Several submitters requested a ‘source of protein’ claim (AFGC, GWF, MLA, Diabetes Australia, DAA, NZGMA, NZJA, NHF NZ, HWA, Nestlé, Unilever) because products like milk and baked beans will not meet the proposed criteria for ‘high protein’ and because it is provided for by Codex.
Some argued for Codex criteria (AFGC, Nestlé, Unilever) while others believed that the criteria defined in Volume 1 of the Code were appropriate (MLA, Diabetes Australia, DAA, HWA).
SA Dept Human Services specifically opposed a ‘source of protein’ claim because Australian protein intake is higher than required and protein information is already provided in the NIP.
NZ submitters who commented on ‘low protein’ claims agreed that there is no need for the claim, despite the fact that it is provided in the NZFR (Horleys, InforMed Systems, MoH NZ). MoH NZ stated that the review of Medical Foods would need to address claims on specialist ‘low’ and ‘very low’ protein foods where these are required for particular medical conditions. InforMed Systems however believed that a combination of professional guidance as well as information in the NIP is sufficient to guide such people.
Other protein claims that submitters supported were ‘good source of protein’ as currently provided under Codex (NZJA, and Natural Products, Unilever), ‘very high in protein’ as provided in the Canadian proposal (CHC and Natural Products), ‘excellent source of protein’ (Natural Products), ‘provides protein’ (GWF) and ‘protein enriched/increased’ (Natural Products). Diabetes Australia and DAA noted that there is no definition for ‘provides protein’, despite a clear definition in Volume 1.
General support for fat claims came from NZGMA (except for the prohibition of ‘fat free’ and the criteria for ‘%fat free’), Tatua (except for the drafting for ‘very low (in) fat’) and FTA Vic. Karen Cashel supported ANZFA’s approach of sub-components of nutrients (e.g. types of fatty acids) triggering full reporting of related components (i.e. fat and its major components). Karen Cashel also supported this approach for food components that are strongly linked in the minds of consumers (e.g. fat and cholesterol).
Several submitters had general concerns with fat claims. NZ Beef and Lamb and ADHB were of the view that there are too many fat claims permitted, which they believe causes confusion amongst consumers. They queried whether claims such as ‘low fat’ and ‘very low fat’ actually achieve different health benefits. ADHB therefore submitted that only ‘reduced fat’ be permitted.
Mainland did not believe the proposed claims and their criteria provided sufficient flexibility for the meat and dairy industry. Tony Beard objected to the inconsistent use of measurements (e.g. 5.1g of fat per 100 mL) on the basis that it is difficult to calculate the percentage of fat within the food. He recommended measurements be based on mass as the majority of fat is labelled in this way. Pritikin similarly objected to the units of expression, particularly for claims such as ‘98% guilt free’, preferring the criteria be based on a percentage of the energy content. For example the fat content for ‘Carnation Light and Creamy’, which carries the ‘98% guilt free’ claim, equates to 15% of the energy value. Pritikin also objected to ‘no added fats’ claims when vegetable oil has been added.
Finally, NHF Australia had concerns about inappropriate methods of fat analysis being used in order to comply with criteria. They cited the results of three different methods of analysis for a cereal based product (1.2, 2.6 and 5.4 g per 100g for the Soxhlet method, the acid digest fatty acids method and the acid hydrolysis method respectively), They noted that manufacturers are more likely to use the Soxhlet analysis when making ‘% fat free’ or ‘low fat’ claims, which is potentially misleading for consumers and not equitable for all manufacturers. NHF Australia therefore recommended that appropriate methods of analysis be listed for product type (e.g. for cereal based products the acid hydrolysis method should be used but for meat products, the Soxhlet method is preferable).
LOW (IN) FAT
Several submitters who provided comment on this claim supported the criteria (AFGC, GWF, CHC, SA Dept Human Services, NHF NZ and Nutrition Foundation). Several other submitters, however, wanted specific criteria developed for certain products that cannot currently make the ‘low fat’ claim but are significantly lower in fat than the proposed 25% reduction required for ‘reduced fat’ claims (Mainland Products, MGC, MLA, Natural Products, DAA). Mainland Products, MGC and MLA requested criteria for ‘low fat’ dairy products as it was pointed out that the Dietary Guidelines for Australians recommend low fat varieties of dairy products and fat levels for different food categories are nominated (e.g. ‘low fat’ cheese is 10% fat or less). MLA also requested that consideration be given to the unique role of non-carbohydrate containing meat products. It was pointed out that the majority of trimmed beef and lamb cuts contain <10% fat. DAA preferred a separate ‘low fat’ definition for main dishes and meal type products with a suggested criterion of 5 g per 100g. Lastly Natural Products recommended criteria of 5% or less fat for crackers.
Pritikin believed that ‘low fat’ criteria could also stipulate that products must have less than 20% energy.
REDUCED (IN) FAT
Most submitters agreed with the criteria (AFGC, CHC, SA Dept Human Services, NHF NZ, NZDA, Natural Products, NZ Beef and Lamb, ADHB, MoH NZ, NZ Nutrition Foundation). NHF Australia, NHF NZ and NZDA also wished to see a reduction of at least 25% in energy when compared with a reference food, while ADHB preferred a 33% reduction of total fat and lower total energy than the reference food.