Braidwood Greens submission on food labelling
Food Labelling Review Secretariat
Department of Health and Ageing
MDP 150
GPO Box 9848
Canberra ACT 2601
Thank you for the opportunity to make a submission on this important issue.
If this review of food labelling law and policy is genuine about considering options to (1) reduce the regulatory burden in food labelling (2) without compromising public health and safety, the Braidwood Greens believe that full and accurate labelling is essential.
In the same way that people have a right to choose whether or not they eat food containing any animal products, so should they have a right to choose whether or not they eat food containing GM organisms, or irradiated or novel foods.
We all have a right to be fully informed about what we eat through food labels. Labelling is not primarily a safety issue as Food Standards Australia NZ (FSANZ) should ensure that only safe foods are registered for sale. This is a separate issue.
Advertising or marketing on food labels should be not be allowed as this compromises objectivity.
All relevant and key information about foods must be truthfully, accurately and clearly presented on comprehensive labels attached to every product. The people who buy and eat food - not the food industry or FSANZ - should be empowered to decide what label information is relevant based on the components listed.
There is a category of foods which may entail higher long-term or unforeseen hazards about which we have a right to know and decide. These foods should be fully labelled as they cannot be finally assessed as safe right now because present knowledge is incomplete. It is important to err on the side of caution.
FSANZ’ “Foods Requiring Pre-Market Clearance”:
Standard 1.5.1 Novel Foods
Standard 1.5.2 GM Foods
Standard 1.5.3 Irradiated Foods
Novel, Genetically Manipulated and Irradiated foods are required to undergo pre-market health and safety assessments because they contain materials and/or are manufactured using production processes which have no history of safe use in the human food supply.
Nanomaterials - new metallic and other chemical substances less than 300 nanometres in size - must also be included in this standard but will instead be regulated by Standards Australia. They should also be fully labelled.
All foods in the categories of Foods Requiring Pre-Market Clearance should be fully labelled. Shoppers will thus be enabled to avoid these foods (or seek them out for that matter) if they decide to do so. Full labelling would allow these novel foods to be traced if adverse impacts were to occur.
The Novel Food Standard 1.5.1
In this standard, non-traditional food means:
(a) a food that does not have a history of human consumption in Australia or New Zealand; or
(b) a substance derived from a food, where that substance does not have a history of human consumption in Australia or New Zealand other than as a component of that food; or
(c) any other substance, where that substance, or the source from which it is derived, does not have a history of human consumption as a food in Australia or New Zealand.
Only some of the foods and food ingredients listed in this standard are required to be labelled. The standard should require all of them to be labelled.
The GM Food Standard 1.5.2
Most GM foods and food ingredients approved in this standard are exempt from labelling. The intellectual and conceptual basis for these exemptions are flawed. All foods made using GM techniques should be labelled, without exception.
In the standard, genetically modified food means food that is, or contains as an ingredient, including a processing aid, a food produced using gene technology which:
(a) contains novel DNA and/or novel protein; or
(b) has altered characteristics;
but this labeling requirement does not include:
(c) highly refined food, other than that with altered characteristics, where the effect of the refining process is to remove novel DNA and/or novel protein;
(d) a processing aid or food additive, except where novel DNA and/or novel protein from the processing aid or food additive remains present in the food to which it has been added;
(e) flavours present in the food in a concentration no more than 1g/kg; or
(f) a food, ingredient, or processing aid in which genetically modified food is unintentionally present in a quantity of no more than 10g/kg per ingredient.
Though not expressly excluded, the meat, milk, eggs, honey etc. from animals fed GM feed are also exempt from any labelling. This is based on the assumption (not the fact) that foreign genes or their influence cannot be transmitted from GM feed to humans.
Standard 1.5.2, “Foods Produced Using Gene Technology” should apply the spirit and substance of this title to its purposes. The standard is unfaithful to its title when it comes to labelling, using the GM industry-concocted concept of substantial equivalence to exempt many foods produced using gene technology from labelling. It denies full and fair information to shoppers by comparing a few chemical analyses of a GM food with its conventional counterpart. If they are similar enough for the assessors (no benchmarks or standards are set in advance) it is assumed that the GM food (like the conventional one) is safe.
The absence of DNA and protein from refined GM foods is another assumption, not a fact, and the absence of DNA and protein does not assure safety. For instance, refined peanut oil that contains no DNA or protein can nevertheless provoke a severe allergic reaction in those who are allergic to peanuts.
All foods produced using gene technology should be labelled, without exception. The standard applied by the Australian Consumer and Competition Commission to the labels “GM-free” and “non-GM” has zero tolerance for the use of the processes or products of gene technology, without any exceptions whatever. So, to be genuinely truthful, fair and equitable to all affected parties, all foods produced using gene technology should be fully labelled as such, without any exceptions whatever.
The Irradiated Food Standard 1.5.3
All foods or food ingredients that are processed with radiation require a label.
This is a clear precedent for the labelling of other processes of production, including gene manipulation. Other precedents include industry’s labelling of valued production processes such as ‘dolphin-friendly’ tuna and ‘fair trade’ coffee.
Nano-materials in food, food packaging and processing
Nanomaterials also have no history of safe use in the human food supply so labels should be required on all foods and food packaging produced using nanotechnology, or manufactured in nanoparticle form. In addition, although sunscreens and cosmetics are not ingested through the mouth, they can be absorbed through the skin, and the Braidwood Green believe that these products should be labelled in the same way.
Markets and labels
So that free markets can optimise social benefits, all parties in the market must be fully and fairly informed. In food markets it is government’s responsibility to require that all relevant product specifications - including origin, processes of production, and composition of all ingredients - are disclosed on labels. Everyone is entitled to make fully informed choices about what they, their families, and animals, eat and this can only be facilitated adequately by complete labelling of products and processes of production, especially where these are novel and have limited history of safe use in the human food supply.
The Braidwood Greens are grateful for the opportunity to make this submission and hope that the result of the review will find in favour of full and accurate labelling as discussed above.
