage 2

Provision of Usage Instructions


Major Food Category

Total Number of

Labels Assessed


1. Dairy 106 14 (13) 92 (87)




5. Confectionery 69 4 (6) 65 (94)









14. Mixed foods 266 107 (40) 159 (60)

Overall Results 1153 243 (21) 910 (79)

4.8 Allergen information

All ‘food contains allergen’ statements provided in both Stages were legible and thus, the

allergen information label element had 100% consistency.

4.8.1 ‘Food contains allergen’ statement

Stage 1

Seven percent (30 labels) of the 448 labels fully assessed in Stage 1 provided ‘food contains

allergen’ statements. These labels were split across several different food categories:

• bread and bakery products (16 of 52 labels); and

• sugar, honey and related products (three of six labels) (refer to Table 35).


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Table 35 Usage of ‘food contains allergen’ statement by major food category for Stage 1

‘Food contains allergen’ Statement Used

Yes No

Major Food Category

Total Number of

Labels Assessed


1. Dairy 42 1 (2) 41 (98)




5. Confectionery 18 2 (11) 16 (89)









14. Mixed foods 80 5 (6) 75 (94)

Overall Results 448 30 (7) 418 93

Stage 2

The proportion of ‘food contains allergen’ statements was doubled in Stage 2, with 14% (163

of 1153 labels) of labels providing ‘food contains allergen’ statements. As with Stage 1,

these labels were split across the different major food categories with the highest usage

relative to category size being for:

• cereal and cereal products (22 of 66 labels);

• bread and bakery products (39 of 143 labels); and

• mixed foods (70 of 266 labels) (refer to Table 36).


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Table 36 Usage of ‘food contains allergen’ statement by major food category for Stage 2

‘Food contains allergen’ Statement Used

Yes No

Major Food Category

Total Number of

Labels Assessed


1. Dairy 106 1 (1) 105 (99)




5. Confectionery 69 7 (10) 62 (90)









14. Mixed foods 266 70 (26) 196 (74)

Overall Results 1153 163 (14) 990 (86)

4.8.1.1 ‘Food contains allergen’ statement attributes

‘Food contains allergen’ statements were predominantly placed near the ingredient list in

both Stage 1 and Stage 2 (26 of 30 labels and 144 of 163 labels, respectively). Statements

were also provided between the ingredient list and NIP, near the NIP and in other positions

(refer to Tables 37 and 38).


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Stage 1

Table 37 Attributes of ‘food contains allergen’ statements for Stage 1

Attributes Assessed Number of Labels

Percentage of all Labels

with ‘food contains

allergen’ statements

Placement of Statement

Between ingredient list & NIP 3 10

Near Ingredient list 26 87

Other position 1 3

* Total sample number = 30

Font Style

Roman (standard) 11 37

Bold 19 63


Size Compared to Ingredient List

Larger 4 13

Same 25 83

Smaller 1 3



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Stage 2

Table 38 Attributes of ‘food contains allergen’ statements for Stage 2

Attributes Assessed Number of Labels

Percentage of all Labels

with ‘food contains

allergen’ statements




Other position 13 8

Near NIP 2 1


Font Style

Roman (standard) 92 56

Bold 71 44



Larger 25 15

Same 135 83

Smaller 3 2


Comparison of ‘food contains allergen’ statement attributes in Stage 1 and Stage 2

In Stage 1 ‘food contains allergen’ statements were mostly placed in a bold font (19 of 30

labels), giving these statements good prominence on the label (refer to Table 37).

Conversely, ‘food contains allergen’ statements in Stage 2 were primarily given in standard

font (92 of 163 labels) (refer to Table 38).

For both Stage 1 and Stage 2, the font size of ‘food contains allergen’ statements compared to

the font size of the ingredient list, was the same in 83% of labels (refer to Table 37 and 38).


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4.8.1.2 Allergens declared in ‘food contains allergen’ statements

Comparison of types of allergens declared in ‘food contains allergen’ statements in

Stage 1 and Stage 2

The type of allergens declared in ‘food contains allergen’ statements in Stage 1 and Stage 2

were primarily gluten-containing cereals, milk and soybean. In Stage 1, a small number of

declarations of egg, fish or peanut allergens were also made, with no statements declaring

crustacea, nut, sesame, sulphite, royal jelly, bee pollen or propolis allergens (refer to Table

39). In comparison, all allergens other than bee pollen and propolis were declared in Stage 2

in ‘food contains allergen’ statements (refer to Table 40).

Statements could be for more than one allergen type.

Table 39 Types of allergens declared for ‘food contains allergen’ statements for Stage 1

Type of Allergen Declared Number of Labels Percentage of total

number of labels with

‘Food contains allergen’

statements*

Gluten Cereal 22 73

Crustacea 0 0

Egg 3 10

Fish 1 3

Milk 12 40

Nut 0 0

Sesame 0 0

Peanut 1 3

Soybean 18 60

Sulphite 0 0

Royal Jelly 0 0

Bee Pollen 0 0

Propolis 0 0

* Total sample number = 30. Some labels declared more than one allergen.


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Table 40 Types of allergens declared for ‘food contains allergen’ statements for Stage 2

Type of Allergen Declared Number of Labels Percentage of total

number of labels with

‘Food contains allergen’

statements*

Gluten Cereal 113 69

Crustacea 1 1

Egg 11 7

Fish 2 1

Milk 68 42

Nut 5 3

Sesame 5 3

Peanut 6 4

Soybean 87 54

Sulphite 17 10

Royal Jelly 2 1

Bee Pollen 0 0

Propolis 0 0

* Total sample number = 163. Some labels declared more than one allergen.

4.8.2 Declaration of allergens in the ingredient list

Fifty seven percent (255 of 448 labels) of labels in Stage 1, and 63% (723 of 1153 labels) of

labels in Stage 2, declared allergens in the ingredient list (refer to Tables 41 and 42).


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Stage 1

Table 41 Usage of declaration of allergens in ingredient list by major food category for

Stage 1

Allergens Declared in Ingredient List

Yes No

Major Food Category

Total Number of

Labels Assessed


1. Dairy 42 39 (93) 3 (7)




5. Confectionery 18 14 (78) 4 (22)









14. Mixed foods 80 59 (74) 21 (26)

Overall Results 448 255 (57) 193 (43)


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Stage 2

Table 42 Usage of declaration of allergens in ingredient list by major food category for

Stage 2

Allergens Declared in Ingredient List

Yes No

Major Food Category

Total Number of

Labels Assessed


1. Dairy 106 99 (93) 7 (7)




5. Confectionery 69 57 (83) 12 (17)









14. Mixed foods 266 197 (74) 69 (26)

Overall Results 1153 723 (63) 430 (37)

4.8.2.1 Attributes of allergens declared in ingredient list

Stage 1

Of the 255 labels declaring allergens in the ingredient list in Stage 1, 59% declared allergens

using common names, 36% used the ingredient’s technical name and 5% used a combination

of both styles of terminology.

Allergens were generally not bolded for emphasis when declared in the ingredient list (93%

or 237 labels not bolded) (refer to Table 43).


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Table 43 Attributes of allergens declared in ingredient list for Stage 1

Attribute Assessed Number of Labels Percentage of all labels

with allergens declared in

ingredient list*

Type of Terminology Used

Common Name (e.g. ‘milk’) 151 59

Ingredient Name (e.g. ‘casein’) 92 36

Mixture of Both 12 5

* Total number of labels assessed = 255

Font Style

Normal 237 93

Bold 18 7


Stage 2

The use of common names to declare the presence of allergens in ingredient lists in Stage 2

was appreciably higher than in Stage 1 (59% of labels in Stage 1 and 82% of labels in Stage

2). Three percent of labels declared allergens using an ingredient name. Again, this figure

was somewhat different to that for Stage 1 (36%). A mixture of both common name and

ingredient name terminology was used in 107 of the 723 labels declaring allergens in the

ingredient list.

As with Stage 1, the majority of allergens declared in the ingredient lists in Stage 2 were not

bolded for emphasis (661 of 723 labels).


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Table 44 Attributes of allergens declared in ingredient list for Stage 2

Attribute Assessed Number of Labels Percentage of all labels

with allergens declared in

ingredient list*

Type of Terminology Used

Common Name (e.g. ‘milk’) 593 82

Ingredient Name (e.g. ‘casein’) 23 3

Mixture of Both 107 15


Font Style

Normal 661 91

Bold 62 9


4.8.2.2 Allergens declared in ingredient lists

Stage 1

Allergens declared in the ingredient list in Stage 1 were predominantly gluten-containing

cereals (49%, 126 of 255 labels), milk (55%, 140 of 255 labels) and soybean (33%, 84 of 255

labels). Egg allergens were the next most commonly declared at 14% (35 of 255 labels) with

some declarations of fish, nut, sesame, peanut, sulphites and crustacea (refer to Table 45).

No declarations were made in the ingredient list of the presence of royal jelly, bee pollen or

propolis allergens.


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Table 45 Types of allergens declared in the ingredient list for Stage 1

Type of Allergen Declared Number of Labels Percentage of all labels

declaring allergens in the

ingredient list*


Crustacea 2 1

Egg 35 14

Fish 15 6

Milk 140 55

Nut 18 7

Sesame 9 4

Peanut 8 3

Soybean 84 33

Sulphite 3 1

Royal Jelly 0 0

Bee Pollen 0 0

Propolis 0 0

* Total sample number = 255. Labels may declare more than one allergen

Stage 2

The percentage declarations of each individual type of allergen in ingredient lists in Stage 2,

was similar to that of Stage 1 (refer to Table 45 and 46), with gluten containing cereals (55%,

398 of 723 labels), milk (59%, 427 of 723 labels) and soybean (41%, 296 of 723 labels) again

being the most commonly declared allergens. Unlike Stage 1, one declaration of royal jelly

was made in Stage 2.


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Table 46 Types of allergens declared in the ingredient list for Stage 2

Type of Allergen Declared Number of Labels Percentage of all labels

declaring allergens in the

ingredient list*


Crustacea 5 Less than 1

Egg 84 12

Fish 32 4

Milk 427 59

Nut 36 5

Sesame 19 3

Peanut 21 3

Soybean 296 41

Sulphite 24 3

Royal Jelly 1 Less than 1

Bee Pollen 0 0

Propolis 0 0

* Total sample number = 723. Labels may declare more than one allergen.

4.8.3 ‘May contain allergen’ statements

Stage 1

Of the 448 Stage 1 labels fully assessed, 12% (54 labels) used ‘may contain allergen’

statements. These labels were from a number of product categories (refer to Table 47), with

the highest usage levels, relative to category size, being for:

• ice creams and edible ices (29%, two of seven labels);

• confectionery (39%, seven of 18 labels);

• cereal and cereal products (47%, seven of 15 labels);

• bread and bakery products (25%, 13 of 52 labels); and

• mixed foods (21%, 17 of 80 labels) (refer to Table 47).


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Table 47 Usage of ‘may contain allergen’ statements by major food category for Stage 1

Used May Contain Allergen Statements

Yes No

Major Food Category

Total Number of

Products Assessed


1. Dairy 42 1 (2) 41 (98)




5. Confectionery 18 7 (39) 11 (61)









14. Mixed foods 80 17 (21) 63 (79)

Overall Results 448 54 (12) 394 (88)

Stage 2

The percentage usage of ‘may contain allergen’ statements in Stage 2 was higher than that of

Stage 1 with 20% of labels using these statements.


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Table 48 Usage of ‘may contain allergen’ statements by major food category for Stage 2

Used May Contain Allergen Statements

Yes No

Major Food Category

Total Number of

Products Assessed


1. Dairy 106 5 (5) 101 (95)




5. Confectionery 69 36 (52) 33 (48)









14. Mixed foods 266 55 (21) 211 (79)

Overall Results 1153 229 (20) 924 (80)

The use of ‘may contain allergen’ statements was more predominant when compared to other

categories in the following major food categories:

• ice cream and edible ices (44%, 15 of 34 labels);

• confectionery (52%, 36 of 69 labels);

• cereal and cereal products (39%, 26 of 66 labels);

• bread and bakery products (45%, 65 of 143 labels); and

• mixed foods (21%, 55 of 266 labels).

Comparison of ‘may contain allergen’ statement usage in Stage 1 and Stage 2

Interestingly, the categories that were more likely to use ‘may contain allergen’ statements

were the same in both Stage 1 and Stage 2, although all categories had a higher percentage

usage in Stage 2.


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4.8.3.1 ‘May contain allergen’ statement attributes

Stage 1

Those 54 labels in Stage 1 using ‘may contain allergen’ statements, placed these statements:

• near the ingredient list (45 of 54 labels);

• near the NIP (four of 54 labels); and

• between the ingredient list and NIP (four of 54 labels).

Additionally, the statement on one label was placed elsewhere (refer to Table 49).

Table 49 Attributes of ‘may contain allergen’ statements for Stage 1

Attributes Assessed Number of Labels*

Percentage of all labels

with ‘may contain

allergen’ statements*




Near NIP 4 7

Other 1 2


Font Style

Normal 33 61

Bold 21 39



Larger 22 41

Same 29 54

Smaller 3 6


Twenty-one (39%) of Stage 1 ‘may contain allergen’ statements were printed in bold

typeface for emphasis (refer to Table 49). The font size used for these statements was the

same size as the ingredient list for 29 of the labels, with a similar number of labels displaying

a larger font size (22 labels or 41%). Three labels providing this statement used a smaller

font size than the ingredient list.

