2020-21 Disclosure Log

PRIVATE & CONFIDENTIAL

Achieving the Policy Objectives

In order to establish that any action relating to alcohol consumption would be successful in achieving the policy objective of decreasing the proportion of Australians who are overweight and obese, it would need to be established that alcohol consumption causes or significantly contributes to obesity.

The relationship between patterns of alcohol consumption and obesity is complex and influenced by many factors including gender, genetics, diet, physical activity, sleep, and body weight.

Approximately one third of epidemiological studies on alcohol and body weight suggest that there is a positive correlation between alcohol consumption and body weight, one third found a negative correlation and one third found no association at all. The discrepancies in data may result from methodological differences between the studies.

When alcohol is consumed in conjunction with a meal, as is the general cultural approach to alcohol in Australia, it becomes the priority substrate and temporarily displaces carbohydrate and fat from oxidative metabolism in the liver. Since there is a maximum oxidation rate for alcohol of approximately 0.1 g/kg (0.7 kcal/g) fat-free mass per hour, only approximately 50% of the resting energy expenditure can be covered by alcohol oxidation and substantially less if this is related to total energy expenditure, which includes physical activity.

This implies that alcohol can temporarily and transiently spare the oxidation of other substrates up to a maximum level of 50% the resting value. This means that alcohol is metabolized before carbohydrates and fats and as such delays the energy inputs of these nutrients into the body, resulting in a lower likelihood of additional calories that contribute to weight gain.

In relation to light to moderate alcohol consumption, there have been several studies that have found that light to moderate drinkers have lower odds of being overweight or obese compared with non-drinkers and ex-drinkers.

For example, a study of 43 543 participants considered the relationship between alcohol consumption and weight over a 13-year period.1 Some key findings from this study are as follows:

• There is an inverse relationship between drinking frequency and weight gain when compared tonon-drinkers, non-drinkers had the highest odds of weight gain.

• Importantly, weight loss was not associated with the amount of alcohol consumed.

• Light to moderate alcohol consumers were less likely to gain weight compared to non-drinkers.

Heavy drinking and binge drinking i.e. harmful alcohol consumption, however, are more likely to carry such an association with excess body weight (Tolstrup et al. 2005, Arif and Rohrer 2005, Lukasiewicz et al. 2005, Wakabayashi et al. 2010, Shelton et al. 2010, Lee 2012). These studies are limited in their ability to demonstrate cause-and-effect relationships or changes in weight status over time, due to significant confunders within this cohort and likelihood of drinking with other behaviors such as consumption of bar or other discretionary snacks and levels of physical activity.

In addition, the caloric profile of alcohol beverages vary considerably. There are alcoholic beverages such as ‘no sugar’ ready to drink beverages, low carbohydrate beer and Weight Watches approved wine. This means that there are alternative alcoholic beverages for those wishing to limit their caloric intake. It also means that a blanket decision on alcohol is meaningless.

As there is no conclusive evidence to support a causative link between alcohol consumption and being overweight or obese, the policy position to include alcohol in the strategy is not evidentiary supported and references to alcohol should be removed. The appropriate place for alcohol policy and strategy is to be found with another arm of Government that is focussed on this area through the National Alcohol Strategy.

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aseas is the general cultural approach to alcohol in

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es carbohydrate and fat from oxidative

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asees carbohydrate and fat from oxidative

metabolism in the liver. Since there is a maximum oxidation rate for alcohol of approximately 0.1 g/kg (0.7

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asemetabolism in the liver. Since there is a maximum oxidation rate for alcohol of approximately 0.1 g/kg (0.7

free mass per hour, only approximately 50% of the resting energy expenditure can be covered by

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asefree mass per hour, only approximately 50% of the resting energy expenditure can be covered by

cohol oxidation and substantially less if this is related to total energy expenditure, which includes physical

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cohol oxidation and substantially less if this is related to total energy expenditure, which includes physical

alcohol can temporarily and transiently spare the oxidation of other substrates up to a

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alcohol can temporarily and transiently spare the oxidation of other substrates up to a This means that alcohol is metabolized before carbohydrates and

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This means that alcohol is metabolized before carbohydrates and fats and as such delays the energy inputs of these nutrients into the body,

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fats and as such delays the energy inputs of these nutrients into the body,

light to moderate alcohol consumption, there have been several studies that have found that

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light to moderate alcohol consumption, there have been several studies that have found that light to moderate drinkers have lower odds of being overweight or obese compared with non

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light to moderate drinkers have lower odds of being overweight or obese compared with non

study of 43 543 participants

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study of 43 543 participants considered the relationship between alcohol consumption and

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considered the relationship between alcohol consumption and Some key findings from this study are as follows:

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Some key findings from this study are as follows:

There is an inverse relationship between drinking frequency and weight gain when compared to

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There is an inverse relationship between drinking frequency and weight gain when compared todrinkers, non

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drinkers, non-

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-dr

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drinkers had the highest odds of weight gain.

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inkers had the highest odds of weight gain.

Importantly, weight loss was not associated with the amount of alcohol consumed.

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Importantly, weight loss was not associated with the amount of alcohol consumed.

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Light to moderate alcohol consumers

Heavy drinking and binge driRTI Rele

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Heavy drinking and binge drinking i.e. harmful alcohol consumption, however, are more likely to carry such RTI Rele

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nking i.e. harmful alcohol consumption, however, are more likely to carry such an association with excess body weight (RTI R

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an association with excess body weight (Wakabayashi et al. 2010, Shelton et al. 2010, Lee 2012).RTI R

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Wakabayashi et al. 2010, Shelton et al. 2010, Lee 2012).


Prevention of Harmful Alcohol Consumption

As outlined above, the only area in which alcohol consumption poses the possible associated risk to obesity is where there is heavy drinking or binge drinking. There are multiple strategies in place to reduce harmful alcohol consumptions as follows:

National Drug Strategy - A ten-year framework that aims to reduce and prevent the harmful effects of alcohol, tobacco and other drugs approved by the federal, state and territory governments of Australia.

National Alcohol Strategy - A framework to prevent and reduce alcohol-related harm approved by the federal, state and territory governments of Australia.

National Alcohol and other Drug Workforce Development Strategy - To enhance the capacity of the Australian AOD workforce to prevent and minimise alcohol and other drug-related harm across the domains of supply, demand and harm reduction activities approved by the federal, state and territory governments of Australia.

NSW Health Alcohol and Other Drugs Strategy - The Centre for Population Health is finalising a strategy for the NSW Health system to address and minimise harm associated with alcohol and other drug use.

ACT Drug Strategy Action Plan 2018-2021 - outlines ACT Government priorities to address and minimise harms from alcohol, tobacco, illicit drugs and non-medical use of pharmaceuticals in the territory.

VicHealth Alcohol Strategy 2019-2023 - reaffirms the 10-year goal of 200,000 more Victorians drinking less alcohol by 2023.

Queensland Mental Health, Drug and Alcohol Strategy - brings together the best ideas to shape a new direction for mental health, drug and alcohol reform.

Tasmanian Alcohol Action Framework – a new framework is being developed and will be informed by both the new National Alcohol Strategy and by a new Tasmanian Drug Strategy expected to be developed in 2019.

Northern Territory Alcohol Harm Minimisation Action Plan – an action plan for the minimisation of alcohol related harm in the Northern Territory.

Western Australian Alcohol and Drug Interagency Strategy 2018-2022 - WA’s key policy document that outlines strategies to prevent and reduce the adverse impacts of AOD.

South Australian Alcohol and Other Drug Strategy 2017-2021 – the guiding strategy for harm minimisation of alcohol and other drugs in SA.

As there a plethora of strategies dedicated to the reduction of harmful alcohol consumption any references to alcohol in the obesity strategy should be removed. This will ensure the focus on harmful alcohol consumption is clear and unambiguous.

Consideration of Nutrition Warning Labelling for Alcoholic Beverages

The consultation paper includes the following:

Action 4.6.2 - Introduce front of pack nutrition warning labels for nutrients of concern (e.g., added sugar, sodium, saturated fats, alcohol, energy content) to complement the Health Star Rating system.

Alcoholic beverages are clearly labeled as such. The label includes information on the percentage of pure alcohol by volume as well as the number of standard drinks in each product. The labelling of alcoholic beverages are regulated by FSANZ in a way that recognises it as a unique product. As such, a label warning that a beverage contains alcohol is not necessary as the information already exists on label.

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To enhance the capacity of the

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To enhance the capacity of the d harm across the domains

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d harm across the domains approved by the federal, state and territory governments of

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The Centre for Population Health is

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harm associated with alcohol and other drug use.

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outlines ACT Government priorities to address

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outlines ACT Government priorities to address harms from alcohol, tobacco, illicit drugs and non

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harms from alcohol, tobacco, illicit drugs and non-

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-medical us

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medical use of pharmaceuticals in the

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e of pharmaceuticals in the

reaffirms the 10

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reaffirms the 10-

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-year goal of 200,000 more Victorians drinking less

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year goal of 200,000 more Victorians drinking less

Queensland Mental Health, Drug and Alcohol Strategy

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Queensland Mental Health, Drug and Alcohol Strategy -

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- brings together the best ideas to sha

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brings together the best ideas to sha

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direction for mental health, drug and alcohol reform.

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direction for mental health, drug and alcohol reform.

–

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– a new framework is being developed and will be informed by both

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a new framework is being developed and will be informed by both and by a new Tasmanian Drug Strategy expected to be developed

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and by a new Tasmanian Drug Strategy expected to be developed

Northern Territory Alcohol Harm

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Northern Territory Alcohol Harm Minimisation

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Minimisation Action Plan

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Action Plan

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related harm in the Northern Territory.

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related harm in the Northern Territory.

Western Australian Alcohol and Drug Interagency Strategy 2018

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Western Australian Alcohol and Drug Interagency Strategy 2018

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outlines strategies to prevent and reduce the adverse impacts of AOD.

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outlines strategies to prevent and reduce the adverse impacts of AOD.

South Australian Alcohol and Other Drug Strategy 2017RTI Rele

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South Australian Alcohol and Other Drug Strategy 2017RTI Rele

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alcohol and other drugs in SA.RTI Rele

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alcohol and other drugs in SA.

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As there a plethora of strategies dedicated to the reduction of harmful alcohol consumption any references


It is important to note that Health Star Rating system specially excludes alcohol. This means that the nutrition warning label for alcohol would not be complementary to the Health Star Rating system in this case.

Lastly, Australia is a signatory to many worldwide trade agreements that are prescriptive on what information can and cannot be mandated for the front-of-label of an alcoholic beverage. Actions by the Australian Government to mandate specific information on front-of-label would be strongly contested and be in breach of many treaties that Australia is a signatory.

As alcoholic products are clearly sold as such with alcohol content stated on the front of label a nutrition warning label for alcohol is unnecessary. As such ABA recommends removing reference to alcohol from action 4.6.2 and that the limited resources available to an obesity strategy are maximised.

Consideration of Price Mechanism to Reduce Alcohol Consumption

The consultation paper includes the following:

4.7.3 Consider using price to reduce consumption of alcoholic beverages, potentially through a uniform volumetric tax and/or a floor price.

Action 4.7.3 is aimed to reduce all alcohol consumption. As outlined above, the risk of obesity becomes a possible issue when there is binge or heavy drinking taking place, noting correlation is not causation.

Price mechanisms have not been proven to be effective in reducing harmful alcohol consumption. Evidence demonstrates that while higher prices can influence the amounts of alcohol light to moderate drinkers consume, heavy and harmful drinkers are price inelastic and do not moderate there consumption in a significant way.

This matter has been considered as part of the National Alcohol Strategy and the Australian Government has clearly signalled it is not supportive of changes to alcohol tax2.

As such, ABA recommends the removal of action 4.7.3 in its entirety.

Unintended Consequences on the inclusion of alcohol in the Strategy

A possible unintended consequence of including alcohol in the obesity strategy is exacerbating the issue of ‘drunkrexia’. ‘Drunkrexia’ refers to extreme weight control behaviours to compensate for binge drinking. The messaging that alcohol causes obesity may further fuel situations where ‘drunkrexia’ is taking place.

As alcohol can form part of a balanced diet and lifestyle, it is important to ensure to alcohol is not portrayed as a beverage that will necessarily lead to weight gain.

Further Consultation

While some mention is made on the overarching webpage that there will be further consultation, there is no clarity on whether there will be an opportunity to provide written feedback on the draft strategy. ABA submits that a second consultation period of at least 60 days be provided once the draft strategy is developed and include consultation to include written submissions.

For any questions on this submission please contact:

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maximised

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maximised

4.7.3 Consider using price to reduce consumption of alcoholic beverages, potentially through a uniform

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. As outlined above, the risk of obesity becomes

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. As outlined above, the risk of obesity becomes issue when there is binge or heavy drinking taking place, noting correlation is not causation.

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issue when there is binge or heavy drinking taking place, noting correlation is not causation.

Price mechanisms have not been proven to be effective in reducin

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Price mechanisms have not been proven to be effective in reducing harmful alcohol consumption. Evidence

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g harmful alcohol consumption. Evidence demonstrates that while higher prices can influence the amounts of alcohol light to moderate drinkers

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demonstrates that while higher prices can influence the amounts of alcohol light to moderate drinkers consume, heavy and harmful drinkers are price inelastic and do not moderate there consumption in a

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consume, heavy and harmful drinkers are price inelastic and do not moderate there consumption in a

This matter has been considered as part of the National Alcohol Strategy and the Australian Government has

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This matter has been considered as part of the National Alcohol Strategy and the Australian Government has changes to alcohol

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changes to alcohol tax

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tax

As such, ABA recommends the removal of action 4.7.3 in

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As such, ABA recommends the removal of action 4.7.3 in

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on the inclusion of alcohol in the Strategy

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on the inclusion of alcohol in the Strategy

A possible unintended consequence of including alcohol in the

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A possible unintended consequence of including alcohol in theDrunkrexia

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Drunkrexia’ refers to

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’ refers to extreme weight control behaviours

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extreme weight control behavioursmessaging that alcohol

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messaging that alcohol causes obesity may further fuel

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causes obesity may further fuel

As alcohol can form part of a balanced diet and lifestyle, it is important to ensure to alcohol is not portrayed RTI Rele

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As alcohol can form part of a balanced diet and lifestyle, it is important to ensure to alcohol is not portrayed RTI Rele

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beverage that will necessarily lead to weight gain.RTI Rele

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beverage that will necessarily lead to weight gain.

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Further Consultation

While some mention is made on the overarching webpage that thRTI Rele

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While some mention is made on the overarching webpage that th

Have your say on a national obesity strategy – long-form survey

PLEASE NOTE: THIS WORD VERSION OF THE SURVEY IS FOR REFERENCE PURPOSES ONLY. PLEASE SUBMIT YOUR RESPONSE VIA THE ONLINE SURVEY AT https://www.surveygizmo.com/s3/5291207/national-obesity-strategy-long-survey

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Have your say on a national obesi strategy PLEASE NOTE: THIS WORD VERSION OF THE SURVEY IS FOR REFERENCE PURPOSES ONLY. PLEASE SUBMIT YOUR RESPONSE VIA THE ONLINE SURVEY AT https://www.surveygizmo.com/s3/5291207/national-obesity-strategy-long-survey

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PLEASE NOTE: THIS WORD VERSION OF THE SURVEY IS FOR REFERENCE PURPOSES

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PLEASE NOTE: THIS WORD VERSION OF THE SURVEY IS FOR REFERENCE PURPOSES PLEASE SUBMIT YOUR RESPONSE VIA THE ONLINE SURVEY AT

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PLEASE SUBMIT YOUR RESPONSE VIA THE ONLINE SURVEY AT

https://www.surveygizmo.com/s3/5291207/national

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https://www.surveygizmo.com/s3/5291207/national-

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obesity

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Introduction The Australian community is invited to take part in a national consultation to inform a national obesity strategy. This consultation runs from 4 November to 15 December 2019 and is being conducted by The Social Deck on behalf of the Council Of Australian Governments (COAG) Health Council. This survey is one of the ways you can have your say. While completing this survey you may want to refer to the consultation paper. The consultation paper provides details of the proposed framework and ideas for consideration to be included in a national obesity strategy. There is also a shorter version of the consultation paper. About the survey This survey is most relevant to organisations or interested individuals who want to have their say about the specific ideas and strategies being considered for inclusion in a national obesity strategy. The survey will close at 11:59 pm on Sunday, 15 December 2019. This survey includes some questions that ask you to rate items on a scale and other questions that ask you to write about your views, suggestions and feedback on specific strategies and ideas that are outlined in the consultation paper. It is designed to enable you to submit comments about each of the proposed strategies if you want to. The survey may take at least 45 minutes to complete, or longer if you provide comments on specific strategies. There is also a shorter survey available, which will only take approximately 20 minutes to complete. The shorter survey is for members of the public. The survey is in six parts, which includes:

• Section 1. Proposed timeframe and scope for a national obesity strategy • Section 2. Proposed principles to guide a national obesity strategy • Section 3. Proposed priority areas and strategies for a national obesity

strategy • Section 4. Proposed enablers for a national obesity strategy • Section 5. Proposed implementation, monitoring, evaluation and reporting of

a national obesity strategy • Section 6. Questions about you [please note these questions are not

provided in this word version].

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There is also a

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There is also a

This survey is most relevant to organisations or interested individuals who want to

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This survey is most relevant to organisations or interested individuals who want to have their say about the specific ideas and strategies

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have their say about the specific ideas and strategies being considered for

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being considered for

Sunday

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Sunday,

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, 1

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15

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5 December 2019.

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December 2019.

includes some questions that ask you to rate items on a scale and other

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includes some questions that ask you to rate items on a scale and other questions that ask you to write about your views

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questions that ask you to write about your views

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pecific strategies and ideas that are outlined in the consultation paper

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pecific strategies and ideas that are outlined in the consultation paperdesigned to enable you to submit comments about each of the proposed strategies if

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designed to enable you to submit comments about each of the proposed strategies if

may take at least 45 minutes to complete, or longer if you provide

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may take at least 45 minutes to complete, or longer if you provide comments on specific strategies.

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comments on specific strategies.

