4. results & discussion · 2018-06-27 · 4. results & discussion the different...
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FSANZ FOOD LABEL MONITORING SURVEY – PHASE 1 REPORT
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4. RESULTS & DISCUSSION
The different sub-sections of the ‘Results and Discussion’ section of this report cover the
assessment of each label element. Tables of results are provided with analysis by major food
categories for:
• label elements assessed for consistency against new Code labelling provisions; and
• baseline data on other labelling aspects (where applicable).
Minor food category result tables are detailed in the appendices of this report, where
appropriate.
4.1 Code used
Stage 1
Of the 1,266 labels sampled for Stage 1, 65% (818 labels) were assessed as being produced to
meet the requirements of the old Code. Thirty five percent of labels (448 labels) were fully
assessed (‘assessable’), of which, 27% were new Code and 8% were indeterminable but,
were assumed to have been produced to the new Code requirements. The use of old Code
labels varied between major food categories but, in the majority of cases, the proportion of
new Code labels was less than old Code labels (refer to Table 3 and Appendix 17).
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Table 3 Code used by major food category for Stage 1
Code Used
Indeterminable New Old Number fully
assessed
Major Food Category
Total
Number of
Products
Sampled Number (%) Number (%) Number (%) Number (%)
1. Dairy 116 1 (1) 41 (35) 74 (64) 42 (36)
2. Edible oils and oil emulsions 30 0 (0) 16 (53) 14 (47) 16 (53)
3. Ice cream and edible ices 40 0 (0) 7 (18) 33 (82) 7 (18)
4. Fruit and vegetables 160 30 (19) 35 (22) 95 (59) 65 (41)
5. Confectionery 76 1 (1) 17 (22) 58 (77) 18 (24)
6. Cereal and cereal products 75 1 (1) 14 (19) 60 (80) 15 (20)
7. Bread and bakery products 160 0 (0) 52 (33) 108 (67) 52 (33)
8. Meat and meat products 96 19 (20) 38 (40) 39 (41) 57 (61)
9. Fish and fish products 35 0 (0) 15 (43) 20 (57) 15 (43)
10. Eggs and egg products 8 0 (0) 3 (38) 5 (62) 3 (38)
11. Sugars, honey and related products 23 0 (0) 6 (26) 17 (74) 6 (26)
12. Food intended for particular dietary use 28 4 (14) 10 (36) 14 (50) 14 (50)
13. Non alcoholic beverages 134 38 (28) 20 (15) 76 (57) 58 (43)
14. Mixed foods 285 8 (3) 72 (25) 205 (72) 80 (28)
Overall Results 1266 102 (8) 346 (27) 818 (65) 448 (35)
Stage 2
Comparatively, the percentage of labels assessed as being produced to meet the requirements
of the old Code for Stage 2, was nine percent (109 of 1262 labels). This was substantially
different from Stage 1 however, differences were expected, as the new Code had been fully
implemented prior to the Stage 2 sampling period. Of the 1153 labels considered
‘assessable’, seven percent (85 of 1262 labels) were indeterminable, but assumed to have
been produced to the new Code requirements and, 85% (1068 of 1262 labels) were new Code
(refer to Table 4 and Appendix 18).
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Table 4 Code used by major food category for Stage 2
Code Used
Indeterminable New Old Number fully
assessed
Major Food Category
Total
Number of
Products
Sampled Number (%) Number (%) Number (%) Number (%)
1. Dairy 112 0 (0) 106 (95) 6 (5) 106 (95)
2. Edible oils and oil emulsions 30 0 (0) 29 (97) 1 (3) 29 (97)
3. Ice cream and edible ices 38 0 (0) 34 (89) 4 (11) 34 (89)
4. Fruit and vegetables 166 20 (12) 123 (74) 23 (14) 143 (86)
5. Confectionery 76 1 (1) 68 (90) 7 (9) 69 (91)
6. Cereal and cereal products 76 1 (1) 65 (86) 10 (13) 66 (87)
7. Bread and bakery products 161 0 (0) 143 (89) 18 (11) 143 (89)
8. Meat and meat products 98 17 (17) 78 (80) 3 (3) 95 (97)
9. Fish and fish products 35 0 (0) 31 (89) 4 (11) 31 (89)
10. Eggs and egg products 8 0 (0) 7 (87) 1 (13) 7 (87)
11. Sugars, honey and related products 23 5 (22) 16 (70) 2 (9) 21 (91)
12. Food intended for particular dietary use 27 2 (7) 20 (74) 5 (19) 22 (81)
13. Non alcoholic beverages 130 35 (27) 86 (66) 9 (7) 121 (93)
14. Mixed foods 282 4 (1) 262 (93) 16 (6) 266 (94)
Overall Results 1262 85 (7) 1068 (85) 109 (9) 1153 (91)
4.1.1 Code used based on brand category
Table 5 and Table 6 detail the Code used based on the brand category of the product for
Stage 1 and Stage 2 respectively. The percentage of assessable labels (new Code and
indeterminable labels) for each brand category varied between 33% and 42% in Stage 1 and
43% and 96% in Stage 2. As mentioned above, the percentage of ‘assessable’ labels was
expected to be higher in Stage 2 when compared to Stage 1, as the new Code had been fully
implemented prior to the Stage 2 sampling period. However, this did not apply to those labels
classified as ‘speciality ‘ products, where there was little change since Stage 1.
Stage 1
Table 5 Code used based on brand category for Stage 1
Code Used
Indeterminable New Old
Brand Category
Total Number
of Products
Sampled Number (%) Number (%) Number (%)
Generic 106 10 (9) 35 (33) 61 (58)
National 966 74 (8) 261 (27) 631 (65)
Speciality 44 4 (9) 14 (32) 26 (59)
State Specific 150 14 (9) 36 (24) 100 (67)
Overall Results 1266 102 (8) 346 (27) 818 (65)
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Stage 2
Table 6 Code used based on brand category for Stage 2
Code Used
Indeterminable New Old
Brand Category
Total Number
of Products
Sampled Number (%) Number (%) Number (%)
Generic 194 15 (8) 170 (88) 9 (5)
National 958 58 (6) 826 (86) 74 (8)
Speciality 30 4 (13) 9 (30) 17 (57)
State Specific 80 8 (10) 63 (79) 9 (11)
Overall Results 1262 85 (7) 1068 (85) 109 (9)
4.1.2 Code used based on country of manufacture
Stage 1
Table 7 details the Code used based on imported status, determined by country of origin
information. There was very little difference between local and imported products, with 35%
of both local and imported products being assessed. Three labels were not included in the
total of 1263 labels in this categorisation, as their country of origin was indeterminable. Two
of these labels were new Code, and one was old Code.
Table 7 Code used based on imported status for Stage 1
Code Used
Indeterminable New Old
Imported Status
Total Number
of Products
Sampled Number (%) Number (%) Number (%)
Imported 164 21 (13) 37 (23) 106 (65)
Local 1099 81 (7) 307 (28) 711 (65)
Overall Results 1263 102 (8) 344 (27) 817 (65)
In terms of country of manufacture, the only countries where there were a sufficient number
of products manufactured to enable inter-country comparisons were Australia and New
Zealand (631 and 468 respectively). The total percentage of assessable labels (new and
indeterminable Code labels) was very similar for these countries (36% Australia and 34%
New Zealand).
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Stage 2
For Stage 2, a greater percentage of local products were fully assessed to the requirements of
the new Code (94%, 1025 of 1093 labels) in comparison to imported products (74%, 114 of
153 labels) (refer to Table 8). This was different to Stage 1 where the percentage of
‘assessable’ labels was the same for imported and local products. Country of origin status
was indeterminable for 16 labels in Stage 2. Of these labels, three were indeterminable for
Code used, 11 were assessed as being produced to the requirements of the new Code, and two
to the old Code.
Table 8 Code used based on imported status for Stage 2
Code Used
Indeterminable New Old
Imported Status
Total Number
of Products
Sampled Number (%) Number (%) Number (%)
Imported 153 13 (8) 101 (66) 39 (25)
Local 1093 69 (6) 956 (87) 68 (6)
Overall Results 1246 82 (7) 1057 (85) 107 (9)
As with Stage 1, only Australia and New Zealand had large enough sample sizes to allow
inter-country comparisons. Six hundred and seventy-three labels in Stage 2 were
manufactured in Australia of which 635 were fully ‘assessable’ (94%). Similarly, labels
manufactured in New Zealand were fully assessable in 93% of cases (390 of 420 labels).
4.2 Overall label consistency
Only labels determined ‘assessable’ were fully assessed against the labelling requirements of
the new Code for the label elements of interest, as detailed in the following sections. Of the
448 Stage 1 labels fully assessed, 15% (65 labels) were consistent with all the requirements
of the new Code assessed in this survey (refer to Table 9 for analysis by major food
categories, Appendix 19 by minor food categories). Consistency of labels in Stage 2 was
lower than Stage 1, with 5% of ‘assessable’ labels consistent with the requirements of the
new Code (56 of 1153 labels) (refer to Table 10 for analysis by major food categories,
Appendix 20 by minor food categories).
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The labels that were consistent in both Stages were all labels for products not requiring and,
subsequently not providing a Nutrition Information Panel (NIP), for example meat and meat
products, fruit and vegetables, fish and fish products and non-alcoholic beverages.
Stage 1
Table 9 Consistency status of labels by major food category for Stage 1
Consistency Status
Consistent Inconsistent
Major Food Category
Total Number of
Labels Assessed
Number (%) Number (%)
1. Dairy 42 1 (2) 41 (98)
2. Edible oils and oil emulsions 16 0 (0) 16 (100)
3. Ice cream and edible ices 7 0 (0) 7 (100)
4. Fruit and vegetables 65 27 (42) 38 (58)
5. Confectionery 18 0 (0) 18 (100)
6. Cereal and cereal products 15 0 (0) 15 (100)
7. Bread and bakery products 52 0 (0) 52 (100)
8. Meat and meat products 57 10 (18) 47 (82)
9. Fish and fish products 15 2 (13) 13 (87)
10. Eggs and egg products 3 0 (0) 3 (100)
11. Sugars, honey and related products 6 0 (0) 6 (100)
12. Food intended for particular dietary use 14 0 (0) 14 (100)
13. Non alcoholic beverages 58 25 (43) 33 (57)
14. Mixed foods 80 0 (0) 80 (100)
Overall Results 448 65 (15) 383 (85)
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Stage 2
Table 10 Consistency status of labels by major food category for Stage 2
Consistency Status
Consistent Inconsistent
Major Food Category
Total Number of
Labels Assessed
Number (%) Number (%)
1. Dairy 106 0 (0) 106 (100)
2. Edible oils and oil emulsions 29 0 (0) 29 (100)
3. Ice cream and edible ices 34 0 (0) 34 (100)
4. Fruit and vegetables 143 13 (9) 130 (91)
5. Confectionery 69 0 (0) 69 (100)
6. Cereal and cereal products 66 0 (0) 66 (100)
7. Bread and bakery products 143 0 (0) 143 (100)
8. Meat and meat products 95 8 (8) 87 (92)
9. Fish and fish products 31 0 (0) 31 (100)
10. Eggs and egg products 7 0 (0) 7 (100)
11. Sugars, honey and related products 21 2 (10) 19 (90)
12. Food intended for particular dietary use 22 0 (0) 22 (100)
13. Non alcoholic beverages 121 30 (25) 91 (75)
14. Mixed foods 266 3 (1) 263 (99)
Overall Results 1153 56 (5) 1097 (95)
4.2.1 Overall label consistency based on label element
Stage 1
Of the 383 labels which were inconsistent with new Code labelling provisions in Stage 1, the
label element primarily responsible for inconsistency was the NIP (94%, 359 labels).
However, the degree or severity of inconsistency with the NIP varied. For standard NIPs for
example, virtually all the 346 inconsistent labels (99%) had minor inconsistencies when
compared to the prescribed format for the NIP in the new Code; 49% had intermediate
inconsistencies and 64% had major inconsistencies (see Section 4.10 for more details).
A large number of inconsistencies also resulted from:
• the characterising ingredient label element (35%, 135 of 383 labels);
• the date marking label element (28%, 108 of 383 labels);
• the storage instructions label element (9%, 35 of 383 labels); and
• the compound ingredient label element (6%, 21 of 383 labels).
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Mandatory advisory statements and ingredient declarations both represented less than one
percent of label inconsistencies (refer to Table 11).
It should be noted, that in a number of instances, labels were inconsistent for more than one
label element.
No labels were inconsistent for the following label elements:
• product name;
• usage instructions; and
• allergen labelling.
Only one label was assessed for genetically modified foods and ingredients and this label was
consistent. No labels were assessed for products that were irradiated or contained irradiated
ingredients (refer to Table 11).
Table 11 Overall label inconsistencies by label element assessed for Stage 1
Label Element Assessed Number of Labels
Inconsistent
Percentage of Total
Number of Inconsistent
Labels Assessed*
Product Name 0 0
Date Marking 108 28
Storage Instructions 35 9
Usage Instructions 0 0
Allergen Information 0 0
Mandatory Advisory Statements 2 less than 1
Nutrition Information Panel 359 94
Ingredient Declaration 1 less than 1
Characterising Ingredient Declaration 135 35
Compound Ingredient Declaration 21 6
Genetically Modified Foods or Ingredients 0 0
Irradiated Foods or Ingredients 0 0
* Total number of inconsistent labels = 383. Labels may be inconsistent for more than one label element.
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Stage 2
In Stage 2, the reasons labels were assessed as inconsistent with the new Code in regards to
label elements were similar to those in Stage 1. Again, the label element with the highest
percentage occurrence of inconsistent labels was the NIP (98%, 1078 of 1097 labels). As
with Stage 1, the severity of NIP inconsistencies varied. For standard NIPs for example,
virtually all the 1063 inconsistent labels (100%) had minor inconsistencies when compared to
the prescribed format for the NIP in the new Code; 45% had intermediate inconsistencies and
51% had major inconsistencies (see Section 4.10 for more details).
Other common reasons for inconsistency in Stage 2 were:
• the characterising ingredient label element (25%, 277 of 1097 labels);
• the date marking label element (18%, 197 0f 1097 labels); and
• the storage instructions label element (6%, 61 of 1097 labels).
Although at very low percentages, inconsistencies also occurred for the product name, usage
instructions, ingredient declaration and compound ingredient declarations label elements
(refer to Table 12). This was different to Stage 1 where no labels were inconsistent for the
product name and usage instructions label elements.
There were no inconsistencies in Stage 2 as a result of:
• allergen information; and
• mandatory advisory statements.
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Table 12 Overall label inconsistencies by label element assessed for Stage 2
Label Element Assessed Number of Labels
Inconsistent
Percentage of Total
Number of Inconsistent
Labels Assessed*
Product Name 3 Less than 1
Date Marking 197 18
Storage Instructions 61 6
Usage Instructions 1 Less than 1
Allergen Information 0 0
Mandatory Advisory Statements 1 Less than 1
Nutrition Information Panel 1078 98
Ingredient Declaration 13 1
Characterising Ingredient Declaration 277 25
Compound Ingredient Declaration 8 1
Genetically Modified Foods or Ingredients 0 0
Irradiated Foods or Ingredients 0 0
* Total number of inconsistent labels = 1097. Labels may be inconsistent for more than one label element.
4.2.2 Overall label consistency based on brand category
Based on brand category, there were some minor differences observed in overall label
consistency (refer to Table 13 and Table 14), with generic products being more consistent
than other types in Stage 1 and specialty products being more consistent in Stage 2. However,
the number of speciality products fully assessed in each Stage was small compared to the
total sample.
Stage 1
Table 13 Consistency status of labels based on brand category for Stage 1
Consistency Status
Consistent Inconsistent
Major Food Category
Total Number of
Labels Assessed
Number (%) Number (%)
Generic 45 9 (20) 36 (80)
National 335 46 (14) 289 (86)
Speciality 18 3 (17) 15 (83)
State Specific 50 7 (14) 43 (86)
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Stage 2
Table 14 Consistency status of labels based on brand category for Stage 2
Consistency Status
Consistent Inconsistent
Major Food Category
Total Number of
Labels Assessed
Number (%) Number (%)
Generic 185 10 (5) 175 (95)
National 885 38 (4) 847 (96)
Speciality 13 2 (15) 11 (85)
State Specific 70 6 (9) 64 (91)
4.2.3 Overall label consistency based on country of manufacture
There was little difference in the level of label consistency between local and imported
products in Stage 1 (15% and 14% of products respectively were consistent), compared to the
overall label consistency of 15% (refer to Table 9 and Table 15). Comparably, in Stage 2, the
consistency of local and imported labels was four percent and eight percent respectively, with
overall label consistency being 5% (refer to Table 10 and Table 16)
Stage 1
Table 15 Consistency status of labels based on imported status for Stage 1
Consistency Status
Consistent Inconsistent
Imported Status
Total Number of
Labels Assessed
Number (%) Number (%)
Imported 58 8 (14) 50 (86)
Local 390 57 (15) 333 (85)
Stage 2
Table 16 Consistency status of labels based on imported status for Stage 2
Consistency Status
Consistent Inconsistent
Imported Status
Total Number of
Labels Assessed*
Number (%) Number (%)
Imported 114 9 (8) 105 (92)
Local 1025 44 (4) 981 (96)
* Some labels could not be assessed as imported or local.
4.3 Overall label legibility
In assessing food labels for legibility, each label element was assessed separately. If any one
label element was deemed not legible, the overall label was inconsistent for legibility.
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Stage 1
Of the 448 labels fully assessed in Stage 1, 92% were legible (refer to Table 17 for analysis
by major food categories and Appendix 21 by minor food categories).
Table 17 Consistency status of legibility by major food category for Stage 1
Consistency Status
Consistent Inconsistent
Major Food Category
Total Number of
Labels Assessed
Number (%) Number (%)
1. Dairy 42 36 (86) 6 (14)
2. Edible oils and oil emulsions 16 16 (100) 0 (0)
3. Ice cream and edible ices 7 6 (86) 1 (14)
4. Fruit and vegetables 65 63 (97) 2 (3)
5. Confectionery 18 18 (100) 0 (0)
6. Cereal and cereal products 15 11 (73) 4 (27)
7. Bread and bakery products 52 43 (83) 9 (17)
8. Meat and meat products 57 52 (91) 5 (9)
9. Fish and fish products 15 15 (100) 0 (0)
10. Eggs and egg products 3 2 (67) 1 (33)
11. Sugars, honey and related products 6 5 (83) 1 (17)
12. Food intended for particular dietary use 14 14 (100) 0 (0)
13. Non alcoholic beverages 58 53 (91) 5 (9)
14. Mixed foods 80 76 (95) 4 (5)
Overall Results 448 410 (92) 38 (8)
Table 18 outlines the reasons why labels were not legible by label element (38 labels not
legible), with date marking and NIPs being the main label elements that were not legibile.
Details of legibility for each label element section and label element sub-section will be
discussed separately under each label element in the relevant sections of the report.
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Table 18 Overall label illegibility by label element assessed for Stage 1
Label Element Assessed Number of Labels
Not Legible
Percentage of Total
Number of Labels Not
Legible
Product Name 0 0
Date Marking 25 66
Storage Instructions 3 8
Usage Instructions 0 0
Allergen Information 0 0
Mandatory Advisory Statements 0 0
Nutrition Information Panel 9 24
Ingredient Declaration 1 3
Genetically Modified Foods or Ingredients 0 0
Irradiated Foods or Ingredients 0 0
Stage 2
Ninety-one percent of labels in Stage 2 were consistent for the legibility label element (refer
to Table 19 for analysis by major food categories and Appendix 22 by minor food
categories). Reasons for legibility inconsistencies are detailed in Table 20 and will be
discussed for each label element section and label element sub-section below.
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Table 19 Consistency status of legibility by major food category for Stage 2
Consistency Status
Consistent Inconsistent
Major Food Category
Total Number of
Labels Assessed
Number (%) Number (%)
1. Dairy 106 97 (92) 9 (8)
2. Edible oils and oil emulsions 29 25 (86) 4 (16)
3. Ice cream and edible ices 34 31 (91) 3 (9)
4. Fruit and vegetables 143 138 (97) 5 (3)
5. Confectionery 69 57 (83) 12 (17)
6. Cereal and cereal products 66 55 (83) 11 (17)
7. Bread and bakery products 143 130 (91) 13 (9)
8. Meat and meat products 95 83 (87) 12 (13)
9. Fish and fish products 31 29 (94) 2 (6)
10. Eggs and egg products 7 3 (43) 4 (57)
11. Sugars, honey and related products 21 20 (95) 1 (5)
12. Food intended for particular dietary use 22 21 (95) 1 (5)
13. Non alcoholic beverages 121 116 (96) 5 (4)
14. Mixed foods 266 246 (92) 20 (8)
Overall Results 1153 1051 (91) 102 (9)
Table 20 Overall label illegibility by label element assessed for Stage 2
Label Element Assessed Number of Labels
Not Legible*
Percentage of Total
Number of Labels Not
Legible
Product Name 3 3
Date Marking 80 78
Storage Instructions 2 2
Usage Instructions 1 1
Allergen Information 0 0
Mandatory Advisory Statements 0 0
Nutrition Information Panel 15 15
Ingredient Declaration 10 10
Genetically Modified Foods or Ingredients 0 0
Irradiated Foods or Ingredients 0 0
*Labels could be illegible for more than one label element
4.4 Product name
Stage 1
With respect to the product name label element, all 448 Stage 1 labels were assessed as
legible and therefore, consistent with the labelling requirements of the new Code. Additional
data collected indicated that 95% of labels fully assessed in Stage 1 had product names that
were a true reflection of the nature of the food (refer to Table 21).
