The definitions of meat and other animal products report is a timely examination of the food labelling regulatory framework intended to benefit and protect consumers.
Food categories have increasingly become blurred and claims on plant-based proteins have not been clearly regulated. Organics, free-range and other raising claim categories are overseen by Australian Consumer Law, while nutritional and compositional labelling are overseen by the Department of Health. However, the Department of Health does not have matching policing or investigative powers.
The growth of new protein categories such as plant-based, cultured and blended animal and plant-based proteins are recognised as providing consumers with new sources of protein. An increasing world population, and pressure on arable farming land by encroaching urban zoning, are competing needs that are in part addressed by manufactured proteins.
The perception of competition between the traditional category of meat protein and manufactured plant-based protein was not borne out in consumption or consumer trends. It appears that the two categories are growing in size in line with a growing hungry world, and it is in Australia’s interests to be a part of the growth of both sectors, utilising our reputation as a producer of high-quality produce, both animal and plant, and high food standards.
What is missing is clarity for the consumer. While industry sectors will argue the relative benefits of one over another by nutrition, sustainability and environmental standards, the consumer is not benefited if the labelling does not clearly define which category the product belongs to. Consumers are increasingly well informed and educated as to ingredient and nutrition labelling, but the use of animal terms and imagery on plant-based products is not adding to the ease of busy consumers.
While it appears most plant-based protein product manufacturers use clear labelling and terms, such as ‘plant-based burger’, there are no labelling standards to ensure that animal terms or images are not used on plant-based protein product packaging.
Anecdotally, since this inquiry began, awareness of this issue has grown considerably following the associated consultation and media interest. This may explain why groups such as the Australian Competition and Consumer Commission (ACCC) and Food and Grocery Council stated they had little or no feedback, yet media reports and consumer surveys had thousands of responses.
However, the committee heard that since Food Standards Australia New Zealand (FSANZ) made changes to Section 1.1.1—13 of the Food Code in 2016, labelling and claims on plant-based proteins have not been clearly regulated.
The agricultural industries spoke of their frustration of a consultation process on the proposed changes in 2016 which focused solely on dairy products, meaning other affected industries, including the meat industry, were not consulted on the changes or even made aware until the proposed changes were signalled by a media release.
The result is that the definitions for dairy were altered to allow manufactured products to use animal terms and appropriate implied claims of equivalency. This pathway has subsequently been used by manufactured plant-based proteins.
As the new protein category in Australia expands from plant-based to cultured (trialling in Japan and others) and blended animal and plant proteins, Australia has an opportunity to identify the best regulator (health, consumer or other) and mandatory labelling requirements.
Domestic labelling guidelines are important to protect the existing and significant export market, which has clear definitions of meat, and to protect the new protein market.
Categories such as organic and free range may also be seeking greater clarity on labelling claims. It is important that there is a national standard that aligns with mandatory export standards found in existing legislation. The alignment between domestic and international standards will provide all stakeholders with clear guidance and enforcement via the ACCC, which has the powers and resources to address improper labelling and marketing practices.
The committee thanks all those people who provided submissions to this inquiry, and came to give evidence.