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only take approximately 20 minutes to complete. The shorter survey is for me

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only take approximately 20 minutes to complete. The shorter survey is for meof the public.RTI R

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If you wish, you can complete the survey in stages. On the bottom right of each page of the survey, there is an option to supply an email address to save your progress. A unique link will be emailed to you that will allow you to return where you left off. Email addresses entered for this purpose are not saved with your responses to the survey. Please note that, depending on which email service you use, these emails can take up to a few hours to come through to your inbox. This survey is being conducted in accordance with the Privacy Act 1988. You can access The Social Deck’s research privacy policy here. Support to help you complete the survey If you have difficulty understanding the survey and need a translator or interpreter, please call the Translating and Interpreting Services (TIS National) on 131 450 and ask them to contact The Social Deck on 0491 617 118. The National Relay Service (NRS) is a service for people who are deaf, hard of hearing and/or have a speech impairment. If you need help contacting us, the NRS can assist. To contact the NRS visit https://www.communications.gov.au/what-we-do/phone/services-people-disability/accesshub/national-relay-service or call the following numbers: • TTY — 133 677 • Speak and Listen — 1300 555 727 • SMS relay — 0423 677 767 If any of the questions or content in the survey/s cause you distress, you can end the survey at any time. If you or someone you know is in crisis or feeling distressed and needs support, call Lifeline on 13 11 14 or Beyond Blue on 1300 224 636. The Butterfly Foundation supports anyone concerned by an eating disorder or body image issues on 1800 334 673. If you have any questions or concerns about the survey, please email [email protected] How will responses be used? Findings from the survey will be collated and included in a report to inform the development of a national obesity strategy. You will be required to consent to having information published or used publicly. If you are an organisation completing this survey, you will be required to provide the name of your organisation and your responses may be attributed to your

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please call the Translating and Interpreting Services (TIS National) on 131 450 and

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vice for people who are deaf, hard of hearing

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vice for people who are deaf, hard of hearing have a speech impairment. If you need help contacting us, the NRS can assist.

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have a speech impairment. If you need help contacting us, the NRS can assist. To contact the NRS visit https://www.communications.gov.au/what

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To contact the NRS visit https://www.communications.gov.au/whatdisability/accesshub/national

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disability/accesshub/national

—

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—

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1300 555 727

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1300 555 7270423 677 767

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0423 677 767

If any of the questions or content in the survey/s cause you distress, you can end the

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If any of the questions or content in the survey/s cause you distress, you can end the survey at any time. If you or someone you know

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survey at any time. If you or someone you know support, call Lifeline on 13 11 14 or Beyond Blue on 1300 224 636. The

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support, call Lifeline on 13 11 14 or Beyond Blue on 1300 224 636. The Butterfly Foundation supports anyone concerned by an eating disorder or body RTI R

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organisation. A list of organisations who completed the survey may be published online and in the consultation report. Organisations will also be required to provide a contact name and email address so that we can contact them about this consultation if required. Names and email addresses will not be published or shared with any third parties. Thank you for completing the survey. Consent to participate in this survey. By participating in this survey, you indicate that:

• You have read the above information; • Your participation in this survey is voluntary; • You consent to your responses being included in public reports; and • You are at least 14 years of age.

Q1. Do you wish to continue with this survey?

1. Yes (skip to Q2) 2. No (if you select no, you will be exited from the survey)

Q2. Are you completing this survey on behalf of an organisation or as an interested individual?

1. On behalf of an organisation 2. As an interested individual

Q3. What is your organisation’s main role or interest in a national obesity strategy? You may select all that apply.

1. We are a health or medical organisation 2. We are a research organisation 3. We are an education institution 4. We are a government organisation 5. We are a business that sells and/or markets food/drinks/produce 6. We are an organisation that represents businesses that sell and/or

market food/drinks/produce 7. We are a health/fitness/sport/wellness organisation 8. We represent a particular population group 9. Other (please specify)

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You consent to your responses being included in public reports;

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You consent to your responses being included in public reports;

Do you wish to continue with this survey?

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Do you wish to continue with this survey?

No (if you select no, you will

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No (if you select no, you will be exited from

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be exited from

Are you completing this survey on behalf of an organisation or as an interested

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Are you completing this survey on behalf of an organisation or as an interested

On behalf of an organisation

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As an interested individual

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What is your RTI Rele

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Q4. What is your main role or interest in a national obesity strategy? You may select all that apply.

1. I am a health professional 2. I am an academic or researcher 3. I am employed by federal, state or territory, or local government 4. I am a business owner 5. I work in a health promotion organisation 6. I work for a business that sells and/or markets food/drinks/produce 7. I work for an organisation that represents businesses that sell and/or

market food/drinks/produce 8. I work in the health/fitness/sport/wellness industry 9. I am a teacher/educator 10. I am an interested member of the community 11. Prefer not to say 12. Other (please specify)

Q5. Many people and organisations have a diverse range of views on what should be included in a national obesity strategy. To ensure transparency throughout the consultation process, it is important to consider these views in the context of any relevant interests. As you are answering this survey on behalf of an organisation, please provide the name of your organisation in the space below. This information is required. Australian Beverages Council Q6. Please provide a contact name and email address for your organisation so that we may contact you about this consultation process if required. Your contact details will only be used for the purpose of this consultation and will not be shared with any third parties. Once again, this information is required. Name: Email We are now going to ask you a series of questions about the proposed framework and ideas that could be included in a national obesity strategy. These are outlined in more detail in the consultation paper.

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member of the community

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member of the community

Many people and organisations have a diverse range of views on what should

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Many people and organisations have a diverse range of views on what should l obesity strategy. To ensure transparency throughout the

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l obesity strategy. To ensure transparency throughout the important to consider these views in the context of any

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important to consider these views in the context of any

answering this survey on behalf of an organisation, please provide the

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answering this survey on behalf of an organisation, please provide the organisation in the space below.

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organisation in the space below.

Australian Beverag

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Australian Beverag

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es Council

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es Council

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Please provide a contact we may contact you about this consultation process if required. RTI R

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we may contact you about this consultation process if required. will RTI R

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The framework and ideas have been informed by the following sources: • Senate Select Committee Inquiry into the Obesity Epidemic in Australia

(2018); • National Obesity Summit (February 2019); • Two commissioned evidence reports (Population-level strategies to support

healthy weight and Addressing the social and commercial determinants of healthy weight); and

• A practice review of state and territory, international, global and consensus strategies and statements.

Section 1. Proposed timeframe and scope for a national obesity strategy Q7. Timeframe of a national obesity strategy It is proposed that a national obesity strategy will guide action over the next 10 years – from 2020 to 2030. Do you think this timeframe is too short, about right, or too long?

1. Too short 2. About right 3. Too long 4. I’m not sure

Q8. Timeframe of a national obesity strategy Why do you think the proposed timeframe of 10 years is (pipe response from previous question)?

The Australian Beverages Council supports the proposed timeframe of 10 years based on the following five key points: 1. It is an appropriate timeframe to allow for effective consultation with

multiple stakeholders to develop a meaningful and measurable strategy with appropriate governance structures;

2. Overweight and obesity is a highly complex, multi-causal issue requiring a comprehensive, systemic program of multiple interventions to be effective which takes considerable time;

3. The timeframe allows for time to engage with and address the needs of the many culturally and linguistically diverse communities in Australia with targeted programs;

4. A multi-government (federal, state and local) and multi-department approach in conjunction with NFP and private sectors will require considerable coordination, capital, human resources and time;

5. Capital funding arrangements will need to be sought and this may be lengthy and/or subject to budgetary constraints; and

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previous question)?The Australian Beverages Council supports the proposed timeframe of 10

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6. The implementation of any recommended changes for food and beverage industry, retailers and food service will require adequate transition periods.

The Australian Beverages Council supports the periodic review of long-term orientated strategies, such as the National Obesity Strategy. For example, the Australian Beverages Council has been involved with other long-term strategies, including the successful Health Star Rating system and the Healthy Food Partnership. In overseas jurisdictions, it is commonplace for industry, government and non-government organisations to collaboratively work on multi-year strategies. Case Study: Health Star Rating In this example, the Health Star Rating system has been the subject of periodic and ongoing review, and multiple stakeholders have provided detailed submissions and feedback in the review of the progress of implementation after two years (27 June 2014 to 26 June 2016) and most recently in the formal review of the system after five years of implementation (June 2014 to June 2019). In addition to the formal review process, the Health Star Rating system is governed by a number of formal structures and is ultimately the responsibility of the Australia and New Zealand Ministerial Forum on Food Regulation [Forum]. The Health Star Rating system is governed by the Front-of-Pack Labelling Steering Committee and the Health Star Rating Advisory Committee [HSRAC]. The activity of the Front-of-Pack Labelling Steering Committee was absorbed into the Food Regulation Standing Committee [FRSC] in November 2015 and work related to the system continues under the FRSC. The work of the HSRAC oversees the implementation and evaluation of the Health Star Rating system and includes the assessment of anomalies related to the system’s calculator and emerging products. Importantly, Members of the HSRAC are from the New Zealand government, Australian state and territory governments, as well as representatives from industry, public health and consumer groups. The HSRAC adheres to detailed Terms of Reference which includes a detailed role and purpose, including the provision of regular reports to the FRSC on: 1. timing, scope and processes for external reviews and on implementing recommendations arising from reviews; 2. budget needs and allocation of resources; 3. appointments to any sub-committees of the Advisory Committee; and

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(June 2014 to June 2019).

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responsibility of the Australia and New Zealand Ministerial Forum oThe Health Star Rating system is governed by the Front

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work related to the system continues under the FRSC.

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4. other matters related to the operation of the HSR System, including its administration. Case Study: Healthy Food Partnership The Australian Beverages Council has also been significantly involved in the oversight of the Healthy Food Partnership and its various working groups. The governance structure for the Healthy Food Partnership comprises an Executive Committee, five working groups and where required industry roundtables. The Healthy Food Partnership is based on the following key areas: Portion Size – promote and communicate appropriate portion sizes, and consumption of portion sizes that align with the Australian Dietary Guidelines. Encourage more appropriate packaging of products to align with consumption, to encourage purchase and minimise wastage. Communication and education – focus on whole foods and total diet. Work to explain the Australian Dietary Guidelines and how to eat a balanced diet encompassing all five food groups. Develop a long term strategy for education which recognises different behavioural, nutritional and information needs of the population. Reformulation – work with industry and key stakeholders to make targeted manufactured foods healthier by building on existing strategies such as the Health Star Rating system and optimising the appropriate balance of nutrients and ingredients in food. The Australian Beverages Council actively participates in these working groups, particularly the Implementation Monitoring and Evaluation Reference Group [IMERG]. In relation to the National Obesity Strategy, the Australia Beverages Council supports governance and review structures that are similar in nature to the Health Star Rating system and Healthy Food Partnership, particularly those that include opportunities for collaboration and partnership across stakeholder groups (NGOs, industry, government and academia). The Australian Beverages Council would welcome opportunities to co-create and partake in formal governance structures, such as committees and working groups, and act as a conduit between the broader non-alcoholic beverage industry and the formal oversight structure.

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the following key areas

promote and communicate appropriate portion sizes, and

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consumption, to encourage purchase and minimise wastage.

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consumption, to encourage purchase and minimise wastage.

focus on whole foods and total diet. Work

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focus on whole foods and total diet. Work to explain the Australian Dietary Guidelines and how

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to explain the Australian Dietary Guidelines and how encompassing all five food groups. Develop a long term strategy for

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encompassing all five food groups. Develop a long term strategy for education which recognises different behavioural, nutritional and

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education which recognises different behavioural, nutritional and information needs of the population.

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information needs of the population.

work with industry and key stakeholders to ma

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work with industry and key stakeholders to mamanufactured foods healthier by building on existing strategies such as the

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manufactured foods healthier by building on existing strategies such as the Health Star Rating system and optimising the appropriate balance of

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Health Star Rating system and optimising the appropriate balance of

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nutrients and ingredients in food.

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nutrients and ingredients in food.

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Q9. The proposed scope of a national obesity strategy Page 9 of the consultation paper outlines the proposed scope of a national obesity strategy. This includes:

Government leadership for a whole-of-society response - The strategy will be a unifying framework, to enable genuine partnerships, improved collaboration and shared responsibility. It will identify strategies for Commonwealth and State and Territory governments, as well as the community and other key stakeholders including, non-government organisations and the private sector. Prevention is the focus – The strategy will focus on primary and secondary preventive actions that promote and support healthy eating, regular physical activity and a healthy weight for all. Prevention actions benefit everyone, by helping to make the healthy option the easiest option. This includes actions to address environmental and social influences.

Outside the scope of a national obesity strategy are: • Actions to manage and address underweight; and • Tertiary prevention actions (e.g., treatment of obesity and/or obesity-

related complications). To what extent do you agree or disagree with each of the following components in the proposed scope for a national obesity strategy?

Strongly disagree

Somewhat disagree

Neither agree nor disagree

Somewhat agree

Strongly agree

I’m not sure

The strategy should encourage government leadership for collaborative, whole-of-society action.

☐ ☐ ☐ ☐ ☒ ☐

The strategy should identify actions for Commonwealth and State and Territory governments. ☐ ☐ ☐ ☐ ☒ ☐

The strategy should identify actions that will involve non- ☐ ☐ ☐ ☐ ☒ ☐

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option the easiest option. This includes actions

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to address environmental and social influences.


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address underweight; andrtiary prevention actions

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rtiary prevention actions (e.g., treatment of obesity

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(e.g., treatment of obesity

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related complications).

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related complications).

do you agree or disagree with each of the following components in

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government organisations and other community stakeholders.

The strategy should identify actions that will involve the private sector.

☐ ☐ ☐ ☐ ☒ ☐

The strategy should focus on primary and secondary preventive actions that promote and support healthy eating, regular physical activity and a healthy weight for all.

☐ ☐ ☐ ☐ ☒ ☐

The strategy should not focus on tertiary prevention actions to treat overweight and obesity.

☐ ☐ ☐ ☒ ☐ ☐

The strategy should not focus on actions to manage and address underweight.

☐ ☐ ☐ ☐ ☒ ☐

Q10. Thinking specifically about the proposed scope for a national obesity strategy, is there anything you would change, add or remove? Please provide your suggestions about the proposed scope in the space below. Please note there are many opportunities to comment on specific strategies and ideas proposed to be included in the strategy throughout the survey. The Australian Beverages Council recommends the next phase of the development of the National Obesity Strategy should focus on clear measurable goals to provide a framework for the recommended strategies in a meaningful, measurable way. Underpinning the National Obesity Strategy should be the reduction of overweight and obesity, prevention of overweight and obesity, and greater nutritional understanding. There are a number of ways to measure a reduction in overweight and obesity while reinforcing strong nutritional literacy, including:

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1. Reduction in BMI; 2. Reduction in high BMIs among certain at-risk groups 3. Reduction in the incidence of chronic disease; 4. Greater diet quality as measured by longitudinal dietary records; 5. Consumer awareness of balanced, nutritious diets; 6. Greater awareness of balanced, nutritious diets among at-risk groups; and 7. Ongoing improvement in diet quality and risk factors for those monitored in

clinical settings. Currently, the goal of the strategy is unclear, beyond to ‘reduce overweight and obesity’. The Australian Beverages Council recommends careful consideration of the feasibility of this goal within the context of the following outlined in the Consultation Paper: “the number of adults living with obesity has doubled in the last 10 years”. A more realistic goal of the strategy might be, “To prevent any further increase in adults living with obesity”. In addition, the development of specific goals for higher risk communities, such as those living in areas of high disadvantage or communities that have high Cultural and Linguistically [CALD] backgrounds, may be beneficial to ensure the strategies and actions are targeted to address the needs of specific groups. As the current Consultation Paper does not include clearly defined goals, it is difficult to comment on specific strategies with confidence. The Australian Beverages Council supports the development of committees or special interest working groups to oversee the creation of specific strategies that target vulnerable or ‘at-risk’ groups. Important comment about the nature of the long-form survey: The nature of the long-form survey presents some challenges in responding to the complex issue of overweight and obesity. The Australian Beverages Council understands that: 1. The ratings of strategies and sub-strategies in the long form survey allow the reviewer to see which strategies are most important and least important to respondents. 2. The ratings give additional context to the comments provided and will not be interpreted in isolation. 3. The rating scales also help the reviewer to dissect the details of the consultation paper, beyond feedback comments. 4. The ratings will be used to split the analysis of the comments provided. For example, the reviewer can split the ideas and comments by those who rated a strategy as more important and those who rated it as less important.

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actions are targeted to address the needs of specific groups

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ion Paper does not include

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supports the development of committees or special interest working groups to oversee the creation of speci

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oversee the creation of specific strategies that target vulnerable or ‘at

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fic strategies that target vulnerable or ‘at

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form survey presents some challenges in responding to the complex issue of overweight and obesity. The

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Given the broad nature of some of the strategies/ideas contained in the consultation paper, it is challenging to accurately reflect a position and it is imperative that all comments be considered as qualifying remarks to the respective positions expressed in the ratings boxes. In the next sections we will ask you a series of questions related to each of the components of the proposed framework for action:

• Five proposed principles that will guide development and implementation of a national obesity strategy.

• Four proposed priority areas and the specific strategies included under each of these priority areas.

• Four proposed enablers that will help support sustained implementation of a national obesity strategy.

Figure 1. Proposed framework for a national obesity strategy Section 2. Proposed principles to guide a national obesity strategy Q11. The proposed guiding principles for a national obesity strategy

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We are interested in what you think of the five proposed guiding principles for a national obesity strategy. They are described in detail on pages 11 and 12 of the consultation paper. Please rate how important you think each of the following proposed principles are for guiding the development and implementation of a national obesity strategy.

Not at all important

Slightly important

Moderately important

Very important

Extremely important

I’m not sure

People First - the strategy is person-centred, meaning it recognises the unique situations, experiences and strengths of individuals

☐ ☐ ☐ ☐ ☒ ☐

Equity - the strategy will promote equity, acknowledging some people and groups need additional supports to achieve good health

☐ ☐ ☐ ☒ ☐ ☐

Collective and Sustained Action - the strategy will promote partnerships and ongoing shared commitment from government and other key stakeholders

☐ ☐ ☐ ☐ ☒ ☐

Evidence-Based - the strategy will be informed by up-to-date evidence and promising or emerging strategies

☐ ☐ ☐ ☐ ☒ ☐

Sustainable Development - the strategy will align with the pillars of sustainable development: economic growth, social equity and environmental protection.

☐ ☒ ☐ ☐ ☐ ☐

Q12. The proposed guiding principles for a national obesity strategy

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ongoing s

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Thinking about the five proposed guiding principles, is there anything you would change, add or remove? Please provide your comments in the space below. The Australian Beverages Council supports the first four proposed guiding principles since overweight and obesity is a highly complex, multi-causal issue and requires a comprehensive, systemic program of multiple interventions to be effective. The following is recommended with specific reference to each Principle: Principle 3: The Australian Beverages Council supports the principle of working collaboratively in meaningful partnerships and notes the term “other key stakeholders”. It is recommended that the food and beverage industry be included in these partnerships as a key stakeholder to ensure the principle of collective and sustained action is met. Principle 4: The Australian Beverages Council supports the strategy being informed by up-to-date evidence but rejects the consideration of ‘promising or emerging strategies’ given the high risk of unintended consequences of unproven, untested strategies. Only the most credible, highest quality evidence should inform the strategy, taking into account the totality of the evidence base. Principle 5: The Australian Beverages Council strongly rejects the inclusion of economic or environmental policy in the National Obesity Strategy. Given the complexity of obesity reduction, there is risk of failure in developing a strategy with a broad scope. In assessing the overarching goal of the strategy to prevent the increase in overweight and obesity, and ultimately aiming to reduce those who are already overweight or obese, it is recommended that the scope of the strategy focuses on Principles 1- 4. Section 3. Proposed priority areas and strategies for a national obesity strategy The proposed priority areas and strategies for a national obesity strategy We are now going to ask you about the four proposed priority areas for a national obesity strategy. The proposed areas are:

1. Supporting children and families – starting early to support healthy weight throughout life

2. Mobilising people and communities – using knowledge, strengths and community connections to enable healthy weight

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date evidence but rejects the consideration of ‘promising or emerging

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k of unintended consequences of unproven, untested strategies. Only the most credible, highest quality ev

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strategies. Only the most credible, highest quality evidence should inform the

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idence should inform the strategy, taking into account the totality of the evidence base.

