Food Labelling Review round 2

More than 6000 submissions were recieved for round 1 of the Review - we need to keep the pressure up for round 2!

Quick Response to Labelling Review

An email or letter, no matter how small, will help. Just follow the procedure here on the Submission Guidelines page. This includes downloading the official 'cover sheet', filling out this cover sheet and attaching it with your written email or letter. You should also re-submit your first submission as an attachment, if you made a submission in round 1.

We have been informed that submissions will have the most impact if they address the questions put forward by the Review Panel Report. If you do not have time to review this entire report, Madge recommends instead that you respond to what we see as the four most important questions for GM labelling which are: Q2, Q6, Q13 and Q19 - here are some quick statements to make for each question:

Q2. All food labelling should be truthful, transparent, accurate, honest, informative and not a promotion. We want the information on the product itself at the point of sale.

Q6. All ingredients derived fully or partly from GM crops or processes need to be labelled. This includes refined products such as oils, sugars, starches, honey, additives and enzymes, and animal products derived fully or partly from GM feed, which currently escape labelling. GM animal feed needs to be labelled. This is "process-based" labelling. We reject suggestions that GM food becomes 'normal unlabelled food', with our usual food being labelled instead as "GM free".

Q13. There have been too few independent studies to feel confident in the safety of GM foods. In fact, Doctors specialising in environmental medicine say there is a link between GM foods and illness. They state "several animal studies indicate serious health risks associated with GM food consumption". They include: allergy; gastrointestinal, liver and kidney changes; immune dysregulation; dysregulation of insulin and cholesterol response; accelerated ageing and reduced fertility. There have been no studies anywhere in the world to say whether GM food has been safe to eat or not. We reject the suggestion that GM is just a consumer concern that doesn't need labelling. GM food is not the same as non-GM food.

Q19. We want full GM process-based food labelling irrespective of how this may "inhibit" the development of new technologies. If new technologies such as GM, nanotechnology and irradiation can only be successful if they are hidden, unlabelled in our food, we should be very suspicious.

Feel you don’t know enough? Listen to these programmes or read the transcripts:

ABC Radio interview regarding the Food Labelling Review – this covers Transfats, additives, GM, country of origin, animal welfare and more
Australia Talks had an excellent talk back programme on labelling. Nutritionist Rosemary Stanton is well worth listening to;
Bush Telegraph on how imported GM foods are regulated and
The World Today on GM and weed problems.

Detailed Reponse to Labelling Review

If you would like to respond in a more detailed way, you can respond directly to the Review Panel Report, as explained below.

This page titled Reports and Publication includes two key documents that together make up the Review Panel Report. These two documents can be downloaded in Word or PDF format:

an 'Issues Consultation Paper' which includes 39 questions for comment and
a separate document titled 'Questions Only', which includes the same questions without the other detailed information and explanations included in the Issues Paper.

Your response will be most effective if you address the questions directly.

When making your submission, please re-attach your first submission as well, clearly marked as round 1. Also, just to be safe, consider mailing in your detailed response as well as emailing.

Below are some points that you may like to include in your responses. If you are not able to answer all the question, then focus on questions 2, 6, 13, and 19.

All food labelling should be truthful, transparent, accurate, honest, informative and not a promotion:

We need clear labelling. Using a supermarket "wand" to read a barcode or an "app" on an iphone to find out what is in a product is inadequate
We need to know what is in our food at home. What if a friend with a food allergy comes to visit? What about people with disabilities, the elderly, people for who English is not the first language? If companies want to sell us food they must be able to tell us what is in it. Otherwise it is deceptive.

These comments are relevant to Q2. What is adequate information and to what extent does such information need to be physically present on the label or be provided through other means (eg education or website)?

All ingredients derived from GM must be labelled:

The report says GM is currently labelled (3.1) in fact oils, sugars, starches from GM crops, milk, eggs, meat from animals fed GM , honey, additives derived from GM, ARE NOT LABELLED.
GM is new and needs labelling. Ordinary food should not be forced to be labelled "GM free".
In Europe, foods produced from GM crops are labelled, irrespective of whether there is GM DNA or protein in the final product.
Labs all over the world including Serbia, Brazil, Hungary and China can quantify GM in food. Australian labs are able to do the same but need certification.

These comments are relevant to Q6. "Is this a satisfactory spectrum for labelling requirements?"

The public are tired of having genuine concerns about GM food ignored:

Doctors specialising in environmental medicine say there is a link between GM foods and illness. They state "several animal studies indicate serious health risks associated with GM food consumption". They include: allergy; gastrointestinal, liver and kidney changes; immune dysregulation; dysregulation of insulin and cholesterol response; accelerated ageing and reduced fertility.

These comments are relevant to Q13. "To what extent should the labelling requirements of the Food Standards Code address additional consumer-related concerns, with no immediate public health and safety impact?"

New technologies – GM, nanotech and irradiation need labelling:

The report (3.16) implies that labelling of GM, nanotech and irradiation will "inhibit" those technologies. We need to be very suspicious of technologies that need to be hidden from consumers.
Everyone has to eat. We have a right to know what is in our food and to be cautious about technologies the food industry wants to sell us.
For more details on this issue see the MADGE press release: "Consumers asked to suppress GM food Concerns"

These comments are relevant to Q19 "In what ways can information disclosure about the use of these technological developments in food production be improved given the available state of scientific knowledge, manufacturing processed involved and detection levels?"

The following information is not specific to any one of the questions, but to the entire scope of the review:

Conflicts of interest with the Food Labelling Review

One of the five members of the review panel, Nick Goddard, is from the Australian Oilseeds Federation. This peak industry body has GM companies as members ie: Monsanto, Bayer Crop Science, Dow Agrosciences. Monsanto is the owner of the GM canola variety grown in Australia. Just over 50% of consumers say they would not buy GM if they could avoid it according to a 2007 Roy Morgan Research.
Our food regulator, FSANZ, is expected to protect the health and safety of consumers AND promote an internationally competitive food industry (as stated in Section 10 of this report). Food regulators should ONLY be concerned with public health.

Monitoring and enforcement slips through the cracks:

There is no national body to enforce labelling standards.
FSANZ has conducted only one pilot study into the labelling laws in 2003. 22% of tested samples had GM DNA. None had labels.
In contrast a NZ maker of soy sausages was prosecuted for labelling its sausages “non-GM” as they had 0.0088 percent GM present. The company pleaded guilty rather than face a legal bill of $63,000.

Threats to Australian food labelling:

The Australian government is currently negotiating a free trade agreement with the Asia Pacific region. The public needs assurance that food labelling laws will not be part of the negotiation.

As for round 1 of the review, please feel free to email us through your submissions and we will post them on this page along with further progress from the outcomes of round 2 as they become available.

SUBMISSIONS FOR ROUND TWO:

Food Labelling Review round 1

There is a federal review into food labelling, and members of MADGE are working to have GM and nanotech ingredients in food and packaging fully labelled. View our campaign email at this page.

Submissions for the Food Labelling Review can be emailed to this address:

FoodLabellingReview@health.gov.au

The Terms of Reference are here.

Many of our members have put in a submission. Here are a few submissions you may like to view:

If you would like to make your submission public for review or comment, please send it thorugh to info@madge.org.au and we can post it here on the site.

We anticipate that an official list of all submissions will be made public by the Federal Department of Health over seeing the review, in the mean time, check back at this page for progress updates we will supply as they become available.

Look closely at the label on this tube of icing sugar - all GM ingredients are stated. Including preservatives and emulsifiers. This is NOT what we currently have in Australia. There are no laws stating any GM ingrients must be labelled in Australia.