FSANZ FOOD LABEL MONITORING SURVEY – STAGE 1 REPORT

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Stage 2

As with Stage 1, the majority of ‘may contain allergen’ statements were placed near the

ingredient list (204 of 229 labels) with a small proportion of labels placing ‘may contain

allergen’ statements between the ingredient list and NIP (8 of 229 labels) and near the NIP (7

of 229 labels). An additional 10 labels placed these statements in another position on the

label (refer to Table 50).

Table 50 Attributes of ‘may contain allergen’ statements for Stage 2

Attributes Assessed Number of Labels*

Percentage of all labels

with ‘may contain

allergen’ statements*




Near NIP 7 3

Other 10 4


Font Style

Normal 163 71

Bold 63 28

Indeterminable 3 1



Larger 37 16

Same 169 74

Smaller 23 10


Three labels were assessed as indeterminable for font style used in Stage 2 as these labels

contained multiple ‘may contain allergen’ statements, of which, on an individual label, one or

more of the statements was bolded and one or more was in normal font. The bolding of ‘may

contain allergen’ statements for emphasis occurred less in Stage 2 with only 28% of labels

bolding these statements. Additionally, more labels gave ‘may contain allergen’ statements

in the same size font as the ingredient list in Stage 2 (74%, 169 of 229 labels) when compared

to Stage 1.


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4.8.3.2 Allergens declared in ‘may contain allergen statements’

The allergen types mentioned in ‘may contain allergen’ statements were:

• nut (63% in Stage 1, 72% in Stage 2);

• peanut (41% in Stage 1, 46% in Stage 2);

• sesame (17% in Stage 1, 28% in Stage 2);

• milk (15% in Stage 1, 14% in Stage 2);

• gluten-containing cereals (6% in Stage 1, 10% in Stage 2);

• crustacea (4% in Stage 1, 8% in Stage 2);

• egg (6% in Stage 1, 21% in Stage 2);

• fish (7% in Stage 1, 6% in Stage 2);

• soybean (7% in Stage 1, 10% in Stage 2);

• sulphite (6% in Stage 1, 7% in Stage 2);

• bee pollen (0% in Stage 1, less than 1% in Stage 2); and

• propolis (0% in Stage 1, less than 1% in Stage 2).

Labels could declare more than one allergen.

4.8.3.3 Format of ‘may contain allergen’ statements

Stage 1

In the majority of cases, ‘may contain allergen’ statements provided took the format of ‘May

contain traces of ‘X’ (39 of 54 labels). Another ten labels used variations of this theme:

• ‘May contain X traces’ (four of 54 labels);

• ‘This product may contain traces of X’ (four of 54 labels);

• ‘Warning. This product may contain X traces’ (one of 54 labels); and

• ‘May contain X’ (one of 54 labels)

where ‘X’ is the allergen group.

Five different statements were used in some instances, as follows:

• ‘Produced in a factory handling X’ (one of 54 labels);

• ‘Manufactured on equipment that also produces products containing X’ (two of 54

labels);


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• ‘Packed on equipment that also packs products containing X’ (one of 54 labels);

• ‘X is used in the facility where this product is made’ (one of 54 labels); and

• ‘Product containing X manufactured in the factory’ (one of 54 labels)


Stage 2

Similar to Stage 1, ‘may contain allergen’ statements in Stage 2 primarily took the format of

‘May contain traces of ‘X’ (125 of 229 labels). Variations of this statement type included:

• ‘May contain X traces’ (14 of 229 labels);

• ‘This product may contain traces of X’ (five of 229 labels);

• ‘This product may contain X’ (five of 229 labels);

• ‘May contain X’ (14 of 229 labels);

• ‘We take great care in the preparation of this product however due to the nature of

processing trace amounts of X may remain’ (one of 229 labels); and

• ‘Trace amounts of X may be present in some packs’ (one of 229 labels)


There was a greater variation of other ‘may contain allergen’ statements used in Stage 2

when compared to Stage 1. These included variations of statements referring to the facility

or factory in which the product was manufactured and the equipment or line that the product

was manufactured on. Statements referring to the facility or factory included:

• ‘Produced in a factory handling X’ (nine of 229 labels);

• ‘Produced in a facility handling X’ (one of 229 labels);

• ‘Manufactured/made in a facility where X is also produced and therefore may contain

traces’ (five of 229);

• ‘Manufactured in a facility which also processes X’ (one of 229 labels);

• ‘This product is manufactured in a modern factory that also uses X’ (one of 229

labels);

• ‘Made in a plant that also processes products containing X’ (two of 229 labels);


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• ‘X also handled on this site’ (one of 229 labels); and

• ‘X are manufactured in the factory’ (one of 229 labels)


Statements that referred to the equipment or line that the product was manufactured on were:

• ‘Manufactured/made on equipment that also processes/manufactures products

containing X’ (25 of 229 labels);

• ‘Manufactured/made on machinery that also processes/manufactures products

containing X’ (three of 229 labels);

• ‘Made on a production line that also produces products containing X’ (one of 229

labels);

• ‘Produced on a line which also uses ingredients containing X’ (one of 229 labels);

• ‘X are also processed on this equipment’ (one of 229 labels);

• ‘Made on a production line that also processes products containing X’ (seven of 229

labels);

• ‘Made on equipment that handles X and therefore may contain traces of them’ (one of

229 labels); and

• ‘Manufactured on equipment that also handles other products and may contain traces

of X’ (one of 229 labels)


Three labels in Stage 2 used multiple ‘may contain allergen’ statements. These statements

included:

• ‘May contain X’ and ‘This product may contain X’;

• ‘Y may contain traces of X’ and ‘This product is manufactured on equipment that also

handles other products therefore may contain traces of X’; and

• ‘May contain traces of X’ and ‘Y may contain X to maintain natural flavour and

colour’


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where ‘X’ is the allergen group and ‘Y’ is a specific ingredient/s.

4.9 Mandatory advisory statements

Four labels required mandatory advisory statements in Stage 1, whilst seven labels required

mandatory advisory statements in Stage 2. All of these labels were consistent for legibility.

Results for the other label elements assessed are detailed below.

4.9.1 Caffeine mandatory advisory statement

For Stage 1, two kola beverages requiring the caffeine advisory statement were assessed.

Both provided a caffeine statement and the statement was of the correct intent. Therefore,

these labels were consistent for this type of advisory statement. Five kola beverage labels

were assessed during Stage 2 as requiring caffeine advisory statements. These five labels

provided a caffeine statement and the statements were deemed to be of the correct intent.

Therefore, all labels bearing caffeine advisory statements in Stage 2 were considered

consistent with the requirements in the new Code.

4.9.2 Guarana mandatory advisory statement

Only one product label in Stage 1 required this statement type. This label did not provide a

statement indicating the presence of caffeine and was consequently assessed as inconsistent.

In Stage 2, two labels were assessed as requiring a guarana mandatory advisory statement.

Both labels were consistent in providing this type of advisory statement, however one was

found not to be of the correct intent and subsequently, was inconsistent for this label element

section.

4.9.3 Phytosterol ester mandatory advisory statement

Only one product label in Stage 1 contained phytosterol esters. The label was consistent for

provision of the three required statements. However, the intent of two of the three statements

required was deemed to not fully reflect the intentions of the new Code and were assessed as

inconsistent. These statements related to the requirements for statements for those whom

products containing phytosterol esters are not recommended, unless under medical

supervision. The statements given were:


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‘Since young children, pregnant and lactating women have special dietary requirements, it

may not be suitable for this group to actively manage their cholesterol. In this instance

consult your doctor.’

‘If you are already on cholesterol lowering medication you should continue taking it as

recommended by your doctor while using ‘Product Name’.’

Therefore, overall the label was deemed to be inconsistent for these advisory statements.

There were no labels assessed as requiring phytosterol ester advisory statements in Stage 2.

4.10 Nutrition information panel

For Stage 1, 72% (320 labels) of labels required a NIP. Of the 28% of labels not required to

provide a NIP, approximately one third (39 labels) voluntarily provided a NIP. Those

voluntarily provided were predominantly on meat and meat products (28 labels), with the

remaining labels from several different major food categories. Ninety-three percent of labels

in Stage 2 required, or voluntarily provided, a NIP.

Combining the results of all three types of NIPs assessed (standard NIP, expanded NIP and

special NIP), no label providing a NIP was consistent with the labelling provisions of the new

Code in Stage 1 or Stage 2. For the purposes of assessment, it was required that the exact

format of the NIP as prescribed needed to be met, that is, all the features (case, layout,

punctuation and wording) had to be exactly the same as those given in the Code, rather than

allowing for wording changes as noted in Standard 1.1.1, Preliminary Provisions, Clause 12.

The NIP inconsistencies were also assessed as to their ‘severity’ in relation to their likely

impact on consumer understanding of the NIP information. All standard NIPs were inconsistent

(346 of 346 labels in Stage 1, 1063 of 1063 labels in Stage 2) and almost all expanded NIP

sections were inconsistent (134 of 135 labels in Stage 1, 275 of 300 labels in Stage 2). Fifteen

of the 16 special NIPs required in Stage 1 and 25 of the 26 special NIPs required in Stage 2

were assessed as inconsistent (refer to Table 51 and Table 52). As a given, labels generally had

a standard NIP and may have had an expanded NIP section or special NIP requirements so may


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have been included in two assessments. The overall NIP was assessed as inconsistent in all

cases. The reasons why these were inconsistent will be discussed under each type of NIP.

Stage 1

Table 51 NIP inconsistency by type of NIP provided for Stage 1

NIP type Number of NIPs

Assessed*

Number of NIPs

Inconsistent

Percentage of NIPs

Inconsistent

Standard NIP 346 346 100

Expanded NIP Section 135 134 99

Special NIP 16 15 94

* Total sample number = 359. Some labels gave more than one NIP.

Stage 2

Table 52 NIP inconsistency by type of NIP provided for Stage 2

NIP type Number of NIPs

Assessed*

Number of NIPs

Inconsistent

Percentage of NIPs

Inconsistent

Standard NIP 1063 1063 100

Expanded NIP Section 300 275 92

Special NIP 26 25 96

* Total sample number = 1078. Some labels gave more than one NIP.

4.10.1 Standard nutrition information panel

All standard NIPs provided in both Stage 1 and Stage 2 were inconsistent.

4.10.1.1 Severity of standard NIP inconsistencies

Table 53 and Table 54 details the reasons standard NIPs were inconsistent by the severity of

the effect on comprehension (likely impact on consumer understanding of the NIP information,

see Appendix 16). Labels could be assessed as inconsistent for more than one reason and

therefore, labels often had more than one inconsistency across one or more of the severity

categories, and in some cases all three types.

Stage 1

Virtually all of the 346 inconsistent standard NIPs (99%) in Stage 1 had inconsistencies that

were considered minor, such as incorrect case (e.g. ‘nutrition information’ not ‘NUTRITION

INFORMATION’). Forty nine percent (171 of 346 labels) had intermediate reasons for

inconsistency (e.g. serving size information given but placed in the wrong position) and 64%


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(223 labels) had major reasons (e.g. mandatory nutrient prescribed in the new Code missing

from the NIP provided on a label).

Table 53 Severity of inconsistency of standard NIP Stage 1

Severity of Inconsistency Number of Standard NIPs

Inconsistent

Percentage of Total

Number of Standard NIPs

Inconsistent*

Minor 342 99

Intermediate 171 49

Major 223 64

*Total number of inconsistent labels for standard NIPs = 346. NIPs could be inconsistent for more than one severity category (refer to

Appendix 16).

Stage 2

One hundred percent of standard NIPs in Stage 2 were inconsistent for minor reasons (1061

of 1063 labels). Intermediate reasons in Stage 2 accounted for 45% of inconsistent labels

whilst major reasons occurred in 51% of inconsistent labels (refer to Table 54).

Table 54 Severity of inconsistency of standard NIP Stage 2

Severity of Inconsistency Number of Standard NIPs

Inconsistent

Percentage of Total

Number of Standard NIPs

Inconsistent*

Minor 1061 100

Intermediate 475 45

Major 537 51

*Total number of inconsistent labels for standard NIPs = 1063. NIPs could be inconsistent for more than one severity category (refer to

Appendix 16).

The sources of inconsistencies for standard NIPs by label element section for Stage 1 and

Stage 2 are outlined in Table 55 and Table 56 and discussed in detail below.


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Table 55 Areas of standard NIP inconsistency by label element section Stage 1

Label Element Section Inconsistent Number of Labels

Inconsistent

Percentage of Total

Number of Labels

Inconsistent for Standard

NIP*

Presence 1 Less than 1

Legibility 5 1

General reasons** 142 41

Borders 319 92

Panel heading 198 57

Serving information 320 92

Columns 180 52

Nutrients 322 93

Values 57 16

Units 98 28

Other 89 26

* Total number of inconsistent labels for standard NIPs = 346. Labels may be inconsistent for more than one reason.

** General reasons includes incorrect measures e.g. averages not indicated, data presented for wrong form of food, e.g. dehydrated not made

up, total not drained weight.

Table 56 Areas of standard NIP inconsistency by label element section Stage 2


Inconsistent

Percentage of Total

Number of Labels


NIP*

Presence 0 0

Legibility 15 1

General reasons** 239 22

Borders 1036 97

Panel heading 613 58


Columns 530 50

Nutrients 986 93

Values 112 11

Units 184 17

Other 129 12

* Total number of inconsistent labels for standard NIPs = 1063. Labels may be inconsistent for more than one reason.