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strategy, taking into account the totality of the evidence base.

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3. Enabling active living – supporting a way of life that helps people move more throughout the day

4. Building a healthier and resilient food system – producing and promoting healthier food and drinks with little impact on the environment

We are interested in what you think of the strategies included under each priority area. You can answer questions relating to all four of these priority areas, or just chose the areas that interest you most.

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Q13. Proposed Priority 1: Supporting children and families – starting early to support healthy weight throughout life For this priority area, there are three proposed strategies, each containing a number of ideas to guide action. These are discussed in detail on pages 14 to 16 of the consultation paper. The first proposed strategy for this priority area is: Support prospective and new parents to be healthier at the time of conception and during pregnancy, and to optimise the healthy development of their children during the first 1000 days. Please rate the extent to which you think each of the following proposed ideas is important for guiding action under this strategy. You can use the comment boxes to provide any feedback you might have about each idea. Remember that you can rate and comment on all of the ideas, or you can skip to the next section if you do not want to provide feedback on a particular area.


Slightly important


Very important

Extremely important

I’m not sure

Provide healthy eating and drinking support and physical activity support for pre-conception and during pregnancy, including specific approaches for prospective parents who are, or at risk of becoming, overweight or obese during pregnancy

☐ ☐ ☐ ☐ ☐ ☐

Provide support for mothers to breastfeed and continue to breastfeed by implementing the

☐ ☐ ☐ ☐ ☐ ☐

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under this strategy.

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use the comment boxes to provide any feedback you might have about each

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if you do not want to provide fee

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National Breastfeeding Strategy

Explore policy options to strengthen protection of infants and families from excess availability and marketing of breast milk substitutes

☐ ☐ ☐ ☐ ☐ ☐

Strengthen healthy eating and physical activity guidance and support for mothers and fathers after birth as they transition and adjust to their new roles as parents

☐ ☐ ☐ ☐ ☐ ☐

Provide guidance to parents, carers and families on appropriate healthy eating and physical activity for infants (e.g., appropriate introduction of solids, responsive feeding, portion size, screen time, motor skill development)

☐ ☐ ☐ ☐ ☐ ☐

Q14. Proposed Priority 1: Supporting children and families – starting early to support healthy weight throughout life The second proposed strategy for this priority area is: Enable parents, carers and families to encourage lifelong healthy habits for children and young people. Please rate the extent to which you think each of the following proposed ideas is important for guiding action under this strategy. You can use the comment boxes in the online survey to provide any feedback you might have about each idea.

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☐ ☐ ☐ ☐ ☐ ☐

Support parents, carers and families to purchase, prepare and enjoy healthy food and drinks, whilst limiting unhealthy food and drinks.

☐ ☐ ☐ ☐ ☐ ☐

Encourage parents, carers and families of children and young people to use parks and recreation facilities, role model active transport and active living, be active with children (co-participation) and restrict screen time

☐ ☐ ☐ ☐ ☐ ☐

Develop fun peer and community activities that enable adolescents to engage in physical activity, including a focus on the role of fathers

☐ ☐ ☐ ☐ ☐ ☐

Encourage greater availability of healthy food and drinks, whilst also limiting unhealthy food and drinks, at sporting, recreation and community venues, facilities, clubs and events.

☐ ☐ ☒ ☐ ☐ ☐

Increase availability of, and equitable access to, appropriate programs that support weight management for children, young people and their families

☐ ☐ ☐ ☐ ☐ ☐

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FOR COMMENT: SECOND PROPOSED STRATEGY: The Australian Beverages Council recognises the importance of early education of children about healthy lifestyles and diet. The non-alcoholic beverage industry welcomes the opportunity to collaborate on the development of education programs, particularly in relation to the role of core and discretionary beverages in children’s diets, including flavoured milk and fruit juice with ‘no added sugar’. At present, there is significant confusion about the role of these nutritious beverages in children’s diets which requires clarity and practical advice commensurate with the Australian Dietary Guidelines. The Australian Beverages Council believes important education on good nutrition, regular sport or physical activity and recreation should be available to all children, regardless of socio-economic status, as a mandatory part of the school curriculum. IDEA 4: While the Australian Beverages Council supports the need to encourage greater availability of healthy food and drinks, and limiting unhealthy food and drinks, at sporting, recreation and community venues, facilities, clubs and events, it is important that the venues provide choice (meaning, a range of different types of food and beverages available to meet all needs, including some sugar-sweetened beverages). Case Study: Advertising on Queensland Government spaces The Queensland Government’s advertising policy on government spaces refers to the ‘National interim guide to reduce children’s exposure to unhealthy food and drink promotion’, which was endorsed by COAG Health Council in 2018. It is important to note that no sugar drinks were not explicitly included in the categories not recommended for promotion. The COAG Health Council document references these products as varying ‘per application and, is therefore optional; to be decided by each jurisdiction, depending on the setting and proposed use of the guide in that setting.’ The Australian Beverages Council strongly rejects the classification of no sugar beverages as products that are ‘not recommended for promotion’ or that these products are in any way ‘unhealthy’. Scientific evidence tabled to Food Standards Australia New Zealand [FSANZ] recently substantiates sweeteners used in a broad range of foods and drinks as safe and suitable for consumption by an array of consumers, including those seeking to reduce their intake of sugar from beverages. This supports the industry’s efforts to reduce sugar, as part of the sugar reduction pledge, and encourage healthier lifestyles.

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meaning, food and beverages available to meet all needs

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food and beverages available to meet all needs, including some sugar

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, including some sugar

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ional interim guide to reduce children’s exposure to unhealthy food and drink , which was endorsed by COAG Health Council

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, which was endorsed by COAG Health Council

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The consumption of no sugar beverages also supports the World Health Organisation’s sugar intake recommendations for less than ten per cent of daily energy to come from free (added) sugars. The Australian Beverages Council would suggest replacing ‘unhealthy’, with ‘less healthy’, as a more accurate descriptor. In assessing ‘less healthy’ products, it is crucial that consumer education underpins any change in policy while recognising that many sports and entertainment venues provide social opportunities for individuals and families, many of whom frequent these settings on occasion. As such, it is appropriate that consumers are offered a broad array of foods and drinks that reflect a social setting, including the availability of sugar-sweetened beverages. The creation of national criteria for “healthy” and “less healthy” food and drinks is strongly recommended, as there is inconsistency across Australian jurisdictions. The Health Star Rating system would be the most appropriate system to use as: 1) studies consistently show that the System is well aligned with Dietary Guidelines and effectively directs consumers towards foods lower in energy, saturated fats, sugars and sodium. 2) The recommended agreed improvements to the HSR System will ensure even better alignment with Dietary Guidelines e.g. increase the HSRs of certain Five Food Group (FFG) products (including certain fruits, vegetables and dairy products) and re-categorise certain discretionary foods (such as jellies and ice confections) to decrease their HSRs. 3) The proposed changes will also more effectively guide consumers on healthier choices within the non-dairy beverage category; and 4) Members of the Australian Beverages Council have agreed to support greater uptake of the Health Star Rating on the front-of-pack to meet the government’s 70 per cent coverage target. 15. Proposed Priority 1: Supporting children and families – starting early to support healthy weight throughout life The third proposed strategy for this priority area is: Enable early childhood education and care settings and schools to adopt whole of facility approaches that better support children to develop healthy eating and physical activity habits and skills. Please rate the extent to which you think each of the following proposed ideas is important for guiding action under this strategy. You can use the comment boxes in the online survey to provide any feedback you might have about each idea.

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strongly recommended, as there is inconsistency across Australian jurisdictions.

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dairy beverage category; and Members of the Australian

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Members of the Australian Beverages Council have agreed to support greater

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Beverages Council have agreed to support greater uptake of the Health Star Rating on the front

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uptake of the Health Star Rating on the frontper cent coverage target.

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per cent coverage target.

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Enhance leadership, professional knowledge, relevant policies and practices, curriculum design and delivery aligned with national guidelines, and partnerships within and beyond the early childhood education and care and school community

☐ ☐ ☐ ☐ ☐ ☐

Establish partnerships to deliver programs where necessary (e.g., healthy breakfast programs, healthy school canteens and childcare menus, active play programs)

☐ ☐ ☐ ☐ ☐ ☐

Enable after-hours use of school facilities to expand available, accessible and affordable physical activity options and destinations for families and communities

☐ ☐ ☐ ☐ ☐ ☐

Support safe, active travel to and from early childhood education and care settings and schools through infrastructure and behaviour change programs in collaboration with local communities

☐ ☐ ☐ ☐ ☐ ☐

Investigate policy and community-led options to extend student retention in schools across the Australian compulsory education period, including focused strategies for Aboriginal and Torres Strait Islander children and children from other priority groups

☐ ☐ ☐ ☐ ☐ ☐

Q16.

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accessible and affordable physical

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accessible and affordable physical activity options and destinations

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for families and communities

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Proposed Priority 1: Supporting children and families – starting early to support healthy weight throughout life Thinking about the strategies you just read for supporting children and families, are there any additional strategies or you think should be included to start early to support healthy weight throughout life? Please provide your comments in the space below. The three proposed strategies are listed again below if you need to re-read these. Proposed strategies:

• Support prospective and new parents to be healthier at the time of conception and during pregnancy, and to optimise the healthy development of their children during the first 1000 days.

• Enable parents, carers and families to encourage lifelong healthy habits for

children and young people.

• Enable early childhood education and care settings and schools to adopt whole of facility approaches that better support children to develop healthy eating and physical activity habits and skills.

Q17. Proposed Priority 2: Mobilising people and communities – using knowledge, strengths and community connections to enable healthy weight For this priority area, there are five proposed strategies, each containing a number of ideas to guide action. These are discussed in detail on pages 17 to 19 of the consultation paper. The first proposed strategy for this priority area is: Improve people’s knowledge, awareness and skills to enable healthy eating, facilitate active lives and foster healthy social and cultural norms, regardless of their weight. Please rate the extent to which you think each of the following proposed ideas is important for guiding action under this strategy. You can use the comment boxes in the online survey to provide any feedback you might have about each idea.

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of their children during the first 1000 days.

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of their children during the first 1000 days.

Enable parents, carers and families to encourage lifelong healthy ha

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Enable parents, carers and families to encourage lifelong healthy ha

y childhood education and care settings and schools to adopt

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y childhood education and care settings and schools to adopt whole of facility approaches that better support children to develop healthy

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whole of facility approaches that better support children to develop healthy eating and physical activity habits and skills.

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eating and physical activity habits and skills.

Proposed Priority 2: Mobilising people and communities

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Proposed Priority 2: Mobilising people and communitiesstrengths and community connections to enable healthy weight

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strengths and community connections to enable healthy weight

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Provide information, education and skill-building programs and initiatives aligned with Australian guidelines for healthy eating, physical activity and sedentary behaviour

☐ ☐ ☐ ☐ ☐ ☐

Develop and fund ongoing national mass media campaigns to shift expectations, beliefs and social norms, whilst minimising weight-related stigma

☐ ☐ ☐ ☐ ☐ ☐

Partner with Aboriginal and Torres Strait Islander people to develop and deliver culturally appropriate and safe social marketing and supporting programs

☐ ☐ ☐ ☐ ☐ ☐

Partner with culturally and linguistically diverse (CALD) groups to develop and deliver culturally appropriate and safe support programs for early migrants

☐ ☐ ☐ ☐ ☐ ☐

Partner with people with disability to develop and deliver initiatives to improve healthy eating and physical activity that are accessible and responsive

☐ ☐ ☐ ☐ ☐ ☐

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linguistically diverse (CALD)

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linguistically diverse (CALD) groups to develop and deliver

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groups to develop and deliver culturally appropriate and safe

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culturally appropriate and safe support programs fo

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Q18. Proposed Priority 2: Mobilising people and communities – using knowledge, strengths and community connections to enable healthy weight The second proposed strategy for this priority area is: Engage and support local communities, groups and organisations to develop and lead their own healthy eating and physical activity initiatives through responding to local need, embedding participation and building community capacity. Please rate the extent to which you think each of the following proposed ideas is important for guiding action under this strategy. You can use the comment boxes in the online survey to provide any feedback you might have about each idea.


Slightly important


Very important

Extremely important

I’m not sure

Invest in targeted community capacity building initiatives that activate leadership, drive innovation and support a collective impact approach to create health promoting community places and spaces

☐ ☐ ☐ ☐ ☐ ☐

Identify a diverse range of local leaders to ‘champion’ place-based healthy eating and physical activity initiatives and develop a supportive nationwide network and learning community

☐ ☐ ☐ ☐ ☐ ☐

Ensure local communities have access to health promoting sponsorship options for events and sport, and are empowered and informed to consider the impact of unhealthy sponsorship choices

☐ ☐ ☐ ☐ ☐ ☐

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collective impact approach to

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collective impact approach to promoting

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promoting community places and spaces

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community places and spaces

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Q19. Proposed Priority 2: Mobilising people and communities – using knowledge, strengths and community connections to enable healthy weight The third proposed strategy for this priority area is: Support all people who are at risk of becoming overweight to access effective weight management interventions without fear of judgement. Please rate the extent to which you think each of the following proposed ideas is important for guiding action under this strategy. You can use the comment boxes in the online survey to provide any feedback you might have about each idea.


Slightly important


Very important

Extremely important

I’m not sure

Evidence-based weight management interventions, ensuring a range of delivery modes and accessibility for all, regardless of age, living location, cultural background and income

☐ ☐ ☐ ☐ ☐ ☐

Advocate for increased intensity of action for population groups experiencing higher levels of overweight and obesity, through effective co-designed behaviour change programs

☐ ☐ ☐ ☐ ☐ ☐

Support those experiencing weight stigma and discrimination and ensure all actions promote positive discussion of weight and prevent weight-related stigmatisation

☐ ☐ ☐ ☐ ☐ ☐

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modes and accessibility for all, regardless of age, living loc

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regardless of age, living location,

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ation, cultural background and income

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cultural background and income

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Q20. Proposed Priority 2: Mobilising people and communities – using knowledge, strengths and community connections to enable healthy weight The fourth proposed strategy for this priority area is: Support health and social services to prioritise the prevention of obesity-related chronic disease. Please rate the extent to which you think each of the following proposed ideas is important for guiding action under this strategy. You can use the comment boxes in the online survey to provide any feedback you might have about each idea.


Slightly important


Very important

Extremely important

I’m not sure

Support better collaboration between sectors dealing with unemployment, social protection and health

☐ ☐ ☐ ☐ ☐ ☐

Develop labour and social policies that provide secure and decent work for all

☐ ☐ ☐ ☐ ☐ ☐

Raise incomes of the poorest groups to reflect the real cost of healthy living and increase access to improved living conditions and opportunities for healthy behaviours

☐ ☐ ☐ ☐ ☐ ☐

Provide professional development for clinicians to support the improvement of healthy eating and physical activity behaviours in their patient/clients

☐ ☐ ☐ ☐ ☐ ☐

Enable early identification of unhealthy weight gain (including modest weight gain) for patients/clients, with a focus on life course transition points often associated with weight gain and

☐ ☐ ☐ ☐ ☐ ☐

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people from at-risk population groups

Increase the availability of, and clarity of referral pathways to, evidence-based weight management treatments (including community-led programs)

☐ ☐ ☐ ☐ ☐ ☐

Q21. Proposed Priority 2: Mobilising people and communities – using knowledge, strengths and community connections to enable healthy weight The fifth proposed strategy for this priority area is: Enable and support workplaces, healthcare facilities and tertiary institutions to lead by example by creating health promoting places of excellence. Please rate the extent to which you think each of the following proposed ideas is important for guiding action under this strategy. You can use the comment boxes in the online survey to provide any feedback you might have about each idea.


Slightly important


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Extremely important

I’m not sure

Adopt best-practice breastfeeding policies and practices (e.g., workplace facilities, maternity leave, flexible work times to allow for breastfeeding)

☐ ☐ ☐ ☐ ☐ ☐

Adopt policies and practices that promote and prioritise physical activity, increase access to healthy food and drinks, and limit access to, or remove unhealthy food and drinks through catering, vending machines, cafes and canteens

☐ ☐ ☒ ☐ ☐ ☐

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Design buildings that support and encourage healthy behaviours (e.g., stairs, kitchen facilities, end-of-trip facilities, storage, standing desks)

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Create physical environments, policies and programs that incentivise and support active travel to work

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Offer flexible work options to reduce travel time, freeing up time for meal planning/preparation and physical activity

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Offer or facilitate access to multi-component, non-discriminatory programs and information to support healthy eating, physical activity and healthy weight

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Q22. Proposed Priority 2: Mobilising people and communities – using knowledge, strengths and community connections to enable healthy weight Thinking about the strategies you just read for mobilising people and communities, are there any additional strategies you think should be included to mobilise people and communities to use knowledge, strengths and community connections to enable healthy weight? Please provide your comments in the space below. The five proposed strategies are listed again below if you need to re-read these. IDEA TWO: While the Australian Beverages Council supports the need for workplaces to “adopt policies and practices that promote and prioritise physical activity, increase access to healthy food and drinks, and limit access to... unhealthy food and drinks through catering, vending machines, cafes and canteens”, the recommendation to “remove unhealthy foods and drinks” is not supported. The Australian Beverages Council reiterates its preference for the term ‘less healthy’ as opposed to ‘unhealthy’. The Australian Beverages Council supports broad consumer choice and sustained behavioural change towards healthier options through actions including providing more low-sugar and no-sugar drinks in vending machines, a greater proportion of low- and no- sugar products on shelf and in targeted promotions. Many Members of the Australian Beverages Council have changed vending machine stock to comprise more low- and no-sugar drinks, including many vending machines that are exclusively stocked with bottled water. Moves toward stocking more low- and no-sugar products and vending machines with exclusively or largely bottled water support healthier lifestyles and are commensurate with the Australian Dietary Guidelines. The National Obesity Strategy must recognise, however, that vending machines are a key channel offering convenience to consumers. Accordingly, vending machines are stocked according to the appropriateness of the setting. For example, vending machines in stadia, sports settings, fitness centres and gyms are likely to be stocked with a higher proportion of electrolyte drinks and water products while those in shopping centres will stock a range of sugar-sweetened, non-sugar sweetened and unsweetened products. The creation of national criteria for “healthy” and “less healthy” food and drinks is strongly recommended, as there is inconsistency across Australian jurisdictions. The Health Star Rating system would be the most appropriate system to use as:

1) studies consistently show that the System is well aligned with Dietary Guidelines and effectively directs consumers towards foods lower in energy, saturated fats, sugars and sodium.

