Food Labelling Review Panel releases Consultation Paper


By Joe Lederman and Charles Fisher
FoodLegal Lawyers and Consultants
© Lawmedia Pty Ltd, March 2010

On 5 March 2010, the Food Labelling Law and Policy Review released an Issues Consultation Paper. This Review, by an expert panel, is supposed to address the numerous flaws inherent in the food labelling system. This Review is very comprehensive, dealing with complex and controversial issues such as Country of Origin, Front of Pack Labelling and Characterising Ingredients. It is essential that any person or company involved in the food industry read the Issues Consultation Paper and make a Submission if deemed necessary.

The scope and questions in the Issues Consultation Paper

The Issues Consultation Paper can be accessed by clicking here. The Paper contains 39 questions that the Review Panel would like to seek public opinion on, through online submissions and public forums (more detail below).

The scope of the Review (although limited to food labelling, excluding food safety and food production) is very broad, taking into account both the laws themselves (as mostly embodied in the Australia New Zealand Food Standards) and the issue of inconsistent national enforcement of the laws. Any comprehensive solution to such issues will have to involve government agencies from each State and Territory, as well as Federal bodies such as the Australian Competition and Consumer Commission and the Australian Quarantine and Inspection Service.

Some of the questions in the Paper go to the heart of the issue: balancing the needs of consumers with the cost and burden on the industry in complying with Australia’s complex and often unnecessary labelling regulations. For example, Question 2 reads:

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 (e.g. education or website)? 

The issue of food labels’ role in supporting health promotion initiatives is also raised (for more on this issue, please see the article “Questions asked of proposed 'Front of Pack Labelling' options in Australia” in this March 2010 issue of FoodLegal Bulletin), as well as the long delayed issue of permitting health claims to be made in relation to food products.

The importance of making a Submission

Given the wide scope of the Review, it affects the entire food industry. FoodLegal strongly recommends any person or company affected by the outcome of any of these issues make a Submission or participate in one of the forums so that the opinions of the industry are adequately taken into account.

Submission process

All online submissions must be made prior to 14 May 2010.

The public forums will be held between in all capital cities in Australia and New Zealand from 17 March to 7 May 2010 as follows:


17th and 18th March 2010


25th March 2010


26th March 2010


29th March 2010


  9th April 2010


12th April 2010


16th April 2010


23rd April 2010


29th April 2010


 7th May 2010

For details as to the location and times of these consultation, please see the website of the Review:  

The Expert Panel’s members and its terms of reference were identified in the previous FoodLegal Bulletin article “Members of Food Labelling Review Committee Selected by Ministerial Council” in the February 2010 issues of FoodLegal Bulletin.


This is general information rather than legal advice and is current as of 12 Dec 2015. We therefore recommend you seek legal advice for your particular circumstances if you want to rely on advice or information to be a basis for any commercial decision-making by you or your business.