** General reasons includes incorrect measures e.g. averages not indicated, data presented for wrong form of food, e.g. dehydrated not made

up, total not drained weight.


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Presence

Stage 1

The absence of a NIP where required was considered a major inconsistency. Only one of the

346 labels requiring a standard NIP in Stage 1 did not provide one. Although the presence of

a NIP was the basic criteria for a label being classified as new Code, this label for a

formulated caffeinated beverage was assessed as a new Code label because the compositional

information panel was provided, as required in the new Code.

Stage 2

No labels in Stage 2 were assessed as inconsistent for not providing an NIP where one was

required.

Legibility

Stage 1

In Stage 1, 99% of the 346 labels requiring a standard NIP were legible. Inconsistencies for

legibility were considered a major inconsistency and were as a result of:

• standard NIP not visible (two of five labels);

• standard NIP not indelible (one of five labels);

• standard NIP not distinct from the label decoration (one of five labels); and

• standard NIP not easy to read case (one of five labels).

Stage 2

Fifteen labels (one percent) in Stage 2 were inconsistent for standard NIP legibility. These

inconsistencies were due to the standard NIP not being:

• indelible (three of 15 labels);

• distinct from label decoration (three of 15 labels);

• distinct from label text (three of 15 labels);

• placed appropriately (two of 15 labels); and

• visible (five of 15 labels).


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Two of the labels inconsistent for legibility in Stage 2 could not be assessed further and two

could only be partially assessed. The remaining 11 labels inconsistent for legibility could be

fully assessed for the standard NIP label element section.

General reasons

Stage 1

Forty one percent of the 346 inconsistent labels in Stage 1 had inconsistencies for other,

general reasons (142 labels). The predominant reason for inconsistency for this label element

section was not to indicate that NIP values were averages (88%, 125 of 142 labels). All

reasons for inconsistency are detailed in Table 57.

Table 57 General reasons for standard NIP inconsistency (the severity of each

inconsistency as assessed in this study is given in brackets) for Stage 1

Reason Inconsistent Number of Labels

Inconsistent

Percentage of Total

Number of Labels


NIP General Reasons*

No indication given that values are averages (major) 125 88

No indication given what values represent (major) 7 5

Dehydrated foods not expressed as when reconstituted# (major) 4 3

Food to be consumed with other food expressed as when made up** (major) 3 2

Optional column not used to show food values when made up (major) 0 0

Optional column for food values when made up incorrectly positioned

(major) 10 7

Food to be drained before consumption not expressed as drained (major) 1 Less than 1

Values not based on appropriate measure (e.g. volume instead of weight)

(major) 6 4

Incorrect explanation of RDI (Recommended Dietary Intake) (major) 2 1

NIP not intact (e.g. split into 2 halves) (intermediate) 7 5

* Total number of labels inconsistent for standard NIP general reasons = 142. Labels may be inconsistent for more than one general reason.

# If made up with only water

** Made up with other foods not just water

Stage 2

In Stage 2, 22% of labels were inconsistent for general reasons. As with Stage 1, the main

reason for inconsistency was labels not indicating that the values given in the standard NIP


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were averages (74%, 176 of 239 labels). All other reasons for inconsistency occurred at less

than 10% (refer to Table 58).

Table 58 General reasons for standard NIP inconsistency (the severity of each



Inconsistent

Percentage of Total

Number of Labels


NIP General Reasons*

No indication given that values are averages (major) 176 74

No indication given what values represent (major) 7 3

Dehydrated foods not expressed as when reconstituted# (major) 5 2

Food to be consumed with other food expressed as when made up** (major) 0 0

Optional column not used to show food values when made up (major) 0 0

Optional column for food values when made up incorrectly positioned

(major) 7 3

Food to be drained before consumption not expressed as drained (major) 6 3

Values not based on appropriate measure (e.g. volume instead of weight)

(major) 19 8

Incorrect explanation of RDI (Recommended Dietary Intake) (major) 3 1

NIP not intact (e.g. split into 2 halves) (intermediate) 22 9

* Total number of labels inconsistent for standard NIP general reasons = 239. Labels may be inconsistent for more than one general reason.

# If made up with only water

** Made up with other foods not just water

Additionally, in Stage 2, three labels were assessed as indeterminable for dehydrated foods

expressed as reconstituted. This was due to the label not indicating what the standard NIP

values represented.


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Borders

Stage 1

Three hundred and nineteen labels were inconsistent in Stage 1 due to the borders label

element sub-section. These inconsistencies were considered to be minor. Borders were

inconsistent as a result of:

• external borders not present (137 of 319 labels);

• internal borders not present (80 of 319 labels);

• extra internal borders provided (219 of 319 labels); and

• other border inconsistencies (one of 319 labels).

Stage 2

Ninety-seven percent of labels (1036 of 1063 labels) in Stage 2 were inconsistent for borders.

These labels were inconsistent mainly due to extra internal borders being provided (76%, 787

of 1036 labels). The absence of external borders (44%, 459 of 1036 labels) and internal

borders (37%, 387 of 1036 labels) were also a source of inconsistency for this label element

sub section. Additionally, two labels were inconsistent for other border inconsistencies.

Borders could be inconsistent for more than one reason in both Stage 1 and 2.

Panel heading

Stage 1

Of the 198 labels inconsistent for panel heading, the main causes were alignment (119 labels)

and wording (104 labels). For the 104 labels inconsistent for heading wording, the main

inconsistency was substitution of ‘Nutritional’ for ‘Nutrition’ (81 labels) (refer to Table 59).


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Table 59 Reasons standard NIP heading inconsistent (the severity of each


Attributes Assessed

Reason Heading Inconsistent Number of Labels

Inconsistent

Percentage of Total

Number of Labels


NIP Panel Headings*

Presence (major) 7 4

Position (major) 17 9

Alignment (minor) 119 60

Case (minor) 57 29

Wording (minor) 104 53

* Total number of labels inconsistent for standard NIP heading = 198. Labels may be inconsistent for more than one reason.

Reason Heading Wording Inconsistent Number of Labels

Inconsistent

Percentage of Total

Number of Labels


NIP Panel Heading

Wording*

Nutrition 81 78

Information 12 12

Other 16 15

* Total number of labels inconsistent for heading wording = 104. Labels may have more than one wording inconsistency.

Other Wording Used In Heading Number of Labels

Percentage of Total

Number of Labels with

‘Other’ Wording in

Standard NIP Heading*

‘FACT’ instead of ‘INFORMATION’ 2 13

‘FACTS’ instead of ‘INFORMATION’ 8 50

‘ANALYSIS’ instead of ‘INFORMATION’ 1 6

Inclusion of product name in heading 3 19

Inclusion of ‘average’ in heading 2 13

* Total number of labels with other heading = 16

Stage 2

Of the 1063 labels requiring or voluntarily providing a standard NIP, 613 were inconsistent

for standard NIP heading. The results in Stage 2 for this label element sub section were very

similar to that of Stage 1, with alignment of the standard NIP heading again being the most

common inconsistency (66%, 403 of 613 labels). Inconsistent wording of the standard NIP

heading was also frequent, accounting for inconsistency in almost half of inconsistent labels

(43%, 263 of 613 labels). Details of wording inconsistencies are provided in Table 60.


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Table 60 Reasons standard NIP heading inconsistent (the severity of each


Attributes Assessed

Reason Heading Inconsistent Number of Labels

Inconsistent

Percentage of Total

Number of Labels


NIP Panel Headings*

Presence (major) 17 3

Position (major) 57 9

Alignment (minor) 403 66

Case (minor) 146 24

Wording (minor) 263 43

* Total number of labels inconsistent for standard NIP heading = 613. Labels may be inconsistent for more than one reason.

Reason Heading Wording Inconsistent Number of Labels

Inconsistent

Percentage of Total

Number of Labels


NIP Panel Heading

Wording*

Nutrition 242 92

Information 9 3

Other 21 8

* Total number of labels inconsistent for heading wording = 263. Labels may have more than one wording inconsistency.

Other Wording Used In Heading Number of Labels

Percentage of Total



Standard NIP Heading*

‘TYPICAL ANALYSIS’ instead of ‘NUTRITION INFORMATION’ 1 5

‘FACTS’ instead of ‘INFORMATION’ 2 10

‘ANALYSIS’ instead of ‘INFORMATION’ 1 5

Inclusion of product name / description in heading 10 45

Inclusion of serving size information 5 24

Inclusion of ‘PER SERVING’ 1 5

Inclusion of ‘PANEL’ 2 10

Inclusion of ‘AUS’ 1 5

Inclusion of ‘FOR DRAINED CONTENTS’ 1 5

* Total number of labels with other heading = 21. Labels may have more than one ‘other’ wording inconsistency.

One label was inconsistent for standard NIP heading wording for two ‘other’ reasons. These

were for including serving size information and product name/description in the heading.


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Serving information

Stage 1

Of the 346 labels in Stage 1 inconsistent for standard NIP, 320 were inconsistent for the

serving information label element section. This was due to:

• absence of ‘servings per package’ (27 of 320 labels, major inconsistency);

• absence of ‘serving size’ (24 of 320 labels, major inconsistency);

• position of serving information (158 of 320 labels, intermediate inconsistency);

• alignment of ‘servings per package’ (58 of 320 labels, minor inconsistency);

• punctuation of ‘servings per package’ (76 of 320 labels, minor inconsistency);

• case of ‘servings per package’ (203 of 320 labels, minor inconsistency);

• wording of ‘servings per package’ (141 of 320 labels, minor inconsistency);

• alignment of ‘serving size’ (121 of 320 labels, minor inconsistency);

• punctuation of ‘serving size’ (77 of 320 labels, minor inconsistency);

• case of ‘serving size’ (228 of 320 labels, minor inconsistency); and

• wording of ‘serving size’ (27 of 320 labels, minor inconsistency).


Alternative statements were sometimes used to give serving information. These statements

combined the ‘servings per package’ and ‘serving size’ information. The main alternative

statements used were:

• ‘X servings of Yg/mL (per Package)’;

• ‘X x Yg/mL servings per Pack’; and

• ‘X Yg/mL servings per package’

where X = number of serves and Y = numerical serving size.

Whilst alternative combined statements provided all the required information, they were

substantially different from the prescribed format (refer to Table 61 and Table 62).


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Details of the wording inconsistencies are summarised in Table 61 for ‘servings per package’

and, Table 62 for ‘serving size’.

Table 61 Standard NIP ‘serving per package’ wording (the severity of each


Attributes Assessed

Word Inconsistent (minor) Number of Labels

Inconsistent

Percentage of Total

Number of Labels

Inconsistent For Standard

NIP ‘Servings Per

Package’ Wording*

Servings 10 7

Per 4 3

Package 108 77

Other 31 22

*Total number of labels inconsistent for ‘servings per package’ wording = 141. Labels could be inconsistent for more than one reason.

Other Wording Used (minor) Number of Labels

Percentage of Total

Number of Labels Using


Standard NIP ‘Servings

Per Package’*

‘Serves’ only no ‘Per Package’ 1 3

Includes Slices 2 6

‘Container’ instead of ‘Package’ 6 19

‘Type of Container’ instead of package# 8 26

‘X Servings of Y g/mL Per Package’ 2 6

Inclusion of ‘For One’ 1 3

‘X Y g/mL Servings Per Package’ 2 6

‘Number of Servings’ 1 3

‘X x Y g/mL Servings Per Pack’ 2 6

Inclusion of ‘Average’ 1 3

‘Contains X Servings Per Package’ 1 3

Inclusion of ‘Approx.’ 2 6

‘Servings’ only no ‘Per Package’ 2 6

* Total number of labels using other wording = 31

# Type of container means use of word ‘can’, ‘bottle’ ‘bar’, ‘loaf’ etc.

X = number of serves

Y = numerical serving size


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Table 62 Standard NIP ‘serving size’ wording for Stage 1

Attributes Assessed


Inconsistent

Percentage of Total

Number of Labels


NIP ‘Serving Size’

Wording*

Servings 6 22

Size 1 4

Other 21 78

* Total number of labels inconsistent for wording = 27. Labels could be inconsistent for more than one reason.


Percentage of Total



Standard NIP ‘Serving

Size’*

X Servings of Y g/mL 1 5

‘Approximate Servings per Package’ 1 5

Inclusion of ‘When Cooked’ 2 9

Inclusion of ‘Approximate’ 1 5


‘Suggested Serving’ 1 5


‘X x Y g/mL Servings Per Pack’ 2 9


‘Per Serving’ Included 1 5

* Total number of labels using alternative wording = 21



For the 158 labels with serving information inconsistently positioned (intermediate

inconsistency), the primary reason was serving information being positioned on the same line

as the column headings (151 labels). This alternative positioning appeared to be used when

space was limited and was set out in the format and order required, but placed in the space

adjacent to the column headings. The second main reason for position inconsistencies was

‘servings per package’ and ‘serving size’ sharing the one line (98 labels). Serving

information being declared in the wrong order was found in 40 labels. Serving information

was also placed at the bottom of the NIP (two of 158 labels) and next to the ‘nutrition

information’ heading (one of 158 labels). Some labels were inconsistent for more than one

reason.