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at are exclusively stocked with bottled water. sugar products and vend

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ing machines with exclusively or largely bottled water support healthier lifestyles and are commensurate with the Australian Dietary

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water support healthier lifestyles and are commensurate with the Australian Dietary Guidelines.

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2) The recommended agreed improvements to the HSR System will ensure even better alignment with Dietary Guidelines e.g. increase the HSRs of certain Five Food Group (FFG) products (including certain fruits, vegetables and dairy products) and re-categorise certain discretionary foods (such as jellies and ice confections) to decrease their HSRs.

3) The proposed changes will also more effectively guide consumers on healthier choices within the non-dairy beverage category; and

4) Members of the Australian Beverages Council have agreed to support greater uptake of the Health Star Rating on the front-of-pack to meet the government’s 70 per cent coverage target.

Case study: Amsterdam’s healthy-weight programme In 2013, one in four to five children in Amsterdam were found to have overweight or obesity. To tackle this problem, the Council and Health Department of Amsterdam set out to develop a long-term approach that reaches into every domain of a child’s life. Council members awarded the programme with unanimous approval and a sizeable, structural budget, reaching as far as 2033, when children of the first ‘healthy generation’ will celebrate their 18th birthday. 1

Amsterdam views a healthy life for children not just as a responsibility of the parents, but as a responsibility shared by everyone who plays a part in the life of children, be it close by like neighbours and teachers, or from afar like policy makers and the food industry. The programme has steadily been working on building a coalition of partners, all working in their own domain on this issue, sending out the same message: healthy behaviour is normal behaviour. Three simple lifestyle rules form the basis of this message: Healthy food and drink, exercise, and sleep. Key actions of Amsterdam’s healthy-weight programme include:2

• Making primary schools healthier places; • Ensuring cycle routes are made safer; • Arranging after-school activities for children; • Subsidisation of sports club membership for low income families; and • Working with supermarkets and local food suppliers to: modify menus and

reduce portion sizes; manage stock better; create healthier checkout environments; use traffic-light labelling posters.

From 2012 to 2015, the number of overweight and obese children has dropped by 12%. Of particular note, Amsterdam has realised the biggest fall in overweight and obesity among the lowest socio-economic groups. Case Study: Community Support in the United States In a number of communities in the United States, the American Beverage Association has partnered with local leaders to enact real change across the community. These

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life. Council members awarded the programme with unanimous approval and a

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sizeable, structural budget, reaching as far as 2033, when children of the f

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is normal behaviour. Three simple lifestyle rules form the basismessage: Healthy food and drink, exercise, and sleep.

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diverse initiatives include collaborating with mayors and public health groups on community health initiatives, creating jobs and driving environmental programs. East Los Angeles: In 2015, beverage companies began working with supermarkets, convenience stores, restaurants and local partners in communities in eastern Los Angeles. The initiative is part of the Balance Calories Initiative, a partnership with the Alliance for a Healthier Generation, to reduce beverage calories consumed per person 20% by 2025 across the nation.3 Specifically, the initiative focusses on the Boyle Heights, Lincoln Heights, El Sereno and East LA neighbourhoods. Efforts behind building more balanced communities in East Los Angeles include:

• working with retailers to display and offer reduced-calorie/kilojoule beverages;

• offering in-store samples and other incentives to try new beverages; • partnering with community organisations to educate families about this new

initiative; • education to increase calorie awareness.

Similar initiatives have been developed in: New York City (South Bronx and the Brooklyn neighbourhoods of Stuyvesant and Crown Heights); Greater Montgomery; Little Rock; and the Mississippi Delta (Coahoma County, Panola County, Quitman County and Tunica County). The Australian Beverage Council would welcome an opportunity to collaborate with governments on developing specific, community-based initiatives for populations at risk of poor diets and less healthy lifestyles. Proposed strategies:

• Improve people’s knowledge, awareness and skills to enable healthy eating, facilitate active lives and foster healthy social and cultural norms, regardless of people’s weight.

• Engage and support local communities, groups and organisations to develop

and lead their own healthy eating and physical activity initiatives through responding to local need, embedding participation and building community capacity.

• Support all people who are at risk of becoming overweight to access effective

weight management interventions without fear of judgement.

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education to increase calorie awareness.

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Little Rock; and the Mississippi Delta (Coahoma County, Panola County, Quitman County and Tunica County).

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(Coahoma County, Panola County, Quitman County and Tunica County).

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• Support health and social services to prioritise the prevention of obesity-related chronic disease.

• Enable and support workplaces, healthcare facilities and tertiary institutions

to lead by example by creating health promoting places of excellence.

1Gemeente Amsterdam (2019). Amsterdam Healthy Weight Programme. Available at: https://www.amsterdam.nl/sociaaldomein/blijven-wij-gezond/amsterdam-healthy/ Last accessed: 11 December 2019 2 Obesity Policy Research Unit (2017). What can be learned from the Amsterdam Healthy Weight Programme to inform the policy response to obesity in England? Available at: https://www.ucl.ac.uk/obesity-policy-research-unit/sites/obesity-policy-research-unit/files/what-learned-from-amsterdam-healthy-weight-programme-inform-policy-response-obesity-england.pdf Last Accessed 11 December 2019 3 American Beverage Association. East Los Angeles. Available at: https://www.balanceus.org/community-support/balance-la/ Last accessed 11 December 2019

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Q23. Proposed Priority 3: Enabling active living – supporting a way of life that helps people move more throughout the day For this priority area, there are two proposed strategies, each containing a number of ideas for guiding action. These are discussed in detail on pages 20 and 21 of the consultation paper. The first proposed strategy for this priority area is: Invest in connected active places and spaces in urban, regional and rural areas. Please rate the extent to which you think each of the following proposed ideas is important for guiding action under this strategy. You can use the comment boxes in the online survey to provide any feedback you might have about each idea.


Slightly important


Very important

Extremely important

I’m not sure

Develop and maintain infrastructure that grows participation in sport, active recreation, walking, cycling and public transport use to encourage individuals and families to be active together

☐ ☐ ☐ ☐ ☐ ☐

Create a culture that promotes active travel through safe walking networks, drinking water stations and pedestrian prioritisation; cycling networks with reduced crash risk; storage and end-of-trip facilities; and efficient, accessible and regular public transport systems with strong connectivity and after-hours service

☐ ☐ ☐ ☐ ☐ ☐

Apply integrated urban (and regional) design and transport policy, regulations and guidelines to create built environments that

☐ ☐ ☐ ☐ ☐ ☐

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prioritise active living for people of all ages and abilities

Conserve and develop open spaces, green networks, recreation trails and ecologically diverse natural environments that enable active interaction with nature

☐ ☐ ☐ ☐ ☐ ☐

Make communities safe with people-friendly spaces that favour people over motorised transport, and crime prevention strategies, such as community policing techniques, peer-led outreach programs and lighting

☐ ☐ ☐ ☐ ☐ ☐

Ensure strategic infrastructure policies and plans prioritise investment in public transport, walking and cycling infrastructure

Consider fiscal policies to reduce driving and increase active travel and the availability and quality of recreation and sport facilities and opportunities

☐ ☐ ☐ ☐ ☐ ☐

Q24. Proposed Priority 3: Enabling active living – supporting a way of life that helps people move more throughout the day The second proposed strategy for this priority area is: Motivate and inspire participation in regular physical activity by people of all ages and abilities. Please rate the extent to which you think each of the following proposed ideas is important for guiding action under this strategy. You can use the comment boxes in the online survey to provide any feedback you might have about each idea.

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Slightly important


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Provide a range of fun, local and social active living options that match the interests of various ages and abilities, engage local communities and organisations, and build social cohesion

☐ ☐ ☐ ☐ ☐ ☐

Partner with Aboriginal and Torres Strait Islander people, people living in regional and remote areas, people with disability, and people experiencing disadvantage, to develop targeted interventions that increase the availability, accessibility and affordability of physical activity opportunities and reduce barriers to active living

☐ ☐ ☐ ☐ ☐ ☐

Support regular participation initiatives in public spaces that engage large portions of the community (e.g., fun runs)

☐ ☐ ☐ ☐ ☐ ☐

Offer free or low-cost access to encourage use of public transport, walking and cycling infrastructure, recreation opportunities, natural environments, sports and active living programs (e.g., subsidies, public liability insurance scheme for cyclists, rental equipment, participation incentives, and after-hours use of public and school sport and recreation facilities)

☐ ☐ ☐ ☐ ☐ ☐

Build physical literacy and promote community-based active events using sustained, evidence-based social marketing

☐ ☐ ☐ ☐ ☐ ☐

COMMENT: SECOND PROPOSED STRATEGY: Motivate and inspire participation in regular physical activity by people of all ages and abilities.

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The Australian Beverages Council supports the need for the National Obesity Strategy to focus on both healthy eating as well as active living. The cause of overweight and obesity is multifactorial, and therefore the National Obesity Strategy must focus on a range of levers including the food environment, physical activity and other environmental, behavioural and psychosocial factors. Q25. Proposed Priority 3: Enabling active living – supporting a way of life that helps people move more throughout the day Thinking about the specific strategies you just read for enabling active living, are there any additional strategies you think should be included to support a way of life that helps people move more throughout the day? Please provide your comments in the space below. The two proposed strategies are listed again below if you need to re-read these. Proposed strategies:

• Invest in connected active places and spaces in urban, regional and rural areas.

• Motivate and inspire participation in regular physical activity by people of all

ages and abilities.

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Invest in connected active

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ages and abilities.



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Q26. Proposed Priority 4: Building a healthier and more resilient food system – producing and promoting healthier food and drinks with little impact on the environment For this priority area, there are seven proposed strategies, each containing a number of ideas to guide action. These are discussed in detail on pages 22 to 25 of the consultation paper. Remember that you can rate and comment on all of the strategies, or you can skip to the next strategy if you do not want to provide feedback on a particular area. The first proposed strategy for this priority area is: Ensure our food system favours the production, processing and manufacture of healthy and sustainable products. Please rate the extent to which you think each of the following proposed ideas is important for guiding action under this strategy. You can use the comment boxes in the online survey to provide any feedback you might have about each idea.


Slightly important


Very important

Extremely important

I’m not sure

Ensure planning and management policies for land and sea use safeguard food system resilience and productivity

☒ ☐ ☐ ☐ ☐ ☐

Develop innovative solutions to efficiently use natural resources, maximise biodiversity, minimise wastage, enable business growth and address climate change

☒ ☐ ☐ ☐ ☐ ☐

Ensure economic policies make production and manufacturing of healthy foods and drinks, such as fresh fruit and vegetables, attractive

☐ ☒ ☐ ☐ ☐ ☐

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uiding action under this strategy.

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policies for land and sea use

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use safeguard food system resilience

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safeguard food system resilience and productivity

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Comment: FIRST PROPOSED STRATEGY: The Australian Beverages Council does not support the proposed strategy, particularly: “Ensure our food system favours the production, processing and manufacture of healthy and sustainable products” in so far as it focuses on “sustainable products” within a National Obesity Strategy. Importantly, the Australian Beverages Council does not support the inclusion of Sustainability in the National Obesity strategy for the following reasons:

1. Not evidence based. Sustainability has been included in this strategy despite the Evidence Check (commissioned to inform the national obesity strategy) not evaluating the effectiveness of such interventions. 1 On closer review of the Evidence Check, it appears that the research cited to support the inclusion of sustainability in the National Obesity Strategy is one published paper which proposes the framework put forward by the Lancet Commission into the Global Syndemic of Obesity, Undernutrition and Climate Change. 2 While this framework is a proposed way of tackling obesity by linking it to climate change, there is no evidence for the effectiveness of such a framework.

2. No place in obesity policy. Globally and locally, national obesity strategies do

not include sustainability in their remit, nor do international authorities such as the OECD recommend including sustainability in obesity policy. 3 4 Evidence-based strategies have been identified in key global reports including: ▪ The McKinsey Global Institute in the UK which analysed a wide range

of interventions to tackle obesity and found that portion control, reformulation, parental education and weight management programs were some of the most effective policy measures. 5

▪ OECD, Heavy Burden of Obesity: The Economics of Prevention. This recently released report identified communication-based approaches such as regulation of advertising, food labelling, menu labelling and mass media campaigns as the most economically effective policy measures, as well as reformulation to achieve a 20% calorie reduction in energy-dense foods and drinks. The OECD report recognises that strategies to reduce obesity may have cross-sectoral effects, for example on climate change, however creating truly synergetic policies is challenging, requiring extensive stakeholder input from across sectors.

3. Relevant to a national food and nutrition policy. The issue of sustainable

food systems is more relevant in a National Nutrition Policy than a National Obesity Strategy, as recommended in the recent Australian Academy of Science’s decadal plan. 6 The Plan calls for: “a policy or plan based on robust evidence that … would provide a framework for sustainable population health improvement initiatives” that would be “based on real-world experience and

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put forward

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of Obesity, Undernutrition and Climate Change

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ile this framework is a proposed way of tacklin

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ile this framework is a proposed way of tackling obesity by linking it to

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g obesity by linking it to climate change, there is no evidence for the effectiveness of such a

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climate change, there is no evidence for the effectiveness of such a

Globally and locally

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ability in their remit, nor do international au

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as the OECD recommend including sustainability in obesity policy

based strategies have been identified in key global reports

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based strategies have been identified in key global reports

The McKinsey Global Institute

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reformulation, parental education and weight management programs were some of the most effective policy measures

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were some of the most effective policy measures▪

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robust evidence, together with monitoring, benchmarking and assessment of population-level health and welfare, nutrition equity, environmental sustainability and productivity “. Furthermore, the Plan acknowledges the need for significant research to identify sustainable diets that maximise nutritional outcomes yet require considerable changes in current production and commercial practices, management of resources and the food system as well as consumer education.

For clarity, the Australian Beverages Council supports Sustainability initiatives and partnerships with other stakeholders to:

1) Increase the availability and use of recycled material in beverage containers via Container Deposit Schemes;

2) Encourage responsible water stewardship across Australia and the South Pacific;

3) Reduce secondary and tertiary packaging across the supply chain; 4) Encourage the use of sustainably-sourced ingredients where possible.

While Sustainability is an important consideration for the non-alcoholic beverage industry, it is most appropriately handled in an environmental strategy in conjunction with support from the Department of Foreign Affairs and Trade, Department of Agriculture and Department of Industry, Innovation and Science. Sustainability policies exist at the Commonwealth and State/Territory levels and via initiatives developed by private enterprise, such as increasing the level of recycled PET in containers to 100 per cent for many product lines and the sustainable sourcing of sugar and water across the industry.

1 Sacks G, Looi E, Cameron A, Backholer K, Strugnell C et al (2019). Population-level strategies to support healthy weight: an Evidence Check rapid review brokered by the Sax Institute (www.saxinstitute.org.au) for Queensland Health. 2 Swinburn, Boyd A., et al (2019). "The global syndemic of obesity, undernutrition, and climate change: The Lancet Commission report." The Lancet 393.10173: 791-846. 3 HM Government (2016). Childhood Obesity: A plan for action. 4 OECD (2019). Heavy Burden of Obesity. The Economics of Prevention 5 McKinsey Global Institute (2014). Overcoming obesity: an initial economic analysis 6 Australian Academy of Science (2019). Nourishing Australia: A decadal plan for the science of nutrition

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kaging across the supply chain;

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sourced ingredients where possible.

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alcoholic beverage industry, it is most appropriately handled in an environmental strategy

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industry, it is most appropriately handled in an environmental strategyconjunction with support from the Department of Foreign Affairs and Trade,

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conjunction with support from the Department of Foreign Affairs and Trade, Department of Agriculture and Department of Industry, Innovation and Science

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Department of Agriculture and Department of Industry, Innovation and Science

ustainability policies exist at the Commonwealth and State/Territory levels and via

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ustainability policies exist at the Commonwealth and State/Territory levels and via developed by private enterprise, such as increasing the level of recycled

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developed by private enterprise, such as increasing the level of recycled PET in containers to 100 per cent for

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PET in containers to 100 per cent for many

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many product lines and the sustainable

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product lines and the sustainable of sugar and water across the industry.

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of sugar and water across the industry.

G, Looi E, Cameron A, Backholer K, Strugnell C et al

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G, Looi E, Cameron A, Backholer K, Strugnell C et alhealthy weight: an Evidence Check rapid review brokered by the Sax Institute (

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healthy weight: an Evidence Check rapid review brokered by the Sax Institute (

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Swinburn, Boyd A., et al (2019). "The global syndemic of obesity, undernutrition, and climate change: The

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Swinburn, Boyd A., et al (2019). "The global syndemic of obesity, undernutrition, and climate change: The

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Lancet Commission report."

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Lancet Commission report." The Lancet

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Q27. Proposed Priority 4: Building a healthier and more resilient food system – producing and promoting healthier food and drinks with little impact on the environment The second proposed strategy for this priority area is: Increase the availability of healthy, more sustainable food and drinks in the places we live and work. Please rate the extent to which you think each of the following proposed ideas is important for guiding action under this strategy. You can use the comment boxes in the online survey to provide any feedback you might have about each idea.


Slightly important


Very important

Extremely important

I’m not sure

Create easier access to healthy food and drinks in local residential communities through:

• urban agriculture (e.g., community garden initiatives and encouraging home gardens);

• urban design (e.g., density of fast food outlets and proximity to schools and community services; access to supermarkets and smaller food businesses); and

• other local community actions (e.g., local food markets, healthy food supply at community events)

☐ ☐ ☐ ☐ ☐ ☐

Encourage land use planning policies that protect high-quality agricultural land on the urban fringe and ensure that planning decisions achieve the policy intent

☐ ☐ ☐ ☐ ☐ ☐

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importantModerately

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food and drinks in local residential

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food and drinks in local residential

urban agriculture (e.g.,

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urban agriculture (e.g., community garden

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community garden itiatives and encouraging

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itiatives and encouraging home gardens);

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home gardens); urban design (e.g., density

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urban design (e.g., density of fast food outlets and

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of fast food outlets and proximity to schools and

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proximity to schools and community services;

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Establish policies on food and drink procurement, catering, and provision across all government departments and settings to encourage healthy eating and drinking

☐ ☐ ☐ ☒ ☐ ☐

Comment: SECOND PROPOSED STRATEGY: The Australian Beverages Council supports the need to “Increase the availability of healthy, more sustainable food and drinks in the places we live and work”. It’s important to note that food and drink choice for consumers has never been greater as there is a wide range of food and drinks available in the food supply, facilitated by a multicultural society. To help consumers navigate this vast and changing food supply, it is recommended that targeted communications to improve consumer understanding of what constitutes a balanced nutritious diet, incorporating novel foods and drinks and ready-to-eat meals, be considered. IDEA THREE: The Australian Beverages Council supports the need for one consistent national policy on the procurement of foods and drinks across government departments and in state-enterprise and institutions, including hospitals, schools and health care centres. Presently, food and drink guidelines vary by jurisdiction and can create considerable confusion among purchasing/procurement managers, Members, and consumers. In school settings, after school care and other environments in which the primary consumers of foods and drinks are children, the Australian Beverages Council advocates for juice (no added sugar) and flavoured milk to be provided by the caregiver in recognition of the positive nutritional profiles of these products. Case study: Flavoured water range A Member of the Australian Beverages Council launched a flavoured water range for children with no sugar, sweeteners or preservatives in late 2018. At the time of launch, there was considerable inconsistency in how the product met the Healthy Food & Drink Criteria in the following States & Territories: Schools: Green (ACT, NSW and VIC), Amber (TAS), Red (NT, QLD, SA) Health services: Green (ACT, NSW, VIC, TAS, QLD), Amber (NT and SA). As stated in the response to Q22, the Australian Beverages Council recommends consideration of the adoption of the Health Star Rating for development of policies that will include clear consistent guidelines on foods and drinks that qualify for “healthy eating and drinking”. If the recommended and approved changes to the HSR are applied to the example above, the beverage would be defined as “unsweetened flavoured waters” with an HSR of 4.5 stars and would qualify as a healthier choice in all jurisdictions.