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Table 21 Product name and description reflect true nature of product by major
food category for Stage 1
Product Name/Description Reflects True Nature
Yes No
Major Food Category
Total Number of
Labels Assessed
Number (%) Number (%)
1. Dairy 42 40 (95) 2 (5)
2. Edible oils and oil emulsions 16 16 (100) 0 (0)
3. Ice cream and edible ices 7 6 (86) 1 (14)
4. Fruit and vegetables 65 63 (97) 2 (3)
5. Confectionery 18 16 (89) 2 (11)
6. Cereal and cereal products 15 15 (100) 0 (0)
7. Bread and bakery products 52 48 (92) 4 (8)
8. Meat and meat products 57 55 (96) 2 (4)
9. Fish and fish products 15 15 (100) 0 (0)
10. Eggs and egg products 3 3 (100) 0 (0)
11. Sugars, honey and related products 6 6 (100) 0 (0)
12. Food intended for particular dietary use 14 14 (100) 0 (0)
13. Non alcoholic beverages 58 53 (91) 5 (9)
14. Mixed foods 80 74 (91) 6 (9)
Overall Results 448 424 (95) 24 (5)
Stage 2
Three labels were assessed as inconsistent for legibility in Stage 2 and consequently, with the
requirements of the new Code for this label element. The reasons these labels were assessed
as inconsistent for legibility are a result of the product name and/or description not being:
• indelible (one of three labels);
• distinct from label decoration (one of three labels); and
• in English (one of three labels).
Ninety four percent of product names and descriptions in Stage 2 were assessed as truly
reflecting the nature of the food (refer to Table 22).
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Table 22 Product name and description reflect true nature of product by major
food category for Stage 2
Product Name/Description Reflects True Nature
Yes No
Major Food Category
Total Number of
Labels Assessed
Number (%) Number (%)
1. Dairy 106 103 (97) 3 (3)
2. Edible oils and oil emulsions 29 29 (100) 0 (0)
3. Ice cream and edible ices 34 25 (74) 9 (26)
4. Fruit and vegetables 143 138 (97) 5 (3)
5. Confectionery 69 64 (93) 5 (7)
6. Cereal and cereal products 66 65 (98) 1 (2)
7. Bread and bakery products 143 135 (94) 8 (6)
8. Meat and meat products 95 95 (100) 0 (0)
9. Fish and fish products 31 29 (94) 2 (6)
10. Eggs and egg products 7 7 (100) 0 (0)
11. Sugars, honey and related products 21 21 (100) 0 (0)
12. Food intended for particular dietary use 22 18 (82) 4 (18)
13. Non alcoholic beverages 121 104 (86) 17 (14)
14. Mixed foods 266 249 (94) 17 (6)
Overall Results 1153 1082 (94) 71 (6)
Comparison of additional data for product name and description in Stage 1 and Stage 2
For Stage 1, the principal reasons that the name or description did not reflect the true nature
of the product for the 24 inconsistent labels were a result of the product name or description:
• not describing what the food was (38%, nine of 24 labels);
• being in a different field of vision2 (17%, four of 24 labels);
• not indicating that the product was a concentrate or dry mix (13%, three of 24 labels);
or
• being deceptive (46%, 11 of 24 labels).
Labels could be inconsistent for more than one reason.
2 Field of vision requirements are not given in the new Code, but refer to requirements in the Australian Trade
Measurements Act. The name of the food or brand required under Trade Measurement legislation may not
necessarily be the same as that used in order to comply with the new Code. For the purposes of this assessment
it was decided that customers should be presented with primary facts in one field of vision and they should not
have to search packs for information such as the name, description or weight.
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Reasons that the name and/or description did not reflect the true nature of the product were
the same in Stage 2, though the percentage occurrence of these reasons was different between
the Stages.
The reasons that the product name and/or description did not reflect the true nature of the
product in Stage 2 were, the product name and description:
• did not describe what the food was (17%, 12 of 71 labels);
• were in a different field of vision² (15%, 11 of 71 labels);
• was deceptive (65%, 46 of 71 labels); or
• did not indicate that the product was a concentrate or dry mix (six percent, four of 71
labels).
Labels could be inconsistent for more than one reason.
The product name or description on the label of a food product was considered to be
deceptive when the product named or described an ingredient that was not present in the
product (e.g. ‘strawberry fruit bars’ with no indication that the product did not contain
strawberries but was merely strawberry flavoured).
4.5 Date marking
Eighty six percent (387 labels) of the 448 labels fully assessed in Stage 1 were required to
provide date marking whilst, eighty seven percent (1006 labels) of the 1153 labels fully
assessed in Stage 2 were required to provide date marking. Those labels that were exempt
from providing date marking statements were assessed as such for this label element in the
overall label assessment, and therefore were not fully assessed for this label element.
For the minor food categories of fresh milk full fat, fresh milk reduced fat, chilled whole
meat products and chilled comminuted meat products, it was deemed for the purpose of this
survey, that date marking should be given as a ‘use by’ date for health and safety reasons.
Stage 1
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Seventy two percent of the labels fully assessed for this label element in Stage 1, were
consistent with the Code (refer to Table 23). The following major food categories had the
highest proportion of inconsistent labels for this label element:
• edible oils and emulsions (seven of 16 labels);
• ice cream and edible ices (four of 7 labels);
• non alcoholic beverages (16 of 39 labels);
• cereal and cereal products (six of 15 labels);
• bread and bakery products (15 of 52 labels);
• meat and meat products (15 of 56 labels); and
• sugars, honey and related products (two of two labels).
Table 23 Consistency status of date marking by major food category for Stage 1
Consistency with date marking requirement
Consistency Inconsistent
Major Food Category
Total Number of
Labels Assessed
Number (%) Number (%)
1. Dairy 41 32 (78) 9 (22)
2. Edible oils and oil emulsions 16 9 (56) 7 (44)
3. Ice cream and edible ices 7 3 (43) 4 (57)
4. Fruit and vegetables 34 30 (88) 4 (12)
5. Confectionery 18 15 (83) 3 (17)
6. Cereal and cereal products 15 9 (60) 6 (40)
7. Bread and bakery products 52 37 (71) 15 (29)
8. Meat and meat products 56 41 (73) 15 (27)
9. Fish and fish products 11 8 (73) 3 (27)
10. Eggs and egg products 3 3 (100) 0 (0)
11. Sugars, honey and related products 2 0 (0) 2 (100)
12. Food intended for particular dietary use 14 12 (86) 2 (14)
13. Non alcoholic beverages 39 23 (59) 16 (41)
14. Mixed foods 79 57 (72) 22 (28)
Overall Results 387 279 (72) 108 (28)
Stage 2
The percentage of labels consistent with the Code in Stage 2 was similar to that of Stage 1,
with 80% of labels fully assessed being consistent (refer to Table 24). In Stage 2, the
following major food categories had the highest proportion of inconsistent labels for this
label element:
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• meat and meat products (40 of 90 labels);
• eggs and egg products (five of seven labels); and
• sugars, honey and related products (four of 10 labels).
Table 24 Consistency status of date marking by major food category for Stage 2
Consistency with date marking requirement
Consistency Inconsistent
Major Food Category
Total Number of
Labels Assessed
Number (%) Number (%)
1. Dairy 104 83 (80) 21 (20)
2. Edible oils and oil emulsions 29 20 (69) 9 (31)
3. Ice cream and edible ices 32 25 (78) 7 (22)
4. Fruit and vegetables 97 77 (79) 20 (21)
5. Confectionery 66 54 (82) 12 (18)
6. Cereal and cereal products 59 48 (81) 11 (19)
7. Bread and bakery products 141 116 (82) 25 (18)
8. Meat and meat products 90 50 (56) 40 (44)
9. Fish and fish products 24 19 (79) 5 (21)
10. Eggs and egg products 7 2 (29) 5 (71)
11. Sugars, honey and related products 10 6 (60) 4 (40)
12. Food intended for particular dietary use 22 20 (91) 2 (9)
13. Non alcoholic beverages 108 96 (89) 12 (11)
14. Mixed foods 217 193 (89) 24 (11)
Overall Results 1006 809 (80) 197 (20)
Of the labels inconsistent for date marking, three reasons for inconsistency were identified,
with some labels being inconsistent for more than one reason:
• date marking not provided on food product labels;
• date marking not legible; and
• incorrect or inappropriate use of date marking statement.
These three categories are discussed in detail below.
4.5.1 Date marking not provided on food product labels
Ninety one percent (352 of 387 labels) of labels required to provide date marking in Stage 1
were consistent in providing these date marking statements (refer to Table 25). This figure was
higher in Stage 2, with 98% (989 of 1006 labels) of labels providing date marking statements
when required (refer to Table 26).
Stage 1
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Table 25 Consistency status for provision of date marking by major food category for
Stage 1
Consistency Status
Consistent Inconsistent
Major Food Category
Total Number of
Labels Assessed*
Number (%) Number (%)
1. Dairy 41 40 (98) 1 (2)
2. Edible oils and oil emulsions 16 11 (69) 5 (31)
3. Ice cream and edible ices 7 5 (71) 2 (29)
4. Fruit and vegetables 34 34 (100) 0 (0)
5. Confectionery 18 16 (89) 2 (11)
6. Cereal and cereal products 15 13 (88) 2 (13)
7. Bread and bakery products 52 50 (96) 2 (4)
8. Meat and meat products 56 54 (96) 2 (4)
9. Fish and fish products 11 9 (82) 2 (18)
10. Eggs and egg products 3 3 (100) 0 (0)
11. Sugars, honey and related products 2 2 (100) 0 (0)
12. Food intended for particular dietary use 14 14 (100) 0 (0)
13. Non alcoholic beverages 39 36 (92) 3 (8)
14. Mixed foods 79 65 (82) 14 (18)
Overall Results 387 352 (91) 35 (9)
*Total number of labels requiring date marking = 387
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Stage 2
Table 26 Consistency status for provision of date marking by major food category for
Stage 2
Consistency Status
Consistent Inconsistent
Major Food Category
Total Number of
Labels Assessed*
Number (%) Number (%)
1. Dairy 104 103 (99) 1 (1)
2. Edible oils and oil emulsions 29 27 (93) 2 (7)
3. Ice cream and edible ices 32 29 (91) 3 (9)
4. Fruit and vegetables 97 91 (94) 6 (6)
5. Confectionery 66 66 (100) 0 (0)
6. Cereal and cereal products 59 59 (100) 0 (0)
7. Bread and bakery products 141 141 (100) 0 (0)
8. Meat and meat products 90 87 (97) 3 (3)
9. Fish and fish products 24 24 (100) 0 (0)
10. Eggs and egg products 7 7 (100) 0 (0)
11. Sugars, honey and related products 10 10 (100) 0 (0)
12. Food intended for particular dietary use 22 22 (100) 0 (0)
13. Non alcoholic beverages 108 108 (100) 0 (0)
14. Mixed foods 217 215 (99) 2 (1)
Overall Results 1006 989 (98) 17 (2)
*Total number of labels requiring date marking = 1006
Comparison of date marking statement provision in Stage 1 and Stage 2
When comparing results for Stage 1 and Stage 2, it is noted that for some major categories, the
difference in terms of percentage consistency for date marking provision is reasonably large.
This is particularly true for edible oils and oil emulsions where 69% of labels requiring date
marking statements in Stage 1 were consistent in providing these statements, whilst in Stage 2
93% were consistent. Other major food categories where this difference was considered
reasonably large include:
• ice cream and edible ices (71% in Stage 1 and 91% in Stage 2);
• confectionery (89% in Stage 1 and 100% in Stage 2);
• cereal and cereal products (88% in Stage 1 and 100% in Stage 2);
• fish and fish products (82% in Stage 1 and 100% in Stage 2); and
• mixed foods (82% in Stage 1 and 99% in Stage 2).
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4.5.2 Date marking not legible
Stage 1
Of the 352 labels providing date marking in Stage 1, 93% (327 labels) were assessed as
consistent with legibility provisions.
Although 25 labels were assessed as inconsistent against legibility provisions, it was still
possible to ascertain if the date marking statement was correct or appropriate in all but two of
these labels (see below).
A lack of colour contrast with background affected date marking legibility. In nine of the 25
labels assessed as inconsistent for legibility, date markings were not placed on the label, but
located on the side of the lid or the body of the container. The lids, containers or product (if
container transparent) were often dark coloured or patterned, causing the date marking
printing to be illegible. The fact that the date markings were often printed onto the container
rather than the label, also contributed to date markings lacking indelibility (nine of the 25
inconsistent labels), as the print did not appear to adhere as well to these surfaces. As date
mark information is often printed on food packs at high line speeds it is noted that it is
difficult for the food industry to control legibility in all cases.
In addition, labels were inconsistent for the lack of:
• noticeability (four of the 25 labels);
• visibility (four of 25 labels); and
• prominence (one of 25 labels).
Stage 2
In Stage 2, 92% (909 of 989 labels) of labels providing date marking were consistent with
legibility requirements.
As with Stage 1, it was still possible to assess date marking statements for correctness and
appropriateness in all but seven of the 80 labels inconsistent for legibility.
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The reasons for inconsistency with respect to date marking legibility in Stage 2, were more
numerous than that of Stage 1.
The prime reason for date marking illegibility in Stage 2 was a lack of indelibility, affecting
37 of the 80 inconsistent labels. Other reasons for date marking illegibility were due to date
marking not being:
• visible (12 of 80 labels);
• aligned appropriately (11 of 80 labels);
• in contrast with background (nine of 80 labels);
• a distinct text (five of 80 labels);
• in an easy to read font (three of 80 labels);
• in an easy to read case (two of 80 labels);
• placed appropriately (two of 80 labels);
• prominent (two of 80 labels);
• distinct from decorations (one of 80 labels);
• distinct or ‘standing out’ (one of 80 labels); and
• sized to fit date marking box (one of 80 labels).
It should be noted that in both Stage 1 and 2, some labels were inconsistent for legibility for
more than one reason.
4.5.3 Incorrect or inappropriate use of date marking statement
Stage 1
Table 27 details the consistency of the date marking statement used (i.e. ‘use by’ or ‘best
before’) against the labelling provisions for Stage 1 labels. Of the 352 labels providing date
markings, 84% of labels were consistent, with 15% inconsistent, and two labels (1%)
indeterminable (due to total illegibility of the date marking).
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Table 27 Consistency status of date marking statement used by major food category for
Stage 1
Consistency Status
Consistent Inconsistent Indeterminable
Major Food Category
Total Number
of Labels
Assessed* Number (%) Number (%) Number (%)
1. Dairy 40 34 (85) 6 (15) 0 (0)
2. Edible oils and oil emulsions 11 9 (82) 2 (18) 0 (0)
3. Ice cream and edible ices 5 3 (60) 1 (20) 1 (20)
4. Fruit and vegetables 34 30 (88) 4 (12) 0 (0)
5. Confectionery 16 15 (94) 1 (6) 0 (0)
6. Cereal and cereal products 13 11 (84) 2 (15) 0 (0)
7. Bread and bakery products 50 42 (84) 8 (16) 0 (0)
8. Meat and meat products 54 43 (80) 11 (20) 0 (0)
9. Fish and fish products 9 8 (89) 1 (11) 0 (0)
10. Eggs and egg products 3 3 (100) 0 (0) 0 (0)
11. Sugars, honey and related products 2 0 (0) 2 (100) 0 (0)
12. Food intended for particular dietary use 14 12 (86) 2 (14) 0 (0)
13. Non alcoholic beverages 36 26 (72) 9 (25) 1 (3)
14. Mixed foods 65 60 (92) 5 (8) 0 (0)
Overall Results 352 296 (84) 54 (15) 2 (1)
* Total number of labels providing date marking only
Of the 54 Stage 1 labels assessed as being inconsistent for the date marking statement used,
the three main reasons were:
• the statement used being incorrect or inappropriate (22 of 54 labels) as a result of:
o ‘best before’ provided where a ‘use by’ statement was necessary (seven of 22
labels);
o statement other than ‘best before’ or ‘use by’ given (e.g. ‘best by’, ‘best before
end’, ‘exp’) (15 of 22 labels);
• provision of a date only, with no accompanying statement given (15 of 54 labels); or
• the date itself was not placed with the statement, with no indication given of its
location (12 of 54 labels).
A few inconsistencies also occurred due to incorrect date format (four labels) and use of
multiple statements (four labels) (e.g. ‘use by’ and ‘best before’). The date marking
statement used could be inconsistent for more than one reason.
Stage 2
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For Stage 2, the consistency status of date marking statements used was similar to that of
Stage 1, with 88% (875 of 989 labels) of labels consistent, 11% (107 of 989 labels)
inconsistent, and less than one percent (seven of 989 labels) indeterminable due to illegibility
(refer to Table 28).
Table 28 Consistency status of date marking statement used by major food category for
Stage 2
Consistency Status
Consistent Inconsistent Indeterminable
Major Food Category
Total Number
of Labels
Assessed* Number (%) Number (%) Number (%)
1. Dairy 103 88 (85) 15 (15) 0 (0)
2. Edible oils and oil emulsions 27 23 (85) 3 (11) 1 (4)
3. Ice cream and edible ices 29 27 (93) 1 (3) 1 (3)
4. Fruit and vegetables 91 81 (89) 10 (11) 0 (0)
5. Confectionery 66 62 (94) 4 (6) 0 (0)
6. Cereal and cereal products 59 56 (95) 3 (5) 0 (0)
7. Bread and bakery products 141 122 (87) 18 (13) 1 (Less than 1)
8. Meat and meat products 87 58 (67) 29 (33) 0 (0)
9. Fish and fish products 24 19 (80) 5 (21) 0 (0)
10. Eggs and egg products 7 4 (57) 2 (29) 1 (14)
11. Sugars, honey and related products 10 7 (70) 3 (30) 0 (0)
12. Food intended for particular dietary use 22 20 (91) 2 (9) 0 (0)
13. Non alcoholic beverages 108 100 (93) 8 (7) 0 (0)
14. Mixed foods 215 208 (97) 4 (2) 3 (1)
Overall Results 989 875 (88) 107 (11) 7 (Less than 1)
* Total number of labels providing date marking only
The reasons for inconsistency in terms of date marking statement used for the 107
inconsistent Stage 2 labels were:
• the statement used being incorrect or inappropriate (74 of 107 labels) as a result of:
• ‘best before’ provided where a ‘use by’ statement was necessary (40 of 74 labels);
• statement other than ‘best before’ or ‘use by’ given (e.g. ‘best by’, ‘best before
end’, ‘exp’) (34 of 74 labels);
• provision of date only, with no accompanying statement given (14 of 107 labels);
• the use of multiple terms (e.g. ‘best before’ and ‘use by’) (nine of 107 labels);
• the use of incorrect date format (nine of 107 labels); and
• the date itself not placed with statement, with no indication given of its location (five
of 107 labels).
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As with Stage 1, the date marking statement used in Stage 2 could be inconsistent for more
than one reason.
Tables 29 and 30 detail the date marking statement types used in the major food categories
for Stage 1 and 2 respectively.
Table 29 Date marking statement type used by major food category for Stage 1
Date Marking Statement Used
Best Before Use By Other Date but no
Statement
Indeterminable*
Major Food Category
Total
Number of
Labels
Assessed# Number (%) Number (%) Number (%) Number (%) Number (%)
1. Dairy 40 21 (53) 18 (45) 1 (2) 0 (0) 0 (0)
2. Edible oils and oil emulsions 11 9 (82) 0 (0) 2 (18) 0 (0) 0 (0)
3. Ice cream and edible ices 5 3 (60) 0 (0) 0 (0) 1 (20) 1 (20)
4. Fruit and vegetables 34 25 (74) 5 (15) 2 (6) 2 (6) 0 (0)
5. Confectionery 16 15 (94) 0 (0) 0 (0) 1 (6) 0 (0)
6. Cereal and cereal products 13 10 (77) 2 (15) 1 (8) 0 (0) 0 (0)
7. Bread and bakery products 50 38 (76) 9 (18) 2 (4) 1 (2) 0 (0)
8. Meat and meat products 54 14 (26) 36 (67) 1 (2) 3 (5) 0 (0)
9. Fish and fish products 9 4 (45) 4 (44) 0 (0) 1 (11) 0 (0)
10. Eggs and egg products 3 3 (100) 0 (0) 0 (0) 0 (0) 0 (0)
11. Sugars, honey and related
products
2 2 (100) 0 (0) 0 (0) 0 (0) 0 (0)
12. Food intended for particular
dietary use
14 6 (43) 6 (43) 2 (14) 0 (0) 0 (0)
13. Non alcoholic beverages 36 23 (64) 5 (14) 3 (8) 4 (11) 1 (3)
14. Mixed foods 65 40 (62) 22 (33) 1 (2) 2 (3) 0 (0)
Overall Results 352 213 (61) 107 (30) 15 (4) 15 (4) 2 (1)
# Number of products requiring date marking only
* Indeterminable due to date mark not being legible
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Table 30 Date marking statement type used by major food category for Stage 2
Date Marking Statement Used
Best Before Use By Other Date but no
Statement
Indeterminable*
Major Food Category
Total
Number of
Labels
Assessed# Number (%) Number (%) Number (%) Number (%) Number (%)
1. Dairy 103 77 (75) 22 (21) 3 (3) 1 (1) 0 (0)
2. Edible oils and oil emulsions 27 23 (85) 0 (0) 2 (7) 1 (4) 1 (4)
3. Ice cream and edible ices 29 26 (90) 1 (3) 0 (0) 1 (3) 1 (3)
4. Fruit and vegetables 91 74 (81) 8 (9) 7 (8) 2 (2) 0 (0)
5. Confectionery 66 61 (92) 1 (2) 2 (3) 2 (3) 0 (0)
6. Cereal and cereal products 59 52 (88) 3 (5) 3 (5) 1 (2) 0 (0)
7. Bread and bakery products 141 112 (79) 14 (10) 12 (9) 2 (1) 1 (1)
8. Meat and meat products 87 34 (39) 52 (60) 1 (1) 0 (0) 0 (0)
9. Fish and fish products 24 11 (46) 9 (38) 2 (8) 1 (4) 1 (4)
10. Eggs and egg products 7 6 (86) 0 (0) 0 (0) 1 (14) 0 (0)
11. Sugars, honey and related
products
10 7 (70) 1 (10) 1 (10) 1 (10) 0 (0)
12. Food intended for particular
dietary use
22 17 (77) 3 (14) 2 (9) 0 (0) 0 (0)
13. Non alcoholic beverages 108 88 (81) 12 (11) 7 (6) 1 (1) 0 (0)
14. Mixed foods 215 192 (89) 15 (7) 5 (2) 0 (0) 3 (1)
Overall Results 989 780 (79) 141 (14) 47 (5) 14 (1) 7 (1)
# Number of products requiring date marking only
* Indeterminable due to date mark not being legible
Comparison of date marking statements used in Stage 1 and Stage 2
In Stage 1 and Stage 2, meat and meat products was the only major food category to
predominantly use ‘use by’ for date marking statements.