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Stage 2

Nine hundred and eighty-seven labels in Stage 2 were inconsistent for a standard NIP for

serving information. These inconsistencies were due to:

• absence of ‘servings per package’ (40 of 987 labels, major inconsistency);

• absence of ‘serving size’ (46 of 987 labels, major inconsistency);

• position of serving information (438 of 987 labels, intermediate inconsistency);

• alignment of ‘servings per package’ (162 of 987 labels, minor inconsistency);

• punctuation of ‘servings per package’ (170 of 987 labels, minor inconsistency);

• case of ‘servings per package’ (716 of 987 labels, minor inconsistency);

• wording of ‘servings per package’ (362 of 987 labels, minor inconsistency);

• alignment of ‘serving size’ (321 of 987 labels, minor inconsistency);

• punctuation of ‘serving size’ (176 of 987 labels, minor inconsistency);

• case of ‘serving size’ (752 of 987 labels, minor inconsistency); and

• wording of ‘serving size’ (42 of 987 labels, minor inconsistency) (refer to Table 63

and Table 64).

As with Stage 1, statements that combined both ‘servings per package’ and ‘serving size’

information were used in Stage 2. Details of these statements and other wording

inconsistencies are given in Table 63 for ‘servings per package’ and Table 64 for ‘serving

size’.


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Table 63 Standard NIP ‘serving per package’ wording (the severity of each


Attributes Assessed


Inconsistent

Percentage of Total Number

of Labels Inconsistent For

Standard NIP ‘Servings Per

Package’ Wording*

Servings 44 12

Per 7 2

Package 299 83

Other 48 13

*Total number of labels inconsistent for ‘servings per package’ wording = 362. Labels could be inconsistent for more than one reason.


Percentage of Total Number

of Labels Using ‘Other’

Wording in Standard NIP

‘Servings Per Package’*

‘Container’ instead of ‘Package’ 3 6

‘Type of Container’ instead of package# 17 35



‘Number of Servings’ per package 3 6

‘Number of Servings’ / bottle 1 2

‘Number of Servings’ 3 6


‘Contains X Serves’ 2 4

Inclusion of ‘Approx.’ 2 4

Inclusion of ‘Typical’ 1 2

Inclusion of ‘About’ 1 2

‘Number of Servings’ per Container’ 1 2

‘Serving Size per Package’ 1 2

‘Servings per pkg’ 1 2

‘kg’ instead of package 1 2

‘Servings per Z package’ 1 2

‘Approx servings per sachet’ 2 4

* Total number of labels using other wording = 48

# Type of container means use of word ‘can’, ‘bottle’ ‘bar’, ‘loaf’ etc.



Z = weight of package


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Table 64 Standard NIP ‘serving size’ wording for Stage 2

Attributes Assessed


Inconsistent

Percentage of Total

Number of Labels


NIP ‘Serving Size’

Wording*

Serving 13 31

Size 2 5

Other 29 69

* Total number of labels inconsistent for wording = 42. Labels could be inconsistent for more than one reason.


Percentage of Total



Standard NIP ‘Serving

Size’*

X Servings of Y g/mL 1 3

Inclusion of ‘When Cooked’ 1 3

Inclusion of ‘Approximate’ 2 7

‘Suggested Serving’ 2 7


‘X Serving = Y’ 1 3

‘Quantity per serving’ 1 3

‘Per 100g Serving’ 1 3

Inclusion of ‘recommended’ 1 3

‘Y Per Serve’ 1 3

‘Approx. X per serve’ 1 3

‘Serving Size One – Y’ 1 3

‘Serving size per 150g pack’ 1 3

‘Serving / serve’ 1 3

Inclusion of ‘per’ 1 3

* Total number of labels using alternative wording = 29



For the 438 labels with serving information inconsistently positioned, the reasons for

inconsistency were:

• ‘servings per package’ and ‘serving size’ sharing the same line (335 of 438 labels);

• ‘servings per package’ and ‘serving size’ being in the wrong order (35 of 438 labels);

and

• ‘servings per package’ and ‘serving size’ being placed in other positions (85 of 438

labels).


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Other positions in which ‘serving information’ was given included sharing the same line as

column headings (69 of 85 labels), being placed next to the nutrition information panel (five

of 85 labels), being placed below the nutrition information panel (six of 85 labels), being

placed at the top of the nutrition information panel (one of 85 labels), being placed under the

column headings (one of 85 labels), placed in different columns (one of 85 labels), and

placed elsewhere on the label (one of 85 labels).

Labels could be inconsistent for ‘serving information’ position for more than one reason.

Columns

Stage 1

The prime reason columns were inconsistent in Stage 1 for a standard NIP was the use of

inconsistent wording for column headings (162 of 180 labels, minor inconsistency).

Additional sources of inconsistency were the position of columns within the NIP (eight

labels, intermediate inconsistency) and the absence of one of the required columns (48 labels,

major inconsistency).

Inconsistency for column presence was mainly as a result of only one column being provided

where the serving size equalled 100g or 100mL (30 labels). This error may have resulted

from manufacturers not believing that they need to provide the same information twice in two

separate columns and because the old Code permitted this exception. Additionally, 11 labels

failed to provide the ‘100 g/mL’ column and for seven labels the ‘per Serving’ column was

missing.

With regards to column position, for the eight inconsistent labels, the position of the ‘per

Serving’ and ‘per 100g’ columns were reversed (intermediate inconsistency).

For the 162 labels with inconsistent column wording (minor inconsistency), the main

inconsistency was the word ‘Quantity’ not being provided (147 labels) or abbreviation of

‘Quantity’ (eight labels). This inconsistency may have arisen as the old Code permitted ‘per

serving’ and ‘per 100g’ to be used. For 12 labels, alternative column wording was used.

Details of the alternative wording used are given in Table 65.


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Some labels were inconsistent for column heading wording for more than one reason.

Table 65 Standard NIP columns wording for Stage 1

Attributes Assessed

Reason Inconsistent (minor) Number of Labels

Inconsistent

Percentage of Total

Number of Labels

Inconsistent For Column

Wording*

Quantity missing 147 91

Quantity abbreviated 8 5

Other 12 7

* Total number of labels column wording inconsistent = 162. Labels could be inconsistent for more than one reason.


Percentage of Total

Number of Labels


Wording Other*

Weight or volume included in heading or given instead of ‘serving’ 4 17

No heading provided 2 17

Alternative heading ‘Values for serving size product name’ 1 8

Alternative heading ‘Typical analysis per 100g’ 1 8

Alternative heading ‘Nutrition Levels’ 1 8

‘Serving’ substituted with ‘One Unit’ 2 17

Inclusion of word ‘Values’ 1 8

* Total labels with other column wording used = 12

Stage 2

Five hundred and thirty labels were inconsistent in Stage 2 for a standard NIP for the

columns label element sub section. Of these 530 labels, reasons for inconsistency were due

to column headings not being:

• present (81 of 530 labels);

• positioned correctly (20 of 530 labels); and

• worded correctly (472 of 530 labels).


Inconsistencies due to columns not being present were primarily a result of product serving

sizes being equal to 100g and therefore, labels only providing one of the two required

columns (67 of 81 labels). Five labels were inconsistent for not providing the ‘per 100g/mL’

column and 11 for not providing the ‘per serving’ column.


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The position of the ‘per 100g/mL’ column was inconsistent in 12 of the 20 labels inconsistent

for column position. In seven labels, the reason for column position inconsistency was the

positioning of the ‘prepared with other food’ column. One column also had the ‘per serving’

column inconsistently positioned.

Reason for column heading wording inconsistencies are detailed in Table 66.


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Table 66 Standard NIP columns wording for Stage 2

Attributes Assessed

Reason Inconsistent (minor) Number of Labels

Inconsistent

Percentage of Total

Number of Labels


Wording*

Quantity missing 261 55

Quantity abbreviated 107 23

Other 180 38

* Total number of labels column wording inconsistent = 472. Labels could be inconsistent for more than one reason.


Percentage of Total

Number of Labels


Wording Other*

Weight or volume included in heading or given instead of ‘serving’ 151 84

No heading provided 4 2

‘Slice’ instead of ‘serving’ 1 1

‘bar’ instead of ‘serving’ 1 1

‘pita’ not ‘serving’ 1 1

‘bagel’ not ‘serving’ 1 1

‘biscuit’ not ‘serving’ 1 1

‘cookie’ not ‘serving’ 1 1

‘egg’ not ‘serving’ 1 1

‘one serving contains’ 1 1

‘typical values’ not ‘quantity’ 1 1

Inclusion of word ‘serving/serve’ in 100g column 7 4

‘per 100mL’ drink 1 1

Includes ‘(1biscuit)’ 1 1

‘per’ abbreviated as ‘/’ 3 2

‘Quantities’ not ‘quantity’ 1 1

‘values’ not ‘quantity’ 1 1

‘typical content’ not ‘quantity’ 1 1

‘tablet’ instead of serving 1 1

‘results’ 1 1

Missing ‘per’ 1 1

200mL given not ‘100mL’ 1 1

* Total labels with other column wording used = 180. Labels could be inconsistent for more than one reason.


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Nutrients

Stage 1

For the 322 labels in Stage 1 where nutrients were inconsistent for a standard NIP, the main

reasons were the use of upper case (293 labels, minor inconsistency), punctuation (262 labels,

minor inconsistency) and wording (77 labels, minor inconsistency). Inconsistencies also

resulted from incorrect position or order of nutrients in the panel (38 labels, major

inconsistency) and nutrients not being provided (eight labels, major inconsistency).

For the eight labels inconsistent for nutrient presence, the main nutrient not declared was

‘sugars’ (six labels) with ‘Fat, total’ and ‘Sodium’ not declared on two labels and ‘saturated’

not declared on one label.

For the 38 labels with nutrients inconsistently positioned, 18 labels were for ‘Protein’, 23

labels for ‘Carbohydrates’, 20 labels for ‘sugars’ and 17 labels for other nutrients provided.

‘Energy’ and ‘Sodium’ were also misplaced for nine and five labels respectively.

For the 77 labels inconsistent for nutrient wording, inconsistencies were mainly for ‘Fat,

total’ (64 of 77 labels) and ‘saturated’ (49 of 77 labels). Other inconsistencies occurred with

‘Carbohydrate’ (19 of 77 labels) and ‘Energy’ (15 of 77 labels). The main cause for

inconsistency of ‘Fat, total’ wording, was omission of ‘, total’ and, for ‘saturated’, the

inclusion of the word ‘Fat’. Inconsistencies also occurred due to the inconsistent wording of

‘sugars’ (nine of 77 labels) and other nutrients provided (two of 77 labels).

Seventy-five labels provided additional nutrients in the standard NIP. The most frequently

provided additional nutrient was calcium (52 labels), with a number of labels also claiming

for iron (20 labels) and vitamin C (19 labels). Details of the other nutrients which were

included in the NIP, can be found in Table 67.


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Table 67 Details of other nutrients provided in standard NIP for Stage 1

Nutrient provided in Standard NIP Number of Labels Percentage of Total


Other Nutrients

Provided*

Iron 20 27

Magnesium 3 4

Thiamin 8 11

Vitamin A 14 19

Vitamin C 19 25

Calcium 52 69

Folate 4 5

Selenium 1 1

Riboflavin 7 9

Vitamin E 1 1

Niacin 8 11

Vitamin B6 1 1

Vitamin B12 1 1

Gluten 1 1

Phosphorus 4 5

Phytosterol Esters 3 4

* 75 labels provided additional nutrients, gluten and phytosterol esters are included in this table though not strictly nutrients. Labels could

provide more than one additional nutrient.

Stage 2

Ninety-three percent (986 of 1063 labels) of labels were inconsistent for nutrients in Stage 2

for a standard NIP. These inconsistencies were due to:

• required nutrients not being present (17 of 986 labels, major inconsistency);

• nutrients being positioned inconsistently (47 of 986 labels, major inconsistency);

• nutrients being worded inconsistently (185 of 986 labels, minor inconsistency);

• nutrients being given in the wrong case (885 of 986 labels, minor inconsistency); and

• nutrients having the wrong punctuation (666 of 986, minor inconsistency).

Nutrients not declared in standard NIPs were ‘sugars’ (12 of 17 labels), ‘Energy’ (two of 17

labels), ‘Protein’ (two of 17 labels), ‘Fat, total’ (four of 17 labels), ‘saturated’ (four of 17

labels), ‘Sodium’ (two of 17 labels) and ‘other’ nutrients where a claim was made (two of 17

labels).

In Stage 2, the most commonly inconsistently positioned nutrient was ‘other’ nutrients (23 of

47 labels). ‘Sodium’ was also inconsistently positioned (five of 47 labels), as were ‘sugars’


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(16 of 47 labels), ‘Carbohydrate’ (18 of 47 labels), ‘saturated’ (five of 47 labels), ‘Fat, total’

(five of 47 labels), ‘Protein’ (four of 47 labels) and ‘Energy’ (three of 47 labels).

‘Fat, total’ accounted for 42% (77 of 185 labels) of wording inconsistencies. Other wording

inconsistencies were for ‘Energy’ (six of 185 labels), ‘Protein’ (five of 185 labels),

‘saturated’ (70 of 185 labels), ‘Carbohydrate’ (70 of 185 labels), ‘sugars’ (37 of 185 labels),

‘Sodium’ (one of 185 labels), and ‘other’ nutrients (two of 185 labels).

Details of ‘other’ nutrients provided in Stage 2 are given in Table 68.


