There are two arguments coming from those opposed to truth in labelling of meat products: that there is no evidence of confusion, and that we should have a thorough investigation into the matter and require evidence before assessing legislation.
Confusion has been clearly demonstrated.
Woolworths have released a survey demonstrating 7 per cent of participants had mistakenly bought the wrong product.
Pollinate research says it's 30pc, the Colmar Brunton research commissioned by Food Frontiers says 9pc and now 7pc from Woolworths.
Confusingly, Woolworths have said that 7pc confusion is no confusion at all.
Confused?
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Regarding the need for evidence to bring on a change in regulation, up until 2016 we had a standard in place that would have helped protect consumers and avoided confusion.
It was removed by the agency without evidence and without notifying the industries impacted.
On March 1, 2016, Standard 1.2.10 Characterising Ingredients and Components of Food was removed from the code. This standard defined characterising components of the foods as a component of the food that is mentioned in the name or associated with the name of the food. Characterising ingredients was an ingredient mentioned in the name of the food, usually associated with the name of the food, and emphasised on the label of a food in word, picture and graphics.
This standard would have helped to protect our consumers and our businesses, and stopped any of the confusing labelling practices we see undertaken by the highly-processed manufactured plant-based protein industry.
At the same time a schedule was also introduced to the code to help define what a 'meat analogue' was for an industry that barely existed.
Schedule 17 details permitted vitamins and minerals to be claimed on products, including analogues of meat, where no less than 12pc of the energy value of the food is derived from protein, and the food contains 5g protein per serve of the food.
Our business cannot claim our 'meat' products as a source of protein with less than 10g of protein per 100g, but any other product can claim to be a meat analogue with 5g of protein.
Our business input costs for meat are three to four times higher than manufactured plant-based protein, yet this instrument enables them to make the same health claims and use the same imagery and descriptors.
Schedule 17 is also an inspiration for the manufacturers of highly processed manufactured plant-based protein products detailing what you might like to put in your recipe and on your label: thiamin, riboflavin, niacin, vitamin B6, vitamin B12, folate, iron and zinc.
How did the agency determine what a meat analogue was and what fortified vitamins and minerals you might like to copy?
Did the agency write this legislation or was it provided to them?
Iron presents in two forms - haem iron and non-haem iron.
Haem iron is more readily absorbed compared to non-haem iron. Animal-derived meat is a rich source of haem iron, while plant-based sources contain non-haem iron only.
Non-haem iron absorption can be aided by consumption of vitamin C - making this the only part of the code that allows a food product to make a beneficial health claim that is dependent on also buying and consuming another product.
Iron is particularly important for infants, children and pregnant women. Products must be required to clearly label when they have been fortified with vitamins and minerals as opposed to when they naturally occur in products in their most bio available.
We need a regulatory framework that provides clarity and protects the consumer.
The only evidence critical to this inquiry is that meat varies in composition to plant-based manufactured proteins by 90pc.
These are not the same product.
We have been eating meat for two million years. It contains critical metabolites whose role in human development and physiology is not yet understood.
The government's job is not to tell consumers what they can and can't eat. It's role is to ensure consumers can be fully informed and that food is safe and clearly labelled so consumers can make that choice.
Standard 1.2.10 could be further developed to stop products that are not meat from using our name, pictures and graphics and avoid confusion and potential negative nutritional impacts from substituting meat with a very poor, highly processed imitation.
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