For Stage 1, the use of ‘best before’ and ‘use by’ statements were equally predominant for the
following categories:
• dairy;
• fish and fish products; and
• food intended for particular dietary use.
The percentage usage of date marking statements was different in Stage 2, where the only
major food category where the use of ‘best before’ and ‘use by’ were equally prominent was
fish and fish products.
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In both Stages, the majority of products in the other major food categories used ‘best before’
for date marking statements.
Overall for Stage 1, 61% of labels providing date marking statements used ‘best before’
statements, 30% used ‘use by’ statements, four percent each used other statements and
4%just provided a date without a qualifying statement. The remaining one percent were
indeterminable as labels were not legible.
In 13 of the 15 cases where other date marking statements were used on food product labels,
the other statements were variations on ‘Best Before’ and included:
• ‘Best Before End’ (eight of the 15 labels);
• ‘B/B’ (one of 15 labels);
• ‘BB’ (two of 15 labels); and
• ‘Best By’ (two of 15 labels).
Additional statements used were ‘exp’ or ‘Exp’ (one of 15) and one label used multiple
terms.
For Stage 2, labels providing date marking statements used ‘best before’ in 79% of cases, and
‘use by’ in 14% of cases. Other date marking statements were used for five percent of the
989 labels providing date marking statements, whilst one percent of labels provided a date
with no qualifying statement.
The majority of other date marking statements used in Stage 2, were also variations on ‘best
before’ and included:
• ‘Best Before End’ (six of 47 labels);
• ‘BB’ (five of 47 labels);
• ‘BBE’ (three of 47 labels);
• ‘B.Before’ (one of 47 labels);
• ‘B/B’ (two of 47 labels);
• ‘B/Before’ (one of 47 labels);
• ‘Baked’ (one of 47 labels);
• ‘Best’ (one of 47 labels);
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• ‘Best Bef’ (one of 47 labels);
• ‘Best Before By’ (one of 47 labels);
• ‘Best Before Frozen’ (one of 47 labels);
• ‘BKD’ (one of 47 labels);
• ‘Baked Before’ (four of 47 labels); and
• ‘Baked on’ (two of 47 labels).
There were however, some variations on the term ‘use by’ in Stage 2, and these included:
• ‘UBD’ (one of 47 labels); and
• ‘Use By Date’ (one of 47 labels).
The remaining ‘other’ statements used were:
• ‘EXP’ (four of 47 labels);
• ‘EX Date’ (one of 47 labels);
• ‘Expiration date’ (one of 47 labels); and
• ‘Expiry’ (one of 47 labels).
Additionally, eight labels in Stage 2 used multiple terms.
4.6 Storage instructions
Stage 1
Where a product requires storage instructions after opening, the Code does not specify the
type of products to which this applies. In theory, single serve products should not require
storage instructions. However, for the purposes of this survey, where it was considered likely
that such products could be stored in the refrigerator after opening, labels were assessed as
inconsistent if such storage instructions were not given.
Fifty four percent (243 of 448 labels) of Stage 1 labels required storage instructions. Of the
205 labels not requiring storage instructions, 32% (65 labels) voluntarily provided these
instructions. Therefore, a total of 308 labels were included for consistency assessment in
this label element for Stage 1.
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Of the 308 labels requiring or voluntarily providing storage instructions in Stage 1, 89% (273
labels) were consistent with the new Code requirements (refer to Table 31). The proportion
of labels that were inconsistent with Code requirements was higher in the following major
food categories:
• fish and fish products (eight of 15 labels);
• ice cream and edible ices (two of seven labels);
• mixed foods (13 of 61 labels); and
• fruits and vegetables (seven of 32 labels).
Table 31 Consistency status of storage instructions by major food category for
Stage 1
Consistency Status
Consistent Inconsistent
Major Food Category
Total Number of
Labels Assessed*
Number (%) Number (%)
1. Dairy 41 40 (98) 1 (2)
2. Edible oils and oil emulsions 12 12 (100) 0 (0)
3. Ice cream and edible ices 7 5 (71) 2 (29)
4. Fruit and vegetables 32 25 (78) 7 (22)
5. Confectionery 4 4 (100) 0 (0)
6. Cereal and cereal products 8 8 (100) 0 (0)
7. Bread and bakery products 32 32 (100) 0 (0)
8. Meat and meat products 57 55 (96) 3 (5)
9. Fish and fish products 15 7 (47) 8 (53)
10. Eggs and egg products 2 2 (100) 0 (0)
11. Sugars, honey and related products 2 2 (100) 0 (0)
12. Food intended for particular dietary use 13 12 (92) 1 (8)
13. Non alcoholic beverages 22 22 (100) 0 (0)
14. Mixed foods 61 48 (79) 13 (21)
Overall Results 308 273 (89) 35 (11)
* Includes all storage instructions, whether required or provided voluntarily
For this label element:
• ninety-nine percent of labels required to provide storage instructions before opening
were consistent in providing these instructions;
• thirty-nine percent of labels for single serve products deemed (for the purposes of this
survey) to require the provision of storage instructions after opening provided these
storage instructions; and
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• sixty-four percent of labels for multiple serve products required to provide storage
instructions after opening provided these instructions.
The reasons storage instructions were considered to be inconsistent were;
• storage instructions were not legible as the instructions were not visible (three of the
35 inconsistent labels);
• storage instructions required before opening were not provided (four of 35 labels);
• storage instructions deemed to be required after opening for single serve products (for
the purposes of this survey) were not provided (11 of 35 labels); and
• storage instructions required after opening for multiple serve products were not
provided (17 of 35 labels).
Of the four labels failing to provide storage instructions required before opening, one was a
frozen ice cream, one a frozen ice-confection, one a chilled comminuted meat and one a
frozen dessert.
Eleven single serve product labels deemed (for the purposes of this survey) to require the
provision of storage instructions after opening in order to maintain food safety and ensure the
product would keep for the specified ‘use by’ or ‘best before’ period, were inconsistent in
providing these instructions. For this label element sub-section there was one each for a
canned vegetable, dessert, and pre-prepared meal, three were canned soups and five were
canned fish products.
Seventeen labels for multiple serve products were assessed as inconsistent for not providing
storage instructions. These 17 labels included one each of pickled vegetable, infant food and
snack food, two canned fruits, three each of canned vegetables and canned fish, and six
sauces.
Stage 2
Of the 1153 labels fully assessed in Stage 2, 41% (474 labels) required storage instructions.
In addition, 355 labels voluntarily provided storage instructions and were included for
consistency assessments. Therefore, a total of 829 labels were assessed for consistency of
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storage instructions in Stage 2. Ninety three percent of these labels were assessed as
consistent with the requirements of the new Code (refer to Table 32).
Table 32 Consistency status of storage instructions by major food category for
Stage 2
Consistency Status
Consistent Inconsistent
Major Food Category
Total Number of
Labels Assessed*
Number (%) Number (%)
1. Dairy 105 103 (98) 2 (2)
2. Edible oils and oil emulsions 23 22 (96) 1 (4)
3. Ice cream and edible ices 30 29 (97) 1 (3)
4. Fruit and vegetables 106 88 (83) 18 (17)
5. Confectionery 10 10 (100) 0 (0)
6. Cereal and cereal products 43 43 (100) 0 (0)
7. Bread and bakery products 91 91 (100) 0 (0)
8. Meat and meat products 95 89 (94) 6 (6)
9. Fish and fish products 31 21 (68) 10 (32)
10. Eggs and egg products 5 5 (100) 0 (0)
11. Sugars, honey and related products 14 14 (100) 0 (0)
12. Food intended for particular dietary use 20 19 (95) 1 (5)
13. Non alcoholic beverages 69 69 (100) 0 (0)
14. Mixed foods 187 165 (88) 22 (12)
Overall Results 829 768 (93) 61 (7)
* Includes all storage instructions, whether required or provided voluntarily
For this label element;
• ninety-eight percent (363 of 370 labels) required to provide storage instructions
before opening were consistent in providing these instructions;
• thirty-nine percent of labels for single serve products deemed (for the purposes of this
survey) to require the provision of storage instructions after opening provided these
storage instructions; and
• fifty-two percent of labels for multiple serve products required to provide storage
instructions after opening provided these instructions.
The reasons storage instructions were assessed as inconsistent for Stage 2 were:
• storage instructions required before opening were not provided (seven of 61 labels);
• storage instructions deemed to be required after opening for single serve products (for
the purposes of this survey) were not provided (11 of 61 labels);
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• storage instructions required after opening for multiple serve products were not
provided (41 of 61 labels); and
• storage instructions were not legible (two of 61 labels) as a result of:
• storage instructions not being distinct from label decoration (one of two labels);
and
• storage instructions not being visible (one of two labels).
Of the labels inconsistent in providing storage instructions required before opening, there was
one each of a fresh yoghurt, chilled comminuted meat, butter, frozen ice cream, and chilled
dessert and two chilled whole meat products.
Single serve products assessed as inconsistent in providing storage instructions deemed to be
required after opening included one canned fruit, one canned pre-prepared meal, one dessert,
three preserved fish, and five canned soups.
Of the multiple serve products assessed as inconsistent in providing storage instructions after
opening, one was a pickled vegetable, one a pickled fruit, one a dessert, three canned meats,
five canned soups, seven canned fruits, seven preserved fish products, eight canned pre-
prepared meals, and eight canned vegetables.
Comparison of storage instruction consistency in Stage 1 and Stage 2
There was very little difference in the overall percentage consistency of storage instructions
between the two Stages (89% for Stage 1 and 93% in Stage 2). There was however some
differences in percentage consistency by major food category, the greatest being for ice
cream and edible ices, with 71% being assessed as consistent in Stage 1 and 97% assessed as
consistent in Stage 2. Other major food categories where there was a substantial increase in
percentage consistency were:
• fish and fish products (47% in Stage 1 and 68% in Stage 2); and
• mixed foods (79% in Stage 1 and 88% in Stage 2).
Three major food categories also had a reduction in percentage consistency from Stage 1 to
Stage 2, however these differences were not as great as those mentioned above.
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4.7 Usage instructions
In Stage 1, 33% (146 of 448 labels) of labels provided usage instructions (refer to Table 33).
All usage instructions provided were legible, thus the consistency for this label element was
100%. In Stage 2, fewer labels provided usage instructions (21%, 243 of 1153 labels) (refer
to Table 34). Furthermore, one label in Stage 2 was assessed as inconsistent as the usage
instructions were not legible due to them not being noticeable.
Table 33 Usage instructions provision by major food category for Stage 1
Provision of Usage Instructions
Provided Not Provided
Major Food Category
Total Number of
Labels Assessed
Number (%) Number (%)
1. Dairy 42 4 (10) 38 (90)
2. Edible oils and oil emulsions 16 3 (19) 13 (81)
3. Ice cream and edible ices 7 1 (14) 6 (86)
4. Fruit and vegetables 65 11 (17) 54 (83)
5. Confectionery 18 1 (6) 17 (94)
6. Cereal and cereal products 15 4 (27) 11 (73)
7. Bread and bakery products 52 15 (29) 37 (71)
8. Meat and meat products 57 15 (26) 42 (74)
9. Fish and fish products 15 4 (27) 11 (73)
10. Eggs and egg products 3 0 (0) 3 (100)
11. Sugars, honey and related products 6 3 (50) 3 (50)
12. Food intended for particular dietary use 14 11 (79) 3 (21)
13. Non alcoholic beverages 58 22 (38) 36 (62)
14. Mixed foods 80 52 (65) 28 (35)
Overall Results 448 146 (33) 302 (67)
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Table 34 Usage instructions provision by major food category for Stage 2
Provision of Usage Instructions
Provided Not Provided
Major Food Category
Total Number of
Labels Assessed
Number (%) Number (%)
1. Dairy 106 14 (13) 92 (87)
2. Edible oils and oil emulsions 29 0 (0) 29 (100)
3. Ice cream and edible ices 34 3 (9) 31 (91)
4. Fruit and vegetables 143 21 (15) 122 (85)
5. Confectionery 69 4 (6) 65 (94)
6. Cereal and cereal products 66 12 (18) 54 (82)
7. Bread and bakery products 143 26 (18) 117 (82)
8. Meat and meat products 95 7 (7) 88 (93)
9. Fish and fish products 31 2 (6) 29 (94)
10. Eggs and egg products 7 0 (0) 7 (100)
11. Sugars, honey and related products 21 1 (5) 20 (95)
12. Food intended for particular dietary use 22 10 (45) 12 (55)
13. Non alcoholic beverages 121 36 (30) 85 (70)
14. Mixed foods 266 107 (40) 159 (60)
Overall Results 1153 243 (21) 910 (79)
4.8 Allergen information
All ‘food contains allergen’ statements provided in both Stages were legible and thus, the
allergen information label element had 100% consistency.
4.8.1 ‘Food contains allergen’ statement
Stage 1
Seven percent (30 labels) of the 448 labels fully assessed in Stage 1 provided ‘food contains
allergen’ statements. These labels were split across several different food categories:
• bread and bakery products (16 of 52 labels); and
• sugar, honey and related products (three of six labels) (refer to Table 35).
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Table 35 Usage of ‘food contains allergen’ statement by major food category for Stage 1
‘Food contains allergen’ Statement Used
Yes No
Major Food Category
Total Number of
Labels Assessed
Number (%) Number (%)
1. Dairy 42 1 (2) 41 (98)
2. Edible oils and oil emulsions 16 0 (0) 16 (100)
3. Ice cream and edible ices 7 0 (0) 7 (100)
4. Fruit and vegetables 65 0 (0) 65 (100)
5. Confectionery 18 2 (11) 16 (89)
6. Cereal and cereal products 15 2 (12) 13 (88)
7. Bread and bakery products 52 16 (31) 36 (69)
8. Meat and meat products 57 1 (2) 56 (98)
9. Fish and fish products 15 0 (0) 15 (100)
10. Eggs and egg products 3 0 (0) 3 (100)
11. Sugars, honey and related products 6 3 (50) 3 (50)
12. Food intended for particular dietary use 14 0 (0) 14 (100)
13. Non alcoholic beverages 58 0 (0) 58 (100)
14. Mixed foods 80 5 (6) 75 (94)
Overall Results 448 30 (7) 418 93
Stage 2
The proportion of ‘food contains allergen’ statements was doubled in Stage 2, with 14% (163
of 1153 labels) of labels providing ‘food contains allergen’ statements. As with Stage 1,
these labels were split across the different major food categories with the highest usage
relative to category size being for:
• cereal and cereal products (22 of 66 labels);
• bread and bakery products (39 of 143 labels); and
• mixed foods (70 of 266 labels) (refer to Table 36).
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Table 36 Usage of ‘food contains allergen’ statement by major food category for Stage 2
‘Food contains allergen’ Statement Used
Yes No
Major Food Category
Total Number of
Labels Assessed
Number (%) Number (%)
1. Dairy 106 1 (1) 105 (99)
2. Edible oils and oil emulsions 29 5 (17) 24 (83)
3. Ice cream and edible ices 34 4 (12) 30 (88)
4. Fruit and vegetables 143 2 (1) 141 (99)
5. Confectionery 69 7 (10) 62 (90)
6. Cereal and cereal products 66 22 (33) 44 (67)
7. Bread and bakery products 143 39 (27) 104 (73)
8. Meat and meat products 95 6 (6) 89 (94)
9. Fish and fish products 31 0 (0) 31 (100)
10. Eggs and egg products 7 0 (0) 7 (100)
11. Sugars, honey and related products 21 2 (10) 19 (90)
12. Food intended for particular dietary use 22 0 (0) 22 (100)
13. Non alcoholic beverages 121 5 (4) 116 (96)
14. Mixed foods 266 70 (26) 196 (74)
Overall Results 1153 163 (14) 990 (86)
4.8.1.1 ‘Food contains allergen’ statement attributes
‘Food contains allergen’ statements were predominantly placed near the ingredient list in
both Stage 1 and Stage 2 (26 of 30 labels and 144 of 163 labels, respectively). Statements
were also provided between the ingredient list and NIP, near the NIP and in other positions
(refer to Tables 37 and 38).
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Stage 1
Table 37 Attributes of ‘food contains allergen’ statements for Stage 1
Attributes Assessed Number of Labels
Percentage of all Labels
with ‘food contains
allergen’ statements
Placement of Statement
Between ingredient list & NIP 3 10
Near Ingredient list 26 87
Other position 1 3
* Total sample number = 30
Font Style
Roman (standard) 11 37
Bold 19 63
* Total sample number = 30
Size Compared to Ingredient List
Larger 4 13
Same 25 83
Smaller 1 3
* Total sample number = 30
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Stage 2
Table 38 Attributes of ‘food contains allergen’ statements for Stage 2
Attributes Assessed Number of Labels
Percentage of all Labels
with ‘food contains
allergen’ statements
Placement of Statement
Between ingredient list & NIP 4 3
Near Ingredient list 144 88
Other position 13 8
Near NIP 2 1
* Total sample number = 163
Font Style
Roman (standard) 92 56
Bold 71 44
* Total sample number = 163
Size Compared to Ingredient List
Larger 25 15
Same 135 83
Smaller 3 2
* Total sample number = 163
Comparison of ‘food contains allergen’ statement attributes in Stage 1 and Stage 2
In Stage 1 ‘food contains allergen’ statements were mostly placed in a bold font (19 of 30
labels), giving these statements good prominence on the label (refer to Table 37).
Conversely, ‘food contains allergen’ statements in Stage 2 were primarily given in standard
font (92 of 163 labels) (refer to Table 38).
For both Stage 1 and Stage 2, the font size of ‘food contains allergen’ statements compared to
the font size of the ingredient list, was the same in 83% of labels (refer to Table 37 and 38).
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4.8.1.2 Allergens declared in ‘food contains allergen’ statements
Comparison of types of allergens declared in ‘food contains allergen’ statements in
Stage 1 and Stage 2
The type of allergens declared in ‘food contains allergen’ statements in Stage 1 and Stage 2
were primarily gluten-containing cereals, milk and soybean. In Stage 1, a small number of
declarations of egg, fish or peanut allergens were also made, with no statements declaring
crustacea, nut, sesame, sulphite, royal jelly, bee pollen or propolis allergens (refer to Table
39). In comparison, all allergens other than bee pollen and propolis were declared in Stage 2
in ‘food contains allergen’ statements (refer to Table 40).
Statements could be for more than one allergen type.
Table 39 Types of allergens declared for ‘food contains allergen’ statements for Stage 1
Type of Allergen Declared Number of Labels Percentage of total
number of labels with
‘Food contains allergen’
statements*
Gluten Cereal 22 73
Crustacea 0 0
Egg 3 10
Fish 1 3
Milk 12 40
Nut 0 0
Sesame 0 0
Peanut 1 3
Soybean 18 60
Sulphite 0 0
Royal Jelly 0 0
Bee Pollen 0 0
Propolis 0 0
* Total sample number = 30. Some labels declared more than one allergen.
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Table 40 Types of allergens declared for ‘food contains allergen’ statements for Stage 2
Type of Allergen Declared Number of Labels Percentage of total
number of labels with
‘Food contains allergen’
statements*
Gluten Cereal 113 69
Crustacea 1 1
Egg 11 7
Fish 2 1
Milk 68 42
Nut 5 3
Sesame 5 3
Peanut 6 4
Soybean 87 54
Sulphite 17 10
Royal Jelly 2 1
Bee Pollen 0 0
Propolis 0 0
* Total sample number = 163. Some labels declared more than one allergen.
4.8.2 Declaration of allergens in the ingredient list
Fifty seven percent (255 of 448 labels) of labels in Stage 1, and 63% (723 of 1153 labels) of
labels in Stage 2, declared allergens in the ingredient list (refer to Tables 41 and 42).
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Stage 1
Table 41 Usage of declaration of allergens in ingredient list by major food category for
Stage 1
Allergens Declared in Ingredient List
Yes No
Major Food Category
Total Number of
Labels Assessed
Number (%) Number (%)
1. Dairy 42 39 (93) 3 (7)
2. Edible oils and oil emulsions 16 7 (44) 9 (56)
3. Ice cream and edible ices 7 5 (71) 2 (29)
4. Fruit and vegetables 65 13 (20) 52 (80)
5. Confectionery 18 14 (78) 4 (22)
6. Cereal and cereal products 15 15 (100) 0 (0)
7. Bread and bakery products 52 52 (100) 0 (0)
8. Meat and meat products 57 21 (37) 36 (63)
9. Fish and fish products 15 15 (100) 0 (0)
10. Eggs and egg products 3 2 (67) 1 (33)
11. Sugars, honey and related products 6 2 (33) 4 (67)
12. Food intended for particular dietary use 14 10 (71) 4 (29)
13. Non alcoholic beverages 58 1 (2) 57 (98)
14. Mixed foods 80 59 (74) 21 (26)
Overall Results 448 255 (57) 193 (43)
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Stage 2
Table 42 Usage of declaration of allergens in ingredient list by major food category for
Stage 2
Allergens Declared in Ingredient List
Yes No
Major Food Category
Total Number of
Labels Assessed
Number (%) Number (%)
1. Dairy 106 99 (93) 7 (7)
2. Edible oils and oil emulsions 29 15 (52) 14 (48)
3. Ice cream and edible ices 34 28 (82) 6 (18)
4. Fruit and vegetables 143 33 (23) 110 (77)
5. Confectionery 69 57 (83) 12 (17)
6. Cereal and cereal products 66 62 (94) 4 (6)
7. Bread and bakery products 143 140 (98) 3 (2)
8. Meat and meat products 95 37 (39) 58 (61)
9. Fish and fish products 31 30 (97) 1 (3)
10. Eggs and egg products 7 4 (57) 3 (43)
11. Sugars, honey and related products 21 3 (14) 18 (86)
12. Food intended for particular dietary use 22 11 (50) 11 (50)
13. Non alcoholic beverages 121 7 (6) 114 (94)
14. Mixed foods 266 197 (74) 69 (26)
Overall Results 1153 723 (63) 430 (37)
4.8.2.1 Attributes of allergens declared in ingredient list
Stage 1
Of the 255 labels declaring allergens in the ingredient list in Stage 1, 59% declared allergens
using common names, 36% used the ingredient’s technical name and 5% used a combination
of both styles of terminology.