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Table 68 Details of other nutrients provided in standard NIP for Stage 2

Nutrient provided in Standard NIP Number of Labels Percentage of Total


Other Nutrients

Provided*

Iron 23 13

Magnesium 1 1

Thiamin 15 8

Vitamin A 9 1

Vitamin C 41 23

Calcium 99 55

Folate 16 9

Riboflavin 12 7

Vitamin E 6 3

Niacin 17 9

Vitamin B5 4 2

Vitamin B6 6 3

Vitamin B12 6 3

Vitamin D 2 1

Zinc 5 3

Gluten 8 4

Phosphorus 2 1

Lycopene 8 4

Caffeine 2 1

Phytoestrogens 2 1

Tannic acid 1 1

Flavonoids 1 1

Starch 1 1

B-Carotene 1 1

* 180 labels provided additional nutrients. Gluten, phytoestrogens, lycopene, caffeine, tannic acid, flavonoids, starch and b-carotene are

included in this table though not strictly nutrients. Labels could provide more than one additional nutrient.

Values

Stage 1

Of the 57 labels inconsistent for values for a standard NIP, 43 labels used symbols instead of

words (major inconsistency), to describe mathematical terms (e.g. ‘<’ rather than ‘less than’).

This appeared to be used to reduce the space required. The term ‘Nil’ or ‘0’ was also used to

express zero values in a number of instances (20 labels, intermediate inconsistency), rather

than ‘0 g’ or ‘Nil g’.


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Stage 2

One hundred and twelve labels were inconsistent for values in Stage 2 for a Standard NIP.

Values inconsistencies were due to mathematical terms not being described in words but

given as symbols (e.g. ‘<’ rather than ‘less than’) (89 of 112 labels) and ‘0 g’ or ‘Nil g’ being

given as ‘0’ or ‘Nil’ (29 of 112 labels).

Units

Stage 1

Ninety-eight labels were inconsistent for units in Stage 1 (major inconsistency). These

inconsistencies were for case of units (46 of 98 labels), position of units (42 of 98 labels) and

units used (34 of 98 labels). Thirty-three of the 34 labels inconsistent for units used were

inconsistent for ‘Energy’. For these 33 labels, the use of ‘kCal’ instead of ‘Cal’ (19 labels)

accounted for approximately half of these inconsistencies. A further 14 labels were

inconsistent because energy was declared only in calories, not kilojoules. Incorrect case was

used only in ‘Energy’ declarations. Commonly, kilojoule units were declared as ‘Kj’ or ‘KJ’

rather than ‘kJ’.

Stage 2

One hundred and eighty-four labels in Stage 2 were inconsistent for the units label element

sub-section. Inconsistencies for this label element sub-section were due to:

• units being inconsistently positioned (58 of 184 labels);

• inconsistent units beings used (61 of 184 labels); and

• units being given in inconsistent case (111 of 184 labels).

Of the 61 labels with inconsistent units used, 51 were due to ‘Energy’ being given as a

calorific value rather than kilojoules. Inconsistent units were also used for all other nutrients

although to a much lesser extent. Commonly, units were given as percentages rather than ‘g’

or ‘mg’ and in some cases no units were given at all.

All 111 labels inconsistent for unit case were due to ‘Energy’. This was a result of:

• ‘kJ’ being given as ‘kj’ or ‘Kj’; and


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• calorie units where provided being given as ‘cal’ or ‘CAL’ instead of ‘Cal’.

There was one instance of inconsistent units being used for each of the other nutrients. This

was due to units being given in upper case rather than lower case.

Other Inconsistencies

Other inconsistencies included those inconsistencies not covered by any of the assessments

made under the other label element sections and, that were not in line with the exact format

of the NIP as prescribed in the new Code. These inconsistencies were not assessed by

severity.

Stage 1

Of the 89 Stage 1 labels with other inconsistencies for a Standard NIP, the most common

inconsistency was not providing brackets around the Calorie values (40 labels), and ‘Average

Quantity’ being grouped across the two column headings above the ‘per Serving’ and ‘per

100g/mL’ columns (15 labels). The nutrient words, and the ‘per Serving’ column values not

being two distinct columns (12 labels), also accounted for a number of other inconsistencies.

Details of these inconsistencies and others present at lower levels (two - three labels only) are

provided in Table 69.


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Table 69 Other standard NIP inconsistencies for Stage 1

Other Reason Inconsistent Number of Labels

Inconsistent

Percentage of Total

Number of Labels With

Other Inconsistencies*

No brackets around calorie values 40 45

Serving information outside of external table border 1 1

Average quantity grouped across two columns 15 17

Addition of ‘Nutrient’ as a heading above Nutrients (e.g. Energy etc) 3 3

Addition of ‘Average Quantity’ as a heading above Nutrients (e.g. Energy) 2 2

Different type of panel provided (e.g. Typical Composition Table or American Calorie

Tables) 3

3

‘Nutrition Information’ heading outside of External Border 1 1

Values grouped across the two columns where they are the same 2 2

Moisture included in NIP 1 1

Extra column present for % Fat 1 1

Energy given as Cal only 1 1

Inclusion of No Preservatives in NIP 1 1

Use of comma instead of full stop to represent a decimal point 1 1

Addition of ‘Typical Analysis’ as a heading above Nutrients (e.g. Energy) 1 1

Addition of ‘Breakdown’ as a heading above Nutrients (e.g. Energy etc) 1 1

Column headings over the top of the Nutrients not the values 1 1

Use of the term ‘trace’ for values 1 1

Nutrients and the Per Serving Column run together 12 14

Breakdown of fatty acids given as percentage 1 1

Heading given for additional nutrients declared (e.g. Vitamins) 1 1

Inclusion of Heading ‘Australia Only’ 1 1

* Total number of labels inconsistent for other reasons = 89. Labels may be inconsistent for more than one reason.

Stage 2

One hundred and twenty-nine labels were inconsistent for other reasons for a standard NIP.

As with Stage 1, the majority of these inconsistencies were a result of calorie information not

being provided in brackets (78 of 129 labels). The addition of extra headings above the

nutrients column was also a common inconsistency in Stage 2. Details of these headings and

other inconsistencies are detailed in Table 70.


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Table 70 Other standard NIP inconsistencies for Stage 2

Other Reason Inconsistent Number of Labels

Inconsistent

Percentage of Total

Number of Labels With

Other Inconsistencies*

No brackets around calorie values 78 60

Serving information outside of external table border 1 1

Addition of ‘Nutrient’ as a heading above Nutrients (e.g. Energy etc) 6 5

Values grouped across the two columns where they are the same 3 2

Some nutrients bolded 3 2

Addition of ‘Typical Analysis’ as a heading above Nutrients (e.g. Energy) 2 2

Addition of ‘per Serving’ as a heading above nutrients 1 1

Addition of ‘total’ as a heading above Nutrients 1 1

Addition of ‘content’ as a heading above nutrients 2 2

Addition of ‘when prepared’ as a heading above nutrients 1 1

‘G’ instead of ‘g’ for unit in ‘per 100g’ column 4 3

‘G’ instead of ‘g’ for unit in serving information 1 1

‘kJ’ and/or ‘Cal’ given in nutrients column and values column 3 2

Product description included in NIP 1 1

Serving size given as ‘g’ in serving information and ‘Ml’ in column headings 1 1

Full stops given after units 1 1

Comma not fullstop used for decimal placing 2 2

Values for ‘other’ nutrients not given for ‘per serving’ 1 1

‘When made up’ information given in panel heading 1 1

Use of ‘gm’ instead of ‘g’ 4 3

Use of ‘Cals’ instead of ‘Cal’ 2 2

Units in brackets where not required 2 2

No value given for ‘servings per package’ 1 1

Package weight included in NIP 3 2

% RDI column in wrong position 1 1

Nutrients column given twice 1 1

Sodium given as ‘mmol’ and ‘mg’ 1 1

Serving size given in a column 1 1

Additional information provided at bottom of NIP for calories and fat per unit 1 1

Contact details in NIP 1 1

Units given in a separate column 1 1

Value missing for a nutrient 1 1

* Total number of labels inconsistent for other reasons = 129. Labels may be inconsistent for more than one reason.


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4.10.2 Expanded nutrition information panel section

Stage 1

Of the 359 labels providing a NIP in Stage 1, 38% (135 labels) provided an expanded NIP

section (refer to Table 71).

Table 71 Provision of expanded NIP section by major food category for Stage 1

Provision of Expanded NIP section


Major Food Category

Total Number of

Labels Required to

Provide / Voluntarily

Providing a NIP


1. Dairy 41 8 (20) 33 (80)




5. Confectionery 18 3 (17) 15 (83)









14. Mixed foods 78 26 (33) 52 (67)

Overall Results 359 135 (38) 224 (62)

Of the 135 labels providing expanded NIP sections, 48% included an expanded fat type, 65%

an expanded carbohydrate type and 46% an expanded salt type. Many labels provided more

than one type of expanded NIP section.

Stage 2

A lower proportion of labels provided expanded NIPs in Stage 2 (28%, 300 of 1078 labels)



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Table 72 Provision of expanded NIP section by major food category for Stage 2

Provision of Expanded NIP section


Major Food Category

Total Number of

Labels Required to

Provide / Voluntarily

Providing a NIP


1. Dairy 106 10 (9) 96 (91)




5. Confectionery 68 4 (6) 64 (94)









14. Mixed foods 263 60 (23) 203 (77)

Overall Results 1078 300 (28) 778 (72)

Of the 300 labels providing expanded NIPs, 26% provided expanded fat type NIPs, 66%

provided expanded carbohydrate type NIPs, and 41% provided expanded salt type NIPs.

Labels could provide more than one expanded NIP type.

4.10.2.1 Severity of expanded NIP section inconsistencies

Stage 1

As previously discussed, only one of the 135 labels providing expanded NIP sections in

Stage 1 was consistent with all NIP requirements. Table 73 details the reasons expanded NIP

sections were inconsistent by the severity of inconsistency. Ninety six percent of NIP

sections were inconsistent for minor reasons, 77% for major reasons and 10% for

intermediate reasons. It should be noted that in a number of instances, expanded NIP

sections were inconsistent for more than one reason, and in some cases these inconsistencies

occurred in all three levels of severity.


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Table 73 Severity of inconsistency of expanded NIP sections for Stage 1

Severity of Inconsistency Number of Labels

Inconsistent

Percentage of Labels

Inconsistent*

Minor 129 96

Intermediate 13 10

Major 104 77

* Total number labels inconsistent for expanded NIP section= 134. Labels may be inconsistent for more than one reason.

The label element sections that were inconsistent for expanded NIP sections were:

• values (28 of 134 labels);

• units (19 of 134 labels); and

• nutrients (132 of 134 labels).

There were no other types of errors for the label element sub-sections reported for expanded

NIPs.

When comparing inconsistency between types of expanded NIP sections, the rate of

inconsistency for carbohydrate expanded NIPs was the highest (100%, 89 labels), with fat

and salt type expanded NIPs accounting for 88% (56 labels) and 82% (51 labels) respectively


Table 74 Reason expanded NIP section inconsistent by type for Stage 1

Type of Expanded NIP Number of Labels

Providing Expanded

NIP section type

Number of Labels

Inconsistent by

Expanded NIP

section type

Percentage of Total

Number of Labels

Inconsistent by

Expanded NIP

section type

Fat 64 56 88

Carbohydrate 89 89 100

Salt 62 51 82

Stage 2

Twenty five labels were assessed as consistent with all expanded NIP requirements of the

new Code in Stage 2. Of the 275 labels inconsistent for expanded NIPs, 96% were for minor

reasons, 79% for major reasons, and seven percent for intermediate inconsistencies. These

figures were very similar to those in Stage 1 (refer to Table 75).


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As with Stage 1, labels could be inconsistent for more than one level of severity.

Table 75 Severity of inconsistency of expanded NIP sections for Stage 2


Inconsistent


Inconsistent*

Minor 264 96

Intermediate 20 7

Major 216 79

* Total number labels inconsistent for expanded NIP section= 275. Labels may be inconsistent for more than one reason.

The label element sections that were inconsistent for expanded NIP sections in Stage 2 were:

• values (27 of 275 labels);

• units (31 of 275 labels); and

• nutrients (272 of 275 labels).

No labels in Stage 2 were inconsistent for other label inconsistencies.

Similar to Stage 1, expanded carbohydrate type NIPs showed the highest inconsistency level

with 99% of labels assessed for this label element section inconsistent. Eighty five percent of

labels with expanded fat type NIPs and 78% with expanded salt type NIPs were inconsistent


Table 76 Reason expanded NIP section inconsistent by type for Stage 2

Type of Expanded NIP Number of Labels

Providing Expanded

NIP section type

Number of Labels

Inconsistent by

Expanded NIP

section type

Percentage of Total

Number of Labels

Inconsistent by

Expanded NIP

section type

Fat 78 66 85

Carbohydrate 201 198 99

Salt 124 97 78

4.10.2.2 Expanded fat nutrition information panel sections

Twelve percent of expanded fat NIP sections were consistent with the labelling provisions for

this type of expanded NIP in Stage 1. Comparatively, 15% of expanded fat NIP sections in

Stage 2 were consistent with the requirements of the new Code (12 of 78 labels).

Stage 1


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The reasons fat expanded NIP sections were inconsistent were:

• nutrients (46 of 56 labels);

• values (21 of 56 labels); and

• units (11 of 56 labels).

Some labels were inconsistent for more than one reason.

There were no other types of errors with this type of expanded NIP section.

