Food labelling – it can be a minefield. In an era of food allergens, many imported products, as well as a bevy of health and safety regulations, food and beverage manufacturers have their work cut out for them to make sure they create products that meet a wide range of food regulations.
It’s something not lost on Fiona Fleming who is the managing director of the Australian Institute of Food Science and Technology (AIFST), which is the body for food industry professionals who work in many different fields within the food and beverage industry. Fleming knows that food labelling can be a difficult subject to navigate, especially for those just starting out in the industry.
What are the main issues surrounding food labelling? Correct labelling of imported foods and declaration of food allergens provide significant challenges, according to Fleming. Australia does appear to be the food allergy capital of the world, with Melbourne leading the way.
There is no single reason for this, more a myriad of causes – peoples’ diets have changed, more sufferers are reporting their allergies and, in the case of Melbourne, some researchers believe low levels of vitamin D contribute due to the city’s cooler climate and children spending less time outdoors in the sun.
READ MORE: Six reasons why food labelling is important
Whatever the reason, consumption of a food allergen can have fatal consequences for those who are allergic to that food or foods. For someone with a severe allergy, exposure to the allergen can cause a life-threatening reaction called anaphylaxis which affects the whole body, often within minutes of exposure.
“They key allergens of concern in Australia and New Zealand are egg, milk, peanut, fish, crustacea, peanuts, soybeans, sesame seed, tree nuts, wheat and other gluten containing cereals, and lupin,” Fleming said.
“These are required to be labelled when present in a food under the Australia New Zealand Food Standards Code. And just to add to the confusion, both for those on the ground in Australia and those wanting to import food products, allergens required to be labelled in one country might not always be required to be labelled in another.”
For example, in Europe, mustard and celery are allergens that must be labelled, whereas in Australia they are not on the list of food allergens required to be labelled.
“Any ingredient that is in a food product has to be labelled, and it is up to the importer to ensure that foods they bring into Australia and New Zealand have the correct allergen declarations to comply with ANZ requirements,” Fleming said.
“Australian and NZ manufacturers have gone further with labelling following best practice guidance developed by the food industry. For example, allergen names are highlighted in bold text in the ingredient list which helps consumers when purchasing products.”
Food allergens are not the only important piece of information that needs to be put on food labels.
For imported foods, all of this information is required to be provided in English, meaning labels must be translated accurately and completely. Failure to include all of the information can potentially result in a costly product recall and injury to consumers.
Importers of foods into Australia have to be responsible and realise that ignorance of local labelling laws is no excuse if the correct information is not available to the buying public. There is an over-riding premise in law that ignorance of law is no defence.
“All food companies have an obligation to know the regulations under which they must operate, and they have an overriding obligation to provide food that is safe and suitable,” Fleming said.
“Accurate food labelling is important for ensuring food safety, and ignorance of the labelling requirements is no defence.”
First and foremost, manufacturers tend to initially concentrate on the product itself. Is it tasty? How much will it cost to produce? Where can we source the ingredients? Can we outsource the manufacturing of our product, or can we set up or own manufacturing facility?
Once a manufacturer gets their head around what is involved in crossing the t’s and dotting the i’s, correct labelling can sometimes be intimidating and time consuming. But there is help available.
Fleming is the first to acknowledge that there no easy route to labelling food and beverage products.
“Food labelling is quite complex,” said Fleming. “I do recognise that it is very hard to start up a food manufacturing enterprise because sometimes companies don’t know where to go to find the information they need.
“There are certainly organisations that provide training in food labelling. If you are in NSW, for example, you can go to the NSW Food Authority’s website where there is a lot of good information for starting a business, and they have some basic information around requirements for food labelling.”
The final piece of advice Fleming would give is with regard to preservatives and additives in food products. They, too, have to be approved for use, and labelled as part of the ingredient listing on products.
“Australia is a small country, population wise, and we import a lot of our products,” Fleming said.
“It is important to remember that just because something is approved to be used in a food product overseas, it doesn’t mean it’s been approved to be used here.
It can be challenging negotiating the regulations, but it is very important for companies to be aware of the requirements and put steps and processes in place to ensure they have the information and knowledge they need to ensure their products are fully compliant.
“I know that sometimes information is not easy to find, but there are also food consultants out there who can assist. The AIFST website has a page that lists members who are consultants and provide this sort of assistance to food companies.”
There are also tools available to food manufacturers developed by the food industry to assist with collection of information and labelling. For example, the Product Information Form, or PIF, is an industry-agreed questionnaire developed by the food industry, for the food industry, in Australia and New Zealand.
The PIF allows companies to include a variety of information about food products and ingredients in a single document that meets information needs for legal and regulatory compliance in Australia and New Zealand, in a standardised manner.
The PIF is an industry tool that can improve company efficiency and reliability in managing product specification and other related data when applied across the sector.
With respect to allergen management and labelling, the Allergen Bureau has a comprehensive website and tools available to assist with allergen risk assessment and labelling (https://allergenbureau.net).
“At the end of the day, as a food manufacturer, whether big or small, Australian or not, you have an important role in ensuring that consumers continue to enjoy a variety of safe and nutritious food that will contribute to their wellbeing,” Fleming said.
Mandatory requirements for labelling – the Big 11
1. Name of food
2. Name and address
3. Lot identification
4. Allergen declaration
5. Ingredient list
6. Date marking
7. Storage and usage instructions
8. Nutrition information
9. Characterising ingredients
10. Country of origin
11. Quantity marking