Allergens were generally not bolded for emphasis when declared in the ingredient list (93%
or 237 labels not bolded) (refer to Table 43).
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Table 43 Attributes of allergens declared in ingredient list for Stage 1
Attribute Assessed Number of Labels Percentage of all labels
with allergens declared in
ingredient list*
Type of Terminology Used
Common Name (e.g. ‘milk’) 151 59
Ingredient Name (e.g. ‘casein’) 92 36
Mixture of Both 12 5
* Total number of labels assessed = 255
Font Style
Normal 237 93
Bold 18 7
* Total number of labels assessed = 255
Stage 2
The use of common names to declare the presence of allergens in ingredient lists in Stage 2
was appreciably higher than in Stage 1 (59% of labels in Stage 1 and 82% of labels in Stage
2). Three percent of labels declared allergens using an ingredient name. Again, this figure
was somewhat different to that for Stage 1 (36%). A mixture of both common name and
ingredient name terminology was used in 107 of the 723 labels declaring allergens in the
ingredient list.
As with Stage 1, the majority of allergens declared in the ingredient lists in Stage 2 were not
bolded for emphasis (661 of 723 labels).
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Table 44 Attributes of allergens declared in ingredient list for Stage 2
Attribute Assessed Number of Labels Percentage of all labels
with allergens declared in
ingredient list*
Type of Terminology Used
Common Name (e.g. ‘milk’) 593 82
Ingredient Name (e.g. ‘casein’) 23 3
Mixture of Both 107 15
* Total number of labels assessed = 723
Font Style
Normal 661 91
Bold 62 9
* Total number of labels assessed = 723
4.8.2.2 Allergens declared in ingredient lists
Stage 1
Allergens declared in the ingredient list in Stage 1 were predominantly gluten-containing
cereals (49%, 126 of 255 labels), milk (55%, 140 of 255 labels) and soybean (33%, 84 of 255
labels). Egg allergens were the next most commonly declared at 14% (35 of 255 labels) with
some declarations of fish, nut, sesame, peanut, sulphites and crustacea (refer to Table 45).
No declarations were made in the ingredient list of the presence of royal jelly, bee pollen or
propolis allergens.
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Table 45 Types of allergens declared in the ingredient list for Stage 1
Type of Allergen Declared Number of Labels Percentage of all labels
declaring allergens in the
ingredient list*
Gluten Cereal 126 49
Crustacea 2 1
Egg 35 14
Fish 15 6
Milk 140 55
Nut 18 7
Sesame 9 4
Peanut 8 3
Soybean 84 33
Sulphite 3 1
Royal Jelly 0 0
Bee Pollen 0 0
Propolis 0 0
* Total sample number = 255. Labels may declare more than one allergen
Stage 2
The percentage declarations of each individual type of allergen in ingredient lists in Stage 2,
was similar to that of Stage 1 (refer to Table 45 and 46), with gluten containing cereals (55%,
398 of 723 labels), milk (59%, 427 of 723 labels) and soybean (41%, 296 of 723 labels) again
being the most commonly declared allergens. Unlike Stage 1, one declaration of royal jelly
was made in Stage 2.
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Table 46 Types of allergens declared in the ingredient list for Stage 2
Type of Allergen Declared Number of Labels Percentage of all labels
declaring allergens in the
ingredient list*
Gluten Cereal 398 55
Crustacea 5 Less than 1
Egg 84 12
Fish 32 4
Milk 427 59
Nut 36 5
Sesame 19 3
Peanut 21 3
Soybean 296 41
Sulphite 24 3
Royal Jelly 1 Less than 1
Bee Pollen 0 0
Propolis 0 0
* Total sample number = 723. Labels may declare more than one allergen.
4.8.3 ‘May contain allergen’ statements
Stage 1
Of the 448 Stage 1 labels fully assessed, 12% (54 labels) used ‘may contain allergen’
statements. These labels were from a number of product categories (refer to Table 47), with
the highest usage levels, relative to category size, being for:
• ice creams and edible ices (29%, two of seven labels);
• confectionery (39%, seven of 18 labels);
• cereal and cereal products (47%, seven of 15 labels);
• bread and bakery products (25%, 13 of 52 labels); and
• mixed foods (21%, 17 of 80 labels) (refer to Table 47).
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Table 47 Usage of ‘may contain allergen’ statements by major food category for Stage 1
Used May Contain Allergen Statements
Yes No
Major Food Category
Total Number of
Products Assessed
Number (%) Number (%)
1. Dairy 42 1 (2) 41 (98)
2. Edible oils and oil emulsions 16 0 (0) 16 (100)
3. Ice cream and edible ices 7 2 (29) 5 (71)
4. Fruit and vegetables 65 2 (3) 63 (97)
5. Confectionery 18 7 (39) 11 (61)
6. Cereal and cereal products 15 7 (47) 8 (53)
7. Bread and bakery products 52 13 (25) 39 (75)
8. Meat and meat products 57 5 (9) 52 (91)
9. Fish and fish products 15 0 (0) 15 (100)
10. Eggs and egg products 3 0 (0) 3 (100)
11. Sugars, honey and related products 6 0 (0) 6 (100)
12. Food intended for particular dietary use 14 0 (0) 14 (100)
13. Non alcoholic beverages 58 0 (0) 58 (100)
14. Mixed foods 80 17 (21) 63 (79)
Overall Results 448 54 (12) 394 (88)
Stage 2
The percentage usage of ‘may contain allergen’ statements in Stage 2 was higher than that of
Stage 1 with 20% of labels using these statements.
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Table 48 Usage of ‘may contain allergen’ statements by major food category for Stage 2
Used May Contain Allergen Statements
Yes No
Major Food Category
Total Number of
Products Assessed
Number (%) Number (%)
1. Dairy 106 5 (5) 101 (95)
2. Edible oils and oil emulsions 29 4 (14) 25 (86)
3. Ice cream and edible ices 34 15 (44) 19 (56)
4. Fruit and vegetables 143 12 (8) 131 (92)
5. Confectionery 69 36 (52) 33 (48)
6. Cereal and cereal products 66 26 (39) 40 (61)
7. Bread and bakery products 143 65 (45) 78 (55)
8. Meat and meat products 95 9 (9) 86 (91)
9. Fish and fish products 31 0 (0) 31 (100)
10. Eggs and egg products 7 0 (0) 7 (100)
11. Sugars, honey and related products 21 1 (5) 20 (95)
12. Food intended for particular dietary use 22 0 (0) 22 (100)
13. Non alcoholic beverages 121 1 (1) 120 (99)
14. Mixed foods 266 55 (21) 211 (79)
Overall Results 1153 229 (20) 924 (80)
The use of ‘may contain allergen’ statements was more predominant when compared to other
categories in the following major food categories:
• ice cream and edible ices (44%, 15 of 34 labels);
• confectionery (52%, 36 of 69 labels);
• cereal and cereal products (39%, 26 of 66 labels);
• bread and bakery products (45%, 65 of 143 labels); and
• mixed foods (21%, 55 of 266 labels).
Comparison of ‘may contain allergen’ statement usage in Stage 1 and Stage 2
Interestingly, the categories that were more likely to use ‘may contain allergen’ statements
were the same in both Stage 1 and Stage 2, although all categories had a higher percentage
usage in Stage 2.
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4.8.3.1 ‘May contain allergen’ statement attributes
Stage 1
Those 54 labels in Stage 1 using ‘may contain allergen’ statements, placed these statements:
• near the ingredient list (45 of 54 labels);
• near the NIP (four of 54 labels); and
• between the ingredient list and NIP (four of 54 labels).
Additionally, the statement on one label was placed elsewhere (refer to Table 49).
Table 49 Attributes of ‘may contain allergen’ statements for Stage 1
Attributes Assessed Number of Labels*
Percentage of all labels
with ‘may contain
allergen’ statements*
Placement of Statement
Between ingredient list & NIP 4 7
Near Ingredient list 45 83
Near NIP 4 7
Other 1 2
* Total sample number = 54
Font Style
Normal 33 61
Bold 21 39
* Total sample number = 54
Size Compared to Ingredient List
Larger 22 41
Same 29 54
Smaller 3 6
* Total sample number = 54
Twenty-one (39%) of Stage 1 ‘may contain allergen’ statements were printed in bold
typeface for emphasis (refer to Table 49). The font size used for these statements was the
same size as the ingredient list for 29 of the labels, with a similar number of labels displaying
a larger font size (22 labels or 41%). Three labels providing this statement used a smaller
font size than the ingredient list.
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Stage 2
As with Stage 1, the majority of ‘may contain allergen’ statements were placed near the
ingredient list (204 of 229 labels) with a small proportion of labels placing ‘may contain
allergen’ statements between the ingredient list and NIP (8 of 229 labels) and near the NIP (7
of 229 labels). An additional 10 labels placed these statements in another position on the
label (refer to Table 50).
Table 50 Attributes of ‘may contain allergen’ statements for Stage 2
Attributes Assessed Number of Labels*
Percentage of all labels
with ‘may contain
allergen’ statements*
Placement of Statement
Between ingredient list & NIP 8 4
Near Ingredient list 204 89
Near NIP 7 3
Other 10 4
* Total sample number = 229
Font Style
Normal 163 71
Bold 63 28
Indeterminable 3 1
* Total sample number = 229
Size Compared to Ingredient List
Larger 37 16
Same 169 74
Smaller 23 10
* Total sample number = 229
Three labels were assessed as indeterminable for font style used in Stage 2 as these labels
contained multiple ‘may contain allergen’ statements, of which, on an individual label, one or
more of the statements was bolded and one or more was in normal font. The bolding of ‘may
contain allergen’ statements for emphasis occurred less in Stage 2 with only 28% of labels
bolding these statements. Additionally, more labels gave ‘may contain allergen’ statements
in the same size font as the ingredient list in Stage 2 (74%, 169 of 229 labels) when compared
to Stage 1.
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4.8.3.2 Allergens declared in ‘may contain allergen statements’
The allergen types mentioned in ‘may contain allergen’ statements were:
• nut (63% in Stage 1, 72% in Stage 2);
• peanut (41% in Stage 1, 46% in Stage 2);
• sesame (17% in Stage 1, 28% in Stage 2);
• milk (15% in Stage 1, 14% in Stage 2);
• gluten-containing cereals (6% in Stage 1, 10% in Stage 2);
• crustacea (4% in Stage 1, 8% in Stage 2);
• egg (6% in Stage 1, 21% in Stage 2);
• fish (7% in Stage 1, 6% in Stage 2);
• soybean (7% in Stage 1, 10% in Stage 2);
• sulphite (6% in Stage 1, 7% in Stage 2);
• bee pollen (0% in Stage 1, less than 1% in Stage 2); and
• propolis (0% in Stage 1, less than 1% in Stage 2).
Labels could declare more than one allergen.
4.8.3.3 Format of ‘may contain allergen’ statements
Stage 1
In the majority of cases, ‘may contain allergen’ statements provided took the format of ‘May
contain traces of ‘X’ (39 of 54 labels). Another ten labels used variations of this theme:
• ‘May contain X traces’ (four of 54 labels);
• ‘This product may contain traces of X’ (four of 54 labels);
• ‘Warning. This product may contain X traces’ (one of 54 labels); and
• ‘May contain X’ (one of 54 labels)
where ‘X’ is the allergen group.
Five different statements were used in some instances, as follows:
• ‘Produced in a factory handling X’ (one of 54 labels);
• ‘Manufactured on equipment that also produces products containing X’ (two of 54
labels);
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• ‘Packed on equipment that also packs products containing X’ (one of 54 labels);
• ‘X is used in the facility where this product is made’ (one of 54 labels); and
• ‘Product containing X manufactured in the factory’ (one of 54 labels)
where ‘X’ is the allergen group.
Stage 2
Similar to Stage 1, ‘may contain allergen’ statements in Stage 2 primarily took the format of
‘May contain traces of ‘X’ (125 of 229 labels). Variations of this statement type included:
• ‘May contain X traces’ (14 of 229 labels);
• ‘This product may contain traces of X’ (five of 229 labels);
• ‘This product may contain X’ (five of 229 labels);
• ‘May contain X’ (14 of 229 labels);
• ‘We take great care in the preparation of this product however due to the nature of
processing trace amounts of X may remain’ (one of 229 labels); and
• ‘Trace amounts of X may be present in some packs’ (one of 229 labels)
where ‘X’ is the allergen group.
There was a greater variation of other ‘may contain allergen’ statements used in Stage 2
when compared to Stage 1. These included variations of statements referring to the facility
or factory in which the product was manufactured and the equipment or line that the product
was manufactured on. Statements referring to the facility or factory included:
• ‘Produced in a factory handling X’ (nine of 229 labels);
• ‘Produced in a facility handling X’ (one of 229 labels);
• ‘Manufactured/made in a facility where X is also produced and therefore may contain
traces’ (five of 229);
• ‘Manufactured in a facility which also processes X’ (one of 229 labels);
• ‘This product is manufactured in a modern factory that also uses X’ (one of 229
labels);
• ‘Made in a plant that also processes products containing X’ (two of 229 labels);
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• ‘X also handled on this site’ (one of 229 labels); and
• ‘X are manufactured in the factory’ (one of 229 labels)
where ‘X’ is the allergen group.
Statements that referred to the equipment or line that the product was manufactured on were:
• ‘Manufactured/made on equipment that also processes/manufactures products
containing X’ (25 of 229 labels);
• ‘Manufactured/made on machinery that also processes/manufactures products
containing X’ (three of 229 labels);
• ‘Made on a production line that also produces products containing X’ (one of 229
labels);
• ‘Produced on a line which also uses ingredients containing X’ (one of 229 labels);
• ‘X are also processed on this equipment’ (one of 229 labels);
• ‘Made on a production line that also processes products containing X’ (seven of 229
labels);
• ‘Made on equipment that handles X and therefore may contain traces of them’ (one of
229 labels); and
• ‘Manufactured on equipment that also handles other products and may contain traces
of X’ (one of 229 labels)
where ‘X’ is the allergen group.
Three labels in Stage 2 used multiple ‘may contain allergen’ statements. These statements
included:
• ‘May contain X’ and ‘This product may contain X’;
• ‘Y may contain traces of X’ and ‘This product is manufactured on equipment that also
handles other products therefore may contain traces of X’; and
• ‘May contain traces of X’ and ‘Y may contain X to maintain natural flavour and
colour’
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where ‘X’ is the allergen group and ‘Y’ is a specific ingredient/s.
4.9 Mandatory advisory statements
Four labels required mandatory advisory statements in Stage 1, whilst seven labels required
mandatory advisory statements in Stage 2. All of these labels were consistent for legibility.
Results for the other label elements assessed are detailed below.
4.9.1 Caffeine mandatory advisory statement
For Stage 1, two kola beverages requiring the caffeine advisory statement were assessed.
Both provided a caffeine statement and the statement was of the correct intent. Therefore,
these labels were consistent for this type of advisory statement. Five kola beverage labels
were assessed during Stage 2 as requiring caffeine advisory statements. These five labels
provided a caffeine statement and the statements were deemed to be of the correct intent.
Therefore, all labels bearing caffeine advisory statements in Stage 2 were considered
consistent with the requirements in the new Code.
4.9.2 Guarana mandatory advisory statement
Only one product label in Stage 1 required this statement type. This label did not provide a
statement indicating the presence of caffeine and was consequently assessed as inconsistent.
In Stage 2, two labels were assessed as requiring a guarana mandatory advisory statement.
Both labels were consistent in providing this type of advisory statement, however one was
found not to be of the correct intent and subsequently, was inconsistent for this label element
section.
4.9.3 Phytosterol ester mandatory advisory statement
Only one product label in Stage 1 contained phytosterol esters. The label was consistent for
provision of the three required statements. However, the intent of two of the three statements
required was deemed to not fully reflect the intentions of the new Code and were assessed as
inconsistent. These statements related to the requirements for statements for those whom
products containing phytosterol esters are not recommended, unless under medical
supervision. The statements given were:
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‘Since young children, pregnant and lactating women have special dietary requirements, it
may not be suitable for this group to actively manage their cholesterol. In this instance
consult your doctor.’
‘If you are already on cholesterol lowering medication you should continue taking it as
recommended by your doctor while using ‘Product Name’.’
Therefore, overall the label was deemed to be inconsistent for these advisory statements.
There were no labels assessed as requiring phytosterol ester advisory statements in Stage 2.
4.10 Nutrition information panel
For Stage 1, 72% (320 labels) of labels required a NIP. Of the 28% of labels not required to
provide a NIP, approximately one third (39 labels) voluntarily provided a NIP. Those
voluntarily provided were predominantly on meat and meat products (28 labels), with the
remaining labels from several different major food categories. Ninety-three percent of labels
in Stage 2 required, or voluntarily provided, a NIP.
Combining the results of all three types of NIPs assessed (standard NIP, expanded NIP and
special NIP), no label providing a NIP was consistent with the labelling provisions of the new
Code in Stage 1 or Stage 2. For the purposes of assessment, it was required that the exact
format of the NIP as prescribed needed to be met, that is, all the features (case, layout,
punctuation and wording) had to be exactly the same as those given in the Code, rather than
allowing for wording changes as noted in Standard 1.1.1, Preliminary Provisions, Clause 12.
The NIP inconsistencies were also assessed as to their ‘severity’ in relation to their likely
impact on consumer understanding of the NIP information. All standard NIPs were inconsistent
(346 of 346 labels in Stage 1, 1063 of 1063 labels in Stage 2) and almost all expanded NIP
sections were inconsistent (134 of 135 labels in Stage 1, 275 of 300 labels in Stage 2). Fifteen
of the 16 special NIPs required in Stage 1 and 25 of the 26 special NIPs required in Stage 2
were assessed as inconsistent (refer to Table 51 and Table 52). As a given, labels generally had
a standard NIP and may have had an expanded NIP section or special NIP requirements so may
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have been included in two assessments. The overall NIP was assessed as inconsistent in all
cases. The reasons why these were inconsistent will be discussed under each type of NIP.
Stage 1
Table 51 NIP inconsistency by type of NIP provided for Stage 1
NIP type Number of NIPs
Assessed*
Number of NIPs
Inconsistent
Percentage of NIPs
Inconsistent
Standard NIP 346 346 100
Expanded NIP Section 135 134 99
Special NIP 16 15 94
* Total sample number = 359. Some labels gave more than one NIP.
Stage 2
Table 52 NIP inconsistency by type of NIP provided for Stage 2
NIP type Number of NIPs
Assessed*
Number of NIPs
Inconsistent
Percentage of NIPs
Inconsistent
Standard NIP 1063 1063 100
Expanded NIP Section 300 275 92
Special NIP 26 25 96
* Total sample number = 1078. Some labels gave more than one NIP.
4.10.1 Standard nutrition information panel
All standard NIPs provided in both Stage 1 and Stage 2 were inconsistent.
4.10.1.1 Severity of standard NIP inconsistencies
Table 53 and Table 54 details the reasons standard NIPs were inconsistent by the severity of
the effect on comprehension (likely impact on consumer understanding of the NIP information,
see Appendix 16). Labels could be assessed as inconsistent for more than one reason and
therefore, labels often had more than one inconsistency across one or more of the severity
categories, and in some cases all three types.
Stage 1
Virtually all of the 346 inconsistent standard NIPs (99%) in Stage 1 had inconsistencies that
were considered minor, such as incorrect case (e.g. ‘nutrition information’ not ‘NUTRITION
INFORMATION’). Forty nine percent (171 of 346 labels) had intermediate reasons for
inconsistency (e.g. serving size information given but placed in the wrong position) and 64%
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(223 labels) had major reasons (e.g. mandatory nutrient prescribed in the new Code missing
from the NIP provided on a label).
Table 53 Severity of inconsistency of standard NIP Stage 1
Severity of Inconsistency Number of Standard NIPs
Inconsistent
Percentage of Total
Number of Standard NIPs
Inconsistent*
Minor 342 99
Intermediate 171 49
Major 223 64
*Total number of inconsistent labels for standard NIPs = 346. NIPs could be inconsistent for more than one severity category (refer to
Appendix 16).
Stage 2
One hundred percent of standard NIPs in Stage 2 were inconsistent for minor reasons (1061
of 1063 labels). Intermediate reasons in Stage 2 accounted for 45% of inconsistent labels
whilst major reasons occurred in 51% of inconsistent labels (refer to Table 54).
Table 54 Severity of inconsistency of standard NIP Stage 2
Severity of Inconsistency Number of Standard NIPs
Inconsistent
Percentage of Total
Number of Standard NIPs
Inconsistent*
Minor 1061 100
Intermediate 475 45
Major 537 51
*Total number of inconsistent labels for standard NIPs = 1063. NIPs could be inconsistent for more than one severity category (refer to
Appendix 16).
The sources of inconsistencies for standard NIPs by label element section for Stage 1 and
Stage 2 are outlined in Table 55 and Table 56 and discussed in detail below.
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Table 55 Areas of standard NIP inconsistency by label element section Stage 1
Label Element Section Inconsistent Number of Labels
Inconsistent
Percentage of Total
Number of Labels
Inconsistent for Standard
NIP*
Presence 1 Less than 1
Legibility 5 1
General reasons** 142 41
Borders 319 92
Panel heading 198 57
Serving information 320 92
Columns 180 52
Nutrients 322 93
Values 57 16
Units 98 28
Other 89 26
* Total number of inconsistent labels for standard NIPs = 346. Labels may be inconsistent for more than one reason.
** General reasons includes incorrect measures e.g. averages not indicated, data presented for wrong form of food, e.g. dehydrated not made
up, total not drained weight.
Table 56 Areas of standard NIP inconsistency by label element section Stage 2
Label Element Section Inconsistent Number of Labels
Inconsistent
Percentage of Total
Number of Labels
Inconsistent for Standard
NIP*
Presence 0 0
Legibility 15 1
General reasons** 239 22
Borders 1036 97
Panel heading 613 58
Serving information 987 93
Columns 530 50
Nutrients 986 93
Values 112 11
Units 184 17
Other 129 12
* Total number of inconsistent labels for standard NIPs = 1063. Labels may be inconsistent for more than one reason.