Nutrients

For the 46 labels inconsistent for nutrients in Stage 1, the reasons were;

• case (40 of 46 labels, minor inconsistency);

• presence (16 of 46 labels, major inconsistency);

• position (18 of 46 labels, major inconsistency);

• wording (11 of 46 labels, minor inconsistency); and

• punctuation (17 of 46 labels, minor inconsistency).

For all 16 labels inconsistent for nutrient presence, the nutrient not provided was trans fatty

acids. Other nutrients were also not provided, but this was only for one to two labels each.

The main nutrient inconsistently positioned was cholesterol (12 labels), with polyunsaturated

and monounsaturated fatty acids also being inconsistently positioned in a number of

instances.

Wording inconsistencies in eight of the eleven labels inconsistent for this label element sub-

section were as a result of the wording for monunsaturates and seven inconsistencies were

due to the wording for polyunsaturates.


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Values

Twenty one labels were inconsistent for values, mainly due to the use of ‘Nil’ instead of ‘0g’

or ‘Nil g’ to express zero values (13 labels, intermediate inconsistency). Eight labels were

also inconsistent due to use of symbols (major inconsistency), rather than words, to describe

mathematical terms (eg. ‘<’ rather than ‘less than’).

Units (major inconsistency)

Of the 11 labels inconsistent for units, all were inconsistent for position and two labels were

also inconsistent for units used. Of the two labels inconsistent for units used, one label used

inconsistent units for monounsaturated fatty acids and one for polyunsaturated fatty acids.

Stage 2

The reasons fat expanded NIP sections were inconsistent were:




Some labels were inconsistent for more than one reason.

Nutrients

Sixty three labels (95%) were inconsistent for the nutrient label element sub section in Stage

2. This figure in regards to percentage inconsistency was very similar to that of Stage 1

(82%).

The reasons for nutrient inconsistency in Stage 2 were:

• case (49 of 63 labels, minor inconsistency);

• presence (22 of 63 labels, major inconsistency);


• wording (11 of 63 labels, minor inconsistency); and



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The nutrient primarily responsible for nutrient provision inconsistencies was trans fatty acids

(18 of 22 labels). Other inconsistencies for this label element sub section also occurred due

to the absence of polyunsaturated fatty acids (13 of 22 labels), monounsaturated fatty acids

(13 of 22 labels), and cholesterol (6 of 22 labels) within the NIP.

Similar to Stage 1, cholesterol was the main nutrient inconsistently positioned in Stage 2 (19

of 25 labels). Inconsistencies also occurred as a result of the positioning of polyunsaturated

fatty acids (three of 25 labels), monounsaturated fatty acids (10 of 25 labels), specific

monounsaturated fatty acids (one of 25 labels) and omega 9 (one of 25 labels) in a position

other than that prescribed by the new Code.

Wording inconsistencies in Stage 2 were also primarily as a result of the wording of

monunsaturates (9 of 11 labels) and polyunsaturates (9 of 11 labels). There were however

wording inconsistencies for trans fatty acids, omega 3, specific monounsaturated fatty acids

and omega 9 also.

Values

Fewer labels in Stage 2 were inconsistent when compared to Stage 1 as a result of the values

label element sub section (32% (21 of 66 labels) compared to 38% in Stage 1). Eight of the

21 inconsistent labels were inconsistent due to the use of symbols as opposed to words to

describe mathematical terms, whilst 16 labels were inconsistent for the use of ‘Nil’ or ‘0’

instead of ‘Nil g’ or ‘0 g’.


Sixteen labels were inconsistent for the units label element section in Stage 2. These labels

were inconsistent for the positioning (10 of 16 labels) and use (6 of 16 labels) of units other

than that prescribed by the new Code. The nutrients that were inconsistent for units used

were:

• trans fatty acid (two of six labels);

• polyunsaturated fatty acids (one of six labels);

• monounsaturated fatty acids (one of six labels); and

• cholesterol (four of six labels).


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4.10.2.3 Expanded carbohydrate type nutrition information panel sections

Stage 1

As discussed previously, all 89 labels carrying expanded carbohydrate NIP sections in Stage

1 were inconsistent. All 89 labels were inconsistent for nutrients, with some inconsistencies

for:



Nutrients

Reasons for inconsistent nutrients were:

• presence (two of 89 labels, major inconsistency);


• wording (78 of 89 labels, major inconsistency);

• case (80 of 89 labels, minor inconsistency); and


Some labels were inconsistent for nutrients for more than one reason.

All of the wording inconsistencies were due to the word ‘, total’ not being provided in

conjunction with ‘dietary fibre’. This is a change from previous regulations, which did not

require the declaration of this word. For the two labels inconsistent for presence, ‘dietary

fibre, total’ was not provided. All inconsistencies for position were also related to ‘dietary

fibre, total’.

Values

For the 11 labels inconsistent for values (major inconsistency), the main reason was for

mathematical terms being described using symbols rather than words (e.g. ‘<’ rather than

‘less than’). Two labels were inconsistent for expressing zero values as ‘Nil’ or ‘0’ rather

than ‘0g’ or ‘Nil g’ (intermediate inconsistency).


All inconsistencies for units were due to the incorrect positioning of these units within NIPs.


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Stage 2

Two hundred and one labels in Stage 2 provided expanded carbohydrate NIPs. Of these 201

labels, 99% were inconsistent (198 of 200 labels). Inconsistencies in Stage 2 were a result of:


• values (four of 198 labels); and


Nutrients

Reasons for inconsistent nutrients in Stage 2 were:

• presence (three of 198 labels, major inconsistency);


• wording (175 of 198 labels, major inconsistency);

• case (182 of 198 labels, minor inconsistency); and


Some labels were inconsistent for nutrients for more than one reason.

Values

Only two percent of labels (four of 198 labels) were inconsistent for the values label element

sub section in Stage 2 compared to 12% (11 of 89 labels) in Stage 1. Reasons for

inconsistent values in Stage 2 were mathematical terms being described with symbols rather

than words (e.g. ‘<’ rather than ‘less than’) (three of four labels) and expressing zero values

as ‘Nil’ or ‘0’ rather than ‘0g’ or ‘Nil g’ (intermediate inconsistency) (one of four labels).

Units

Fourteen of the 15 labels inconsistent for units, were for the positioning of units within the

NIP in a position other than that prescribed by the new Code. Additionally, one label was

inconsistent for the case used for the unit.

4.10.2.4 Expanded salt type nutrition information panel sections

Stage 1


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Of the 62 labels including expanded salt type NIP sections in Stage 1, 82% (51 labels) were

inconsistent with the labelling provisions for this type of expanded NIP section. The prime

reason for inconsistency were:


• values (three of 51 labels); and

• units (seven of 51 labels).

Nutrients

For the 44 labels inconsistent for nutrients, the majority (43 labels) were inconsistent for case

(minor inconsistency). Other nutrient errors were related to potassium, with one instance

each of non provision (major), inconsistent positioning (major) and punctuation

inconsistency (minor).

Values

Values were only inconsistent for three labels for similar reasons to other NIP types

(intermediate or major inconsistency).


For the seven labels inconsistent for units, this was mainly due to position (six labels). The

other instance of inconsistent units was due to units used (grams were used instead of

milligrams).

Stage 2

One hundred and twenty four labels provided salt expanded NIPs in Stage 2, of which 22%

were consistent (27 of 124 labels). Thus, consistency in Stage 2, was higher than Stage 1

(18%). Inconsistencies resulted from:


• values (two of 97 labels); and



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Nutrients

In Stage 2, the majority of nutrient inconsistencies were a result of nutrients being given in

the wrong case (84 of 93 labels). Though like Stage 1, case was the most common

inconsistency for the nutrient label element sub section, this inconsistency occurred less

frequently in terms of percentage occurrence in Stage 2 when compared to Stage 1 (98% in

Stage 1 and 90% in Stage 2).

Other nutrient inconsistencies arose in Stage 2 due to potassium not being:

• present (two of 93 labels);

• positioned correctly (17 of 93 labels); and

• worded correctly (one of 93 labels).

One label was also inconsistent for punctuation.

Values

Two labels were inconsistent in Stage 2 for not expressing zero values as ‘Nil g’ or ‘0g’ but

as ‘Nil’ or ‘0’.

Units

Inconsistencies for the units label element sub section were as a result of units being:

• positioned incorrectly (12 of 14 labels);

• incorrect (one of 14 labels); and

• in the incorrect case (one of 14 labels).

4.10.3 Special nutrition information panels

Sixteen labels provided a special NIP in Stage 1, as discussed at the beginning of Section

4.10, only one label was consistent with the labelling provisions for their respective types of

product. As with Stage 1, only one of the 26 labels providing a special NIP in Stage 2 was

consistent with the requirements of the new Code for that special NIP.

4.10.3.1 Severity of special NIP inconsistencies

Table 77 and Table 78 outline the reason special NIPs were inconsistent by the severity of the

inconsistency for Stage 1 and 2 respectively. Of the 15 inconsistent labels in Stage 1, 14

labels were inconsistent for minor reasons, 11 for major reasons and seven labels for


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intermediate reasons. In Stage 2, there was a lower proportion of minor and intermediate

inconsistencies compared to Stage 1 (refer to Table 77 and Table 78). There was however,

an increase in major inconsistencies from 73% in Stage 1 to 88% in Stage 2.

It should be noted that most NIPs were inconsistent for more than one reason.

Table 77 Severity of inconsistency of special NIP for Stage 1


Inconsistent

Percentage of Total

Number of Labels

Inconsistent For Special

NIP*

Minor 14 93

Intermediate 7 47

Major 11 73

* Total number labels inconsistent for special NIP = 15. Labels could be inconsistent for more than one severity category.

Table 78 Severity of inconsistency of special NIP for Stage 2


Inconsistent

Percentage of Total

Number of Labels


NIP*

Minor 19 76

Intermediate 6 24

Major 22 88

* Total number labels inconsistent for special NIP = 25. Labels could be inconsistent for more than one severity category.

For the 15 inconsistent special NIPs in Stage 1, the main reasons for inconsistency were the

nutrients (13 labels, 87%), other inconsistencies (12 labels, 80%) and borders (12 labels,

80%) label element sub-sections. Inconsistencies also resulted from the panel heading,

serving information, column and units (refer to Table 79). This was the same in Stage 2 with

nutrients (24 labels, 96%), borders (15 labels, 60%) and other (8 labels, 32%) inconsistencies

again being the main reasons for inconsistency (refer to Table 80).


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Table 79 Reason special NIP inconsistent by label element section for Stage 1

Label Element Section Inconsistent Number of Labels Special

NIPs Inconsistent

Percentage of Total

Number of Labels


NIP*

Presence 1 7

Legibility 0 0

General reasons 3 20

Borders 12 80

Panel heading 6 40


Columns 8 53

Nutrients 13 87

Values 1 7

Units 5 33

Other 12 80

* Total number labels inconsistent for special NIP = 15. Labels may be inconsistent for more than one reason.

Table 80 Reason special NIP inconsistent by label element section for Stage 2

Label Element Section Inconsistent Number of Labels Special

NIPs Inconsistent

Percentage of Total

Number of Labels


NIP*

Presence 0 0

Legibility 0 0

General reasons 2 8

Borders 15 60

Panel heading 7 28


Columns 5 20

Nutrients 24 96

Values 1 4

Units 6 24

Other 8 32

* Total number labels inconsistent for special NIP = 25. Labels may be inconsistent for more than one reason.


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4.10.3.2 Formulated caffeinated beverages

Stage 1

Of the four formulated caffeinated beverage products studied in Stage 1, only two were new

Code labels and hence fully assessed. Both these labels were inconsistent, as one only

provided the standard NIP and the other only a composition information panel (both labels

are required to provide both NIP types). Only the sample with the composition information

panel provided will be discussed here as the standard NIP has been covered under that NIP

type section (4.10.1).

The composition information panel was inconsistent with the labelling requirements due to

the panel heading, nutrients and other inconsistencies label element sub sections.

Panel heading

The panel heading was inconsistent due to alignment, case and wording of the heading.

Inconsistencies with wording were owing to the use of ‘Compositional’ instead of

‘Composition’.

Nutrients

Nutrient inconsistencies were as a consequence of not all nutrients being provided and the

positioning of these nutrients in the special NIP. The nutrients not provided were thiamin,

riboflavin, pantothenic acid and inositol. The nutrients inconsistently positioned were taurine

and glucoronolactone.

Stage 2

Three labels in Stage 2 for formulated caffeinated beverage products were assessed as being

produced to the requirements of the new Code. These three labels were assessed as

inconsistent for this label element section due to the borders, panel heading, and nutrients

label element sub sections.


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Borders

All three of the labels assessed for providing a formulated caffeinated beverage special NIP,

were inconsistent for the borders labels element sub section. The reasons for borders

inconsistency were:

• the absence of external special NIP borders (two of three labels); and

• the absence of internal special NIP borders (two of three labels).


Panel heading

Inconsistencies as a result of the compositional information panel heading occurred in 100%

(three of three labels) of labels assessed for this label element. These inconsistencies were

due to the:

• compositional information panel heading missing (two of three labels); and

• incorrect alignment of the compositional information panel heading (one of three

labels).

Nutrients

Of the three labels assessed for the formulated caffeinated beverage label element section, all

were inconsistent for not providing required nutrients, two were inconsistent for providing

nutrients in the wrong position, two for incorrect wording of nutrients, and two for nutrients

being given in the wrong case.