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consumers has never been greater as there is a wide range of food and drinks y a multicultural society

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recommend

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improve consumer understanding of what constitutes a balanced

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and ready

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: The Australian Beverages Council supports the need for one consistent

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: The Australian Beverages Council supports the need for one consistent national policy on the procurement of foods and drinks across government

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national policy on the procurement of foods and drinks across government enterprise and institutions, incl

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enterprise and institutions, including hospitals, schools

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uding hospitals, schools

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Presently, food and drink guidelines vary by jurisdiction and can create considerable

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Presently, food and drink guidelines vary by jurisdiction and can create considerable confusion among purchasing/procurement managers, Members, and consumer

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confusion among purchasing/procurement managers, Members, and consumer

In school settings, after school care and oth

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In school settings, after school care and othconsumers of foods and drinks are children, the Australian Beverages Council

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consumers of foods and drinks are children, the Australian Beverages Council advocates for juice (no added sugar) and flavoured milk to be provided by the

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advocates for juice (no added sugar) and flavoured milk to be provided by the caregiver in recogn

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caregiver in recogn

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ition of the positive nutritional profiles of

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ition of the positive nutritional profiles of

Case study: Flavoured water range

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To avoid confusion, the Australian Beverages Council strongly recommends greater consideration be given to defining the use of ‘healthy’ or ‘unhealthy’ food and drinks. Although the Australian Dietary Guidelines provide advice on ‘core’ and ‘discretionary’ foods, they do not provide specific information on many packaged products. Additionally, the Australian Dietary Guidelines are not updated sufficiently frequently to reflect changes in the food supply, such as innovative new foods and drinks, including Kombucha, sports water, ready-to-eat snacks and meals. For packaged foods and drinks, a national adoption of the Health Star Rating algorithm as outlined in comments, Q22, is recommended. Q28. Proposed Priority 4: Building a healthier and more resilient food system – producing and promoting healthier food and drinks with little impact on the environment The third proposed strategy for this priority area is: Make processed food and drinks healthier and more sustainable by limiting energy and nutrients of concern. Please rate the extent to which you think each of the following proposed ideas is important for guiding action under this strategy. You can use the comment boxes in the online survey to provide any feedback you might have about each idea.


Slightly important


Very important

Extremely important

I’m not sure

Work in partnership with industry to establish and monitor reformulation targets for food and drink manufacturers, retailers and caterers

☐ ☐ ☐ ☐ ☒ ☐

Develop national targets to reduce serving sizes of unhealthy food and drinks in food service and retail settings, particularly for food and drink items designed for children

☐ ☐ ☒ ☐ ☐ ☐

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oducing and promoting healthier food and drinks with little impact on the

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The third proposed strategy for this priority area is:

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and more sustainable by limiting energy

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and more sustainable by limiting energy

e rate the extent to which you think each of the following proposed ideas is

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e rate the extent to which you think each of the following proposed ideas is important for guiding action under this strategy.

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important for guiding action under this strategy.

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Explore setting compositional limits for nutrients of concern (e.g., sodium, saturated fat, added sugar and/or energy content) across a range of food and drink types

☒ ☐ ☐ ☐ ☐ ☐

Reduce food waste during manufacturing and processing and eliminate unnecessary packaging

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COMMENTS: THIRD PROPOSED STRATEGY: The Australian Beverage Council partially supports the third proposed strategy in relation to “Make processed food and drinks healthier... by limiting energy and nutrients of concern”, but strongly rejects the inclusion of “more sustainable” in the statement. Limiting energy (kJ) and nutrients of concern in processed foods and drinks will not necessarily make them more sustainable and focussing on Sustainability is unlikely to have an impact on obesity and overweight levels (please refer to comments under Q26). The Australian Beverages Council and its Members have specific sustainability policies in place that acknowledge a responsibility and commitment to the environment. The Australian Beverages Council supports Sustainability initiatives and partnerships with other stakeholders to:

1) Increase the availability and use of recycled material in beverage containers via Container Deposit Schemes;

2) Encourage responsible water stewardship across Australia; 3) Reduce secondary and tertiary packaging across the supply chain; 4) Encourage the use of sustainably-sourced ingredients where possible.

While Sustainability is an important consideration for the non-alcoholic beverage industry, it is most appropriately handled in an environmental strategy. Sustainability policies exist at the Commonwealth and State/Territory levels and via initiatives developed by private enterprise, such as increasing the level of recycled PET in containers to 100 per cent for most product lines and the sustainable sources of sugar and water across the drinks industry. The Australian Beverages Council strongly recommends the focus of the National Obesity Strategy be limited to high impact and cost-effective interventions. The Australian Beverages Council acknowledges the importance of the beverage industry’s contribution to the third proposed strategy, “to make processed foods and drinks healthier...”, and the industry has effective initiatives in place to reduce our contribution to energy and sugar intakes.

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but strongly rejects the inclusion

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ent. Limiting energy (kJ) and nutrients of concern in

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processed foods and drinks will not necessarily make them more sustainable and

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focussing on Sustainability is unlikely to have an impact on obesity and overweight

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focussing on Sustainability is unlikely to have an impact on obesity and overweight

The Australian Beverages Council and its Members have specific sustainability

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policies in place that acknowledge a responsibility and commitment to the

The Australian Beverages Council supports Sustai

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The Australian Beverages Council supports Sustaiwith other stakeholders to:

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with other stakeholders to:

Increase the availability and use of recycled material in beverage containers

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Increase the availability and use of recycled material in beverage containers via Container Deposit Schemes;

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via Container Deposit Schemes;

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Encourage responsible water stewardship across Australia;

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Encourage responsible water stewardship across Australia;Reduce secondary and t

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Reduce secondary and tEncourage the use of sustainably

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Encourage the use of sustainably

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Case Study: Sugar Reduction Pledge The Sugar Reduction Pledge, is an industry commitment to reduce sugar across the industry by 10 per cent by 2020 and 20 per cent by 2025. The first independent progress report of the Pledge was released in November 2019 and covers the period 2015-2018. The progress report identified a seven per cent reduction in sugar across the period. The report’s findings are encouraging and demonstrate the effectiveness of actions being taken by signatories to the pledge, including product reformulation (reducing sugar and energy content of existing products), smaller pack sizes, product innovation (creating great tasting new lower or no sugar drinks) and innovative marketing to drive behaviour change towards no- and low-sugar options. These proactive actions are shifting behaviour and will continue to reduce sugar and energy (kJ) content across the industry. The Sugar Reduction Pledge will be reviewed each year with both a 2020 and 2025 target. The Australian Beverages Council is also committed to establishing a second tier of the Sugar Reduction Pledge, specifically for those Members that are unable to sign up to the 20 per cent reduction, but that wish to commit to a range of other initiatives in support of the Pledge’s overarching objective to help people choose a drink with less, low or no sugar as a way to supporting a healthy lifestyle. Supporter Members that become a part of the second tier may, in time, transition from the second to the first tier of the initiative and become a Signatory Member. Participating in the Supporter Tier is a clear and identifiable example of a Member taking a proactive role by, for example, providing more choice for people, while continuing to provide great tasting and refreshing drinks. Supporter Members will undertake a range of measurable activities, which will be subject to rigorous and regular review. As with the other tier, Supporter Members will use a variety of levers or instruments to demonstrate their support for the intent of the Sugar Reduction Pledge, including:

• Reformulating existing products; • Increasing the volume sales of low and no sugar varieties; • Introducing additional low and no sugar varieties into the market by 2020

and 2025; • Encouraging sales through the promotion and marketing of low or no sugar

varieties; • Introducing smaller pack sizes or reducing average container sizes;

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sugar and energy content of existing products), smaller pack sizes, product

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sugar and energy content of existing products), smaller pack sizes, product innovation (creating great tasting new lower or no sugar drinks) and innovative

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sugar

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e shifting behaviour and will continue to reduce sugar and

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The Sugar Reduction Pledge will be reviewed each year with both a 2020 and 2025

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The Sugar Reduction Pledge will be reviewed each year with both a 2020 and 2025

cil is also committed to

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cil is also committed to establishing a second tier of

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establishing a second tier of the Sugar Reduction Pledge, specifically for those Members that are unable to sign

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the Sugar Reduction Pledge, specifically for those Members that are unable to sign up to the 20 per cent reduction, but that wish to commit to a range of other

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up to the 20 per cent reduction, but that wish to commit to a range of other initiatives in support of the Pledge’s ov

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initiatives in support of the Pledge’s ov

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erarching objective to he

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erarching objective to hedrink with less, low or no sugar as a way to supporting a healthy lifestyle.

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drink with less, low or no sugar as a way to supporting a healthy lifestyle.

Supporter Members that become a part of the second tier may, in time, transition

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Supporter Members that become a part of the second tier may, in time, transition from the second to the first tier of the initiative a

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from the second to the first tier of the initiative a

Participating in the Supporter Tier is a clear and identifiable example of a Member

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Participating in the Supporter Tier is a clear and identifiable example of a Member taking a proactive role by, for example, providing more choice for people, while

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taking a proactive role by, for example, providing more choice for people, while

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continuing to provide great tasting and refreshing drinks.

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continuing to provide great tasting and refreshing drinks.

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• Promoting consumption of bottled water by young Australians and only milk and water for the very young;

• A cap in sugar content on all existing drinks brands; • A cap in sugar on new recipes launched in Australia; • Investing in improved nutritional literacy; and • Transition vending machines to include more low, or no, sugar varieties

(where practical). Supporter Members will not be required to report on average reductions in total grams of sugar per 100mL or meet the 20 per cent target by 2025 that Signatory Members are subject to. Further information about the Sugar Reduction Pledge can be found at www.australianbeverages.org/pledge Case Study: Healthy Food Partnership The first three of the recommended ideas for the third proposed strategy, are currently being implemented through the work of the Healthy Food Partnership (HFP). A public-private partnership, the HFP is designed to cooperatively reduce obesity and encourage healthy eating, including strategies to educate consumers on consuming fresh produce, appropriate portion sizes, and to accelerate efforts to reformulate food to make it healthier. The Australian Beverages Council and its Members fully support the work of the HFP as outlined below: 1. Meeting product reformulation targets. For example, several Members have reformulated some of the nation’s favourite drinks to make them lower in kilojoules and sugar including reformulation of more than 30 recipes since 2015. 2. Educating consumers on appropriate portion and serve sizes. The Australian Beverages Council has worked with its Members over a number of years to introduce smaller pack sizes across the industry to support other initiatives that encourage healthy lifestyles and balanced diets. Smaller pack sizes, particularly in the sugar-sweetened beverage category, promote balanced diets and recognise that these beverages can be consumed in moderation as a discretionary food item. It is also important to note the wide variety of beverages in child-appropriate portion sizes are available on the market – a move by the industry as it has recognised the need to encourage portion control.

Furthermore, both the beverage and confectionery industry voluntarily introduced serve size guidelines. For example, our members have introduced new serves-per- pack labelling on our larger multi-serve bottles (e.g. 1.25L= 5 serves) to help better inform consumers on how many servings are in a bottle.

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Further information about the Sugar Reduction Pledge can be found at

The first three of the recommended ideas for the third proposed strategy, are

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The first three of the recommended ideas for the third proposed strategy, are currently being implemented through the work of the Healthy Food Partnership

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currently being implemented through the work of the Healthy Food Partnership te partnership, the HFP is designed to cooperatively reduce

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te partnership, the HFP is designed to cooperatively reduce obesity and encourage healthy eating, including strategies to educate consumers on

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consuming fresh produce, appropriate portion sizes, and to accelerate efforts to thier.

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thier.

The Australian Beverages Council and its Members fully support the work of the HFP

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The Australian Beverages Council and its Members fully support the work of the HFP

Meeting product reformulation targets.

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reformulated some of the nation’s favourite drinks to makand sugar including reformulation of more than 30 recipes since 2015.

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and sugar including reformulation of more than 30 recipes since 2015.

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3. Explore setting compositional limits for nutrients of concern. We do not believe that this is necessary for the non-alcoholic beverage category for the following reasons:

a. Sugar Reduction Pledge by the Australian non-alcoholic beverage industry (Ref:

2018 Aggregation Report, October 2019). The Pledge is in effect, driving compositional change for the two nutrients of concern – energy (kJ) and sugar. As stated, there has been a 7% reduction in sugar per 100mL (2015 to 2018). The graph below illustrates the industry’s performance on a yearly basis (2015 – 2018), aggregated for the average sugar content (g/100mL) for all beverage categories as well as the remaining reduction required by the pledge signatories to achieve a 20% reduction by 2025.

b. Nutrition Guidelines to drive reformulation and new product development. Many Members have introduced nutrition guidelines which in turn, reduce ‘nutrients of concern’ and align with the principles of the Industry Sugar Reduction Pledge. For example, a Member has strict Nutrition Guidelines for the Australian market, focussing on seven key areas that include energy (kJ), sugar (≤ 7.9g sugar per 100mL (excluded 100% fruit juice) & ‘no added sugar’ – 100% Fruit Juice), total fat, saturated fat and caffeine. These are based on the Australian & New Zealand Dietary Guidelines as well as targets set by leading health authorities including the World Health Organisation guidelines on free sugars. They are reviewed annually and apply to new products and product reformulations.

c. Healthy Food Partnership The Healthy Food Partnership already addressing compositional limits continue to support industry to reformulate their foods, supported by the Health Star Rating system.

d. Administratively burdensome to implement

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Some stakeholders may advocate for the introduction of compositional limits of ‘risk nutrients’ on the basis of adopting a precautionary principle approach. Not only is this position redundant, as industry is already providing many new products that are low in risk nutrients or do not contain any at all, the cost incurred by government to administer a compositional mechanism would be high without realising any public health benefit.

IDEA FOUR: “Reduce food waste during manufacturing and processing and eliminate unnecessary packaging”. This idea, although important, is not relevant to a National Obesity Strategy and likely belongs in a National Food and Nutrition Policy.

It’s important to note that the Evidence Check commissioned to inform the National Obesity Strategy did not evaluate the effectiveness of interventions targeted at minimising food waste nor packaging on reducing obesity. 1 The Australian Beverages Council recommends the National Obesity Strategy ideas focus on interventions that will have high impact on obesity in a cost-effective way. Evidence-based strategies have been identified in key global reports including:

▪ The McKinsey Global Institute in the UK which analysed a wide range

of interventions to tackle obesity and found that portion control, reformulation, parental education and weight management programs were some of the most effective policy measures. 2

▪ OECD, The Heavy Burden of Obesity: The Economics of Prevention. 3 This recently released report identified communication-based approaches such as regulation of advertising, food labelling, menu labelling and mass media campaigns as the most economically effective policy measures, as well as reformulation to achieve a 20 per cent calorie reduction in energy-dense foods and drinks.

1 Sacks G, Looi E, Cameron A, Backholer K, Strugnell C et al (2019). Population-level strategies to support healthy weight: an Evidence Check rapid review brokered by the Sax Institute (www.saxinstitute.org.au) for Queensland Health. 2 McKinsey Global Institute (2014). Overcoming obesity: an initial economic analysis 3 OECD (2019). Heavy Burden of Obesity. The Economics of Prevention

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based strategies have been identified in key global reports including

e McKinsey Global Institute

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e McKinsey Global Institute in the UK which analysed a

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in the UK which analysed a of interventions to tackle obesity and found that portion control,

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of interventions to tackle obesity and found that portion control, reformulation, parental education and weight management programs

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reformulation, parental education and weight management programs were some of the most effective policy measures

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were some of the most effective policy measures

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he Heavy Burden of Obesity: The Economics of

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he Heavy Burden of Obesity: The Economics of recently released report identified communication

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recently released report identified communicationapproaches such as regulation of advertising, food labelling, menu

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approaches such as regulation of advertising, food labelling, menu labelling and mass media campaigns as the most economically effective

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labelling and mass media campaigns as the most economically effectivepolicy measures, as well as reformulation to

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policy measures, as well as reformulation tocalorie reduction in energy

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Q29. Proposed Priority 4: Building a healthier and more resilient food system – producing and promoting healthier food and drinks with little impact on the environment The fourth proposed strategy for this priority area is: Support targeted interventions that increase the availability, accessibility and affordability of healthy food and drinks for rural and remote communities, communities experiencing disadvantage and Aboriginal and Torres Strait Islander people. Please rate the extent to which you think each of the following proposed ideas is important for guiding action under this strategy. You can use the comment boxes in the online survey to provide any feedback you might have about each idea.


Slightly important


Very important

Extremely important

I’m not sure

Encourage good quality, culturally appropriate, healthy food availability and affordability in stores, workplaces and institutions in rural and remote communities

☐ ☐ ☐ ☐ ☐ ☐

Investigate partnership arrangements with large supermarkets to offset the price of healthier food and drinks in communities experiencing disadvantage and small remote stores

☐ ☐ ☐ ☐ ☐ ☐

Celebrate cultural knowledge and diversity by using a self-determination approach to find the best solutions for reducing common barriers to healthy food and drink access, selection and preparation

☐ ☐ ☐ ☐ ☐ ☐

Build on existing housing initiatives to improve community ☐ ☐ ☐ ☐ ☐ ☐

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Encourage good quality, culturally

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appropriate, healthy food affordability in

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affordability in stores, workplaces and

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stores, workplaces and institutions in rural and remote

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institutions in rural and remote

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and household food preparation and storage facilities

Q30. Proposed Priority 4: Building a healthier and more resilient food system – producing and promoting healthier food and drinks with little impact on the environment The fifth proposed strategy for this priority area is: Reduce exposure to unhealthy food and drink marketing and promotion. Please rate the extent to which you think each of the following proposed ideas is important for guiding action under this strategy. You can use the comment boxes in the online survey to provide any feedback you might have about each idea.