** General reasons includes incorrect measures e.g. averages not indicated, data presented for wrong form of food, e.g. dehydrated not made
up, total not drained weight.
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Presence
Stage 1
The absence of a NIP where required was considered a major inconsistency. Only one of the
346 labels requiring a standard NIP in Stage 1 did not provide one. Although the presence of
a NIP was the basic criteria for a label being classified as new Code, this label for a
formulated caffeinated beverage was assessed as a new Code label because the compositional
information panel was provided, as required in the new Code.
Stage 2
No labels in Stage 2 were assessed as inconsistent for not providing an NIP where one was
required.
Legibility
Stage 1
In Stage 1, 99% of the 346 labels requiring a standard NIP were legible. Inconsistencies for
legibility were considered a major inconsistency and were as a result of:
• standard NIP not visible (two of five labels);
• standard NIP not indelible (one of five labels);
• standard NIP not distinct from the label decoration (one of five labels); and
• standard NIP not easy to read case (one of five labels).
Stage 2
Fifteen labels (one percent) in Stage 2 were inconsistent for standard NIP legibility. These
inconsistencies were due to the standard NIP not being:
• indelible (three of 15 labels);
• distinct from label decoration (three of 15 labels);
• distinct from label text (three of 15 labels);
• placed appropriately (two of 15 labels); and
• visible (five of 15 labels).
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Two of the labels inconsistent for legibility in Stage 2 could not be assessed further and two
could only be partially assessed. The remaining 11 labels inconsistent for legibility could be
fully assessed for the standard NIP label element section.
General reasons
Stage 1
Forty one percent of the 346 inconsistent labels in Stage 1 had inconsistencies for other,
general reasons (142 labels). The predominant reason for inconsistency for this label element
section was not to indicate that NIP values were averages (88%, 125 of 142 labels). All
reasons for inconsistency are detailed in Table 57.
Table 57 General reasons for standard NIP inconsistency (the severity of each
inconsistency as assessed in this study is given in brackets) for Stage 1
Reason Inconsistent Number of Labels
Inconsistent
Percentage of Total
Number of Labels
Inconsistent for Standard
NIP General Reasons*
No indication given that values are averages (major) 125 88
No indication given what values represent (major) 7 5
Dehydrated foods not expressed as when reconstituted# (major) 4 3
Food to be consumed with other food expressed as when made up** (major) 3 2
Optional column not used to show food values when made up (major) 0 0
Optional column for food values when made up incorrectly positioned
(major) 10 7
Food to be drained before consumption not expressed as drained (major) 1 Less than 1
Values not based on appropriate measure (e.g. volume instead of weight)
(major) 6 4
Incorrect explanation of RDI (Recommended Dietary Intake) (major) 2 1
NIP not intact (e.g. split into 2 halves) (intermediate) 7 5
* Total number of labels inconsistent for standard NIP general reasons = 142. Labels may be inconsistent for more than one general reason.
# If made up with only water
** Made up with other foods not just water
Stage 2
In Stage 2, 22% of labels were inconsistent for general reasons. As with Stage 1, the main
reason for inconsistency was labels not indicating that the values given in the standard NIP
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were averages (74%, 176 of 239 labels). All other reasons for inconsistency occurred at less
than 10% (refer to Table 58).
Table 58 General reasons for standard NIP inconsistency (the severity of each
inconsistency as assessed in this study is given in brackets) for Stage 2
Reason Inconsistent Number of Labels
Inconsistent
Percentage of Total
Number of Labels
Inconsistent for Standard
NIP General Reasons*
No indication given that values are averages (major) 176 74
No indication given what values represent (major) 7 3
Dehydrated foods not expressed as when reconstituted# (major) 5 2
Food to be consumed with other food expressed as when made up** (major) 0 0
Optional column not used to show food values when made up (major) 0 0
Optional column for food values when made up incorrectly positioned
(major) 7 3
Food to be drained before consumption not expressed as drained (major) 6 3
Values not based on appropriate measure (e.g. volume instead of weight)
(major) 19 8
Incorrect explanation of RDI (Recommended Dietary Intake) (major) 3 1
NIP not intact (e.g. split into 2 halves) (intermediate) 22 9
* Total number of labels inconsistent for standard NIP general reasons = 239. Labels may be inconsistent for more than one general reason.
# If made up with only water
** Made up with other foods not just water
Additionally, in Stage 2, three labels were assessed as indeterminable for dehydrated foods
expressed as reconstituted. This was due to the label not indicating what the standard NIP
values represented.
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Borders
Stage 1
Three hundred and nineteen labels were inconsistent in Stage 1 due to the borders label
element sub-section. These inconsistencies were considered to be minor. Borders were
inconsistent as a result of:
• external borders not present (137 of 319 labels);
• internal borders not present (80 of 319 labels);
• extra internal borders provided (219 of 319 labels); and
• other border inconsistencies (one of 319 labels).
Stage 2
Ninety-seven percent of labels (1036 of 1063 labels) in Stage 2 were inconsistent for borders.
These labels were inconsistent mainly due to extra internal borders being provided (76%, 787
of 1036 labels). The absence of external borders (44%, 459 of 1036 labels) and internal
borders (37%, 387 of 1036 labels) were also a source of inconsistency for this label element
sub section. Additionally, two labels were inconsistent for other border inconsistencies.
Borders could be inconsistent for more than one reason in both Stage 1 and 2.
Panel heading
Stage 1
Of the 198 labels inconsistent for panel heading, the main causes were alignment (119 labels)
and wording (104 labels). For the 104 labels inconsistent for heading wording, the main
inconsistency was substitution of ‘Nutritional’ for ‘Nutrition’ (81 labels) (refer to Table 59).
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Table 59 Reasons standard NIP heading inconsistent (the severity of each
inconsistency as assessed in this study is given in brackets) for Stage 1
Attributes Assessed
Reason Heading Inconsistent Number of Labels
Inconsistent
Percentage of Total
Number of Labels
Inconsistent for Standard
NIP Panel Headings*
Presence (major) 7 4
Position (major) 17 9
Alignment (minor) 119 60
Case (minor) 57 29
Wording (minor) 104 53
* Total number of labels inconsistent for standard NIP heading = 198. Labels may be inconsistent for more than one reason.
Reason Heading Wording Inconsistent Number of Labels
Inconsistent
Percentage of Total
Number of Labels
Inconsistent for Standard
NIP Panel Heading
Wording*
Nutrition 81 78
Information 12 12
Other 16 15
* Total number of labels inconsistent for heading wording = 104. Labels may have more than one wording inconsistency.
Other Wording Used In Heading Number of Labels
Percentage of Total
Number of Labels with
‘Other’ Wording in
Standard NIP Heading*
‘FACT’ instead of ‘INFORMATION’ 2 13
‘FACTS’ instead of ‘INFORMATION’ 8 50
‘ANALYSIS’ instead of ‘INFORMATION’ 1 6
Inclusion of product name in heading 3 19
Inclusion of ‘average’ in heading 2 13
* Total number of labels with other heading = 16
Stage 2
Of the 1063 labels requiring or voluntarily providing a standard NIP, 613 were inconsistent
for standard NIP heading. The results in Stage 2 for this label element sub section were very
similar to that of Stage 1, with alignment of the standard NIP heading again being the most
common inconsistency (66%, 403 of 613 labels). Inconsistent wording of the standard NIP
heading was also frequent, accounting for inconsistency in almost half of inconsistent labels
(43%, 263 of 613 labels). Details of wording inconsistencies are provided in Table 60.
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Table 60 Reasons standard NIP heading inconsistent (the severity of each
inconsistency as assessed in this study is given in brackets) for Stage 2
Attributes Assessed
Reason Heading Inconsistent Number of Labels
Inconsistent
Percentage of Total
Number of Labels
Inconsistent for Standard
NIP Panel Headings*
Presence (major) 17 3
Position (major) 57 9
Alignment (minor) 403 66
Case (minor) 146 24
Wording (minor) 263 43
* Total number of labels inconsistent for standard NIP heading = 613. Labels may be inconsistent for more than one reason.
Reason Heading Wording Inconsistent Number of Labels
Inconsistent
Percentage of Total
Number of Labels
Inconsistent for Standard
NIP Panel Heading
Wording*
Nutrition 242 92
Information 9 3
Other 21 8
* Total number of labels inconsistent for heading wording = 263. Labels may have more than one wording inconsistency.
Other Wording Used In Heading Number of Labels
Percentage of Total
Number of Labels with
‘Other’ Wording in
Standard NIP Heading*
‘TYPICAL ANALYSIS’ instead of ‘NUTRITION INFORMATION’ 1 5
‘FACTS’ instead of ‘INFORMATION’ 2 10
‘ANALYSIS’ instead of ‘INFORMATION’ 1 5
Inclusion of product name / description in heading 10 45
Inclusion of serving size information 5 24
Inclusion of ‘PER SERVING’ 1 5
Inclusion of ‘PANEL’ 2 10
Inclusion of ‘AUS’ 1 5
Inclusion of ‘FOR DRAINED CONTENTS’ 1 5
* Total number of labels with other heading = 21. Labels may have more than one ‘other’ wording inconsistency.
One label was inconsistent for standard NIP heading wording for two ‘other’ reasons. These
were for including serving size information and product name/description in the heading.
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Serving information
Stage 1
Of the 346 labels in Stage 1 inconsistent for standard NIP, 320 were inconsistent for the
serving information label element section. This was due to:
• absence of ‘servings per package’ (27 of 320 labels, major inconsistency);
• absence of ‘serving size’ (24 of 320 labels, major inconsistency);
• position of serving information (158 of 320 labels, intermediate inconsistency);
• alignment of ‘servings per package’ (58 of 320 labels, minor inconsistency);
• punctuation of ‘servings per package’ (76 of 320 labels, minor inconsistency);
• case of ‘servings per package’ (203 of 320 labels, minor inconsistency);
• wording of ‘servings per package’ (141 of 320 labels, minor inconsistency);
• alignment of ‘serving size’ (121 of 320 labels, minor inconsistency);
• punctuation of ‘serving size’ (77 of 320 labels, minor inconsistency);
• case of ‘serving size’ (228 of 320 labels, minor inconsistency); and
• wording of ‘serving size’ (27 of 320 labels, minor inconsistency).
Labels could be inconsistent for more than one reason.
Alternative statements were sometimes used to give serving information. These statements
combined the ‘servings per package’ and ‘serving size’ information. The main alternative
statements used were:
• ‘X servings of Yg/mL (per Package)’;
• ‘X x Yg/mL servings per Pack’; and
• ‘X Yg/mL servings per package’
where X = number of serves and Y = numerical serving size.
Whilst alternative combined statements provided all the required information, they were
substantially different from the prescribed format (refer to Table 61 and Table 62).
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Details of the wording inconsistencies are summarised in Table 61 for ‘servings per package’
and, Table 62 for ‘serving size’.
Table 61 Standard NIP ‘serving per package’ wording (the severity of each
inconsistency as assessed in this study is given in brackets) for Stage 1
Attributes Assessed
Word Inconsistent (minor) Number of Labels
Inconsistent
Percentage of Total
Number of Labels
Inconsistent For Standard
NIP ‘Servings Per
Package’ Wording*
Servings 10 7
Per 4 3
Package 108 77
Other 31 22
*Total number of labels inconsistent for ‘servings per package’ wording = 141. Labels could be inconsistent for more than one reason.
Other Wording Used (minor) Number of Labels
Percentage of Total
Number of Labels Using
‘Other’ Wording in
Standard NIP ‘Servings
Per Package’*
‘Serves’ only no ‘Per Package’ 1 3
Includes Slices 2 6
‘Container’ instead of ‘Package’ 6 19
‘Type of Container’ instead of package# 8 26
‘X Servings of Y g/mL Per Package’ 2 6
Inclusion of ‘For One’ 1 3
‘X Y g/mL Servings Per Package’ 2 6
‘Number of Servings’ 1 3
‘X x Y g/mL Servings Per Pack’ 2 6
Inclusion of ‘Average’ 1 3
‘Contains X Servings Per Package’ 1 3
Inclusion of ‘Approx.’ 2 6
‘Servings’ only no ‘Per Package’ 2 6
* Total number of labels using other wording = 31
# Type of container means use of word ‘can’, ‘bottle’ ‘bar’, ‘loaf’ etc.
X = number of serves
Y = numerical serving size
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Table 62 Standard NIP ‘serving size’ wording for Stage 1
Attributes Assessed
Word Inconsistent (minor) Number of Labels
Inconsistent
Percentage of Total
Number of Labels
Inconsistent For Standard
NIP ‘Serving Size’
Wording*
Servings 6 22
Size 1 4
Other 21 78
* Total number of labels inconsistent for wording = 27. Labels could be inconsistent for more than one reason.
Other Wording Used (minor) Number of Labels
Percentage of Total
Number of Labels Using
‘Other’ Wording in
Standard NIP ‘Serving
Size’*
X Servings of Y g/mL 1 5
‘Approximate Servings per Package’ 1 5
Inclusion of ‘When Cooked’ 2 9
Inclusion of ‘Approximate’ 1 5
‘X Servings of Y g/mL Per Package’ 1 5
‘Suggested Serving’ 1 5
‘X Y g/mL Servings Per Package’ 2 9
‘X x Y g/mL Servings Per Pack’ 2 9
Inclusion of ‘Average’ 9 43
‘Per Serving’ Included 1 5
* Total number of labels using alternative wording = 21
X = number of serves
Y = numerical serving size
For the 158 labels with serving information inconsistently positioned (intermediate
inconsistency), the primary reason was serving information being positioned on the same line
as the column headings (151 labels). This alternative positioning appeared to be used when
space was limited and was set out in the format and order required, but placed in the space
adjacent to the column headings. The second main reason for position inconsistencies was
‘servings per package’ and ‘serving size’ sharing the one line (98 labels). Serving
information being declared in the wrong order was found in 40 labels. Serving information
was also placed at the bottom of the NIP (two of 158 labels) and next to the ‘nutrition
information’ heading (one of 158 labels). Some labels were inconsistent for more than one
reason.
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Stage 2
Nine hundred and eighty-seven labels in Stage 2 were inconsistent for a standard NIP for
serving information. These inconsistencies were due to:
• absence of ‘servings per package’ (40 of 987 labels, major inconsistency);
• absence of ‘serving size’ (46 of 987 labels, major inconsistency);
• position of serving information (438 of 987 labels, intermediate inconsistency);
• alignment of ‘servings per package’ (162 of 987 labels, minor inconsistency);
• punctuation of ‘servings per package’ (170 of 987 labels, minor inconsistency);
• case of ‘servings per package’ (716 of 987 labels, minor inconsistency);
• wording of ‘servings per package’ (362 of 987 labels, minor inconsistency);
• alignment of ‘serving size’ (321 of 987 labels, minor inconsistency);
• punctuation of ‘serving size’ (176 of 987 labels, minor inconsistency);
• case of ‘serving size’ (752 of 987 labels, minor inconsistency); and
• wording of ‘serving size’ (42 of 987 labels, minor inconsistency) (refer to Table 63
and Table 64).
As with Stage 1, statements that combined both ‘servings per package’ and ‘serving size’
information were used in Stage 2. Details of these statements and other wording
inconsistencies are given in Table 63 for ‘servings per package’ and Table 64 for ‘serving
size’.
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Table 63 Standard NIP ‘serving per package’ wording (the severity of each
inconsistency as assessed in this study is given in brackets) for Stage 2
Attributes Assessed
Word Inconsistent (minor) Number of Labels
Inconsistent
Percentage of Total Number
of Labels Inconsistent For
Standard NIP ‘Servings Per
Package’ Wording*
Servings 44 12
Per 7 2
Package 299 83
Other 48 13
*Total number of labels inconsistent for ‘servings per package’ wording = 362. Labels could be inconsistent for more than one reason.
Other Wording Used (minor) Number of Labels
Percentage of Total Number
of Labels Using ‘Other’
Wording in Standard NIP
‘Servings Per Package’*
‘Container’ instead of ‘Package’ 3 6
‘Type of Container’ instead of package# 17 35
‘X Servings of Y g/mL Per Package’ 2 4
‘X Y g/mL Servings Per Package’ 1 2
‘Number of Servings’ per package 3 6
‘Number of Servings’ / bottle 1 2
‘Number of Servings’ 3 6
Inclusion of ‘Average’ 5 10
‘Contains X Serves’ 2 4
Inclusion of ‘Approx.’ 2 4
Inclusion of ‘Typical’ 1 2
Inclusion of ‘About’ 1 2
‘Number of Servings’ per Container’ 1 2
‘Serving Size per Package’ 1 2
‘Servings per pkg’ 1 2
‘kg’ instead of package 1 2
‘Servings per Z package’ 1 2
‘Approx servings per sachet’ 2 4
* Total number of labels using other wording = 48
# Type of container means use of word ‘can’, ‘bottle’ ‘bar’, ‘loaf’ etc.
X = number of serves
Y = numerical serving size
Z = weight of package
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Table 64 Standard NIP ‘serving size’ wording for Stage 2
Attributes Assessed
Word Inconsistent (minor) Number of Labels
Inconsistent
Percentage of Total
Number of Labels
Inconsistent For Standard
NIP ‘Serving Size’
Wording*
Serving 13 31
Size 2 5
Other 29 69
* Total number of labels inconsistent for wording = 42. Labels could be inconsistent for more than one reason.
Other Wording Used (minor) Number of Labels
Percentage of Total
Number of Labels Using
‘Other’ Wording in
Standard NIP ‘Serving
Size’*
X Servings of Y g/mL 1 3
Inclusion of ‘When Cooked’ 1 3
Inclusion of ‘Approximate’ 2 7
‘Suggested Serving’ 2 7
Inclusion of ‘Average’ 13 45
‘X Serving = Y’ 1 3
‘Quantity per serving’ 1 3
‘Per 100g Serving’ 1 3
Inclusion of ‘recommended’ 1 3
‘Y Per Serve’ 1 3
‘Approx. X per serve’ 1 3
‘Serving Size One – Y’ 1 3
‘Serving size per 150g pack’ 1 3
‘Serving / serve’ 1 3
Inclusion of ‘per’ 1 3
* Total number of labels using alternative wording = 29
X = number of serves
Y = numerical serving size
For the 438 labels with serving information inconsistently positioned, the reasons for
inconsistency were:
• ‘servings per package’ and ‘serving size’ sharing the same line (335 of 438 labels);
• ‘servings per package’ and ‘serving size’ being in the wrong order (35 of 438 labels);
and
• ‘servings per package’ and ‘serving size’ being placed in other positions (85 of 438
labels).
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Other positions in which ‘serving information’ was given included sharing the same line as
column headings (69 of 85 labels), being placed next to the nutrition information panel (five
of 85 labels), being placed below the nutrition information panel (six of 85 labels), being
placed at the top of the nutrition information panel (one of 85 labels), being placed under the
column headings (one of 85 labels), placed in different columns (one of 85 labels), and
placed elsewhere on the label (one of 85 labels).
Labels could be inconsistent for ‘serving information’ position for more than one reason.
Columns
Stage 1
The prime reason columns were inconsistent in Stage 1 for a standard NIP was the use of
inconsistent wording for column headings (162 of 180 labels, minor inconsistency).
Additional sources of inconsistency were the position of columns within the NIP (eight
labels, intermediate inconsistency) and the absence of one of the required columns (48 labels,
major inconsistency).
Inconsistency for column presence was mainly as a result of only one column being provided
where the serving size equalled 100g or 100mL (30 labels). This error may have resulted
from manufacturers not believing that they need to provide the same information twice in two
separate columns and because the old Code permitted this exception. Additionally, 11 labels
failed to provide the ‘100 g/mL’ column and for seven labels the ‘per Serving’ column was
missing.
With regards to column position, for the eight inconsistent labels, the position of the ‘per
Serving’ and ‘per 100g’ columns were reversed (intermediate inconsistency).
For the 162 labels with inconsistent column wording (minor inconsistency), the main
inconsistency was the word ‘Quantity’ not being provided (147 labels) or abbreviation of
‘Quantity’ (eight labels). This inconsistency may have arisen as the old Code permitted ‘per
serving’ and ‘per 100g’ to be used. For 12 labels, alternative column wording was used.
Details of the alternative wording used are given in Table 65.
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Some labels were inconsistent for column heading wording for more than one reason.
Table 65 Standard NIP columns wording for Stage 1
Attributes Assessed
Reason Inconsistent (minor) Number of Labels
Inconsistent
Percentage of Total
Number of Labels
Inconsistent For Column
Wording*
Quantity missing 147 91
Quantity abbreviated 8 5
Other 12 7
* Total number of labels column wording inconsistent = 162. Labels could be inconsistent for more than one reason.
Other Wording Used (minor) Number of Labels
Percentage of Total
Number of Labels
Inconsistent For Column
Wording Other*
Weight or volume included in heading or given instead of ‘serving’ 4 17
No heading provided 2 17
Alternative heading ‘Values for serving size product name’ 1 8
Alternative heading ‘Typical analysis per 100g’ 1 8
Alternative heading ‘Nutrition Levels’ 1 8
‘Serving’ substituted with ‘One Unit’ 2 17
Inclusion of word ‘Values’ 1 8
* Total labels with other column wording used = 12
Stage 2
Five hundred and thirty labels were inconsistent in Stage 2 for a standard NIP for the
columns label element sub section. Of these 530 labels, reasons for inconsistency were due
to column headings not being:
• present (81 of 530 labels);
• positioned correctly (20 of 530 labels); and
• worded correctly (472 of 530 labels).
Labels could be inconsistent for more than one reason.
Inconsistencies due to columns not being present were primarily a result of product serving
sizes being equal to 100g and therefore, labels only providing one of the two required
columns (67 of 81 labels). Five labels were inconsistent for not providing the ‘per 100g/mL’
column and 11 for not providing the ‘per serving’ column.
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The position of the ‘per 100g/mL’ column was inconsistent in 12 of the 20 labels inconsistent
for column position. In seven labels, the reason for column position inconsistency was the
positioning of the ‘prepared with other food’ column. One column also had the ‘per serving’
column inconsistently positioned.
