Technical evaluation for Labelling Review recommendation 14: Mandatory declaration of total and naturally occurring dietary fibre in the nutrition information panel

Executive summary

In 2009, the then Australian and New Zealand Ministerial Council for Food Regulation (now known as the Australia and New Zealand Ministerial Forum on Food Regulation (Forum)) agreed to proceeding with a comprehensive independent review of food labelling law and policy. An expert panel, chaired by Dr Neal Blewett, AC, undertook the review and the panel's final report, Labelling Logic: Review of Food Labelling Law and Policy (2011) (Labelling Logic) was publicly released in January 2011. 

Recommendation 14 from Labelling Logic stated that declaration of total and naturally occurring fibre content be considered as a mandatory requirement in the Nutrition Information Panel (NIP). Currently, mandatory declaration of total dietary fibre in the NIP is not required (although voluntary declarations are permitted), unless nutrition content or health claims are made about dietary fibre, any specifically named fibre, sugars or any other types of carbohydrate. There are no requirements to declare the naturally occurring dietary fibre content of a food. 

In 2011, the Forum provided a response to the Labelling Logic report which considered Recommendation 14 in association with two other recommendations (Recommendations 12 and 13) also relating to NIP declarations along with ingredient listing. The Forum asked FSANZ to undertake a technical evaluation and provide advice on these proposed changes to the ingredient listing and NIP. However, FSANZ has progressed its technical evaluation and advice on Recommendation 14 separately, because of the diverse nature of the specific issues involved in each of the three recommendations. 

In relation to Recommendation 14, the Forum also noted that some industry stakeholders have concerns about the scientific basis and technical feasibility of distinguishing between naturally occurring fibre and other fibre on the food label. 

• conducted a scientific and technical assessment considering the types of dietary fibre in food, analytical and alternative techniques for estimating levels of naturally occurring versus total dietary fibre, and the physiological effects of dietary fibre
• compared the current requirements and permissions in the Code for providing label information on the dietary fibre content of food to those of overseas food regulations
• undertaken preliminary consideration of the impact of mandating declaration of total dietary fibre in the NIP by:
  
  
  
   -   completing a rapid evidence assessment of consumer knowledge, attitudes and behaviours relating to the declaration of dietary fibre in the NIP, and
  
  
  
   -  estimating the direct labelling costs of mandating the declaration of total dietary fibre content in the NIP. 

• There is no simple means by which naturally occurring dietary fibre can be distinguished from total dietary fibre. Naturally occurring dietary fibre can often be found together with dietary fibres from refined sources in the same food (and can even consist of the same substance in the food).

• Available information also suggests that differences in physiological effects cannot be used as a way of distinguishing natural occurring and refined dietary fibres as both have the potential to contribute to some of the recognised health outcomes for dietary fibre.

• There is no readily available method of analysis that clearly distinguishes naturally occurring dietary fibre from total dietary fibre where both natural and refined fibres are present. The use of non-analytical alternative approaches, such as calculating the naturally occurring dietary fibre of ingredients from food composition data, is currently not possible, as national food composition tables and nutrition labelling tools for Australia and New Zealand do not contain the information required for these purposes.

• Therefore, FSANZ considers that to separately declare naturally occurring dietary fibre from total dietary fibre in the NIP to be difficult and impractical to implement.  

Declaration of total dietary fibre

• The current regulatory approach to the declaration of total dietary fibre content in Australia and New Zealand is consistent with codex Alimentarius guidelines and European Union regulations. Other than the United States of America and Canada, FSANZ is not aware of any other overseas regulations that mandate the declaration of total dietary fibre content on all food labels. 

• Preliminary consideration has shown that some consumers will value increased access to total dietary fibre information, but also that there could potentially be costs to industry. Due to data limitations, a more definitive analysis cannot be made, especially on the magnitude of the costs to industry. However, FSANZ has identified the following:
  
  
  
  -  The rapid evidence assessment of consumer knowledge, attitudes and behaviour suggests that there is value to some consumers in the display of dietary fibre information in the NIP and that this information may influence dietary fibre intakes. 
  
  
  
  -  There is limited evidence on how consumers respond to dietary fibre declarations; however, the literature that is available suggests consumers are more likely to use this information when selecting products perceived to be higher in dietary fibre and less likely when selecting products that are viewed as lower in dietary fibre. Also, consumers have limited knowledge of what is a nutritionally high or low level of dietary fibre.

It is likely that inclusion of a declaration of total dietary fibre in the NIP would be a minor labelling change (for those foods that are not already declaring this information) with an estimated direct labelling cost of around AU$4,000 per single Stock Keeping Unit (SKU). This cost does not take into consideration indirect costs (e.g. write-off of stock in hand, reformulation, product testing, marketing costs or administrative costs).

Available information suggests there are around 28,000 packaged food SKUs on supermarket shelves. While noting that the actual number of SKUs affected will be less because some SKUs already declare total dietary fibre in the NIP voluntarily or are exempt from requiring a NIP, the SKU figure does provide a general indication of the magnitude of the costs that might be incurred if the declaration of total dietary fibre was a mandatory requirement in the NIP. Further work would be required, including a robust cost benefit analysis, to fully consider the costs and expected benefits of mandating the declaration of total dietary fibre in the NIP.