Nutrients not provided were thiamin (three of three labels), riboflavin (two of three labels),

and glucuronolactone (one of three labels). The nutrients incorrectly positioned were

pantothenic acid (two of three labels), taurine (two of three labels), glucuronolactone (one of

three labels) and inositol (two of three labels). Riboflavin and niacin were incorrectly

worded in one and two cases respectively.

4.10.3.3 Formulated meal replacements

Stage 1

Only one of the four formulated meal replacements in Stage 1 was a new Code label, and

subsequently fully assessed. This label was assessed as inconsistent due to:


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• nutrients inconsistent with labelling provisions for position, wording and case.;

• thiamin and riboflavin were worded as their vitamin B numbers (i.e. vitamin B1 and

B2); and

• some values were either missing in each column or placed outside the NIP.

Stage 2

Three of the four formulated meal replacements sampled in Stage 2 were assessed as being

produced to the requirements of the new Code. These three labels were assessed as

inconsistent due to the nutrients, units and other label element sub sections.

Nutrients

All three labels assessed as a formulated meal replacement were inconsistent due to the

nutrients label element sub section. These inconsistencies arose as a result of nutrients not

being provided when required (two of three labels), nutrients not being worded correctly (one

of three labels), and nutrients being given in the wrong case (one of three labels).

Nutrients that were not provided when required included:

• vitamin D (one of two labels);

• vitamin E (one of two labels);

• iodine (one of two labels);

• iron (one of two labels);

• magnesium (one of two labels);

• zinc (one of two labels);

• inorganic chromium (one of two labels);

• organic chromium (one of two labels);

• inorganic copper (one of two labels); and

• organic copper (one of two labels).

Vitamin D was incorrectly worded in one instance.

Units

One label was inconsistent for units due to positioning units next to the actual nutrient name

not the nutrient value.


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Other inconsistencies

Inconsistencies as a result of other special NIP components occurred in two labels due to:

• information being provided for manganese, molybdenum and selenium, however not

being broken down into organic and inorganic; and

• an extra ‘Vitamins and Minerals’ heading being provided within the NIP.

4.10.3.4 Electrolyte drinks

Stage 1

Of the seven electrolyte drinks and drink bases sampled, none were new Code labels and

hence were not included in the assessment.

Stage 2

Five electrolyte drinks and drink bases were assessed as being produced to the new Code in

Stage 2. One of the five labels assessed was consistent with the requirements of the new

Code for this label element section. Inconsistencies in the four inconsistent labels were due

to nutrients required to be provided in the special NIP not being given (four of four labels),

nutrients being in the wrong case (two of four labels), and nutrients having the wrong

punctuation (one of four labels).

The nutrients that were required to be provided in the four electrolyte drinks and electrolyte

bases that were not provided were:

• sucrose (one of four labels);

• potassium phosphate (two of four labels);

• potassium citrate (three of four labels);

• sodium chloride (three of four labels); and

• calcium (one of four labels).


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4.10.3.5 Formulated supplementary foods

Stage 1

Of the eight products studied for formulated supplementary foods and formulated

supplementary foods for young children, only one was a new Code label and therefore fully

assessed. That sample was consistent with the appropriate special NIP labelling

requirements.

Stage 2

All three of the labels assessed as being produced to the new Code in Stage 2 were

inconsistent in meeting the requirements of this Code. Inconsistencies were due to the

nutrients, units and other label element sub sections.

Nutrients

Inconsistencies as a result of the nutrients label element sub section occurred in 100% of

labels (three of three labels) assessed for this label element section. These labels were

inconsistent due to nutrients not being:

• provided in the NIP when added to the product (two of three labels);

• in the correct position (one of three labels);

• worded correctly (three of three labels); and

• in the correct case (one of three labels).

All labels with nutrients worded incorrectly were due to the nutrients thiamin and riboflavin

being given as their B group numbers (e.g. vitamin B1 and vitamin B2).

Units

One label was inconsistent for the units label element sub section due to units being provided

next to the nutrient name not the nutrient values.


One label had another label inconsistency due to the presence of additional ‘Vitamins’ and

‘Minerals’ headings in the NIP.


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4.10.3.6 Infant formula

Stage 1

For infant formula products, two forms of NIPs were permitted in July 2002. Given this, all

four products sampled were fully assessed.

All of these NIPs were found to be inconsistent, for the reasons detailed in Table 81.

Table 81 Reason infant formula special NIP inconsistent by label element section for

Stage 1


Inconsistent

Percentage of Total

Number of Labels

Inconsistent For Infant

Formula Special NIP*

Presence 0 0

Legibility 0 0


Borders 4 100

Panel heading 1 25


Columns 3 75

Nutrients 3 75

Values 0 0

Units 3 75

Other 3 75

* Total number labels inconsistent for infant formula special NIP = 4

General reasons

The two inconsistencies for the general reasons label element section were due to NIPs being

split in half and the two parts being placed side by side.

Borders

For the four labels inconsistent for borders, this was due to either all the required internal

borders not being provided (two labels) or extra internal borders (two labels) being provided.

Panel heading

The panel heading was inconsistent on one label due to inconsistent wording relating to both

‘Nutrition’ and ‘Information’.


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Columns

The three labels inconsistent for columns were all inconsistent for wording. Additionally, the

columns were inconsistently positioned for one label, as the ‘100g powder’ and ‘made up

formula’ columns were reversed. Column wording was inconsistent because the word

‘average’ was abbreviated and the word ‘amount’ was missing.

Nutrients

For the three labels inconsistent for nutrients, this was because of case, position and wording

for all three labels. Nutrient presence and punctuation was also inconsistent for two and one

labels, respectively. The required nutrients not provided were vitamin C, niacin, pantothenic

acid, selenium, chloride, potassium and sodium. For the three inconsistent NIPs, the order in

which nutrients were provided varied from the prescribed format. Vitamins D and K were

the principal causes of wording inconsistencies as numbers were provided with these.

Vitamin B6 and pantothenic acid were also inconsistently worded.

Units

Three labels were inconsistent for units due to the units used and their position. Incorrect

units were used for:

• energy (kCal instead of Cal);

• vitamin E (milligrams instead of micrograms); and

• vitamin K (milligrams instead of micrograms).

Other Inconsistencies

The three labels with other inconsistencies were inconsistent due to a ‘Major Nutrient’

heading provided above the nutrient column, the inclusion of extra nutrients (old Code format

NIP), the position of column headings and the calorie values not being declared in brackets.

Table 82 details other nutrients provided for these types of NIPs.



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Table 82 Other nutrients provided in infant formula NIP for Stage 1

Other Nutrient Provided Number of Labels Percentage of Labels*

Chlorine# 2 50

Carnitine 1 25

Taurine 3 75

Whey / Casein Ratio 2 50

Beta Carotene 1 25

* Total of infant formula special NIPs assessed = 4

# Chloride is included in the prescribed NIP but not Chlorine

Stage 2

All four infant formula labels sampled in Stage 2 were also assessed and were inconsistent

for reasons detailed below (refer to Table 83).

Table 83 Reason infant formula special NIP inconsistent by label element section for

Stage 2


Inconsistent

Percentage of Total

Number of Labels


Formula Special NIP*

Presence 0 0

Legibility 0 0

General reasons 0 0

Borders 4 100

Panel heading 1 25


Columns 2 50

Nutrients 3 75

Values 0 0

Units 3 75

Other 1 25

* Total number labels inconsistent for infant formula special NIP = 4

Borders

As with Stage 1, the borders label element sub section accounted for the highest proportion of

infant formula special NIP inconsistencies in Stage 2 (four of four labels). These

inconsistencies were due to:

• the absence of external borders (two of four labels);

• the absence of internal borders (two of four labels); and

• the presence of extra internal borders (two of four labels).


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Panel Heading

One label was inconsistent for the panel heading label element sub section as a result of the

incorrect alignment of the heading.

Columns

Two of the four labels assessed for infant formula special NIPs were inconsistent for the

columns label element sub section. This was due to the absence of the ‘100g powder’

column (two of two labels), and the use of the words ‘prepared feed’ in the column headings

instead of the words ‘made up formula’ (two of two labels).

Nutrients

Three labels were inconsistent for nutrients for the infant formula label element section as a

result of nutrients not being provided (two of three labels), nutrients being incorrectly

positioned (two of three labels), nutrients being incorrectly worded (one of three labels), and

nutrients being given in the wrong case (one of three labels).

In comparison with Stage 1, the nutrients not provided for the two labels inconsistent for

nutrient provision were more numerous and included vitamin B6, vitamin B12, vitamin D,

vitamin E, vitamin K, biotin, niacin, folate, pantothenic acid, copper, iodine, magnesium,

manganese, selenium, zinc and chloride.

Units

Two of the three labels inconsistent for units were for the positioning of units in a location

that differed from the prescribed format. Furthermore, two labels were assessed as

inconsistent for providing incorrect units.

It should be noted that labels could be inconsistent for more than one reason.


One of the four labels assessed for infant formula special NIP was inconsistent for other

inconsistencies as an additional ‘Vitamins and Minerals’ heading was provided in the special

NIP and serving information was provided where not required.


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4.10.3.7 Infant food

Stage 1

All eight infant food products sampled in Stage 1 were fully assessed since it was difficult to

determine the Code used based on the NIP, as saturated fat is not required in the new Code

NIP format for infant foods.

All labels were inconsistent for this label element. Table 84 details the reasons they were

inconsistent by label element sections of the NIP assessed, the main reasons being borders,

serving information and nutrients.

Table 84 Reason infant food special NIP inconsistent by label element section for

Stage 1


Inconsistent

Percentage of Total

Number of Labels


Food Special NIP*

Presence 0 0

Legibility 0 0

General reasons 0 0

Borders 8 100

Panel heading 4 50


Columns 5 63

Nutrients 8 100

Values 1 13

Units 2 25

Other 6 75

* Total number labels inconsistent for infant food special NIP = 8. Labels may be inconsistent for more than one reason.

Borders

Borders were inconsistent for all eight labels due to extra internal borders being provided.

Panel heading

The panel headings were inconsistent for four of the eight labels due to alignment, case and

wording. The wording inconsistency was due to ‘Nutrition’ being given as ‘Nutritional’.


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Serving information

The reasons why serving information was inconsistent were errors with case (eight labels),

position (four labels) and wording (five labels) (refer to Table 85). In all cases, serving

information position was inconsistent due to sharing the line with the column headings.

‘Servings per package’, and ‘servings size’ were also placed in the wrong order on some

labels.

Table 85 Reason infant food special NIP serving information inconsistent for Stage

1


Inconsistent

Percentage of Total

Number of Labels


Food NIP Serving

Information*

Servings per package present 0 0

Servings per package position 4 50

Servings per package alignment 0 0

Servings per package punctuation 0 0

Servings per package case 7 88

Servings per package wording 5 63

Serving size present 0 0

Serving size position 4 50

Serving size alignment 1 13

Serving size punctuation 0 0

Serving size case 8 100

Serving size wording 1 13

* Total number labels inconsistent for infant food NIP serving information = 8. Labels may be inconsistent for more than one reason.

The reason why five labels had inconsistent wording for ‘servings per package’ was the

wording of ‘package’, with only one label having inconsistent wording for ‘servings’.

Columns

Five labels were assessed as inconsistent for the columns label element section, due to

wording inconsistencies (three labels), other inconsistencies (two labels) and presence (one

label). One sample only provided one column because the serving size equalled 100g/100mL.

For the three labels inconsistent for wording this was due to ‘Quantity’ not being provided

for all labels, with one label where ‘Serving’ was called ‘Serve’ and one label where

‘Quantity’ was abbreviated.


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Nutrients

For the eight labels inconsistent for nutrients, this was as a result of case and punctuation

(seven labels each), and wording (two labels). The main reason why wording was

inconsistent on two labels was for ‘Fat, total’, due to ‘, total’ not being provided.

A number of other nutrients were provided, related to claims made; these are detailed in

Table 86.

Table 86 Other nutrients provided in infant food NIP for Stage 1

Nutrients Provided Number of Labels

Providing ‘Other’

Nutrient

Percentage of Total

Number of Labels


Nutrients*

Gluten# 2 25

Vitamin C 2 25

Iron 5 63

Thiamin 4 50

Riboflavin 4 50

Niacin 4 50

Calcium 2 25

Phosphorous 1 13

Folate 1 13

Lactose 1 13

*Total number of labels providing ‘other’ nutrients = 8. Labels may declare more than one additional nutrient.

# Not a nutrient, but permitted to be declared in NIP

Values

One infant food was inconsistent for values due to a symbol being used to represent a

mathematical value (‘<’ rather than ‘less than’).

Units

Two labels were inconsistent for units, as a result of position, case and units used. Energy

was inconsistent for case and units used (kCal used and expressed in the wrong case).


The six labels inconsistent for other reasons were a result of calorie values not appearing in

brackets (five labels) and provision of saturated fat where no claim was made (one label).


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Stage 2

Similar to Stage 1, all eight infant food products sampled were fully assessed in Stage 2. Of

these eight labels, all were inconsistent. Reasons for inconsistency are detailed in Table 87

and discussed below.

Table 87 Reason infant food special NIP inconsistent by label element section for

Stage 2


Inconsistent

Percentage of Total

Number of Labels


Food Special NIP*

Presence 0 0

Legibility 0 0


Borders 8 100

Panel heading 3 38


Columns 3 38

Nutrients 8 100

Values 1 13

Units 1 13

Other 1 13

*Total number labels inconsistent for infant food special NIP = 8. Labels may be inconsistent for more than one reason.