Reason for column heading wording inconsistencies are detailed in Table 66.
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Table 66 Standard NIP columns wording for Stage 2
Attributes Assessed
Reason Inconsistent (minor) Number of Labels
Inconsistent
Percentage of Total
Number of Labels
Inconsistent For Column
Wording*
Quantity missing 261 55
Quantity abbreviated 107 23
Other 180 38
* Total number of labels column wording inconsistent = 472. Labels could be inconsistent for more than one reason.
Other Wording Used (minor) Number of Labels
Percentage of Total
Number of Labels
Inconsistent For Column
Wording Other*
Weight or volume included in heading or given instead of ‘serving’ 151 84
No heading provided 4 2
‘Slice’ instead of ‘serving’ 1 1
‘bar’ instead of ‘serving’ 1 1
‘pita’ not ‘serving’ 1 1
‘bagel’ not ‘serving’ 1 1
‘biscuit’ not ‘serving’ 1 1
‘cookie’ not ‘serving’ 1 1
‘egg’ not ‘serving’ 1 1
‘one serving contains’ 1 1
‘typical values’ not ‘quantity’ 1 1
Inclusion of word ‘serving/serve’ in 100g column 7 4
‘per 100mL’ drink 1 1
Includes ‘(1biscuit)’ 1 1
‘per’ abbreviated as ‘/’ 3 2
‘Quantities’ not ‘quantity’ 1 1
‘values’ not ‘quantity’ 1 1
‘typical content’ not ‘quantity’ 1 1
‘tablet’ instead of serving 1 1
‘results’ 1 1
Missing ‘per’ 1 1
200mL given not ‘100mL’ 1 1
* Total labels with other column wording used = 180. Labels could be inconsistent for more than one reason.
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Nutrients
Stage 1
For the 322 labels in Stage 1 where nutrients were inconsistent for a standard NIP, the main
reasons were the use of upper case (293 labels, minor inconsistency), punctuation (262 labels,
minor inconsistency) and wording (77 labels, minor inconsistency). Inconsistencies also
resulted from incorrect position or order of nutrients in the panel (38 labels, major
inconsistency) and nutrients not being provided (eight labels, major inconsistency).
For the eight labels inconsistent for nutrient presence, the main nutrient not declared was
‘sugars’ (six labels) with ‘Fat, total’ and ‘Sodium’ not declared on two labels and ‘saturated’
not declared on one label.
For the 38 labels with nutrients inconsistently positioned, 18 labels were for ‘Protein’, 23
labels for ‘Carbohydrates’, 20 labels for ‘sugars’ and 17 labels for other nutrients provided.
‘Energy’ and ‘Sodium’ were also misplaced for nine and five labels respectively.
For the 77 labels inconsistent for nutrient wording, inconsistencies were mainly for ‘Fat,
total’ (64 of 77 labels) and ‘saturated’ (49 of 77 labels). Other inconsistencies occurred with
‘Carbohydrate’ (19 of 77 labels) and ‘Energy’ (15 of 77 labels). The main cause for
inconsistency of ‘Fat, total’ wording, was omission of ‘, total’ and, for ‘saturated’, the
inclusion of the word ‘Fat’. Inconsistencies also occurred due to the inconsistent wording of
‘sugars’ (nine of 77 labels) and other nutrients provided (two of 77 labels).
Seventy-five labels provided additional nutrients in the standard NIP. The most frequently
provided additional nutrient was calcium (52 labels), with a number of labels also claiming
for iron (20 labels) and vitamin C (19 labels). Details of the other nutrients which were
included in the NIP, can be found in Table 67.
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Table 67 Details of other nutrients provided in standard NIP for Stage 1
Nutrient provided in Standard NIP Number of Labels Percentage of Total
Number of Labels with
Other Nutrients
Provided*
Iron 20 27
Magnesium 3 4
Thiamin 8 11
Vitamin A 14 19
Vitamin C 19 25
Calcium 52 69
Folate 4 5
Selenium 1 1
Riboflavin 7 9
Vitamin E 1 1
Niacin 8 11
Vitamin B6 1 1
Vitamin B12 1 1
Gluten 1 1
Phosphorus 4 5
Phytosterol Esters 3 4
* 75 labels provided additional nutrients, gluten and phytosterol esters are included in this table though not strictly nutrients. Labels could
provide more than one additional nutrient.
Stage 2
Ninety-three percent (986 of 1063 labels) of labels were inconsistent for nutrients in Stage 2
for a standard NIP. These inconsistencies were due to:
• required nutrients not being present (17 of 986 labels, major inconsistency);
• nutrients being positioned inconsistently (47 of 986 labels, major inconsistency);
• nutrients being worded inconsistently (185 of 986 labels, minor inconsistency);
• nutrients being given in the wrong case (885 of 986 labels, minor inconsistency); and
• nutrients having the wrong punctuation (666 of 986, minor inconsistency).
Nutrients not declared in standard NIPs were ‘sugars’ (12 of 17 labels), ‘Energy’ (two of 17
labels), ‘Protein’ (two of 17 labels), ‘Fat, total’ (four of 17 labels), ‘saturated’ (four of 17
labels), ‘Sodium’ (two of 17 labels) and ‘other’ nutrients where a claim was made (two of 17
labels).
In Stage 2, the most commonly inconsistently positioned nutrient was ‘other’ nutrients (23 of
47 labels). ‘Sodium’ was also inconsistently positioned (five of 47 labels), as were ‘sugars’
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(16 of 47 labels), ‘Carbohydrate’ (18 of 47 labels), ‘saturated’ (five of 47 labels), ‘Fat, total’
(five of 47 labels), ‘Protein’ (four of 47 labels) and ‘Energy’ (three of 47 labels).
‘Fat, total’ accounted for 42% (77 of 185 labels) of wording inconsistencies. Other wording
inconsistencies were for ‘Energy’ (six of 185 labels), ‘Protein’ (five of 185 labels),
‘saturated’ (70 of 185 labels), ‘Carbohydrate’ (70 of 185 labels), ‘sugars’ (37 of 185 labels),
‘Sodium’ (one of 185 labels), and ‘other’ nutrients (two of 185 labels).
Details of ‘other’ nutrients provided in Stage 2 are given in Table 68.
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Table 68 Details of other nutrients provided in standard NIP for Stage 2
Nutrient provided in Standard NIP Number of Labels Percentage of Total
Number of Labels with
Other Nutrients
Provided*
Iron 23 13
Magnesium 1 1
Thiamin 15 8
Vitamin A 9 1
Vitamin C 41 23
Calcium 99 55
Folate 16 9
Riboflavin 12 7
Vitamin E 6 3
Niacin 17 9
Vitamin B5 4 2
Vitamin B6 6 3
Vitamin B12 6 3
Vitamin D 2 1
Zinc 5 3
Gluten 8 4
Phosphorus 2 1
Lycopene 8 4
Caffeine 2 1
Phytoestrogens 2 1
Tannic acid 1 1
Flavonoids 1 1
Starch 1 1
B-Carotene 1 1
* 180 labels provided additional nutrients. Gluten, phytoestrogens, lycopene, caffeine, tannic acid, flavonoids, starch and b-carotene are
included in this table though not strictly nutrients. Labels could provide more than one additional nutrient.
Values
Stage 1
Of the 57 labels inconsistent for values for a standard NIP, 43 labels used symbols instead of
words (major inconsistency), to describe mathematical terms (e.g. ‘<’ rather than ‘less than’).
This appeared to be used to reduce the space required. The term ‘Nil’ or ‘0’ was also used to
express zero values in a number of instances (20 labels, intermediate inconsistency), rather
than ‘0 g’ or ‘Nil g’.
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Stage 2
One hundred and twelve labels were inconsistent for values in Stage 2 for a Standard NIP.
Values inconsistencies were due to mathematical terms not being described in words but
given as symbols (e.g. ‘<’ rather than ‘less than’) (89 of 112 labels) and ‘0 g’ or ‘Nil g’ being
given as ‘0’ or ‘Nil’ (29 of 112 labels).
Units
Stage 1
Ninety-eight labels were inconsistent for units in Stage 1 (major inconsistency). These
inconsistencies were for case of units (46 of 98 labels), position of units (42 of 98 labels) and
units used (34 of 98 labels). Thirty-three of the 34 labels inconsistent for units used were
inconsistent for ‘Energy’. For these 33 labels, the use of ‘kCal’ instead of ‘Cal’ (19 labels)
accounted for approximately half of these inconsistencies. A further 14 labels were
inconsistent because energy was declared only in calories, not kilojoules. Incorrect case was
used only in ‘Energy’ declarations. Commonly, kilojoule units were declared as ‘Kj’ or ‘KJ’
rather than ‘kJ’.
Stage 2
One hundred and eighty-four labels in Stage 2 were inconsistent for the units label element
sub-section. Inconsistencies for this label element sub-section were due to:
• units being inconsistently positioned (58 of 184 labels);
• inconsistent units beings used (61 of 184 labels); and
• units being given in inconsistent case (111 of 184 labels).
Of the 61 labels with inconsistent units used, 51 were due to ‘Energy’ being given as a
calorific value rather than kilojoules. Inconsistent units were also used for all other nutrients
although to a much lesser extent. Commonly, units were given as percentages rather than ‘g’
or ‘mg’ and in some cases no units were given at all.
All 111 labels inconsistent for unit case were due to ‘Energy’. This was a result of:
• ‘kJ’ being given as ‘kj’ or ‘Kj’; and
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• calorie units where provided being given as ‘cal’ or ‘CAL’ instead of ‘Cal’.
There was one instance of inconsistent units being used for each of the other nutrients. This
was due to units being given in upper case rather than lower case.
Other Inconsistencies
Other inconsistencies included those inconsistencies not covered by any of the assessments
made under the other label element sections and, that were not in line with the exact format
of the NIP as prescribed in the new Code. These inconsistencies were not assessed by
severity.
Stage 1
Of the 89 Stage 1 labels with other inconsistencies for a Standard NIP, the most common
inconsistency was not providing brackets around the Calorie values (40 labels), and ‘Average
Quantity’ being grouped across the two column headings above the ‘per Serving’ and ‘per
100g/mL’ columns (15 labels). The nutrient words, and the ‘per Serving’ column values not
being two distinct columns (12 labels), also accounted for a number of other inconsistencies.
Details of these inconsistencies and others present at lower levels (two - three labels only) are
provided in Table 69.
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Table 69 Other standard NIP inconsistencies for Stage 1
Other Reason Inconsistent Number of Labels
Inconsistent
Percentage of Total
Number of Labels With
Other Inconsistencies*
No brackets around calorie values 40 45
Serving information outside of external table border 1 1
Average quantity grouped across two columns 15 17
Addition of ‘Nutrient’ as a heading above Nutrients (e.g. Energy etc) 3 3
Addition of ‘Average Quantity’ as a heading above Nutrients (e.g. Energy) 2 2
Different type of panel provided (e.g. Typical Composition Table or American Calorie
Tables) 3
3
‘Nutrition Information’ heading outside of External Border 1 1
Values grouped across the two columns where they are the same 2 2
Moisture included in NIP 1 1
Extra column present for % Fat 1 1
Energy given as Cal only 1 1
Inclusion of No Preservatives in NIP 1 1
Use of comma instead of full stop to represent a decimal point 1 1
Addition of ‘Typical Analysis’ as a heading above Nutrients (e.g. Energy) 1 1
Addition of ‘Breakdown’ as a heading above Nutrients (e.g. Energy etc) 1 1
Column headings over the top of the Nutrients not the values 1 1
Use of the term ‘trace’ for values 1 1
Nutrients and the Per Serving Column run together 12 14
Breakdown of fatty acids given as percentage 1 1
Heading given for additional nutrients declared (e.g. Vitamins) 1 1
Inclusion of Heading ‘Australia Only’ 1 1
* Total number of labels inconsistent for other reasons = 89. Labels may be inconsistent for more than one reason.
Stage 2
One hundred and twenty-nine labels were inconsistent for other reasons for a standard NIP.
As with Stage 1, the majority of these inconsistencies were a result of calorie information not
being provided in brackets (78 of 129 labels). The addition of extra headings above the
nutrients column was also a common inconsistency in Stage 2. Details of these headings and
other inconsistencies are detailed in Table 70.
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Table 70 Other standard NIP inconsistencies for Stage 2
Other Reason Inconsistent Number of Labels
Inconsistent
Percentage of Total
Number of Labels With
Other Inconsistencies*
No brackets around calorie values 78 60
Serving information outside of external table border 1 1
Addition of ‘Nutrient’ as a heading above Nutrients (e.g. Energy etc) 6 5
Values grouped across the two columns where they are the same 3 2
Some nutrients bolded 3 2
Addition of ‘Typical Analysis’ as a heading above Nutrients (e.g. Energy) 2 2
Addition of ‘per Serving’ as a heading above nutrients 1 1
Addition of ‘total’ as a heading above Nutrients 1 1
Addition of ‘content’ as a heading above nutrients 2 2
Addition of ‘when prepared’ as a heading above nutrients 1 1
‘G’ instead of ‘g’ for unit in ‘per 100g’ column 4 3
‘G’ instead of ‘g’ for unit in serving information 1 1
‘kJ’ and/or ‘Cal’ given in nutrients column and values column 3 2
Product description included in NIP 1 1
Serving size given as ‘g’ in serving information and ‘Ml’ in column headings 1 1
Full stops given after units 1 1
Comma not fullstop used for decimal placing 2 2
Values for ‘other’ nutrients not given for ‘per serving’ 1 1
‘When made up’ information given in panel heading 1 1
Use of ‘gm’ instead of ‘g’ 4 3
Use of ‘Cals’ instead of ‘Cal’ 2 2
Units in brackets where not required 2 2
No value given for ‘servings per package’ 1 1
Package weight included in NIP 3 2
% RDI column in wrong position 1 1
Nutrients column given twice 1 1
Sodium given as ‘mmol’ and ‘mg’ 1 1
Serving size given in a column 1 1
Additional information provided at bottom of NIP for calories and fat per unit 1 1
Contact details in NIP 1 1
Units given in a separate column 1 1
Value missing for a nutrient 1 1
* Total number of labels inconsistent for other reasons = 129. Labels may be inconsistent for more than one reason.
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4.10.2 Expanded nutrition information panel section
Stage 1
Of the 359 labels providing a NIP in Stage 1, 38% (135 labels) provided an expanded NIP
section (refer to Table 71).
Table 71 Provision of expanded NIP section by major food category for Stage 1
Provision of Expanded NIP section
Provided Not Provided
Major Food Category
Total Number of
Labels Required to
Provide / Voluntarily
Providing a NIP
Number (%) Number (%)
1. Dairy 41 8 (20) 33 (80)
2. Edible oils and oil emulsions 16 14 (88) 2 (12)
3. Ice cream and edible ices 7 0 (0) 7 (100)
4. Fruit and vegetables 35 17 (49) 18 (51)
5. Confectionery 18 3 (17) 15 (83)
6. Cereal and cereal products 15 12 (80) 3 (19)
7. Bread and bakery products 52 24 (46) 28 (54)
8. Meat and meat products 38 4 (11) 34 (89)
9. Fish and fish products 13 9 (69) 4 (31)
10. Eggs and egg products 3 1 (33) 2 (67)
11. Sugars, honey and related products 6 2 (33) 4 (67)
12. Food intended for particular dietary use 14 9 (64) 5 (36)
13. Non alcoholic beverages 23 6 (26) 17 (74)
14. Mixed foods 78 26 (33) 52 (67)
Overall Results 359 135 (38) 224 (62)
Of the 135 labels providing expanded NIP sections, 48% included an expanded fat type, 65%
an expanded carbohydrate type and 46% an expanded salt type. Many labels provided more
than one type of expanded NIP section.
Stage 2
A lower proportion of labels provided expanded NIPs in Stage 2 (28%, 300 of 1078 labels)
(refer to Table 72).
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Table 72 Provision of expanded NIP section by major food category for Stage 2
Provision of Expanded NIP section
Provided Not Provided
Major Food Category
Total Number of
Labels Required to
Provide / Voluntarily
Providing a NIP
Number (%) Number (%)
1. Dairy 106 10 (9) 96 (91)
2. Edible oils and oil emulsions 29 22 (76) 7 (24)
3. Ice cream and edible ices 34 4 (12) 30 (88)
4. Fruit and vegetables 124 47 (38) 77 (62)
5. Confectionery 68 4 (6) 64 (94)
6. Cereal and cereal products 66 37 (56) 29 (44)
7. Bread and bakery products 143 51 (36) 92 (64)
8. Meat and meat products 79 7 (9) 72 (91)
9. Fish and fish products 31 14 (45) 17 (55)
10. Eggs and egg products 7 1 (14) 6 (86)
11. Sugars, honey and related products 18 0 (0) 18 (100)
12. Food intended for particular dietary use 22 16 (73) 6 (27)
13. Non alcoholic beverages 88 27 (31) 61 (69)
14. Mixed foods 263 60 (23) 203 (77)
Overall Results 1078 300 (28) 778 (72)
Of the 300 labels providing expanded NIPs, 26% provided expanded fat type NIPs, 66%
provided expanded carbohydrate type NIPs, and 41% provided expanded salt type NIPs.
Labels could provide more than one expanded NIP type.
4.10.2.1 Severity of expanded NIP section inconsistencies
Stage 1
As previously discussed, only one of the 135 labels providing expanded NIP sections in
Stage 1 was consistent with all NIP requirements. Table 73 details the reasons expanded NIP
sections were inconsistent by the severity of inconsistency. Ninety six percent of NIP
sections were inconsistent for minor reasons, 77% for major reasons and 10% for
intermediate reasons. It should be noted that in a number of instances, expanded NIP
sections were inconsistent for more than one reason, and in some cases these inconsistencies
occurred in all three levels of severity.
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Table 73 Severity of inconsistency of expanded NIP sections for Stage 1
Severity of Inconsistency Number of Labels
Inconsistent
Percentage of Labels
Inconsistent*
Minor 129 96
Intermediate 13 10
Major 104 77
* Total number labels inconsistent for expanded NIP section= 134. Labels may be inconsistent for more than one reason.
The label element sections that were inconsistent for expanded NIP sections were:
• values (28 of 134 labels);
• units (19 of 134 labels); and
• nutrients (132 of 134 labels).
There were no other types of errors for the label element sub-sections reported for expanded
NIPs.
When comparing inconsistency between types of expanded NIP sections, the rate of
inconsistency for carbohydrate expanded NIPs was the highest (100%, 89 labels), with fat
and salt type expanded NIPs accounting for 88% (56 labels) and 82% (51 labels) respectively
(refer to Table 74).
Table 74 Reason expanded NIP section inconsistent by type for Stage 1
Type of Expanded NIP Number of Labels
Providing Expanded
NIP section type
Number of Labels
Inconsistent by
Expanded NIP
section type
Percentage of Total
Number of Labels
Inconsistent by
Expanded NIP
section type
Fat 64 56 88
Carbohydrate 89 89 100
Salt 62 51 82
Stage 2
Twenty five labels were assessed as consistent with all expanded NIP requirements of the
new Code in Stage 2. Of the 275 labels inconsistent for expanded NIPs, 96% were for minor
reasons, 79% for major reasons, and seven percent for intermediate inconsistencies. These
figures were very similar to those in Stage 1 (refer to Table 75).
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As with Stage 1, labels could be inconsistent for more than one level of severity.
Table 75 Severity of inconsistency of expanded NIP sections for Stage 2
Severity of Inconsistency Number of Labels
Inconsistent
Percentage of Labels
Inconsistent*
Minor 264 96
Intermediate 20 7
Major 216 79
* Total number labels inconsistent for expanded NIP section= 275. Labels may be inconsistent for more than one reason.
The label element sections that were inconsistent for expanded NIP sections in Stage 2 were:
• values (27 of 275 labels);
• units (31 of 275 labels); and
• nutrients (272 of 275 labels).
No labels in Stage 2 were inconsistent for other label inconsistencies.
Similar to Stage 1, expanded carbohydrate type NIPs showed the highest inconsistency level
with 99% of labels assessed for this label element section inconsistent. Eighty five percent of
labels with expanded fat type NIPs and 78% with expanded salt type NIPs were inconsistent
(refer to Table 76).
Table 76 Reason expanded NIP section inconsistent by type for Stage 2
Type of Expanded NIP Number of Labels
Providing Expanded
NIP section type
Number of Labels
Inconsistent by
Expanded NIP
section type
Percentage of Total
Number of Labels
Inconsistent by
Expanded NIP
section type
Fat 78 66 85
Carbohydrate 201 198 99
Salt 124 97 78
4.10.2.2 Expanded fat nutrition information panel sections
Twelve percent of expanded fat NIP sections were consistent with the labelling provisions for
this type of expanded NIP in Stage 1. Comparatively, 15% of expanded fat NIP sections in
Stage 2 were consistent with the requirements of the new Code (12 of 78 labels).
Stage 1
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The reasons fat expanded NIP sections were inconsistent were:
• nutrients (46 of 56 labels);
• values (21 of 56 labels); and
• units (11 of 56 labels).
Some labels were inconsistent for more than one reason.
There were no other types of errors with this type of expanded NIP section.
Nutrients
For the 46 labels inconsistent for nutrients in Stage 1, the reasons were;
• case (40 of 46 labels, minor inconsistency);
• presence (16 of 46 labels, major inconsistency);
• position (18 of 46 labels, major inconsistency);
• wording (11 of 46 labels, minor inconsistency); and
• punctuation (17 of 46 labels, minor inconsistency).
For all 16 labels inconsistent for nutrient presence, the nutrient not provided was trans fatty
acids. Other nutrients were also not provided, but this was only for one to two labels each.
The main nutrient inconsistently positioned was cholesterol (12 labels), with polyunsaturated
and monounsaturated fatty acids also being inconsistently positioned in a number of
instances.
Wording inconsistencies in eight of the eleven labels inconsistent for this label element sub-
section were as a result of the wording for monunsaturates and seven inconsistencies were
due to the wording for polyunsaturates.
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Values
Twenty one labels were inconsistent for values, mainly due to the use of ‘Nil’ instead of ‘0g’
or ‘Nil g’ to express zero values (13 labels, intermediate inconsistency). Eight labels were
also inconsistent due to use of symbols (major inconsistency), rather than words, to describe
mathematical terms (eg. ‘<’ rather than ‘less than’).