Slightly important


Very important

Extremely important

I’m not sure

Reduce unhealthy food and drink marketing on publicly-owned or managed settings (e.g., public transport infrastructure)

☐ ☒ ☐ ☐ ☐ ☐

Explore options to reduce unhealthy food and drink advertising prominence in places frequently visited by large numbers of people, especially children (e.g., vending machines, supermarket checkouts and aisles, entertainment venues)

☐ ☐ ☒ ☐ ☐ ☐

Explore options to reduce unhealthy food and drink sponsorship and marketing associated with sport and major community events

☐ ☒ ☐ ☐ ☐ ☐

Restrict unhealthy food and drink advertising during peak television viewing times for children

☐ ☐ ☐ ☒ ☐ ☐

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Reduce unhealthy food and drink

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managed settings (e.g., public transport infrastructure)

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transport infrastructure)

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reduce unhealthy food and drink

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Restrict promotions using devices that appeal to children (e.g. toys, games)

☐ ☐ ☐ ☒ ☐ ☐

Partner with relevant industry stakeholders to introduce user controls that can limit exposure to digital advertising of unhealthy food and drinks

☐ ☐ ☒ ☐ ☐ ☐

Comments: FIFTH PROPOSED STRATEGY: The Australian Beverages Council supports, “Reduce exposure to unhealthy food and drink marketing and promotion”, in so far as it aligns with current policy actions by the Australian Beverages Council and other allied industry associations. These policies are effectively reducing exposure to less healthy beverage choices, via marketing and advertising Codes set out by the Australian Association of National Advertisers (AANA), the Australian Beverages Council and the Australian Food & Grocery Council’s Responsible Children’s Marketing Initiative. The Australian Beverages Council understands that the World Health Organization Western Pacific Region, of which Australia is a member state, recently endorsed the Regional Action Framework on Protecting Children from the Harmful Impact of Food Marketing in the Western Pacific. The framework is centred on four pillars: strengthening policy frameworks, multi-sectoral and multi-stakeholder collaboration, advocacy and communication, and monitoring and evaluation. Members of the Australian Beverages Council support a robust self-regulatory approach to advertising and marketing in this market and it is important to note that the activities of Members are commensurate with the Framework, as the Non-alcoholic Beverage Industry Marketing and Advertising Standard and other self-regulatory codes contribute to its aims. Case Study: Non-alcoholic Beverage Industry Marketing and Advertising Standard The Australian Beverages Council recently updated it’s Non-alcoholic Beverage Industry Marketing and Advertising Standard. All Members of the Australian Beverages Council have committed to adhere to the Standard by ensuring that marketing and advertising communications, including digital communications are carried out in accordance with the Standard. Notably, Members have committed to promote the responsible consumption of all non-alcoholic beverages as part of a balanced diet and in support of the Australian Dietary Guidelines. The Standard includes commitments to:

▪ reflect responsible consumption of beverages, illustrating appropriate portion sizes for the beverage consumption occasion;

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exposure to unhealthy food and drink marketing and promotion”,

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with current policy actions by the Australian Beverages Council and other allied

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These policies are effectively reducing exposure

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C

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Codes set out by the Australian

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odes set out by the Australian , the Australian Beverages Council and the

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, the Australian Beverages Council and the Council’s Responsible Children’s Marketing Initiative.

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Council’s Responsible Children’s Marketing Initiative.

The Australian Beverages Council understands that the World Health Organization

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The Australian Beverages Council understands that the World Health Organization Western Pacific Region, of which Australia is a m

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Western Pacific Region, of which Australia is a member state, recently endorsed the

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ember state, recently endorsed the Regional Action Framework on Prot

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Regional Action Framework on Protecting Children from the Harmful Impact of Food

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ecting Children from the Harmful Impact of Food Marketing in the Western Pacific.

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Marketing in the Western Pacific. The framework is centred on four pillars:

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The framework is centred on four pillars: strengthening policy frameworks, multi

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strengthening policy frameworks, multi-

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-sectoral and multi

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sectoral and multicollaboration, advocacy and communication, and monitoring and

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collaboration, advocacy and communication, and monitoring and Members of the Australian Beverages Council support a robust self

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Members of the Australian Beverages Council support a robust selfapproach to advertising and marketing in this market and it is important to note that

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approach to advertising and marketing in this market and it is important to note that s of Members are commensurate with the Framework, as the

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s of Members are commensurate with the Framework, as the ic Beverage Industry Marketing and Advertising Standard

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ic Beverage Industry Marketing and Advertising Standardregulatory codes contribute to its aims.

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regulatory codes contribute to its aims.

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▪ not direct market or advertising of sugar-sweetened drinks at children aged 14 years and under or to primary schools, including not advertising sugar-sweetened drinks during children’s television programming

▪ encourage the consumption of bottled water, juice with no added sugar and flavoured milk for children and adolescents, where relevant.

Case Study: Promotion of water The Australasian Bottled Water Institute (ABWI), the dedicated bottled and packaged water division of the Australian Beverages Council, promotes the consumption of water as the beverage of choice for young Australians. The industry acknowledges water is the healthiest beverage available to consumers and recommends drinking plenty of water every day, reinforcing one of the Australian Dietary Guidelines, ‘drink plenty of water’. The industry encourages people to consume as much water as they need – from a tap, bubbler or bottle. The work of ABWI is contributing to increased water consumption in Australia, as the most commonly consumed non-dairy, non-alcoholic beverage is water, which includes spring water, purified water and mineral water. This is often packaged in plastic and glass bottles, but also boxes (with a bladder), pouches, cartons and cans. There has been considerable growth in bottled and packaged water in Australia as consumers embrace the convenience and health value while seeking beverages that contain no sugar at all. According to IBISWorld, the Bottled Water Manufacturing industry in Australia “is projected to grow modestly over the next five years” and “Rising health consciousness is also forecast to aid revenue, as consumers reduce their spending on soft drinks and shift towards healthy beverages such as bottled water.” 1 The Australian Beverages Council recommends any further actions related to marketing restrictions are based on evidence indicating the need for additional intervention. The effective self-regulatory model for advertising and marketing activity, overseen by the AANA, Australian Beverages Council and others, remain the most efficient and effective structure. AUSTRALIAN BEVERAGES COUNCIL RECOMMENDATION: We recommend advertising and marketing activity should not be the core focus of the National Obesity Strategy based on four key issues:

- the long-term commitment made by the non-alcoholic beverage industry under its revised Standard, which includes new media like digital and our commitment to advertise and market products in line with the Australian Dietary Guidelines;

- lack of causation between responsible advertising and harmful consumption, which means further restricting the advertising of certain products is highly unlikely to yield significant improvements in health outcomes but may lead to economic and societal costs in the advertising and marketing industry, and supporting sectors;

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ge is water, which includes spring water, purified water and mineral water. This is often packaged in

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includes spring water, purified water and mineral water. This is often packaged in lastic and glass bottles, but also boxes (with a bladder), pouches, cartons and cans.

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lastic and glass bottles, but also boxes (with a bladder), pouches, cartons and cans.

There has been considerable growth in bottled and packaged water

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There has been considerable growth in bottled and packaged water

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consumers embrace the convenience and health value while seeking beverages that

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consumers embrace the convenience and health value while seeking beverages that no sugar at all. According to IBISWorld, the Bottled Water Manufacturing

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no sugar at all. According to IBISWorld, the Bottled Water Manufacturing is projected to grow modestly over the next five years

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Rising health consciousness is also forecast to aid revenue, as consumers reduce soft drinks and shift towards healthy beverages such as bottled

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soft drinks and shift towards healthy beverages such as bottled

The Australian Beverages Council

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are based on evidence

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- lack of evidence on the effect of advertising on overconsumption of food and beverages which, if presented and on the weight of evidence, might present an evidence-driven basis for regulatory change. In short, evidence does not show a causal relationship between responsible advertising and harmful levels of consumption of food and beverages.

- positive changes in marketing of reduced-, low- or no-sugar products. Many Members of the Australian Beverages Council are harnessing their marketing capabilities to promote reduced and no sugar products and packs. For example, in 2018, 96% of one Member’s product marketing featured reduced or no-sugar products for a best-selling brand.

NOTE: As stated in comments related to Q22 & Q27, consistent national criteria for “unhealthy” vs “healthy” foods and drinks, based on the Health Star Rating system, should be developed as a priority. Case Study: Advertising on Queensland Government spaces The Australian Beverages Council does not support bans on marketing unhealthy food and drinks on publicly-owned or managed settings, such as the Queensland Government’s announcement of the phasing out of unhealthy marketing at more than 2,000 outdoor advertising spaces, including bus stops, train stations and road corridors. The Queensland Government’s advertising policy refers to the ‘National interim guide to reduce children’s exposure to unhealthy food and drink promotion’, which was endorsed by COAG Health Council in 2018. It is important to note that no sugar drinks were not explicitly included in the categories not recommended for promotion. The COAG Health Council document references these products as varying ‘per application and, is therefore optional; to be decided by each jurisdiction, depending on the setting and proposed use of the guide in that setting.’ The Australian Beverages Council strongly rejects the classification of no sugar beverages as products that are ‘not recommended for promotion’ or that these products are in any way ‘unhealthy’. Scientific evidence tabled to Food Standards Australia New Zealand [FSANZ] recently substantiates no sugar products as safe and suitable for consumption by a broad array of consumers, including those seeking to reduce their intake of sugar from beverages. The consumption of no sugar beverages also supports the World Health Organisation’s sugar intake recommendations for less than ten per cent of daily energy to come from free sugars. In assessing ‘unhealthy’ products, it is crucial that consumer education underpins any change in policy while recognising that many sports and entertainment venues provide social opportunities for individuals and families, many of whom frequent these settings on occasion. As such, it is appropriate that consumers are offered a

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“unhealthy” vs “healthy” foods and drinks, based on the Health Star Rating system,

overnment spaces

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The Australian Beverages Council does not support bans on marketing unhealthy owned or managed settings, such as the Queensland

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owned or managed settings, such as the Queensland nt of the phasing out of

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nt of the phasing out of unhealthy marketing at more

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unhealthy marketing at more ,000 outdoor advertising spaces, including bus stops, train stations and road

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,000 outdoor advertising spaces, including bus stops, train stations and road

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was endorsed by COAG Health Council in 2018. I

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in 2018. Idrinks were not explicitly included in the categories not recommended for

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drinks were not explicitly included in the categories not recommended for

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and, is therefore optional; to be decided by each jurisdiction, depending

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and, is therefore optional; to be decided by each jurisdiction, depending on the setting and proposed use of the guide in that setting.’

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on the setting and proposed use of the guide in that setting.’

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broad array of foods and drinks that reflect a social setting, including the availability of sugar-sweetened beverages.

1 IBISWorld (2019). Bottled Water Manufacturing in Australia.

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Q31. Proposed Priority 4: Building a healthier and more resilient food system – producing and promoting healthier food and drinks with little impact on the environment The sixth proposed strategy for this priority area is: Increase the availability and accessibility of information to support the consumer to make a healthier choice at the time of purchasing food or drinks. Please rate the extent to which you think each of the following proposed ideas is important for guiding action under this strategy. You can use the comment boxes in the online survey to provide any feedback you might have about each idea.


Slightly important


Very important

Extremely important

I’m not sure

Continue to strengthen the uptake of the Health Star Rating system towards universal implementation and continue to consider options for the ongoing enhancement of the system

☐ ☐ ☐ ☐ ☒ ☐

Introduce front of pack nutrition warning labels for nutrients of concern (e.g., added sugar, sodium, saturated fats, alcohol, high energy content) to complement the Health Star Rating system

☒ ☐ ☐ ☐ ☐ ☐

Support multi-component interventions to improve nutrition information and increase accessibility and prominence of healthier options in supermarkets

☐ ☐ ☒ ☐ ☐ ☐

Adopt consistent national regulation on menu energy (kilojoule) labelling in businesses that sell ready-to-eat-food

☐ ☐ ☐ ☐ ☒ ☐

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and continue to consider options

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ar, sodium, saturated fats,

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sodium, saturated fats, alcohol,

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alcohol, high energy content) to

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Consider adoption of sustainability indicators that provide clear consumer information on the environmental impacts of food and drink products

☒ ☐ ☐ ☐ ☐ ☐

COMMENTS: IDEA ONE: In relation to front-of-pack labelling, the Health Star Rating [HSR] system is performing well, with most Australian consumers viewing the HSR System as easy to understand and use. Most consumers have indicated the HSR makes it easier to decide which packaged foods are healthier. As stated in the HSR Five Year Review Report, 23 per cent of surveyed Australian consumers were influenced by the HSR to change their purchasing behaviour and purchase a product with more stars. 1 Importantly, the HSR System is also encouraging positive reformulation of foods and drinks. An Australian study found that products displaying the HSR had made significant reductions in energy and saturated fat over the four years since the System was introduced, compared to those not displaying the HSR. With adoption of the recommended changes from the Review and additional consumer awareness campaigns, the Australian Beverages Council anticipates increased, positive consumer awareness and influence on purchasing behaviour. IDEA TWO: The Australian Beverages strongly rejects the need for warning labels or any similar pictorial approach on front-of-pack as the HSR system will continue to function effectively. Warning labels or pictorial approaches on the front-of-pack may confuse consumers, cause unintended consequences and introduce a competitive force into the existing labelling framework by challenging the Health Star Rating [HSR]. The proposed revised HSR should continue to be the only front-of-pack labelling [FoPL] system for supporting consumer choices in line with the ADGs. The HSR is an existing, reputable and widely used labelling system that considers the nutritional profile of food and drink. In short, an additional system for a single nutrient is misleading to consumers and contravenes ‘whole-of-diet’ advice. IDEA THREE: While the Australian Beverages Council supports “multi-component interventions to improve nutrition information and increase accessibility and prominence of healthier options in supermarkets”, it is important that further information be provided prior to feedback being sought on behalf of the industry. As detailed in the comments section of Q26, the Australian Beverages Council rejects the focus on Sustainability within a National Obesity Strategy. The inclusion of

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recommended changes from the Review and additional consumer awareness

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an Beverages Council anticipates increased, positive

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an Beverages Council anticipates increased, positive consumer awareness and influence

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consumer awareness and influence on purchasing behaviour.

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on purchasing behaviour.

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any similar pictorial approach on frontfunction effectively.

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function effectively.

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indicators as part of Sustainability are more applicable to a national food and nutrition policy. Sustainability has been included in the National Obesity Strategy despite the Evidence Check (commissioned to inform the National Obesity Strategy) not evaluating the effectiveness of such interventions. 2 On closer review of the Evidence Check, the research cited to support the inclusion of Sustainability in the National Obesity Strategy is a published paper which proposes the framework put forward by the Lancet Commission into the Global Syndemic of Obesity, Undernutrition and Climate Change. 3While this framework is a proposed way of tackling obesity by linking it to climate change, there is scant evidence for the effectiveness of such a framework, and further consultation and review must be carried out prior to recommendations being made. By comparison, evidence-based strategies have been identified in key global reports including:

▪ The McKinsey Global Institute in the UK which analysed a wide range of interventions to tackle obesity and found that portion control, reformulation, parental education and weight management programs were some of the most effective policy measures. 4

▪ OECD, The Heavy Burden of Obesity: The Economics of Prevention. 5 This recently released report identified communication-based approaches such as regulation of advertising, food labelling, menu labelling and mass media campaigns as the most economically effective policy measures, as well as reformulation to achieve a 20% calorie reduction in energy-dense foods and drinks. The OECD report recognises that strategies to reduce obesity may have cross-sectoral effects, for example on climate change, however creating truly synergetic policies is challenging, requiring extensive stakeholder input from across sectors.

1 MP Consulting (2019). Health Star Rating System Five Year Review Report. 2 Sacks G, Looi E, Cameron A, Backholer K, Strugnell C et al (2019). Population-level strategies to support healthy weight: an Evidence Check rapid review brokered by the Sax Institute (www.saxinstitute.org.au) for Queensland Health. 3 Swinburn, Boyd A., et al (2019). "The global syndemic of obesity, undernutrition, and climate change: The Lancet Commission report." The Lancet 393.10173: 791-846. 4 McKinsey Global Institute (2014). Overcoming obesity: an initial economic analysis 5 OECD (2019). Heavy Burden of Obesity. The Economics of Prevention

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interventions to tackle obesity and found that portion control, reformulation, parental education and weight management progra

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parental education and weight management programs were some of the

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campaigns as the most economically effective policy measures, as well as

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reformulation to achieve a 20% calorie reduction in energyThe OECD report recognises that strategies to reduce obesity may

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Q32. Proposed Priority 4: Building a healthier and more resilient food system – producing and promoting healthier food and drinks with little impact on the environment The seventh proposed strategy for this priority area is: Explore policy options related to the price of food and drinks to help shift consumer purchases towards healthier options. Please rate the extent to which you think each of the following proposed ideas is important for guiding action under this strategy. You can use the comment boxes in the online survey to provide any feedback you might have about each idea.


Slightly important


Very important

Extremely important

I’m not sure

Subsidise healthy food and drinks (e.g., fruit, vegetables and water), potentially including transport subsidies to remote communities

☐ ☐ ☐ ☐ ☐ ☐

Consider emerging evidence and policy approaches that use price to reduce consumption of sugar-sweetened beverages and high sugar snacks

☒ ☐ ☐ ☐ ☐ ☐

Consider using price to reduce consumption of alcoholic beverages, potentially through a uniform volumetric tax and/or a floor price

☐ ☐ ☐ ☐ ☐ ☐

Restrict temporary price reductions (e.g., half-price, multi-buys) on unhealthy food and drink products

☐ ☐ ☐ ☐ ☐ ☒

Explore and consider options for incorporating the cost of obesity and greenhouse gas emissions into the price of food and drinks

☒ ☐ ☐ ☐ ☐ ☐

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subsidies to remote communities

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Comments: SEVENTH PROPOSED STRATEGY: The Australian Beverages Council does not support, “Explore policy options related to the price of food and drinks to help shift consumer purchases towards healthier options” in relation to the majority of ideas presented for guiding action under this strategy. IDEA TWO: The Australian Beverages Council does not support “Consider emerging evidence and policy approaches that use price to reduce consumption of sugar-sweetened beverages and high sugar snacks”, since there is a growing body of evidence suggesting SSB taxes are a systematically flawed public health policy option to reduce overweight and obesity. Moreover, pricing measures between manufacturers and retailers should be excluded from the National Obesity Strategy as these are commercial agreements that operate in a functioning competitive market. The key reasons are outlined below: 1. Global health fora are specifically avoiding SSB taxation

The UN has considered and rejected taxation as a public health recommendation three times in the last 18 months:

1. Political Declaration from the High-Level Meeting on Non-Communicable Diseases (NCDs) in September 2018;

2. Resolution for Global Health and Foreign policy in December 2018; and

3. Political Declaration from the High-Level Meeting on Universal Health Coverage (UHC) in September 2019.

Numerous input reports and fora serving to inform these meetings have specifically excluded SSB taxation from their final determinations, including:

• In the 2017 report, “Tackling NCDs,” WHO identified the 16 “Best Buy” interventions that governments can undertake to combat NCDs.1 Notably, taxation of soft drinks is NOT a Best Buy intervention – WHO’s own internal modelling (the CHOICE analysis) concluded it did not meet those standards;

• In October 2017, a SSB tax was considered and rejected by Member States for the Montevideo Roadmap at the WHO Global High-Level Conference on NCDs;

• In May 2018, WHO’s “Saving Lives, Spending Less” Report, which serves as

its global investment case for quantifying the best investments in evidence-based interventions in order to maximize health returns, focuses solely on WHO’s most cost-effective interventions, Best Buys.2 As mentioned above, WHO does not consider an SSB tax to be a Best Buy, and therefore has not included it in this report as a best investment;

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be excluded from the National Obesity Strategy agreements that operate in a functioning competitive

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ifically avoiding SSB taxation

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ifically avoiding SSB taxation

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has considered and rejected taxation as a public health recommendation

Political Declaration from the High

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Level Meeting on NonDiseases (NCDs) in September 2018;

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Diseases (NCDs) in September 2018;

tion for Global Health and Foreign policy in December 2018; and

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tion for Global Health and Foreign policy in December 2018; and

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Coverage (UHC) in September 2019.

