Food Standards Australia New Zealand is undertaking industry consultation as it proposes to introduce further mandatory labelling requirements onto alcohol products.
After the industry battled over pregnancy warning labelling last year, the focus has now turned on nutrition labelling.
These new rules will force brewers and other alcohol producers to include energy, carbohydrate and sugar content information on beer packaging. Alcohol products are currently exempt from having to provide nutrition information.
In recent months, FSANZ engaged with key industry stakeholders including the Independent Brewers Association, the Brewers Association, consisting of Lion, Carlton & United Breweries and Coopers, and the Brewers Guild of New Zealand. These industry organisations are currently making submissions.
“We expect to report to the FSANZ Board on this initial work in early June 2021, and subject to their consideration commence a second stage of work to explore regulatory and/or non-regulatory options for energy labelling of alcoholic beverages, and identify a preferred approach,” FSANZ said in a statement to Brews News.
The proposals have been met with dismay from the industry which was already forced to make its case against mandatory labelling with pregnancy warning labels. The IBA worked out would cost $100 million over 10 years to make those changes.
Industry response to label mandates
While the concerns around the onerous costs of label changes are being revisited in this latest round of labelling consultations, Sabrina Kunz, executive director of the Brewers Guild of New Zealand has also highlighted a number of issues with the requirements.
“The big issue around this labelling is how to record energy content,” Kunz told Brews News.
“We and the IBA pushed back on this. We wanted to know what methodology is required. Are the breweries going to have scientific equipment available? Are they going to have access to the tools? Can they afford it?”
According to Kunz there are two options, one is scientific testing and the other an algorithm, similar to how homebrewers calculate ABV.
“It not only comes down to what goes on the label – it’s got all the design, cost and clutter issues as we had with pregnancy warning – but what does it mean for brewers on a practical level?
“ABV for instance is determined on the basis of a sample across three batches, this is our average ABV over those three batches, so we know that’s within spec,” she said.
“Increasingly small breweries doing one-off batches that they are then packaging, which makes this harder.
“The interrelation between the processes is complicated and the actual implications to brewers are numerous.”
Kylie Lethbridge, general manager of the Independent Brewers Association in Australia explained that the industry organisations are working together to ensure they are aligned in their responses to FSANZ.
“We’ll be working with all of our partners in the industry because this is not just a craft and independent brewers issue, this is an issue that impacts spirits, cider, everybody,” she said.
“We’re working strategically to make sure we really get to the nub of the issue, which is where do [FSANZ] want to be with alcohol labelling? Do they want to be like tobacco with plain packaging?
“By the time we finish with what FSANZ wants there won’t be any room for branding. We’re still saying there’s no evidence to support that putting this information on labels changes behaviour. So is there a better solution when it comes to education or providing info or awareness raising?”
The IBA has been communicating with its members to raise awareness of the issue and to have individual members use their own networks to help raise the issue with decision-makers, as has the Brewers Guild.
“Many brewers have a great relationship with local members, especially those in rural areas, so we need to shout loudly and clearly on what this means for business.
“What we would be keen on is open and honest dialogue. We don’t feel this constant change to labelling will make people consume alcohol in a different way.”
Much like with pregnancy warning labels, it has been a long journey to get to this point, and the issue has been simmering in the background for several years after it was brought up initially in response to food labelling policy documents from 2011.
In August 2019, the Australia and New Zealand Forum on Food Regulation on the labelling of alcoholic beverages referred some of its work to FSANZ.
In principle, the forum said, it supported the concept that the energy content should be displayed on the labels of all alcoholic beverages, consistent with the requirements for other food products.
Back then, further research on a cost-benefit analysis and broader policy issues regarding energy labelling on alcoholic beverages was commissioned, before the consultations began in earnest this year.
The Food Ministers’ forum has since justified the work on energy labelling as necessary because a consumer’s ability to understand the energy contribution of alcohol is limited without this labelling.
However, there has been serious debate over the efficacy of these labels and whether they will actually impact consumer behaviour.
Indeed when it came to health warning labels on alcohol (as opposed to nutrition labels) a federal parliamentary enquiry has previously found that while labels can raise awareness, they do not necessarily translate to behavioural changes in at-risk groups. This was reiterated in reports from FSANZ on the pregnancy warning labels, however, it was still implemented.
There has also been a struggle to get FSANZ to consider both energy and carb and sugar content labelling as one issue.
“The biggest challenges from an industry perspective is that these things are interrelated but they were being managed as distinct processes in the initial stages,” explained the Brewers Guild’s Sabrina Kunz.
“By 2019 FSANZ started to understand these things had implications for one another, which was a good effort to try to appreciate at a basic level.
“[This is important because] each label change has a cost associated with it, and with the number of SKUs we produce in this industry, the cost could be astronomical.”