Units (major inconsistency)
Of the 11 labels inconsistent for units, all were inconsistent for position and two labels were
also inconsistent for units used. Of the two labels inconsistent for units used, one label used
inconsistent units for monounsaturated fatty acids and one for polyunsaturated fatty acids.
Stage 2
The reasons fat expanded NIP sections were inconsistent were:
• nutrients (63 of 66 labels);
• values (21 of 66 labels); and
• units (16 of 66 labels).
Some labels were inconsistent for more than one reason.
Nutrients
Sixty three labels (95%) were inconsistent for the nutrient label element sub section in Stage
2. This figure in regards to percentage inconsistency was very similar to that of Stage 1
(82%).
The reasons for nutrient inconsistency in Stage 2 were:
• case (49 of 63 labels, minor inconsistency);
• presence (22 of 63 labels, major inconsistency);
• position (25 of 63 labels, major inconsistency);
• wording (11 of 63 labels, minor inconsistency); and
• punctuation (14 of 63 labels, minor inconsistency).
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The nutrient primarily responsible for nutrient provision inconsistencies was trans fatty acids
(18 of 22 labels). Other inconsistencies for this label element sub section also occurred due
to the absence of polyunsaturated fatty acids (13 of 22 labels), monounsaturated fatty acids
(13 of 22 labels), and cholesterol (6 of 22 labels) within the NIP.
Similar to Stage 1, cholesterol was the main nutrient inconsistently positioned in Stage 2 (19
of 25 labels). Inconsistencies also occurred as a result of the positioning of polyunsaturated
fatty acids (three of 25 labels), monounsaturated fatty acids (10 of 25 labels), specific
monounsaturated fatty acids (one of 25 labels) and omega 9 (one of 25 labels) in a position
other than that prescribed by the new Code.
Wording inconsistencies in Stage 2 were also primarily as a result of the wording of
monunsaturates (9 of 11 labels) and polyunsaturates (9 of 11 labels). There were however
wording inconsistencies for trans fatty acids, omega 3, specific monounsaturated fatty acids
and omega 9 also.
Values
Fewer labels in Stage 2 were inconsistent when compared to Stage 1 as a result of the values
label element sub section (32% (21 of 66 labels) compared to 38% in Stage 1). Eight of the
21 inconsistent labels were inconsistent due to the use of symbols as opposed to words to
describe mathematical terms, whilst 16 labels were inconsistent for the use of ‘Nil’ or ‘0’
instead of ‘Nil g’ or ‘0 g’.
Units (major inconsistency)
Sixteen labels were inconsistent for the units label element section in Stage 2. These labels
were inconsistent for the positioning (10 of 16 labels) and use (6 of 16 labels) of units other
than that prescribed by the new Code. The nutrients that were inconsistent for units used
were:
• trans fatty acid (two of six labels);
• polyunsaturated fatty acids (one of six labels);
• monounsaturated fatty acids (one of six labels); and
• cholesterol (four of six labels).
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4.10.2.3 Expanded carbohydrate type nutrition information panel sections
Stage 1
As discussed previously, all 89 labels carrying expanded carbohydrate NIP sections in Stage
1 were inconsistent. All 89 labels were inconsistent for nutrients, with some inconsistencies
for:
• values (11 of 89 labels); and
• units (10 of 89 labels).
Nutrients
Reasons for inconsistent nutrients were:
• presence (two of 89 labels, major inconsistency);
• position (20 of 89 labels, major inconsistency);
• wording (78 of 89 labels, major inconsistency);
• case (80 of 89 labels, minor inconsistency); and
• punctuation (79 of 89 labels, minor inconsistency).
Some labels were inconsistent for nutrients for more than one reason.
All of the wording inconsistencies were due to the word ‘, total’ not being provided in
conjunction with ‘dietary fibre’. This is a change from previous regulations, which did not
require the declaration of this word. For the two labels inconsistent for presence, ‘dietary
fibre, total’ was not provided. All inconsistencies for position were also related to ‘dietary
fibre, total’.
Values
For the 11 labels inconsistent for values (major inconsistency), the main reason was for
mathematical terms being described using symbols rather than words (e.g. ‘<’ rather than
‘less than’). Two labels were inconsistent for expressing zero values as ‘Nil’ or ‘0’ rather
than ‘0g’ or ‘Nil g’ (intermediate inconsistency).
Units (major inconsistency)
All inconsistencies for units were due to the incorrect positioning of these units within NIPs.
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Stage 2
Two hundred and one labels in Stage 2 provided expanded carbohydrate NIPs. Of these 201
labels, 99% were inconsistent (198 of 200 labels). Inconsistencies in Stage 2 were a result of:
• nutrients (198 of 198 labels);
• values (four of 198 labels); and
• units (15 of 198 labels).
Nutrients
Reasons for inconsistent nutrients in Stage 2 were:
• presence (three of 198 labels, major inconsistency);
• position (21 of 198 labels, major inconsistency);
• wording (175 of 198 labels, major inconsistency);
• case (182 of 198 labels, minor inconsistency); and
• punctuation (149 of 198 labels, minor inconsistency).
Some labels were inconsistent for nutrients for more than one reason.
Values
Only two percent of labels (four of 198 labels) were inconsistent for the values label element
sub section in Stage 2 compared to 12% (11 of 89 labels) in Stage 1. Reasons for
inconsistent values in Stage 2 were mathematical terms being described with symbols rather
than words (e.g. ‘<’ rather than ‘less than’) (three of four labels) and expressing zero values
as ‘Nil’ or ‘0’ rather than ‘0g’ or ‘Nil g’ (intermediate inconsistency) (one of four labels).
Units
Fourteen of the 15 labels inconsistent for units, were for the positioning of units within the
NIP in a position other than that prescribed by the new Code. Additionally, one label was
inconsistent for the case used for the unit.
4.10.2.4 Expanded salt type nutrition information panel sections
Stage 1
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Of the 62 labels including expanded salt type NIP sections in Stage 1, 82% (51 labels) were
inconsistent with the labelling provisions for this type of expanded NIP section. The prime
reason for inconsistency were:
• nutrients (44 of 51 labels);
• values (three of 51 labels); and
• units (seven of 51 labels).
Nutrients
For the 44 labels inconsistent for nutrients, the majority (43 labels) were inconsistent for case
(minor inconsistency). Other nutrient errors were related to potassium, with one instance
each of non provision (major), inconsistent positioning (major) and punctuation
inconsistency (minor).
Values
Values were only inconsistent for three labels for similar reasons to other NIP types
(intermediate or major inconsistency).
Units (major inconsistency)
For the seven labels inconsistent for units, this was mainly due to position (six labels). The
other instance of inconsistent units was due to units used (grams were used instead of
milligrams).
Stage 2
One hundred and twenty four labels provided salt expanded NIPs in Stage 2, of which 22%
were consistent (27 of 124 labels). Thus, consistency in Stage 2, was higher than Stage 1
(18%). Inconsistencies resulted from:
• nutrients (93 of 97 labels);
• values (two of 97 labels); and
• units (14 of 97 labels).
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Nutrients
In Stage 2, the majority of nutrient inconsistencies were a result of nutrients being given in
the wrong case (84 of 93 labels). Though like Stage 1, case was the most common
inconsistency for the nutrient label element sub section, this inconsistency occurred less
frequently in terms of percentage occurrence in Stage 2 when compared to Stage 1 (98% in
Stage 1 and 90% in Stage 2).
Other nutrient inconsistencies arose in Stage 2 due to potassium not being:
• present (two of 93 labels);
• positioned correctly (17 of 93 labels); and
• worded correctly (one of 93 labels).
One label was also inconsistent for punctuation.
Values
Two labels were inconsistent in Stage 2 for not expressing zero values as ‘Nil g’ or ‘0g’ but
as ‘Nil’ or ‘0’.
Units
Inconsistencies for the units label element sub section were as a result of units being:
• positioned incorrectly (12 of 14 labels);
• incorrect (one of 14 labels); and
• in the incorrect case (one of 14 labels).
4.10.3 Special nutrition information panels
Sixteen labels provided a special NIP in Stage 1, as discussed at the beginning of Section
4.10, only one label was consistent with the labelling provisions for their respective types of
product. As with Stage 1, only one of the 26 labels providing a special NIP in Stage 2 was
consistent with the requirements of the new Code for that special NIP.
4.10.3.1 Severity of special NIP inconsistencies
Table 77 and Table 78 outline the reason special NIPs were inconsistent by the severity of the
inconsistency for Stage 1 and 2 respectively. Of the 15 inconsistent labels in Stage 1, 14
labels were inconsistent for minor reasons, 11 for major reasons and seven labels for
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intermediate reasons. In Stage 2, there was a lower proportion of minor and intermediate
inconsistencies compared to Stage 1 (refer to Table 77 and Table 78). There was however,
an increase in major inconsistencies from 73% in Stage 1 to 88% in Stage 2.
It should be noted that most NIPs were inconsistent for more than one reason.
Table 77 Severity of inconsistency of special NIP for Stage 1
Severity of Inconsistency Number of Labels
Inconsistent
Percentage of Total
Number of Labels
Inconsistent For Special
NIP*
Minor 14 93
Intermediate 7 47
Major 11 73
* Total number labels inconsistent for special NIP = 15. Labels could be inconsistent for more than one severity category.
Table 78 Severity of inconsistency of special NIP for Stage 2
Severity of Inconsistency Number of Labels
Inconsistent
Percentage of Total
Number of Labels
Inconsistent For Special
NIP*
Minor 19 76
Intermediate 6 24
Major 22 88
* Total number labels inconsistent for special NIP = 25. Labels could be inconsistent for more than one severity category.
For the 15 inconsistent special NIPs in Stage 1, the main reasons for inconsistency were the
nutrients (13 labels, 87%), other inconsistencies (12 labels, 80%) and borders (12 labels,
80%) label element sub-sections. Inconsistencies also resulted from the panel heading,
serving information, column and units (refer to Table 79). This was the same in Stage 2 with
nutrients (24 labels, 96%), borders (15 labels, 60%) and other (8 labels, 32%) inconsistencies
again being the main reasons for inconsistency (refer to Table 80).
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Table 79 Reason special NIP inconsistent by label element section for Stage 1
Label Element Section Inconsistent Number of Labels Special
NIPs Inconsistent
Percentage of Total
Number of Labels
Inconsistent For Special
NIP*
Presence 1 7
Legibility 0 0
General reasons 3 20
Borders 12 80
Panel heading 6 40
Serving information 8 53
Columns 8 53
Nutrients 13 87
Values 1 7
Units 5 33
Other 12 80
* Total number labels inconsistent for special NIP = 15. Labels may be inconsistent for more than one reason.
Table 80 Reason special NIP inconsistent by label element section for Stage 2
Label Element Section Inconsistent Number of Labels Special
NIPs Inconsistent
Percentage of Total
Number of Labels
Inconsistent For Special
NIP*
Presence 0 0
Legibility 0 0
General reasons 2 8
Borders 15 60
Panel heading 7 28
Serving information 8 32
Columns 5 20
Nutrients 24 96
Values 1 4
Units 6 24
Other 8 32
* Total number labels inconsistent for special NIP = 25. Labels may be inconsistent for more than one reason.
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4.10.3.2 Formulated caffeinated beverages
Stage 1
Of the four formulated caffeinated beverage products studied in Stage 1, only two were new
Code labels and hence fully assessed. Both these labels were inconsistent, as one only
provided the standard NIP and the other only a composition information panel (both labels
are required to provide both NIP types). Only the sample with the composition information
panel provided will be discussed here as the standard NIP has been covered under that NIP
type section (4.10.1).
The composition information panel was inconsistent with the labelling requirements due to
the panel heading, nutrients and other inconsistencies label element sub sections.
Panel heading
The panel heading was inconsistent due to alignment, case and wording of the heading.
Inconsistencies with wording were owing to the use of ‘Compositional’ instead of
‘Composition’.
Nutrients
Nutrient inconsistencies were as a consequence of not all nutrients being provided and the
positioning of these nutrients in the special NIP. The nutrients not provided were thiamin,
riboflavin, pantothenic acid and inositol. The nutrients inconsistently positioned were taurine
and glucoronolactone.
Stage 2
Three labels in Stage 2 for formulated caffeinated beverage products were assessed as being
produced to the requirements of the new Code. These three labels were assessed as
inconsistent for this label element section due to the borders, panel heading, and nutrients
label element sub sections.
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Borders
All three of the labels assessed for providing a formulated caffeinated beverage special NIP,
were inconsistent for the borders labels element sub section. The reasons for borders
inconsistency were:
• the absence of external special NIP borders (two of three labels); and
• the absence of internal special NIP borders (two of three labels).
Labels could be inconsistent for more than one reason.
Panel heading
Inconsistencies as a result of the compositional information panel heading occurred in 100%
(three of three labels) of labels assessed for this label element. These inconsistencies were
due to the:
• compositional information panel heading missing (two of three labels); and
• incorrect alignment of the compositional information panel heading (one of three
labels).
Nutrients
Of the three labels assessed for the formulated caffeinated beverage label element section, all
were inconsistent for not providing required nutrients, two were inconsistent for providing
nutrients in the wrong position, two for incorrect wording of nutrients, and two for nutrients
being given in the wrong case.
Nutrients not provided were thiamin (three of three labels), riboflavin (two of three labels),
and glucuronolactone (one of three labels). The nutrients incorrectly positioned were
pantothenic acid (two of three labels), taurine (two of three labels), glucuronolactone (one of
three labels) and inositol (two of three labels). Riboflavin and niacin were incorrectly
worded in one and two cases respectively.
4.10.3.3 Formulated meal replacements
Stage 1
Only one of the four formulated meal replacements in Stage 1 was a new Code label, and
subsequently fully assessed. This label was assessed as inconsistent due to:
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• nutrients inconsistent with labelling provisions for position, wording and case.;
• thiamin and riboflavin were worded as their vitamin B numbers (i.e. vitamin B1 and
B2); and
• some values were either missing in each column or placed outside the NIP.
Stage 2
Three of the four formulated meal replacements sampled in Stage 2 were assessed as being
produced to the requirements of the new Code. These three labels were assessed as
inconsistent due to the nutrients, units and other label element sub sections.
Nutrients
All three labels assessed as a formulated meal replacement were inconsistent due to the
nutrients label element sub section. These inconsistencies arose as a result of nutrients not
being provided when required (two of three labels), nutrients not being worded correctly (one
of three labels), and nutrients being given in the wrong case (one of three labels).
Nutrients that were not provided when required included:
• vitamin D (one of two labels);
• vitamin E (one of two labels);
• iodine (one of two labels);
• iron (one of two labels);
• magnesium (one of two labels);
• zinc (one of two labels);
• inorganic chromium (one of two labels);
• organic chromium (one of two labels);
• inorganic copper (one of two labels); and
• organic copper (one of two labels).
Vitamin D was incorrectly worded in one instance.
Units
One label was inconsistent for units due to positioning units next to the actual nutrient name
not the nutrient value.
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Other inconsistencies
Inconsistencies as a result of other special NIP components occurred in two labels due to:
• information being provided for manganese, molybdenum and selenium, however not
being broken down into organic and inorganic; and
• an extra ‘Vitamins and Minerals’ heading being provided within the NIP.
4.10.3.4 Electrolyte drinks
Stage 1
Of the seven electrolyte drinks and drink bases sampled, none were new Code labels and
hence were not included in the assessment.
Stage 2
Five electrolyte drinks and drink bases were assessed as being produced to the new Code in
Stage 2. One of the five labels assessed was consistent with the requirements of the new
Code for this label element section. Inconsistencies in the four inconsistent labels were due
to nutrients required to be provided in the special NIP not being given (four of four labels),
nutrients being in the wrong case (two of four labels), and nutrients having the wrong
punctuation (one of four labels).
The nutrients that were required to be provided in the four electrolyte drinks and electrolyte
bases that were not provided were:
• sucrose (one of four labels);
• potassium phosphate (two of four labels);
• potassium citrate (three of four labels);
• sodium chloride (three of four labels); and
• calcium (one of four labels).
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4.10.3.5 Formulated supplementary foods
Stage 1
Of the eight products studied for formulated supplementary foods and formulated
supplementary foods for young children, only one was a new Code label and therefore fully
assessed. That sample was consistent with the appropriate special NIP labelling
requirements.
Stage 2
All three of the labels assessed as being produced to the new Code in Stage 2 were
inconsistent in meeting the requirements of this Code. Inconsistencies were due to the
nutrients, units and other label element sub sections.
Nutrients
Inconsistencies as a result of the nutrients label element sub section occurred in 100% of
labels (three of three labels) assessed for this label element section. These labels were
inconsistent due to nutrients not being:
• provided in the NIP when added to the product (two of three labels);
• in the correct position (one of three labels);
• worded correctly (three of three labels); and
• in the correct case (one of three labels).
All labels with nutrients worded incorrectly were due to the nutrients thiamin and riboflavin
being given as their B group numbers (e.g. vitamin B1 and vitamin B2).
Units
One label was inconsistent for the units label element sub section due to units being provided
next to the nutrient name not the nutrient values.
Other inconsistencies
One label had another label inconsistency due to the presence of additional ‘Vitamins’ and
‘Minerals’ headings in the NIP.
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4.10.3.6 Infant formula
Stage 1
For infant formula products, two forms of NIPs were permitted in July 2002. Given this, all
four products sampled were fully assessed.
All of these NIPs were found to be inconsistent, for the reasons detailed in Table 81.
Table 81 Reason infant formula special NIP inconsistent by label element section for
Stage 1
Label Element Section Inconsistent Number of Labels
Inconsistent
Percentage of Total
Number of Labels
Inconsistent For Infant
Formula Special NIP*
Presence 0 0
Legibility 0 0
General reasons 2 50
Borders 4 100
Panel heading 1 25
Serving information 0 0
Columns 3 75
Nutrients 3 75
Values 0 0
Units 3 75
Other 3 75
* Total number labels inconsistent for infant formula special NIP = 4
General reasons
The two inconsistencies for the general reasons label element section were due to NIPs being
split in half and the two parts being placed side by side.
Borders
For the four labels inconsistent for borders, this was due to either all the required internal
borders not being provided (two labels) or extra internal borders (two labels) being provided.
Panel heading
The panel heading was inconsistent on one label due to inconsistent wording relating to both
‘Nutrition’ and ‘Information’.
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Columns
The three labels inconsistent for columns were all inconsistent for wording. Additionally, the
columns were inconsistently positioned for one label, as the ‘100g powder’ and ‘made up
formula’ columns were reversed. Column wording was inconsistent because the word
‘average’ was abbreviated and the word ‘amount’ was missing.
Nutrients
For the three labels inconsistent for nutrients, this was because of case, position and wording
for all three labels. Nutrient presence and punctuation was also inconsistent for two and one
labels, respectively. The required nutrients not provided were vitamin C, niacin, pantothenic
acid, selenium, chloride, potassium and sodium. For the three inconsistent NIPs, the order in
which nutrients were provided varied from the prescribed format. Vitamins D and K were
the principal causes of wording inconsistencies as numbers were provided with these.
Vitamin B6 and pantothenic acid were also inconsistently worded.
Units
Three labels were inconsistent for units due to the units used and their position. Incorrect
units were used for:
• energy (kCal instead of Cal);
• vitamin E (milligrams instead of micrograms); and
• vitamin K (milligrams instead of micrograms).
Other Inconsistencies
The three labels with other inconsistencies were inconsistent due to a ‘Major Nutrient’
heading provided above the nutrient column, the inclusion of extra nutrients (old Code format
NIP), the position of column headings and the calorie values not being declared in brackets.
Table 82 details other nutrients provided for these types of NIPs.
Labels could be inconsistent for more than one reason.
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Table 82 Other nutrients provided in infant formula NIP for Stage 1
Other Nutrient Provided Number of Labels Percentage of Labels*
Chlorine# 2 50
Carnitine 1 25
Taurine 3 75
Whey / Casein Ratio 2 50
Beta Carotene 1 25
* Total of infant formula special NIPs assessed = 4
# Chloride is included in the prescribed NIP but not Chlorine
Stage 2
All four infant formula labels sampled in Stage 2 were also assessed and were inconsistent
for reasons detailed below (refer to Table 83).
Table 83 Reason infant formula special NIP inconsistent by label element section for
Stage 2
Label Element Section Inconsistent Number of Labels
Inconsistent
Percentage of Total
Number of Labels
Inconsistent For Infant
Formula Special NIP*
Presence 0 0
Legibility 0 0
General reasons 0 0
Borders 4 100
Panel heading 1 25
Serving information 0 0
Columns 2 50
Nutrients 3 75
Values 0 0
Units 3 75
Other 1 25
* Total number labels inconsistent for infant formula special NIP = 4
Borders
As with Stage 1, the borders label element sub section accounted for the highest proportion of
infant formula special NIP inconsistencies in Stage 2 (four of four labels). These
inconsistencies were due to:
• the absence of external borders (two of four labels);
• the absence of internal borders (two of four labels); and
• the presence of extra internal borders (two of four labels).
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Labels could be inconsistent for more than one reason.
Panel Heading
One label was inconsistent for the panel heading label element sub section as a result of the
incorrect alignment of the heading.
Columns
Two of the four labels assessed for infant formula special NIPs were inconsistent for the
columns label element sub section. This was due to the absence of the ‘100g powder’
column (two of two labels), and the use of the words ‘prepared feed’ in the column headings
instead of the words ‘made up formula’ (two of two labels).
Nutrients
Three labels were inconsistent for nutrients for the infant formula label element section as a
result of nutrients not being provided (two of three labels), nutrients being incorrectly
positioned (two of three labels), nutrients being incorrectly worded (one of three labels), and
nutrients being given in the wrong case (one of three labels).
In comparison with Stage 1, the nutrients not provided for the two labels inconsistent for
nutrient provision were more numerous and included vitamin B6, vitamin B12, vitamin D,
vitamin E, vitamin K, biotin, niacin, folate, pantothenic acid, copper, iodine, magnesium,
manganese, selenium, zinc and chloride.
Units
Two of the three labels inconsistent for units were for the positioning of units in a location
that differed from the prescribed format. Furthermore, two labels were assessed as
inconsistent for providing incorrect units.