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(UHC) in September 2019.

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• In June 2018, WHO’s Independent High-Level Commission on NCDs issued a

report, “Time to Deliver” that identified the six key recommendations to accelerate progress in combating NCDs.3 This High-Level Commission considered and then explicitly rejected including a soft drink tax recommendation in their report, finding it to be neither bold, innovative or evidence-based.

2.SSB taxes lack any real-world evidence they have any discernible impact on obesity rates or public health The global experience with SSB taxation to date demonstrates, initial minimal, then unsustained drop in calories/energy from taxation of beverages, which does not reduce obesity nor impact public health as outlined below. MEXICO: In Mexico, the evidence from the 2014 SSB tax (also on high calorie snacks) has shown a brief, small and unsustained reduction in SSB consumption. Data from Mexico’s 2016 national health and nutrition survey has shown that obesity rates have edged upward among adults from 2012-2016, especially among adult women (a statistically significant rise from 73% of the adult female population to 75.6% percent of that population). 4 The tax resulted in a decrease of only four calories per day in year one with government sales tax receipts demonstrating resumed levels of consumption in years two and three.5 Moreover, the primary study from Mexico purporting a greater drop in sales to the tax receipts data, used counterfactuals to compare actual consumption with what consumption would have been, had the tax not been introduced (the counterfactual). 6 This study showed an alleged decrease in calories from taxed beverages of only six calories per day and representing 0.2% of the average daily dietary intake of 3,025 calories. BERKELEY, CALIFORNIA: A tax on SSBs has caused caloric intake to increase rather than decrease. While caloric consumption of taxed beverages dropped marginally by an average of six calories per day, caloric consumption of untaxed, non-alcoholic beverages rose by an average of 32 calories per day, resulting in a net increase of 26 calories per person per day as a result of the tax. 7 Crucially, consumers in Berkeley responded by switching from taxed drinks to untaxed milkshakes, smoothies and other calorie-dense products, resulting in more calories consumed per day. OAKLAND, CALIFORNIA: A study on the tax on SSBs in this jurisdiction was carried out and published in September 2019, ‘Oakland's Sugar-Sweetened Beverage Tax: Impacts on Prices, Purchases and Consumption by Adults and Children’. 8 The study found that ‘We do not find evidence of substantial changes in the overall consumption of SSBs or of added sugars consumed through beverages for either adults or children after the tax.’

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taxation of beverages, which does not

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the 2014 SSB tax (also on high calorie snacks)

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and unsustained reduction in SSB consumption

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Mexico’s 2016 national health and nutrition survey has shown that obesity rates

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Mexico’s 2016 national health and nutrition survey has shown that obesity rates2016, especially among adult women

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2016, especially among adult women (a statistically significant rise from 73% of the adult female population to 75.6%

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(a statistically significant rise from 73% of the adult female population to 75.6% The tax resulted in a decrease of only four calories per

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The tax resulted in a decrease of only four calories per ear one with government sales tax receipts demonstrating resumed levels of

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ear one with government sales tax receipts demonstrating resumed levels of consumption in years two and three.

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consumption in years two and three.5

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verages of only six calories per day and representing 0.2% of the average daily dietary intake of 3,025 calories.

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dietary intake of 3,025 calories.

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PHILADELPHIA, PENNSYLVANIA: This is the largest city in the United States with a soda tax. In Philadelphia, the tax also applies to low calorie beverages, underscoring the intention to raise revenue rather than reduce obesity. The Philadelphia Beverage Tax, introduced by The City of Philadelphia from 1 January 2017, imposes a 1.5 cents per ounce tax on the supply of sweetened beverages to retail dealers (regular and diet sodas, teas, for example). The tax is also levied on syrups and concentrates used to make sweetened drinks. An analysis of independent market data shows that consumption decreases are due to cross-border shopping: shoppers are crossing city boundaries where the tax applies to purchase the same beverages in jurisdictions where the tax does not apply. Beverage sales fell 24 percent at Philadelphia grocery stores but rose 14 percent in adjacent settlements. 9Seiler et al found that once cross-shopping was accounted for, there was no true reduction in sales as a result of the tax. 10 Cawley et al supported these findings, showing that a shift was seen away from diet drinks (taxed) to 100% fruit juice (untaxed). 11 It is therefore not surprising that adult’s added sugar intake decreased only by 6g (~ a teaspoon) and children by 2.5g (~0.5 teaspoon). Both reductions are small and statistically insignificant. A number of reputable studies and reports from credible institutions further question the efficacy of sugar and/or soft drink taxes. For example: ▪ “Sugar taxes: A review of the evidence”: At the request of New Zealand’s

Ministry of Health, the New Zealand Institute of Economic Research conducted this analysis and Report in which the authors ultimately concluded that “the evidence that sugar taxes improve health is weak.” 12 In their review of the 47 peer-reviewed studies and working papers on the topic of sugar taxes, the authors found, among other things, that: no study based on actual experience with sugar taxes has identified an impact on health outcomes.

▪ McKinsey Global Institute’s 2014 Report: This highly regarded analysis found that taxing sugar is one of the least effective interventions in combating obesity. This study reveals that out of more than 40 modelled interventions, taxation was not even among the top ten interventions. And even at this level of ineffectiveness, the science supporting taxation as an effective policy intervention was deemed weak (a 1 on a scale of 1-5, with 5 being the best science).13 According to the McKinsey Global Institute, the most effective ways to combat obesity include reformulating drinks, offering smaller portion sizes and providing better education.

▪ International Tax and Investment Centre and Oxford Economics, “The Impact of Selective Food and Non-Alcoholic Beverage Taxes,”14 published in June 2016 evaluated the different factors that influence the effectiveness of selective food and non-alcoholic beverage taxes (“SFBT”) on two policy objectives: improving public health and raising government revenues. It concluded that the evidence “suggests that the impact of introducing SFBT can be wide-ranging and highly uncertain. Very few studies provide a robust and complete account of the effects of such taxes, meaning that governments seeking to introduce them are doing so in a highly speculative context.”

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mall and statistically insignificant.

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A number of reputable studies and reports from credible institutions further sugar and/or soft drink taxes. For example:

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sugar and/or soft drink taxes. For example:

“Sugar taxes: A review of the evidence”:

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“Sugar taxes: A review of the evidence”: At the request of New Zealand

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At the request of New ZealandMinistry of Health, the New Zealand Institute of Economic Research conducted

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Ministry of Health, the New Zealand Institute of Economic Research conducted

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this analysis and Report in which the authors ultimately con

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this analysis and Report in which the authors ultimately conevidence that sugar taxes improve health is weak.”

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evidence that sugar taxes improve health is weak.” reviewed studie

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reviewed studies and working papers on the topic of sugar taxes, the

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s and working papers on the topic of sugar taxes, the authors found, among other things, that: no study based on actual experience

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authors found, among other things, that: no study based on actual experience r taxes has identified an impact on health outcomes.

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that taxing sugar is one of the least effective interventions in combating obesity. This study reveals that out of more than 4

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▪ Systematic Review 2017. This published paper on the effectiveness of SSB taxation in middle income countries found no evidence that taxing SSBs would reduce population weight permanently.15

3.SSB taxes have been demonstrated to be poor economic policy Considering selective, discriminatory and regressive taxation measures often over-simplifies the economic complexities of taxation and ignores significant pitfalls, including: SSB taxation may lead to government revenue shortfalls and exacerbate the funding needs for certain programs. Taxation policy is complex, and there are documented “unintended consequences” to SSB taxation: ▪ Case Study A: Philadelphia tax resulted in job losses and misdirected funds The tax raised $79 million in 2017, but the impact on the cost of soda was not small. The tax adds approximately $1 to the cost of a 2-litre bottle of soda and a 12-pack of 12-ounce sodas went up by $2.16.

Philadelphia’s 1.5 cent per ounce Beverage Tax was intended to develop pre-kindergarten programs, parks, libraries and other services. Rather than this, the money raised has largely been left unspent. While the tax was billed as a capital stream to fund pre-kindergarten programs, parks, libraries and other services, according to a March 2018 report from the City Controller, only about 26 percent of the revenue generated from the tax has gone to the programs it was intended to fund. The remaining 74 percent has gone to a general fund. 16 Crucially, the tax has not been used to tackle NCDs or fund public health campaigns.

There has been a very real economic cost in lost jobs, lower revenue and unkept promises for schools. The impact means that Philadelphia lost an estimated 1,190 jobs, $54 million USD in labour income, and $80 million USD in annual GDP. Additionally, the City’s tax revenues are decreasing because shoppers are buying in bulk and/or in other jurisdictions where the tax does not apply. The revenue was expected to raise $92 million in 2017, while it only raised $79 million in reality. 17

▪ Case Study B: United Kingdom: Inflation and costs rise Unintended real-world fiscal consequences of a SSB tax are apparent elsewhere, such as the United Kingdom’s experience with its recently implemented Soft Drink Industry Levy (SDIL). The Government Office of Budget Responsibility (OBR) found that the increase in price of soft drinks due to the tax will increase inflation. This food inflation in turn will raise the cost of interest payments on index-linked payments by the Government by about £1 billion in 2018-19. Ultimately, the new SDIL will cost the Government more than it raises in revenue and do even less for taxpayers who will ultimately pay this bill. 18 Reports indicate that the SDIL has raised less revenue than expected. It would seem incongruous that it could be good policy

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The tax raised $79 million in 2017, but the impact on the

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aseThe tax raised $79 million in 2017, but the impact on the cost of soda was not small.

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litre bottle of soda and a 12

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litre bottle of soda and a 12

ent per ounce Beverage Tax was intended to develop pre

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ent per ounce Beverage Tax was intended to develop prebraries and other services. Rather than this, the

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braries and other services. Rather than this, the money raised has largely been left unspent.

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money raised has largely been left unspent. While the tax was billed as a capital

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kindergarten programs, parks, libraries and other services,

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ams, parks, libraries and other services, according to a March 2018 report from the Cit

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according to a March 2018 report from the City Controller, only about 26 percent of

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y Controller, only about 26 percent of the revenue generated from the tax has gone to the programs it was intended to

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the revenue generated from the tax has gone to the programs it was intended to fund. The remaining 74 percent has gone to a genera

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fund. The remaining 74 percent has gone to a generanot been used to tackle NCDs or fund public health cam

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not been used to tackle NCDs or fund public health cam

has been

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has been a very real economic cost in lost jobs, lower revenue and unkept

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a very real economic cost in lost jobs, lower revenue and unkept promises for schools. The impact means that Philadelphia lost an estimated 1,190

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promises for schools. The impact means that Philadelphia lost an estimated 1,190

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jobs, $54 million USD in labour income, and $80 million USD in annual GDP.

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jobs, $54 million USD in labour income, and $80 million USD in annual GDP.

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to levy a new tax that costs more money than it raises, particularly in the absence of a strong altruistic public health argument.

It is important to note that comparisons drawn between the British non-alcoholic beverage industry and the Australian non-industry alcoholic beverage industry are unlikely to yield meaningful results, particularly within the context of the UK Soft Drinks Industry Levy. At the time of introduction, the Australian non-alcoholic beverage industry was already more than three years into its ongoing reformulation agenda which has most recently been demonstrated in the first progress report on the voluntary sugar reduction pledge (refer to Q28 Case Study for further information). Furthermore, the UK experience is markedly different to Australia’s in respect to socio-economic factors.

4. A tax solely focused on SSBs is not supported by scientific evidence

Sugar and sugar-containing products are not uniquely responsible for the rising rates of obesity and other NCDs around the globe. As an initial matter, the intake of sugar and/or SSBs have been decreasing in several countries, yet the prevalence of overweight and obesity have either stayed the same or increased.19 Therefore, a unique focus on sugar and sugar-containing foods and beverages is misguided and unlikely to have a meaningful impact on obesity and overweight. There is no rational basis for only taxing SSBs but not other sugar-containing products (e.g., cookies, cakes, pastries, etc.) or other products with comparable amounts of kilojoules. Ultimately, a tax that targets sugar and/or specific sugar-containing foods and beverages as unique contributors to obesity or other NCDs, independent of all other sources of sugar or kilojoules, is not only misleading to consumers, but would also fail to improve public health. It also fails to recognize that many SSBs such as 100 per cent juices (no added sugar), milk-based beverages, and reduced-kilojoule juice beverages are inherently nutrient dense products that provide a good source of nutrients such as Vitamin C, Vitamin D, protein, and calcium. 5. SSB taxation is regressive policy and places an unfair burden on lower SES households Lastly, experience demonstrates that the burden of taxation is often carried by those who can least afford it. In Mexico, which adopted an SSB tax in 2014, 63.7% of the tax was collected from the lowest socio-economic group. 20The tax successfully raised revenue from poorer Mexicans in exchange for a minimal decrease in calories and without a corresponding improvement in public health; while the poor were poorer, they were not healthier. Moreover, according to data from the National Household Income and Expenditure Survey (“ENIGH”), and the Monthly Survey of the Manufacturing Industry (“EMIM”), the tax reportedly cost the country 10,815 jobs both in the non-alcoholic beverage industry directly and in agricultural companies that are the major suppliers to the industry. 21

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ucts are not uniquely responsible for the rising rates

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esity and other NCDs around the globe. As an initial matter, the intake of sugar

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aseesity and other NCDs around the globe. As an initial matter, the intake of sugar

and/or SSBs have been decreasing in several countries, yet the prevalence of

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and/or SSBs have been decreasing in several countries, yet the prevalence of ayed the same or increased.

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ayed the same or increased.19

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containing foods and beverages is misguided and

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containing foods and beverages is misguided and unlikely to have a meaningful impact on obesity and overweight.

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unlikely to have a meaningful impact on obesity and overweight.

There is no rational basis for only taxing SSBs but not other sugar

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There is no rational basis for only taxing SSBs but not other sugar, cookies, cakes, pastries, etc.)

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, cookies, cakes, pastries, etc.) or other products with comparable

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or other products with comparable s. Ultimately, a tax that targets sugar and/or specific sugar

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s. Ultimately, a tax that targets sugar and/or specific sugarcontaining foods and beverages as unique contributors to obesity or other NCDs,

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containing foods and beverages as unique contributors to obesity or other NCDs,

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independent of all other sources of sugar or

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independent of all other sources of sugar or consumers, but would also fail to improve public health. It also fails to recognize

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consumers, but would also fail to improve public health. It also fails to recognize that many SSBs such as 100 per

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that many SSBs such as 100 per cent juices

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cent juiceskilojoule

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kilojoule juice beverages are inherently nutrient de

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juice beverages are inherently nutrient deprovide a good source of nutrients such as Vitamin C, Vitamin D, protein, and

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provide a good source of nutrients such as Vitamin C, Vitamin D, protein, and

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calcium.

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calcium.

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The Evidence Check commissioned to inform the National Obesity Strategy notes that an SSB tax is consistently regressive across socioeconomic groups. 22 However, more recent evidence has found that taxes financially impact lower socioeconomic groups more heavily with these groups reducing their sugar intake less than higher socioeconomic groups. 23 24 6. Alternatives to SSB tax If the stated objective of a tax on products containing sugar is to reduce sugar in the diet through reduced consumption of regular sugar-sweetened beverages, then more innovative and creative ways of achieving this are already in market and having the desired effect. For example, the Australian Beverage Industry’s Pledge to reduce sugar by 20 per cent by 2025 is driving tangible and sustained change within the industry: ▪ 7 per cent reduction in sugar in the first progress report (more than one third of

the way towards reducing sugar by 20 per cent by 2025). ▪ Sugar reduction achieved by voluntary actions including reformulation of existing

high sugar drinks, reducing portion sizes and innovative marketing programs to increase consumption of low- and no-sugar drinks.

▪ Aligns with key statement in proposed priority 4, to produce and promote healthier food and drinks..., that are commensurate with the Australian Dietary Guidelines and the intent of the National Obesity Strategy.

In addition to Australia’s sugar reduction pledge, around the globe and in various countries, the beverage industry has made specific commitments to reduce sugar and therefore calories in beverages. For example:

o In conjunction with Singapore’s Ministry of Health, seven major beverage companies, including The Coca-Cola Company and PepsiCo, signed an industry pledge to remove by 2020 drinks that contain more than 12 percent sugar from their portfolios of SSBs.

o In partnership with the Conference Board of Canada, the Canadian

Beverage Association and its membership have committed to reducing the non-alcoholic beverage calories consumed per person by 20 percent by 2025. A report prepared by The Conference Board of Canada shows that in the first two years of Balance Calories alone, calories have been reduced by an unprecedented 10.2 percent. That means that since 2004 there has been almost a 30 percent reduction in calories consumed from non-alcoholic beverages by Canadians.1

1 The Conference Board of Canada, “Counting the Calories, Canadian’s Consumption of High-Calorie Beverages Continues to Decline” (August 2018), available at https://www.conferenceboard.ca/press/newsrelease/2018/08/09/counting-the-calories-canadians-consumption-of-high-calorie-beverages-continues-to-decline?AspxAutoDetectCookieSupport=1 (last accessed January 7, 2019).

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g tangible and sustained change within the industry:

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cent reduction in sugar in the first progress report (more than one third of

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the way towards reducing sugar by 20 per cent by 2025).

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high sugar drinks, reducing portion sizes and innovative marketing programs to

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high sugar drinks, reducing portion sizes and innovative marketing programs to sugar drinks.

