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• Food label monitoring survey (10)

Food industry information sheet

Results of food label monitoring surveys: Identifying key labelling issues

Why is FSANZ conducting ongoing label monitoring surveys?

Food Standards Australia New Zealand (FSANZ) has been conducting food label monitoring surveys since 2002 to assess how food manufacturers are interpreting and managing key labelling requirements set out in the Australia New Zealand Food Standards Code (the Code). In any one year of the survey, approximately 1200 food labels are collected and assessed for consistency against key labelling requirements in the Code.

From these ongoing food label monitoring surveys, FSANZ can determine the effectiveness of current labelling regulatory measures and use the data to make better informed decisions about labelling regulations in future.

Correct labelling is considered an important aspect for FSANZ to achieve one of its objectives of ensuring consumers have adequate information on food labels to assist them to make an informed choice.

These ongoing surveys are not being conducted for enforcement purposes, as this is the responsibility of the governments of Australia and New Zealand and the Australian States and Territories, and not FSANZ. FSANZ, in parallel with many jurisdictions and food industry organisations, is considering the best ways to assist manufacturers to obtain and utilise helpful information on labelling requirements.

When were the surveys held?

Phase 1 surveys were conducted in 2002 and 2003. The first stage was carried out in 2002 before new labelling regulations (as set out in the Code) became mandatory on 20 December 2002, and was a benchmark for further measurement. The second stage was carried out in 2003 while some long life goods produced under old labelling regulations were still on the shelf.

Phase 2 surveys were conducted in 2005 and 2006, with the report of the 2005 survey scheduled to be published on the FSANZ website in early 2008.

This paper presents a summary of results from the Phase 1 survey report Food Label Monitoring Survey, Phase 1 Pilot Report (incorporating Stages 1 and 2), July 2002-December 2003.

What products were surveyed?

Phase 1 surveys aimed to examine the labels of 1200 packaged food items each year, selected from 14 food categories (approximately 2.5% of available product lines) from a range of outlets including both supermarkets and small retailers. The sample was broadly representative of products available for sale in Australia and New Zealand and, for each category, sample numbers were calculated based on the level of variety within that food category.

What were the key labelling requirements surveyed?

For the surveys, each label was assessed for consistency against twelve key labelling requirements in the Code. These were:

1. Overall label legibility
2. Product name
3. Date markings
4. Storage instructions
5. Usage instructions
6.  Allergen labelling
7.  Mandatory advisory statements
8.  Nutrition information panel (NIP)
9. Percentage daily intake information
10.  Ingredient declarations
11.  Characterising ingredients
12.  Compound ingredients

What did the surveys find?

A summary of the main findings are provided in Table 1:

Table 1             Percentage of labels consistent with key labelling requirements (for labels required to or voluntarily providing information)

Labelling requirement	2002 % consistent	2003 % consistent
Overall label legibility	92	91
Allergen declarations*	100	100
Mandatory advisory statements*	100	100
I ngredient declarations*	99	99
Usage instructions*	100	99
Product name*	100	99
Storage instructions	89	93
Date markings	72	80
Compound ingredients	71	70
Characterising ingredients	38	57
Nutrition information panel #	0	0

*Based on legibility only

# Standard NIP only. The reasons an NIP may have been assessed as inconsistent were grouped into major, intermediate and minor.

From Table 1, very high levels of consistency were noted for key labelling requirements such as overall legibility of labels, allergen declarations, mandatory advisory statements, ingredient declarations, usage instructions and product name.

Key labelling requirements that showed lower levels of consistency included storage instructions, date markings, compound ingredients and labelling of characterising ingredients (percentage labelling).

Labelling requirements in relation to the NIP presented some problems. Virtually all standard NIPs were assessed as inconsistent; however, inconsistencies were predominantly classed as minor, as they related to formatting issues.

What were the major reasons for label inconsistencies?

Nutrition information panel

In assessing the NIP it was assumed that the panel should be in exactly the same format as that prescribed in Standard 1.2.8 of the Code

In 2002, 64% of NIPs had major inconsistencies, while in 2003, 51% had major inconsistencies. In both years, predominant reasons for major inconsistencies included failure to indicate that NIP values were averages, incorrect position or order of nutrients in the panel, the absence of nutrients (the nutrient most commonly not declared was ‘sugars’), the use of symbols rather than words to describe mathematical terms, inconsistent units, absence of ‘servings per package’ or ‘serving size’ and absence of one of the required columns.

