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Proposal P274 – Review of Minimum Age Labelling of Foods for Infants – Preliminary Final Assessment Report

23 September 2008

Dear Sir/Madam

Thank you for the opportunity to comment on 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 would like to make comment on four areas as outlined in the Executive Summary of the Preliminary Final Assessment Report (PFAR), and on subclause [2.3] (1) (c) of the draft variation.

Comment on Table 2 to clause 8

We support the proposed amendment to table 2 to clause 8 regarding a change in the reference recommended dietary intake for iron.

Comment on revised risk assessment and updated costs analysis

We are pleased the issue around sale of foods for infants suitable from the age of 4 months has been addressed with the inclusion of clause 5 (3) (b).

We support the revised risk assessment and updated cost analysis in relation to the amendment to the minimum age labelling permitted on infant foods from ‘4 months’ to ‘around 6 months’. We would however like to note that included in this risk assessment is advice from the Infant and Child Health Scientific Advisory Group highlighting the stage of an infant’s development being more important than age with regard to the introduction of solids. This will be discussed in more detail below.

Comment on proposed transition period

We support an extended transition period of 18 months.

Comment on approach to age and / or stage labelling of first complementary foods

As stated in previous submissions by NZFSA and MoH, in New Zealand, the ‘stages of development approach’ for infant feeding is recognised and supported in New Zealand policy, published most recently in Food and Nutrition Guidelines for Healthy Infants and Toddlers Aged 0-2 (‘the Guidelines’) (MoH 2008).

We are disappointed that there has not been any meaningful consideration of the stage approach, especially as we have already made a significant compromise in our submission on the Consultation Paper.

A main focus of the Guidelines is the developmental readiness to begin complementary foods, then progressing through the stages, as the infant develops, towards eating more family foods at 12 months of age. Evidence summarised in the Guidelines shows that there are risks associated with early or late introduction of complementary foods (pg 23). The ages are given as a guide, to ensure that infants are started on complementary foods at around 6 months to reduce those risks, and then progress appropriately along the texture continuum. An age and consistency only approach does not provide adequate guidance or support to those caregivers whose infants are developmentally ready to wean earlier (around 4-5 months) or later (up to 7 months), and then subsequently move through the stages of feeding safely.

We are aware of FSANZ’s objective of 'minimum effective regulation' and the importance of allowing industry to be innovative with respect to labelling. However, it is our view that variation in the labelling of infant foods around developmental stages could potentially cause consumer confusion if it were not in line with New Zealand policy. Mandating at least first stage labelling would potentially drive industry alignment with Government policy. The Guidelines offer a detailed table of the age, developmental stages, and appropriate textures and flavours, for consideration by FSANZ (pg 28).

Much of the rationale for an ‘age’ only approach is based on interpretation of consumer research carried out in 2004. It is important to note the limitations of this research; a small sample size which is unrepresentative of New Zealand consumers and it is now relatively outdated. This research does however indicate that ”participants regarded food labels as helpful in the selecting of foods once solids have been introduced, but labels had little if any influence on the decision to start introducing solid foods.” This finding has been used in the PFAR to justify an ‘age’ based approach. It is our view however that this supports our recommendation 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. This will aid caregivers in making a safe and appropriate choice at point of purchase, once they have decided to start introducing complementary foods.

As reported in the PFAR, the consultation process on P274 has widely supported a stage approach, for example:

• Results from telephone interviews with health professionals indicated ‘a stages with ages’ approach was the preferred approach for labelling. One respondent also echoed our concern around the potential risk if infants were started on solids after 6 months and then a stage of feeding was skipped because age appropriate foods were given.

• Members of the Infant and Child Health Scientific Advisory Group concluded that the stage of an infants’ development was more important with regard to the introduction of solids, than ‘age’.

• FSANZ consultation with key infant food manufacturers in New Zealand showed support of mandatory first stage labelling.

• FSANZ consultation with a key New Zealand child health professionals group was also supportive of infant food labels to include stages to guide caregivers.

Further, recent discussions between NZFSA and a leading New Zealand infant food manufacturer indicated that they, and their Australian branch, are supportive of mandatory first stage labelling in addition to age. These findings contradict those outlined in the report stating ”Australian infant food manufacturers were not supportive of mandating a ‘first stage’ approach”.

Comment on subclause [2.3] (1) (c)

As stated in previous submissions NZFSA and MoH would like subclause [2.3] (1) (c) to be reworded so that it reads; ‘may contain added thiamine, 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.

Summary

In summary, New Zealand is broadly supportive of FSANZ’s preferred approach outlined in the PFAR. However, the noticeable absence of a stage based approach to complementary feeding remains inconsistent with New Zealand guidelines on infant feeding. New Zealand again states its desire to see this approach included in FSANZ’s final considerations.

Yours sincerely

Citation: Ministry of Health (2008). Food and Nutrition Guidelines for Healthy Infants and Toddlers (Aged 0-2): A background paper. Wellington: Ministry of Health.