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Proposal P274 – Review of Minimum Age Labelling of Foods for Infants – Consultation Paper for Final Assessment

19 October 2007

Dear Sir/Madam

Thank you for the opportunity to comment on this consultation paper for proposal P274. The New Zealand Food Safety Authority (NZFSA) has consulted with the Ministry of Health (MoH) and this submission reflects the views of both organisations.

We acknowledge that FSANZ has considered our comments provided in previous submissions. We believe that two areas of concern remain in the draft variations to Standard 2.9.2 and would like to discuss these and propose a solution. NZFSA and the MoH have the following comments to make on the draft variations to Standard 2.9.2 contained at Attachment 1 of the Consultation Paper.

First area of concern: sale of foods for infants suitable from the age of four months is still allowed

As stated in the Initial Assessment Report (IAR), P274 was initially raised because of the regulatory problem that ‘while minimum age labelling required by Standard 2.9.2, ‘from 4 months’, is consistent with current New Zealand infant feeding guidelines, it is however, no longer considered consistent with revised guidelines in Australia. The revised Australian guidelines recommend the introduction of solid foods at around six months of age. This situation has the potential to create confusion for consumers (i.e. parents/carers), particularly in Australia as the labelling of infant foods will conflict with the recommended timing of the introduction of solids to infants’.

It appears that the proposed draft variation to the Food Standards Code (FSC) contained at Attachment 1 would still allow for the sale of foods for infants suitable from the age of 4 months. As there is no prohibition against the labelling of foods for infants ‘from 4 months’ the proposed draft variation does not appear to address the objective of P274, in that the continued sale of these products will be permitted. Therefore there is still the potential for consumer confusion as the labelling of infants foods may continue to be inconsistent with Australian infant feeding guidelines and revised New Zealand Food and Nutrition Guidelines for Healthy Infants and Toddlers (Aged 0-2).

Second area of concern: guidance on age ranges and associated textures is not provided

As stated in previous submissions by NZFSA and MoH, in New Zealand the ‘stages of development’ approach is well recognised and supported in policy documents and health education material. Although a reference to age may be appropriate for some, these ages are arbitrary and the key issue is: ‘is the infant ready to start solids and when is the infant ready for the next stage of food’?

We believe there are some risks associated with using an ‘age’ only approach to the labelling of foods for infants. Of concern is the absence of any guidance on what age/age ranges and associated textures should be used for these products. This will be left to the manufacturer’s discretion and has the potential for consumer confusion if different age/age ranges are used. The use of a definitive age on product labels does not recognise individual differences in development. Infants might not be developmentally ready to progress to more textured foods, despite labels stating an age from which the food is suitable.

It is also interesting to note that some Australian infant food manufacturers are now using ‘stages’ rather than ‘ages’ as the primary labelling on foods for infants (see attached advertisement).

Ideally the age/age ranges and associated textures would be defined, and not left open to manufacturer’s discretion. However we realise this would be a substantive piece of work, and would not be consistent with the FSANZ objective of minimum effective regulation. It is possible that consistency of age/age ranges and associated textures between manufacturers may develop over time, without mandating, following the release of the revised Food and Nutrition Guidelines for Healthy Infants and Toddlers (Aged 0-2): A background paper.

Proposed solution for mitigating the two areas of concern:

NZFSA and MoH recommend that the sale of food specifically aimed at infants less than 6 months of age is prohibited, including no marketing of foods labelled for infants aged 4-6 months.

To ensure that it is clear to parents/carers as to what is the most appropriate complementary food to be starting infants with, NZFSA and MoH recommend that the statement ‘around 6 months’ be accompanied with wording to the effect that this is intended as a first complementary food for the infant (where ‘complementary’ means the introduction of solid food along with the usual milk feed). The words suggested for the label are ‘Stage 1’ or ‘1^st Stage’ to be associated with ‘around 6 months’, however we wish to consider this further and discuss the options for stage labelling with FSANZ prior to the completion of the Final Assessment Report.

These actions would ensure that foods labelled as suitable for infants aged around 6 months are intended as a first complementary food.

Comment on subclause 2(4)

NZFSA and MoH do not agree that subclause 2(4) should be omitted. We support retaining this subclause along with the editorial note which follows. The substitution wording proposed in the draft variation contained at Attachment 1 makes reference to food that is ‘manufactured to a consistency that is soft and free of lumps’. We believe that parents/carers need to be assured that first foods are of an appropriate consistency which minimises the risk of choking.

Comment on Subclause [2.2] (1) (c)

NZFSA and MoH would like subclause [2.2] (1) (c) to be reworded so that it reads; ‘may contain added thiamin, niacin, vitamin B6, vitamin C, folic acid, magnesium in the forms permitted in Schedule 1 of Standard 2.9.1’ as it is folic acid which is added not folate. This is consistent with the position we have taken in previous submissions regarding the addition of folic acid to food and it remains an area of ambiguity as written in the proposed draft variation.

Yours sincerely