In both years, virtually all labels assessed had minor inconsistencies, and almost half of all labels had intermediate inconsistencies. Minor and intermediate inconsistencies included the absence of external and internal borders, the presence of extra internal borders, incorrect alignment and wording of panel headings, incorrect case, position and wording of serving information, inconsistent wording for column headings, incorrect case, punctuation and omission of words (e.g. ‘total’) in relation to nutrients, and the use of ‘Nil’ or ‘0’ rather than ‘Nil g’ or ‘0 g’,

Characterising ingredients

In 2002, 35% of labels assessed for characterising ingredients were inconsistent with requirements. The majority of these labels were inconsistent due to ingredients present in the product description not being declared. In 2003, 30% of labels assessed for characterising ingredients were inconsistent. In contrast to 2002, the majority of these labels were inconsistent due to ingredients present in the product name not being declared.

Compound ingredients

In 2002, 23% of labels that declared the presence of compound ingredients were inconsistent with requirements. In 2003, only 3% of labels that declared the presence of compound ingredients were inconsistent. For both years, the majority of these inconsistent labels failed to provide all ingredients present in the compound ingredient where the compound ingredient was present at greater than 5%.

Date marking

Fifteen percent of labels in 2002 and 11% of labels in 2003 were inconsistent with requirements for this label element, due to the incorrect or inappropriate use of date marking statements. The main reasons were:

• the statement used being incorrect or inappropriate as a result of:
  • ‘best before’ provided where a ‘use by’ statement was necessary
  • statement other than ‘best before’ or ‘use by’ provided (e.g. ‘BB’, ‘Best By’, ‘Use By Date’, ‘EXP’, ‘Expiration date’)
• provision of a date only, without any accompanying statement
• the use of multiple terms (e.g. both ‘best before’ and ‘use by’ provided)
• the use of incorrect date formats
• the date itself not being placed with the statement, with no indication of its location.

Storage instructions

In both 2002 and 2003, there were high levels of consistency for providing storage instructions before opening. However, levels of consistency were lower for providing storage instructions after opening for multiple serve products. Such products included pickled vegetables, canned fruits, canned fish, canned vegetables and sauces.

Allergen labelling

In addition to an assessment against legibility requirements, data were collected to determine how allergens were currently declared and the prominence given to allergen statements.

Allergen declarations outside the ingredient list

In both years, statements that a food contains an allergen (primarily gluten-containing cereals, milk and soybean) were predominantly placed near the ingredient list. In 2002 such statements were mostly printed in a bold font, giving these statements good prominence on the label. Conversely, in 2003, ‘food contains allergen’ statements’ were primarily given in standard font. For both years, the font size of ‘food contains allergen’ statements compared to the font size of the ingredient list was the same in over 80% of labels.

Declarations of allergens in the ingredient list

In both years, the majority of labels declared allergens in the ingredient list rather than using a separate statement. Fifty-seven percent of labels in 2002 and 63% of labels in 2003 declared allergens in the ingredient list. In both years, the use of common names (rather than ingredient names or a mixture of both common and ingredient names) was the primary method used to declare allergens (59% in 2002 and 82% in 2003). In both years, allergens were generally not bolded for emphasis when declared in the ingredient list. The types of allergens declared in the ingredient list were primarily gluten-containing cereals, milk and soybean.

‘May contain allergen’ statements

Twelve percent of labels in 2002 and 20% of labels in 2003 provided ‘may contain allergen’ statements. As with ‘food contains allergen’   statements, in both years ‘may contain allergen’ statements were predominantly placed near the ingredient list, with over 80% of labels providing ‘may contain allergen’ statements in this position. The types of allergens declared in ‘may contain allergen’ statements were primarily nut, peanut, sesame and milk.

In the majority of cases, statements took the format of ‘May contain traces of X’. Variations on this theme included:

•  ‘May contain X traces’
• ‘This product may contain traces of X’
•  ‘This product may contain X’
•  ‘May contain X’.
• ‘Produced in a factory handling X’
•  ‘Manufactured/made in a facility where X is also produced and therefore may contain traces’
• ‘Manufactured/made on equipment that also processes/manufactures products containing X’.

What other label monitoring activities are being undertaken?

In 2005, a re-assessment of 2003 labels was conducted to look specifically at how food manufacturers present nutrition, health and related claims on packaged food labels. The final report of this survey On-going Food Label Monitoring Survey in Australia and New Zealand: Report on the Re-assessment of 2003 Labels for Nutrition, Health and Related Claims was published in October 2005.

A report on the assessment of 2005 labels for nutrition, health and related claims was released in April 2007, entitledOn-going Food Label Monitoring Survey in Australia and New Zealand:Report on the Assessment of 2005 Labels for Nutrition, Health and Related Claims.

A final report of 2005 labels covering the assessment of twelve key label elements is scheduled to be published on the FSANZ website in early 2008. Labels collected in 2006 have been assessed and a draft report of the assessment of these labels is also expected in early 2008.