It should be noted that labels could be inconsistent for more than one reason.
Other inconsistencies
One of the four labels assessed for infant formula special NIP was inconsistent for other
inconsistencies as an additional ‘Vitamins and Minerals’ heading was provided in the special
NIP and serving information was provided where not required.
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4.10.3.7 Infant food
Stage 1
All eight infant food products sampled in Stage 1 were fully assessed since it was difficult to
determine the Code used based on the NIP, as saturated fat is not required in the new Code
NIP format for infant foods.
All labels were inconsistent for this label element. Table 84 details the reasons they were
inconsistent by label element sections of the NIP assessed, the main reasons being borders,
serving information and nutrients.
Table 84 Reason infant food special NIP inconsistent by label element section for
Stage 1
Label Element Section Inconsistent Number of Labels
Inconsistent
Percentage of Total
Number of Labels
Inconsistent For Infant
Food Special NIP*
Presence 0 0
Legibility 0 0
General reasons 0 0
Borders 8 100
Panel heading 4 50
Serving information 8 100
Columns 5 63
Nutrients 8 100
Values 1 13
Units 2 25
Other 6 75
* Total number labels inconsistent for infant food special NIP = 8. Labels may be inconsistent for more than one reason.
Borders
Borders were inconsistent for all eight labels due to extra internal borders being provided.
Panel heading
The panel headings were inconsistent for four of the eight labels due to alignment, case and
wording. The wording inconsistency was due to ‘Nutrition’ being given as ‘Nutritional’.
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Serving information
The reasons why serving information was inconsistent were errors with case (eight labels),
position (four labels) and wording (five labels) (refer to Table 85). In all cases, serving
information position was inconsistent due to sharing the line with the column headings.
‘Servings per package’, and ‘servings size’ were also placed in the wrong order on some
labels.
Table 85 Reason infant food special NIP serving information inconsistent for Stage
1
Reason Inconsistent Number of Labels
Inconsistent
Percentage of Total
Number of Labels
Inconsistent For Infant
Food NIP Serving
Information*
Servings per package present 0 0
Servings per package position 4 50
Servings per package alignment 0 0
Servings per package punctuation 0 0
Servings per package case 7 88
Servings per package wording 5 63
Serving size present 0 0
Serving size position 4 50
Serving size alignment 1 13
Serving size punctuation 0 0
Serving size case 8 100
Serving size wording 1 13
* Total number labels inconsistent for infant food NIP serving information = 8. Labels may be inconsistent for more than one reason.
The reason why five labels had inconsistent wording for ‘servings per package’ was the
wording of ‘package’, with only one label having inconsistent wording for ‘servings’.
Columns
Five labels were assessed as inconsistent for the columns label element section, due to
wording inconsistencies (three labels), other inconsistencies (two labels) and presence (one
label). One sample only provided one column because the serving size equalled 100g/100mL.
For the three labels inconsistent for wording this was due to ‘Quantity’ not being provided
for all labels, with one label where ‘Serving’ was called ‘Serve’ and one label where
‘Quantity’ was abbreviated.
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Nutrients
For the eight labels inconsistent for nutrients, this was as a result of case and punctuation
(seven labels each), and wording (two labels). The main reason why wording was
inconsistent on two labels was for ‘Fat, total’, due to ‘, total’ not being provided.
A number of other nutrients were provided, related to claims made; these are detailed in
Table 86.
Table 86 Other nutrients provided in infant food NIP for Stage 1
Nutrients Provided Number of Labels
Providing ‘Other’
Nutrient
Percentage of Total
Number of Labels
Providing ‘Other’
Nutrients*
Gluten# 2 25
Vitamin C 2 25
Iron 5 63
Thiamin 4 50
Riboflavin 4 50
Niacin 4 50
Calcium 2 25
Phosphorous 1 13
Folate 1 13
Lactose 1 13
*Total number of labels providing ‘other’ nutrients = 8. Labels may declare more than one additional nutrient.
# Not a nutrient, but permitted to be declared in NIP
Values
One infant food was inconsistent for values due to a symbol being used to represent a
mathematical value (‘<’ rather than ‘less than’).
Units
Two labels were inconsistent for units, as a result of position, case and units used. Energy
was inconsistent for case and units used (kCal used and expressed in the wrong case).
Other inconsistencies
The six labels inconsistent for other reasons were a result of calorie values not appearing in
brackets (five labels) and provision of saturated fat where no claim was made (one label).
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Stage 2
Similar to Stage 1, all eight infant food products sampled were fully assessed in Stage 2. Of
these eight labels, all were inconsistent. Reasons for inconsistency are detailed in Table 87
and discussed below.
Table 87 Reason infant food special NIP inconsistent by label element section for
Stage 2
Label Element Section Inconsistent Number of Labels
Inconsistent
Percentage of Total
Number of Labels
Inconsistent For Infant
Food Special NIP*
Presence 0 0
Legibility 0 0
General reasons 2 25
Borders 8 100
Panel heading 3 38
Serving information 8 100
Columns 3 38
Nutrients 8 100
Values 1 13
Units 1 13
Other 1 13
*Total number labels inconsistent for infant food special NIP = 8. Labels may be inconsistent for more than one reason.
General reasons
Both labels inconsistent for general reasons in Stage 2 were due to labels not indicating that
nutrition information values were averages.
Borders
In Stage 2, two labels were inconsistent for not providing external borders, and all eight
labels were inconsistent for providing extra internal borders.
Panel heading
Of the three labels inconsistent for the panel heading label element sub section, two were
inconsistent for the alignment of the panel heading and two due to the case of the panel
heading.
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Serving information
Serving information was inconsistent for all eight labels due to serving information position
(five of eight labels), case (seven of eight labels), and wording (three of eight labels). For the
labels inconsistently positioned, serving information shared the same line as the column
headings.
Wording inconsistencies in Stage 2 were a result of ‘package’ (three of three labels) in the
‘Servings per package’ information.
Table 88 Reason infant food special NIP serving information inconsistent for Stage
2
Reason Inconsistent Number of Labels
Inconsistent
Percentage of Total
Number of Labels
Inconsistent For Infant
Food NIP Serving
Information*
Servings per package present 0 0
Servings per package position 5 63
Servings per package alignment 0 0
Servings per package punctuation 0 0
Servings per package case 7 88
Servings per package wording 3 38
Serving size present 0 0
Serving size position 5 63
Serving size alignment 0 0
Serving size punctuation 0 0
Serving size case 7 88
Serving size wording 0 0
* Total number labels inconsistent for infant food NIP serving information = 8. Labels may be inconsistent for more than one reason.
Columns
All column inconsistencies were due to the column heading wording (three of three labels).
Two of the three labels abbreviated the word ‘quantity’ in the column heading and one label
gave the products actual serving size in the column heading.
Nutrients
Nutrient inconsistencies in Stage 2 were as a result of nutrients not being:
• present (one of eight labels);
• positioned consistently (one of eight labels);
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• worded consistently (two of eight labels);
• in the right case (eight of eight labels); and
• punctuated consistently (three of eight labels).
For the one label inconsistent for nutrient presence, the missing nutrient was an ‘other’
nutrient required to be present due to the label making a claim about that nutrient. The
position of ‘Carbohydrate’ and ‘sugars’ was also inconsistent on one label.
Nutrient wording inconsistencies in Stage 2 were as a result of:
• ‘Fat, total’ (one of two labels);
• ‘Carbohydrate’ (two of two labels);
• ‘sugars’ (one of two labels); and
• ‘other’ nutrient/s (one of two labels).
‘Other’ nutrients provided in infant food special NIPs are given in Table 89.
Table 89 Other nutrients provided in infant food NIP in Stage 2
Nutrients Provided Number of Labels
Providing ‘Other’
Nutrient
Percentage of Total
Number of Labels
Providing ‘Other’
Nutrients*
Gluten# 4 67
Vitamin C 3 50
Iron 1 17
Lactose 1 17
Saturated fat 2 33
Sodium 3 50
* Total number of labels providing ‘other’ nutrients = 6. Labels may declare more than one additional nutrient.
# Not a nutrient, but permitted to be declared in NIP
Values
One label was inconsistent for the values label element sub section in Stage 2, for giving a
mathematical term as a symbol (e.g. ‘<’ instead of ‘less than’).
Units
Reasons for unit label element sub section inconsistencies in Stage 2 were due to ‘Energy’
units being given as ‘kcal’ not ‘Cal’ and because the case used for ‘cal’ was inconsistent
(‘cal’ instead of ‘Cal’).
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Other inconsistencies
One label was inconsistent for other inconsistencies due to calories not being given in
brackets.
4.11 Percentage daily intake information
Of the 359 labels providing NIPs in Stage 1, 17% (60 labels) provided percentage daily
intake information. For these 60 labels, the optional percentage daily intake column in the
NIP was only used in 30% of these cases (18 labels). For Stage 2, 130 labels providing an
NIP provided percentage daily intake information (12%, 130 of 1078 labels). Of these 130
labels, 12% used the optional percentage daily intake column (16 of 130 labels).
Where the optional column was not used, percentage daily intake information was given
adjacent to the corresponding nutrient value.
4.12 Ingredient declaration
Stage 1
Eighty four percent (378 of 448 labels) of labels in Stage 1 required or voluntarily provided
an ingredient declaration. Only one of these labels was inconsistent as it was not legible due
to visibility.
Stage 2
Of the 1153 labels assessed for Stage 2, 1058 (92%) required or voluntarily provided an
ingredient declaration. Thirteen of the 1058 labels were inconsistent, three for failing to
provide an ingredient list when one was required and ten due to illegibility. The reasons that
these labels were assessed as inconsistent for legibility are due to the ingredient declaration
not being:
• indelible (three of ten labels);
• distinct from label decoration (two of ten labels);
• distinct from label text (three of ten labels); and
• visible (two of ten labels).
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4.13 Characterising ingredients
Stage 1
Of the 448 labels fully assessed in Stage 1, 378 labels were assessed as having characterising
ingredients present. Of the 70 labels with no characterising ingredients required to be
declared, 5 labels voluntarily provided characterising ingredients.
Including labels voluntarily providing characterising ingredient information, 383 labels were
eligible for assessment for characterising ingredients. Of these 383 labels, 145 labels were
consistent with the labelling provisions, with 103 labels exempt. The remaining 135 labels
were inconsistent (refer to Table 90).
Table 90 Consistency status of characterising ingredients by major food category
for Stage 1
Consistency Status of characterising ingredient
Consistent Inconsistent Exempt
Major Food Category
Total Number
of Labels
Assessed* Number (%) Number (%) Number (%)
1. Dairy 32 13 (41) 11 (34) 8 (25)
2. Edible oils and oil emulsions 14 3 (21) 7 (50) 4 (29)
3. Ice cream and edible ices 5 1 (20) 4 (80) 0 (0)
4. Fruit and vegetables 60 21 (35) 7 (12) 32 (53)
5. Confectionery 12 9 (75) 3 (25) 0 (0)
6. Cereal and cereal products 11 9 (82) 2 (18) 0 (0)
7. Bread and bakery products 38 20 (53) 18 (47) 0 (0)
8. Meat and meat products 56 18 (32) 14 (25) 24 (43)
9. Fish and fish products 14 3 (21) 8 (57) 3 (21)
10. Eggs and egg products 3 0 (0) 0 (0) 3 (100)
11. Sugars, honey and related products 4 1 (25) 2 (50) 1 (25)
12. Food intended for particular dietary use 10 3 (30) 6 (60) 1 (10)
13. Non alcoholic beverages 53 19 (36) 8 (15) 26 (49)
14. Mixed foods 71 25 (35) 45 (63) 1 (1)
Overall Results 383 145 (38) 135 (35) 103 (27)
* Includes characterising ingredients voluntarily provided and excludes labels where no characterising ingredients were present
Table 91 details the types of characterising ingredients not declared. Of the 135 inconsistent
labels, 111 were inconsistent due to ingredients present in the product description not being
declared, 102 due to ingredients in the product name not being declared and 32 labels due to
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ingredients pictured or in graphics not being declared. It should be noted that labels were
often inconsistent for more than one reason.
Table 91 Reason characterising ingredient not declared for Stage 1
Reason Inconsistent Number of Labels
Inconsistent
Percentage of Labels
Inconsistent*
Characterising ingredients in product name not declared 102 76
Characterising ingredients in product description not declared 111 82
Characterising ingredients in graphics or pictures (no serving suggestion) not
declared 32 24
* Total number of labels inconsistent for characterising ingredients = 135. Labels may be inconsistent for more than one reason.
Stage 2
In Stage 2, 904 labels were required to provide characterising ingredient information. Of
these 904 labels, 33 labels also gave the percentage presence of other ingredients not assessed
as being characterising ingredients.
An additional 34 labels assessed as not required to declare the percentage of characterising
ingredients, voluntarily gave these percentages. Therefore, a total of 938 labels were
assessed for this label element in Stage 2.
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Table 92 Consistency status of characterising ingredients by major food category
for Stage 2
Consistency Status of characterising ingredient
Consistent Inconsistent Exempt
Major Food Category
Total Number
of Labels
Assessed* Number (%) Number (%) Number (%)
1. Dairy 79 34 (43) 21 (27) 24 (30)
2. Edible oils and oil emulsions 26 13 (50) 1 (4) 12 (46)
3. Ice cream and edible ices 30 18 (60) 12 (40) 0 (0)
4. Fruit and vegetables 130 67 (52) 33 (25) 30 (23)
5. Confectionery 49 39 (80) 10 (20) 0 (0)
6. Cereal and cereal products 61 40 (66) 10 (16) 11 (18)
7. Bread and bakery products 104 79 (76) 25 (24) 0 (0)
8. Meat and meat products 94 51 (54) 23 (25) 20 (21)
9. Fish and fish products 30 14 (47) 13 (43) 3 (10)
10. Eggs and egg products 7 0 (0) 0 (0) 7 (100)
11. Sugars, honey and related products 12 4 (33) 1 (8) 7 (58)
12. Food intended for particular dietary use 18 6 (33) 12 (67) 0 (0)
13. Non alcoholic beverages 72 43 (60) 21 (29) 8 (11)
14. Mixed foods 226 128 (57) 95 (42) 3 (1)
Overall Results 938 536 (57) 277 (30) 125 (13)
* Includes characterising ingredients voluntarily provided and excludes labels where no characterising ingredients were present
Of the 938 labels requiring or voluntarily providing characterising ingredients, 57% were
consistent with the requirements of the new Code, considerably higher than that reported for
Stage 1. However, the percentage of inconsistent labels in Stage 2 was similar to that of
Stage 1, with 30% of labels being inconsistent (refer to Table 92).
One label in Stage 2 was indeterminable as to whether or not characterising ingredients
present in the product name and product description were declared, as the ingredient list was
not legible.
Reasons for inconsistency in Stage 2, were primarily due to characterising ingredients given
in the product’s name not being declared (70%, 195 of 277 labels). Characterising
ingredients given in the product’s description not being declared accounted for 51% (142 of
277 labels) of inconsistencies, whilst characterising ingredients given in pictures or graphics
on the label not being declared accounted for 25% (70 of 277 labels) (refer to Table 93).
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Table 93 Reason characterising ingredient not declared for Stage 2
Reason Inconsistent Number of Labels
Inconsistent
Percentage of Labels
Inconsistent*
Characterising ingredients in product name not declared 195 70
Characterising ingredients in product description not declared 142 51
Characterising ingredients in graphics or pictures (no serving suggestion) not
declared 70 25
* Total number of labels inconsistent for characterising ingredients = 277. Labels may be inconsistent for more than one reason.
4.14 Compound ingredients
Stage 1
Only 20% (90 labels) of labels in Stage 1 declared the presence of compound ingredients. Of
these 90 labels, 71% (64 labels) were consistent, with 5 labels indeterminable and 23% (21
labels) inconsistent (refer to Table 94).
Table 94 Consistency status for compound ingredients by major food category for
Stage 1
Consistency Status
Consistent Inconsistent Indeterminable
Major Food Category
Total Number
of Labels
Assessed* Number (%) Number (%) Number (%)
1. Dairy 9 7 (75) 2 (25) 0 (0)
2. Edible oils and oil emulsions 0 0 (0) 0 (0) 0 (0)
3. Ice cream and edible ices 4 4 (100) 0 (0) 0 (0)
4. Fruit and vegetables 3 3 (100) 0 (0) 0 (0)
5. Confectionery 5 3 (67) 2 (33) 0 (0)
6. Cereal and cereal products 3 3 (100) 0 (0) 0 (0)
7. Bread and bakery products 21 14 (65) 5 (25) 2 (10)
8. Meat and meat products 3 2 (67) 1 (33) 0 (0)
9. Fish and fish products 2 1 (50) 1 (50) 0 (0)
10. Eggs and egg products 0 0 (0) 0 (0) 0 (0)
11. Sugars, honey and related products 0 0 (0) 0 (0) 0 (0)
12. Food intended for particular dietary use 2 1 (50) 1 (50) 0 (0)
13. Non alcoholic beverages 0 0 (0) 0 (0) 0 (0)
14. Mixed foods 38 26 (68) 9 (23) 3 (8)
Overall Results 90 64 (71) 21 (23) 5 (6)
*Excludes labels which did not contain compound ingredients
For the 21 inconsistent labels, 19 labels did not provide all ingredients present in compound
ingredients where the compound ingredient was present at greater than 5%. This is possibly
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due to the fact that in the old Code, ingredient declarations were not required unless the
ingredient was present at greater than 25%.
Stage 2
Two hundred and seventy-eight labels were assessed in Stage 2 for the compound ingredient
label element. Of these 278 labels, 70% (194 of 278 labels) were consistent in providing
required information regarding compound ingredients, three percent inconsistent, and 27%
indeterminable (refer to Table 95).
Table 95 Consistency status for compound ingredients by major food category for
Stage 2
Consistency Status
Consistent Inconsistent Indeterminable
Major Food Category
Total Number
of Labels
Assessed* Number (%) Number (%) Number (%)
1. Dairy 13 8 (62) 2 (15) 3 (23)
2. Edible oils and oil emulsions 1 0 (0) 0 (0) 1 (100)
3. Ice cream and edible ices 11 8 (73) 0 (0) 3 (27)
4. Fruit and vegetables 12 5 (42) 0 (0) 7 (58)
5. Confectionery 23 16 (70) 1 (4) 6 (26)
6. Cereal and cereal products 27 21 (78) 0 (0) 6 (22)
7. Bread and bakery products 62 52 (84) 1 (2) 9 (15)
8. Meat and meat products 6 5 (83) 0 (0) 1 (17)
9. Fish and fish products 2 1 (50) 0 (0) 1 (50)
10. Eggs and egg products 0 0 (0) 0 (0) 0 (0)
11. Sugars, honey and related products 0 0 (0) 0 (0) 0 (0)
12. Food intended for particular dietary use 4 4 (100) 0 (0) 0 (0)
13. Non alcoholic beverages 2 2 (100) 0 (0) 0 (0)
14. Mixed foods 115 72 (63) 4 (3) 39 (34)
Overall Results 278 194 (70) 8 (3) 76 (27)
*Excludes labels which did not contain compound ingredients
Reasons for inconsistency in Stage 2 were due to all ingredients not being declared where the
compound ingredient was present at greater than 5% (75%, six of eight labels), and food
additives and/or allergens not being declared where the compound ingredient was present at 5%
or less (38%, three of eight labels).
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4.15 Genetically modified foods and ingredients
One label in Stage 1 declared the use of genetically modified ingredients. This label was
consistent with the labelling requirements for this label element. No labels in Stage 2
declared the use of genetically modified ingredients.
Stage 1
Three percent (14 labels) of labels assessed in Stage 1 made claims to the effect that a
product was free of genetic modification. These claims were made in a number of different
formats, with the most common being ‘Every ingredient has been/is certified by suppliers as
not known to contain GM material’ – accounting for six labels) of the claims made. Details
of all ‘genetically modified free’ statements used in Stage 1 are given in Table 96.
Table 96 Details of ‘genetically modified free’ statements used for Stage 1
Statement Type Used Number of Labels
With Claim
Percentage of Labels
With Claim*
Every ingredient has been certified by suppliers as not known to contain GM material 6 43
Every ingredient is certified by suppliers as not known to contain GM material 1 7
GE free 1 7
No genetically modified ingredients 1 7
X does not contain any genetically modified ingredients 1 7
Made from non-genetically modified soy 2 15
GM free 2 15
* Total number of labels with ‘genetically modified free’ claim = 14
X = product name
Stage 2
Twenty-nine labels in Stage 2 (three percent) used ‘genetically modified free’ statements. The
range of types of ‘genetically modified free’ claims used in Stage 2 was greater than that of
Stage 1, however the statement ‘Every ingredient has been/is certified by suppliers as not
known to contain GM material’ (five of 29 labels) was still the most commonly used
statement. The statements ‘GE free’, ‘GM free’ and ‘free of genetic modification’ were also
commonly used (three labels each) (refer to Table 97).
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Table 97 Details of ‘genetically modified free’ statements used for Stage 2
Statement Type Used Number of Labels
With Claim
Percentage of Labels
With Claim*
Every ingredient has been certified by suppliers as not known to contain GM material 5 (17)
Every ingredient has certified as not known to contain GM material 1 (3)
GE free 3 (10)
No genetically modified ingredients 2 (7)
No genetically modified ingredients used 1 (3)
Free from genetically engineered rice 2 (7)
Made from non-GM canola 1 (3)
GM free 3 (10)
Our flax seeds are not genetically altered 1 (3)
Free of genetic modification 3 (10)
Free from genetic modification 1 (3)
GMO free 2 (7)
Non GMO 1 (3)
Ingredients are not genetically modified 1 (3)
All X are vegan and we DO NOT use GM products 1 (3)
Guaranteed GM free 1 (3)
* Total number of labels with ‘genetically modified free’ claim = 29
X = product name
4.16 Irradiated foods and ingredients
Nineteen percent of labels in Stage 1 and 20% of labels in Stage 2 were herbs, spices or
herbal infusions, or contained these types of ingredients. In both Stages, no labels declared
the use of irradiation. For the purposes of this survey herbs and spices were assessed as they
are currently the only foods permitted to be irradiated at the time.