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Comprehensive Review of Food Labelling Law and Policy

14 May 2010


The Comprehensive Review of Food Labelling Law and Policy (2011) was undertaken at the request of the Australian Ministerial Council, with the agreement of the Council of Australian Governments.

The OPC's first submission was in response to the Food Regulation Standing Committee's (FRSC) Consultation Paper for a Front of Pack Labelling Policy Guideline. The OPC recommended that the policy guideline should support the introduction of a uniform, mandatory and easy to use front of pack labelling system, preferably a traffic light labelling system.

The OPC's second submission was in response to the review panel's issues consultation paper. It outlined a number of key recommendations for changes to food labelling law and policy to encourage healthier patterns of eating in the Australian population, including:

  • Mandatory traffic light labelling on the front of food packages, in fast food outlets and in food retail outlets in public institutions (e.g. hospitals and schools)
  • Restrictions on use of nutrition claims (e.g. high fibre) in food advertising and on packaging to foods that meet general nutrition profile criteria (to ensure claims can only be made about foods that are healthy overall)
  • Requirements for disclosure of nutrition information in food advertisements
  • Establishment of a national food labelling enforcement authority
  • Development of overarching food labelling principles, and detailed food labelling interpretation guidelines

The Review Panel adopted a number of the OPC's recommendations for food labelling reforms (see Labelling Logic – Review of Food Labelling Law and Policy Report). In particular, the Review Panel recommended:

  • the introduction of a traffic light labelling system on the front of food packs and fast food menus (recommendations 50–54)
  • the introduction of mandatory energy labelling on fast food menus and vending machines (recommendation 18)
  • the requirement that all foods that make nutrition claims must meet general nutrition profile criteria (recommendation 20b)
  • establishment of a food labelling bureau (recommendation 57–61).

The OPC's third submission was to inform the Commonwealth and State and Territory governments' response to the Labelling Logic report. It encouraged Australian governments to support the adoption of the recommendations in the report, particularly recommendations 50–54, 18, 20b and 57–61. It also made some additional suggestions to strengthen the effectiveness of, and compliance with, any traffic light labelling scheme.


In December 2011, the Legislative and Governance Forum on Food Regulation announced a whole of government response to the Labelling Logic report. Among other things, the response recommended the development of an interpretive front of pack labelling system. It recommended that the Food Regulation Standing Committee (FRSC) and the Australian Health Ministers Advisory Council manage a collaborative approach to review and identify problems with current systems, and identify consensus/points of difference between stakeholders. FRSC will provide a progress report in June 2012, with the system to be developed by December 2012. The whole of government response did not support mandatory kilojoule labelling in fast food outlets or the development of a national Food Labelling Bureau.