General reasons

Both labels inconsistent for general reasons in Stage 2 were due to labels not indicating that

nutrition information values were averages.

Borders

In Stage 2, two labels were inconsistent for not providing external borders, and all eight

labels were inconsistent for providing extra internal borders.

Panel heading

Of the three labels inconsistent for the panel heading label element sub section, two were

inconsistent for the alignment of the panel heading and two due to the case of the panel

heading.


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Serving information

Serving information was inconsistent for all eight labels due to serving information position

(five of eight labels), case (seven of eight labels), and wording (three of eight labels). For the

labels inconsistently positioned, serving information shared the same line as the column

headings.

Wording inconsistencies in Stage 2 were a result of ‘package’ (three of three labels) in the

‘Servings per package’ information.

Table 88 Reason infant food special NIP serving information inconsistent for Stage

2


Inconsistent

Percentage of Total

Number of Labels


Food NIP Serving

Information*

Servings per package present 0 0

Servings per package position 5 63

Servings per package alignment 0 0

Servings per package punctuation 0 0

Servings per package case 7 88

Servings per package wording 3 38

Serving size present 0 0

Serving size position 5 63

Serving size alignment 0 0

Serving size punctuation 0 0

Serving size case 7 88

Serving size wording 0 0

* Total number labels inconsistent for infant food NIP serving information = 8. Labels may be inconsistent for more than one reason.

Columns

All column inconsistencies were due to the column heading wording (three of three labels).

Two of the three labels abbreviated the word ‘quantity’ in the column heading and one label

gave the products actual serving size in the column heading.

Nutrients

Nutrient inconsistencies in Stage 2 were as a result of nutrients not being:

• present (one of eight labels);

• positioned consistently (one of eight labels);


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• worded consistently (two of eight labels);

• in the right case (eight of eight labels); and

• punctuated consistently (three of eight labels).

For the one label inconsistent for nutrient presence, the missing nutrient was an ‘other’

nutrient required to be present due to the label making a claim about that nutrient. The

position of ‘Carbohydrate’ and ‘sugars’ was also inconsistent on one label.

Nutrient wording inconsistencies in Stage 2 were as a result of:

• ‘Fat, total’ (one of two labels);

• ‘Carbohydrate’ (two of two labels);

• ‘sugars’ (one of two labels); and

• ‘other’ nutrient/s (one of two labels).

‘Other’ nutrients provided in infant food special NIPs are given in Table 89.

Table 89 Other nutrients provided in infant food NIP in Stage 2

Nutrients Provided Number of Labels


Nutrient

Percentage of Total

Number of Labels


Nutrients*

Gluten# 4 67

Vitamin C 3 50

Iron 1 17

Lactose 1 17

Saturated fat 2 33

Sodium 3 50

* Total number of labels providing ‘other’ nutrients = 6. Labels may declare more than one additional nutrient.

# Not a nutrient, but permitted to be declared in NIP

Values

One label was inconsistent for the values label element sub section in Stage 2, for giving a

mathematical term as a symbol (e.g. ‘<’ instead of ‘less than’).

Units

Reasons for unit label element sub section inconsistencies in Stage 2 were due to ‘Energy’

units being given as ‘kcal’ not ‘Cal’ and because the case used for ‘cal’ was inconsistent

(‘cal’ instead of ‘Cal’).


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One label was inconsistent for other inconsistencies due to calories not being given in

brackets.

4.11 Percentage daily intake information

Of the 359 labels providing NIPs in Stage 1, 17% (60 labels) provided percentage daily

intake information. For these 60 labels, the optional percentage daily intake column in the

NIP was only used in 30% of these cases (18 labels). For Stage 2, 130 labels providing an

NIP provided percentage daily intake information (12%, 130 of 1078 labels). Of these 130

labels, 12% used the optional percentage daily intake column (16 of 130 labels).

Where the optional column was not used, percentage daily intake information was given

adjacent to the corresponding nutrient value.

4.12 Ingredient declaration

Stage 1

Eighty four percent (378 of 448 labels) of labels in Stage 1 required or voluntarily provided

an ingredient declaration. Only one of these labels was inconsistent as it was not legible due

to visibility.

Stage 2

Of the 1153 labels assessed for Stage 2, 1058 (92%) required or voluntarily provided an

ingredient declaration. Thirteen of the 1058 labels were inconsistent, three for failing to

provide an ingredient list when one was required and ten due to illegibility. The reasons that

these labels were assessed as inconsistent for legibility are due to the ingredient declaration

not being:

• indelible (three of ten labels);

• distinct from label decoration (two of ten labels);

• distinct from label text (three of ten labels); and

• visible (two of ten labels).


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4.13 Characterising ingredients

Stage 1

Of the 448 labels fully assessed in Stage 1, 378 labels were assessed as having characterising

ingredients present. Of the 70 labels with no characterising ingredients required to be

declared, 5 labels voluntarily provided characterising ingredients.

Including labels voluntarily providing characterising ingredient information, 383 labels were

eligible for assessment for characterising ingredients. Of these 383 labels, 145 labels were

consistent with the labelling provisions, with 103 labels exempt. The remaining 135 labels

were inconsistent (refer to Table 90).

Table 90 Consistency status of characterising ingredients by major food category

for Stage 1

Consistency Status of characterising ingredient

Consistent Inconsistent Exempt

Major Food Category

Total Number

of Labels


1. Dairy 32 13 (41) 11 (34) 8 (25)




5. Confectionery 12 9 (75) 3 (25) 0 (0)









14. Mixed foods 71 25 (35) 45 (63) 1 (1)

Overall Results 383 145 (38) 135 (35) 103 (27)

* Includes characterising ingredients voluntarily provided and excludes labels where no characterising ingredients were present

Table 91 details the types of characterising ingredients not declared. Of the 135 inconsistent

labels, 111 were inconsistent due to ingredients present in the product description not being

declared, 102 due to ingredients in the product name not being declared and 32 labels due to


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ingredients pictured or in graphics not being declared. It should be noted that labels were

often inconsistent for more than one reason.

Table 91 Reason characterising ingredient not declared for Stage 1


Inconsistent


Inconsistent*

Characterising ingredients in product name not declared 102 76

Characterising ingredients in product description not declared 111 82

Characterising ingredients in graphics or pictures (no serving suggestion) not

declared 32 24

* Total number of labels inconsistent for characterising ingredients = 135. Labels may be inconsistent for more than one reason.

Stage 2

In Stage 2, 904 labels were required to provide characterising ingredient information. Of

these 904 labels, 33 labels also gave the percentage presence of other ingredients not assessed

as being characterising ingredients.

An additional 34 labels assessed as not required to declare the percentage of characterising

ingredients, voluntarily gave these percentages. Therefore, a total of 938 labels were

assessed for this label element in Stage 2.


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Table 92 Consistency status of characterising ingredients by major food category

for Stage 2

Consistency Status of characterising ingredient

Consistent Inconsistent Exempt

Major Food Category

Total Number

of Labels


1. Dairy 79 34 (43) 21 (27) 24 (30)




5. Confectionery 49 39 (80) 10 (20) 0 (0)









14. Mixed foods 226 128 (57) 95 (42) 3 (1)

Overall Results 938 536 (57) 277 (30) 125 (13)

* Includes characterising ingredients voluntarily provided and excludes labels where no characterising ingredients were present

Of the 938 labels requiring or voluntarily providing characterising ingredients, 57% were

consistent with the requirements of the new Code, considerably higher than that reported for

Stage 1. However, the percentage of inconsistent labels in Stage 2 was similar to that of

Stage 1, with 30% of labels being inconsistent (refer to Table 92).

One label in Stage 2 was indeterminable as to whether or not characterising ingredients

present in the product name and product description were declared, as the ingredient list was

not legible.

Reasons for inconsistency in Stage 2, were primarily due to characterising ingredients given

in the product’s name not being declared (70%, 195 of 277 labels). Characterising

ingredients given in the product’s description not being declared accounted for 51% (142 of

277 labels) of inconsistencies, whilst characterising ingredients given in pictures or graphics

on the label not being declared accounted for 25% (70 of 277 labels) (refer to Table 93).


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Table 93 Reason characterising ingredient not declared for Stage 2


Inconsistent


Inconsistent*

Characterising ingredients in product name not declared 195 70

Characterising ingredients in product description not declared 142 51

Characterising ingredients in graphics or pictures (no serving suggestion) not

declared 70 25

* Total number of labels inconsistent for characterising ingredients = 277. Labels may be inconsistent for more than one reason.

4.14 Compound ingredients

Stage 1

Only 20% (90 labels) of labels in Stage 1 declared the presence of compound ingredients. Of

these 90 labels, 71% (64 labels) were consistent, with 5 labels indeterminable and 23% (21

labels) inconsistent (refer to Table 94).

Table 94 Consistency status for compound ingredients by major food category for

Stage 1

Consistency Status


Major Food Category

Total Number

of Labels


1. Dairy 9 7 (75) 2 (25) 0 (0)




5. Confectionery 5 3 (67) 2 (33) 0 (0)









14. Mixed foods 38 26 (68) 9 (23) 3 (8)

Overall Results 90 64 (71) 21 (23) 5 (6)

*Excludes labels which did not contain compound ingredients

For the 21 inconsistent labels, 19 labels did not provide all ingredients present in compound

ingredients where the compound ingredient was present at greater than 5%. This is possibly


Page 168 of 187

due to the fact that in the old Code, ingredient declarations were not required unless the

ingredient was present at greater than 25%.

Stage 2

Two hundred and seventy-eight labels were assessed in Stage 2 for the compound ingredient

label element. Of these 278 labels, 70% (194 of 278 labels) were consistent in providing

required information regarding compound ingredients, three percent inconsistent, and 27%

indeterminable (refer to Table 95).

Table 95 Consistency status for compound ingredients by major food category for

Stage 2

Consistency Status


Major Food Category

Total Number

of Labels


1. Dairy 13 8 (62) 2 (15) 3 (23)




5. Confectionery 23 16 (70) 1 (4) 6 (26)









14. Mixed foods 115 72 (63) 4 (3) 39 (34)

Overall Results 278 194 (70) 8 (3) 76 (27)

*Excludes labels which did not contain compound ingredients

Reasons for inconsistency in Stage 2 were due to all ingredients not being declared where the

compound ingredient was present at greater than 5% (75%, six of eight labels), and food

additives and/or allergens not being declared where the compound ingredient was present at 5%

or less (38%, three of eight labels).


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4.15 Genetically modified foods and ingredients

One label in Stage 1 declared the use of genetically modified ingredients. This label was

consistent with the labelling requirements for this label element. No labels in Stage 2

declared the use of genetically modified ingredients.

Stage 1

Three percent (14 labels) of labels assessed in Stage 1 made claims to the effect that a

product was free of genetic modification. These claims were made in a number of different

formats, with the most common being ‘Every ingredient has been/is certified by suppliers as

not known to contain GM material’ – accounting for six labels) of the claims made. Details

of all ‘genetically modified free’ statements used in Stage 1 are given in Table 96.

Table 96 Details of ‘genetically modified free’ statements used for Stage 1

Statement Type Used Number of Labels

With Claim


With Claim*

Every ingredient has been certified by suppliers as not known to contain GM material 6 43

Every ingredient is certified by suppliers as not known to contain GM material 1 7

GE free 1 7

No genetically modified ingredients 1 7

X does not contain any genetically modified ingredients 1 7

Made from non-genetically modified soy 2 15

GM free 2 15

* Total number of labels with ‘genetically modified free’ claim = 14

X = product name

Stage 2

Twenty-nine labels in Stage 2 (three percent) used ‘genetically modified free’ statements. The

range of types of ‘genetically modified free’ claims used in Stage 2 was greater than that of

Stage 1, however the statement ‘Every ingredient has been/is certified by suppliers as not

known to contain GM material’ (five of 29 labels) was still the most commonly used

statement. The statements ‘GE free’, ‘GM free’ and ‘free of genetic modification’ were also

commonly used (three labels each) (refer to Table 97).


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Table 97 Details of ‘genetically modified free’ statements used for Stage 2

Statement Type Used Number of Labels

With Claim


With Claim*

Every ingredient has been certified by suppliers as not known to contain GM material 5 (17)

Every ingredient has certified as not known to contain GM material 1 (3)

GE free 3 (10)

No genetically modified ingredients 2 (7)

No genetically modified ingredients used 1 (3)

Free from genetically engineered rice 2 (7)

Made from non-GM canola 1 (3)

GM free 3 (10)

Our flax seeds are not genetically altered 1 (3)

Free of genetic modification 3 (10)

Free from genetic modification 1 (3)

GMO free 2 (7)

Non GMO 1 (3)

Ingredients are not genetically modified 1 (3)

All X are vegan and we DO NOT use GM products 1 (3)

Guaranteed GM free 1 (3)

* Total number of labels with ‘genetically modified free’ claim = 29

X = product name

4.16 Irradiated foods and ingredients

Nineteen percent of labels in Stage 1 and 20% of labels in Stage 2 were herbs, spices or

herbal infusions, or contained these types of ingredients. In both Stages, no labels declared

the use of irradiation. For the purposes of this survey herbs and spices were assessed as they

are currently the only foods permitted to be irradiated at the time.

4. results & discussion · 2018-06-27 · 4. results & discussion the different...

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