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sugar drinks.Aligns with key statement in proposed priority 4,

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to produce and promote are commensurate with the Australian Dietary

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are commensurate with the Australian Dietary National Obesity Strategy

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National Obesity Strategy

In addition to Australia’s sugar reduction pledge,

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In addition to Australia’s sugar reduction pledge, countries, the beverage industry has made specific commit

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countries, the beverage industry has made specific commitand therefore calories in beverages. For example:

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and therefore calories in beverages. For example:

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In conjunction with Singapore’s Ministry of Health

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Singapore’s Ministry of Healthbeverage

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beverage companies, including The Coca

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companies, including The Cocasigned an industry pledge to remove by 2020 d

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signed an industry pledge to remove by 2020 dthan 12 percent

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o In 2014, in partnership with the Alliance for a Healthier Generation, the American Beverage Association, The Coca-Cola Company, Dr Pepper Snapple Group and PepsiCo set a goal to reduce beverage calories consumed per person nationally by 20 percent by 2025. Working together, as well as individually as companies, the US beverage industry is increasing access to beverages with less sugar, as well as smaller portions, across the country. In the first three years of implementation (2015-2017), introduction of no-, low- and mid-calorie beverage innovations outpaced introductions of full-calorie beverages. Together, about 60 percent of all new brands and flavors introduced were no-, low- and mid-calorie choice.2

o Through the auspices of UNESDA, the European soft drink association,

the leading beverage companies have committed to reducing the average added sugar content of their still and carbonated soft drinks by 10 percent between 2015 and 2020. This commitment was introduced at the EU Platform for Action on Diet, Physical Activity and Health, a multi-stakeholder convening chaired by the EU Commission, and will be rolled out across Europe and aims to deliver an average 10 percent sugar reduction, impacting over 500 million consumers. This commitment comes on top of the 12 percent sugar and calorie reduction already achieved from 2000 and 2015, and represents an effective tripling of the sugar reduction pace.3

2 Keybridge, “2025 Beverage Calories Initiative: Report on 2017 Progress toward the National Calorie Goal” (August 2018), available at

https://aba-bigtree.s3.amazonaws.com/files/resources/bci-2017-national-progress-report-vfinal-08-22-18-.pdf

3 https://www.unesda.eu/wp-content/uploads/2017/02/UNESDA_Press-release_FINAL.pdf

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nd carbonated soft drinks

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er convening chaired by the EU Commission,

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and will be rolled out across Europe an

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d aims to deliver an average 10

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tion, impacting over 500 million consumers. mmitment comes on top of the 12 percent

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eady achieved from 2000 and 2015, and represents an

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eady achieved from 2000 and 2015, and represents an effective tripling of the sugar reduction pace.

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In the U.S., under the Healthy Weight Commitment (“HWCF”), 16 food and beverage manufacturers, including leading drinks companies, collectively pledged to remove 1.5 trillion calories from the marketplace by 2015. By 2012, independent monitoring by the Robert Wood Johnson Foundation verified that 6.4 trillion calories had been removed from the food supply - exceeding the 2015 pledge by more than 400 percent and three years early.4 The McKinsey Global Institute ranked HWCF’s public-private partnership as one of two of the most effective programs in the global fight against obesity.5

As evidenced from the above, these public-private partnerships offer tangible results that align with governmental and public health objectives, in the absence of discriminatory and regressive taxes or other regulatory interventions or measures.

The importance of partnerships with the private sector is being echoed by leading global fora including the Political Declarations from the United Nation’s High-Level Meeting on Non-Communicable Diseases in September 2018 and on Universal Health Coverage in September 2019, and most recently by the WHO’s Independent High-Level Commission on Non-Communicable Diseases report ‘Time to walk the talk’ (Recommendation 6), released at the WHO Global Meeting to Accelerate Progress on SDG target 3.4, in Muscat, Oman, in December 2019.

Q33. Proposed Priority 4: Building a healthier and more resilient food system – producing and promoting healthier food and drinks with little impact on the environment Thinking about the specific strategies you just read for building a healthier and more resilient food system, are there any additional strategies or recommendations you think should be included to produce and promote healthier food and drinks with little impact on the environment? These might include strategies that help people overcome specific challenges they encounter when making decisions about the food and drinks they consume. Please provide your comments in the space below. The seven proposed strategies are listed again below if you need to re-read these.

4 Healthy Weight Commitment Foundation, available at http://www.healthyweightcommit.org/about/ (last accessed January 7, 2019).

5 McKinsey Global Institute, “Overcoming obesity: An initial economic analysis” (November 2014), available at https://www.mckinsey.com/~/media/McKinsey/Business%20Functions/Economic%20Studies%20TEMP/Our%20Insights/How%20the%20world%20could%20better%20fight%20obesity/MGI_Overcoming_obesity_Full_report.ashx (last accessed January 7, 2019).

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aseThe importance of partnerships with the private sector is being echoed by leading

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from the United Nation’s High

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er 2018

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e in September 2019, and most recently by the WHO’s Independent

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Communicable Diseases report ‘Time to walk the

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Communicable Diseases report ‘Time to walk the ), released at the WHO G

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), released at the WHO Global Meeting to Acce

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lobal Meeting to Accerogress on SDG target 3.4, in Muscat, Oman, in December 2019.

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rogress on SDG target 3.4, in Muscat, Oman, in December 2019.

Proposed Priority 4: Building a healthier and more resilient food system

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Proposed Priority 4: Building a healthier and more resilient food system producing and promoting healthier food and drinks with little impact on the

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producing and promoting healthier food and drinks with little impact on the

Thinking about the s

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Thinking about the specific strategies you just read for building a healthier and more

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pecific strategies you just read for building a healthier and more

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resilient food system, are there any additional strategies or recommendations you

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resilient food system, are there any additional strategies or recommendations you think should be included to produce and promote healthier food and drinks

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think should be included to produce and promote healthier food and drinks impact on the environ

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impact on the environment?

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ment?

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The Australian Beverages Council strongly opposes the focus on Sustainability within a National Obesity Strategy. Sustainability indicators are more relevant to a National Nutrition Policy, and not to a National Obesity Strategy with a focus on reducing the prevalence overweight and obesity and preventing overweight and obesity. Sustainability has been included in this strategy despite the Evidence Check (commissioned to inform the national obesity strategy) not evaluating the effectiveness of such interventions. 25 On closer review of the Evidence Check, it appears that the research cited to support the inclusion of sustainability in the national obesity strategy is one published paper which proposes the framework put forward by the Lancet Commission into the Global Syndemic of Obesity, Undernutrition and Climate Change. 26 While this framework is a proposed way of tackling obesity by linking it to climate change, there is no evidence for the effectiveness of such a framework. Evidence-based strategies have been identified in key global reports including The McKinsey Global Institute in the UK which analysed a wide range of interventions to tackle obesity and found that portion control, reformulation, parental education and weight management programs were some of the most effective policy measures.27 The recently released report The Heavy Burden of Obesity: The Economics of Prevention also identified the most economically effective approaches, which include communication-based approaches such as regulation of advertising, food labelling, menu labelling and mass media campaigns, as well as reformulation to achieve a 20% calorie reduction in energy-dense foods and drinks.28 The Australian Beverages Council recommends changes to one of the proposed ideas in Strategy 4 in relation to “availability, accessibility and affordability of healthy food and drinks” as without engagement with each community, it will be unclear who the target group within the community is and what intervention levers are necessary (such as, availability, accessibility and affordability may not be the key issues). The Australian Beverages Council recommends Strategy 4 is reworked to state: “support targeted interventions for rural and remote communities, communities experiencing disadvantage and Aboriginal and Torres Strait Islander people”. Some examples of targeted, collaborative and multifaceted programs are outlined below:

▪ The Dutch Obesity Intervention in Teenagers (DOiT) – Netherlands The DoiT intervention is a multicomponent school-based program aimed at preventing excess weight gain in adolescents aged 12-14 years. Its aim is to increase awareness and to induce behavioural changes concerning energy intake (e.g. consumption of SSB and high-energy snack foods) and energy output (e.g. physical activity and screen-viewing behaviour). The intervention consisted of both an individual component (i.e. an educational program), and an environmental component (i.e. encouraging schools to offer additional physical education classes and advice for changes to the foods sold in the school cafeteria).

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based strategies have been identified in key global reports including The

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McKinsey Global Institute in the UK which analysed a wide range of interventions to

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t portion control, reformulation, parental educatio

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t portion control, reformulation, parental educatioweight management programs were some of the most effective policy measures

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weight management programs were some of the most effective policy measuresThe Heavy Burden of Obesity: The Economics of

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The Heavy Burden of Obesity: The Economics of also identified the most economicall

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also identified the most economically effective approaches, which include

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y effective approaches, which include based approaches such as regulation of advertising, food labelling,

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based approaches such as regulation of advertising, food labelling, menu labelling and mass media campaigns, as well as reformulation to achieve a

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menu labelling and mass media campaigns, as well as reformulation to achieve a dense foods and drinks

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dense foods and drinks

The Australian Beverages Council recommends

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The Australian Beverages Council recommends

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in Strategy 4 in relation to “availability, accessibility and affordability of healthy food

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in Strategy 4 in relation to “availability, accessibility and affordability of healthy food

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” as without engagement with each community, it will be unclear who the

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” as without engagement with each community, it will be unclear who the target group within the community is and what inter

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target group within the community is and what inter(such as, availability, accessibility and affordability may not be the key issues).

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(such as, availability, accessibility and affordability may not be the key issues).

The Australian Beverages Council recommends Strategy 4 is reworked to state:

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examples of targeted, collaborative and multifaceted programs are outlined below:

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Results from a randomised controlled trial in 18 secondary schools reported an improvement in body composition in girls and a reduction in SSB consumption in boys and girls. 29

▪ The OPAL Program – South Australia The OPAL program in South Australia is the largest childhood prevention program in South Australia, operating in 20 local communities across the State and one community in the Northern Territory (over seven years of implementation). 30 It is a multi-setting, multi-sectoral, community-based, systems-wide program. The program has six goals around healthy eating and physical activity, with seven strategies to guide a comprehensive approach to health promotion. The program has taken multifaceted steps towards a healthier community, including encouraging children and families to walk and cycle to school, eat healthier breakfasts at school and home, and encouraging playing outdoors.

A 2016 evaluation of the OPAL program31 found that children in the OPAL community had a: ▪ 53 per cent reduced likelihood of obesity in children 9-11 years compared to the control group; ▪ 50 per cent increased probability of meeting the daily recommended servings for fruit, with no change in probability in the control group; ▪ 50 per cent increased probability of meeting the discretionary (“extra”) food and drink guideline compared to children in the control communities; and ▪ 60-70 per cent more likely to meet the physical activity guidelines at the end of the intervention, although no significant difference vs. the control community.


• Ensure our food system favours the production, processing and manufacture of healthy and sustainable products.

• Increase the availability of healthy, sustainable food and drinks in the places

we live and work.

• Make processed food and drinks healthier and more sustainable by limiting energy and nutrients of concern.

• Support targeted interventions that increase the availability, accessibility and

affordability of healthy food and drinks for rural and remote communities, communities experiencing disadvantage and Aboriginal and Torres Strait Islander people.

• Reduce exposure to unhealthy food and drink marketing and promotion.

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le to school, eat healthier breakfasts at school and home, and encouraging

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le to school, eat healthier breakfasts at school and home, and encouraging

found that children in the OPAL

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53 per cent reduced likelihood of obesity in children 9

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53 per cent reduced likelihood of obesity in children 9-

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-11 years compare

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11 years compare

50 per cent increased probability of meeting the daily recommended

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50 per cent increased probability of meeting the daily recommended servings for fruit, with no change in

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servings for fruit, with no change in probability in the control group;

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probability in the control group;50 per cent increased probability of meeting the discretionary (“extra”)

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50 per cent increased probability of meeting the discretionary (“extra”) uideline compared to children in the control communities;

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uideline compared to children in the control communities;

70 per cent more likely to meet the physical activity guideline

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70 per cent more likely to meet the physical activity guidelineend of the intervention, although no significant difference

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end of the intervention, although no significant difference


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Ensure

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• Increase the availability and accessibility of information to support the consumer to make a healthier choice at the time of purchasing food or drinks.

• Explore policy options related to the price of food and drinks to help shift

consumer purchases towards healthier options.

1 WHO, “Tackling NCDs” (2017). available at http://apps.who.int/iris/bitstream/handle/10665/259232/WHO-NMH-NVI-17.9-eng.pdf;jsessionid=5F8B961B9136EBC7E5A23A3D9F15C789?sequence=1 (last accessed January 7, 2019). 2 WHO, “Saving Lives, Spending Less, A Strategic Response to Non-communicable Diseases” (2018), available at http://apps.who.int/iris/bitstream/handle/10665/272534/WHO-NMH-NVI-18.8-eng.pdf?ua=1 (last accessed January 7, 2019). 3 WHO, “Time to Deliver” (2018), available at http://apps.who.int/iris/bitstream/handle/10665/272710/9789241514163-eng.pdf?ua=1 (last accessed January 7, 2019). 4 See Mexico’s 2016 National Health Survey (ENSANUT), finding that the prevalence of obesity and overweight rose overall from 71.2% to 72.5% among adults from 2012-2016, and among adult women it rose from 73% to 75.6% during that same time frame, a statistically significant result. 5 Notably, a recent article in the journal Health Affairs claimed incorrectly that the drop in consumption witnessed in 2014 was sustained in later years. Regrettably, the authors of this article are relying on theoretical models, which are estimations that do not align with actual tax receipts from the Mexican Secretariat for Finance and Public Credit (SHCP). This real-world data shows increases in sugar-sweetened beverage sales through 2016, as opposed to the projected decrease suggested by the authors. This government tax receipt data can be reviewed here. 6 Colchero MA, Popkin BA, Rivera JA, Ng SW (2016). Beverage purchases from stores in in Mexico under the excise tax on sugar-sweetened beverages: observational study. BMJ. 7 L. Silver et al., (2017) “Changes in prices, sales, consumer spending, and beverage consumption one year after a tax on sugar-sweetened beverages in Berkeley, California, US: A before-and-after study,” PLOS Medicine. 8 Cawley, J., Frisvold, D. E., Hill, A., & Jones, D. (2019). Oakland’s Sugar-Sweetened Beverage Tax: Impacts on Prices, Purchases and Consumption by Adults and Children (No. w26233). National Bureau of Economic Research. 9 Oxford Economics, The Economic Impact of Philadelphia’s Beverage Tax,” (2017), available at https://www.ameribev.org/files/resources/oe-economic-impact-study.pdf 10 Seiler, Stephan and Tuchman, Anna and Yao, Song, The Impact of Soda Taxes: Pass-Through, Tax Avoidance, and Nutritional Effects (October 26, 2019). Stanford University Graduate School of Business Research Paper No. 19-12. Available at SSRN: https://ssrn.com/abstract=3302335 or http://dx.doi.org/10.2139/ssrn.3302335 11 Cawley, J., Frisvold, D., Hill, A., & Jones, D. (2018). The impact of the Philadelphia beverage tax on prices and product availability (No. w24990). National Bureau of Economic Research. 12 NZIER (2017). “Sugar taxes: A review of the evidence,” available at https://nzier.org.nz/static/media/filer_public/f4/21/f421971a-27e8-4cb0-a8fc-95bc30ceda4e/sugar_tax_report.pdf (last accessed January 7, 2019) 13 R. Dobbs et al., (2014). “Overcoming obesity: An initial economic analysis,” McKinsey Global Institute. 14 Oxford Economics and International Tax and Investment Center (2016). “The Impact of Selective Food and Non-Alcoholic Beverage Taxes” available at http://www.oxfordeconomics.com/my-oxford/projects/341055 (last accessed January 7, 2019) 15 S. Nakhimovsky et al., (2016). “Taxes on Sugar-Sweetened Beverages to Reduce Overweight and Obesity in Middle-Income Countries: A Systematic Review” available at https://journals.plos.org/plosone/article?id=10.1371/journal.pone.0163358 (last accessed January 8, 2019) 16 Oxford Economics (2017). The Economic Impact of Philadelphia’s Beverage Tax.

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17 Seiler, S, Tuchman, A and Yao, S, (2019). The Impact of Soda Taxes: Pass-Through, Tax Avoidance, and Nutritional Effects. Stanford University Graduate School of Business Research Paper No. 19-12. Available at http://dx.doi.org/10.2139/ssrn.3302335 18 http://www.taxpayersalliance.com/unintended_consequences_of_the_sugar_tax 19 J. Brand-Miller and A. Barclay (2017). “Declining Consumption of Added Sugars and Sugar-Sweetened Beverages in Australia: A Challenge for Obesity Prevention” Am J Clin Nutr; 105:854-63 20 Kantar World Panel Mexico Report (2014) 21 J. Cantu, D. Curiel, and L. Valero (2015). “The Non-Alcoholic Beverage Industry in Mexico, Centro de Investigaciones Económicas,”. 22 Sacks G, Looi E, Cameron A, Backholer K, Strugnell C et al (2019). Population-level strategies to support healthy weight: an Evidence Check rapid review brokered by the Sax Institute (www.saxinstitute.org.au) for Queensland Health. 23 Seiler, S, Tuchman, A and Yao, S, (2019). The Impact of Soda Taxes: Pass-Through, Tax Avoidance, and Nutritional Effects. Stanford University Graduate School of Business Research Paper No. 19-12. Available at http://dx.doi.org/10.2139/ssrn.3302335 24 Public Health England (2019). Sugar Reduction: Report on progress between 2015 and 2018. 25 Sacks G, Looi E, Cameron A, Backholer K, Strugnell C et al (2019). Population-level strategies to support healthy weight: an Evidence Check rapid review brokered by the Sax Institute (www.saxinstitute.org.au) for Queensland Health. 26 Swinburn, Boyd A., et al (2019). "The global syndemic of obesity, undernutrition, and climate change: The Lancet Commission report." The Lancet 393.10173: 791-846. 27 McKinsey Global Institute (2014). Overcoming obesity: an initial economic analysis 28 OECD (2019). Heavy Burden of Obesity. The Economics of Prevention 29 Singh AS, Chin APMJ, Brug J, van Mechelen W. (2009) Dutch obesity intervention in teenagers: effectiveness of a school-based program on body composition and behavior. Arch Pediatr Adolesc Med. 30 City of Playford (2016). OPAL: The City of Playford Available from: www.playford.sa.gov.au/OPAL. 31 Flinders University (2016). OPAL Evaluation Project Final Report.

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Q34. Priority areas Before we move on to the next section of the survey, do you have any other feedback about the four priority areas you have just read about:

1. Supporting children and families – Starting early to support healthy weight throughout life

2. Mobilising people and communities – Using knowledge, strengths and community connections to enable health weight

3. Enabling active living – Supporting a way of life that helps people move throughout the day

4. Building a healthier and resilient food system – Producing and promoting healthier food and drinks with little impact on the environment

Please provide your comments in the space below. The Australian Beverages Council reiterates previous comments on the proposed priority areas and strategies:

1. Sustainability should not be included in the National Obesity Strategy. Sustainability is more relevant to a national nutrition policy, as recommended in the Decadal Plan for Nutrition 2019. There is no evidence presented in the Evidence Check (commissioned to inform the National Obesity Strategy) regarding the effectiveness of interventions that include sustainability e.g. sustainability indicators and increasing the availability of healthy, sustainable food and drinks. 1 Overweight and obesity is a highly complex, multi-causal issue requiring a comprehensive, systemic program of multiple interventions to be effective. It is therefore essential to focus on evidence-based strategies as identified in key global reports including The McKinsey Global Institute in the UK and OECD which analysed a wide range of interventions to tackle obesity and found that portion control, reformulation, parental education, weight management programs, food labelling and mass media campaigns were some of the most effective policy measures. 2 3

1 Sacks G, Looi E, Cameron A, Backholer K, Strugnell C et al (2019). Population-level strategies to support healthy weight: an Evidence Check rapid review brokered by the Sax Institute (www.saxinstitute.org.au) for Queensland Health. 2 McKinsey Global Institute (2014). Overcoming obesity: an initial economic analysis 3 OECD (2019). Heavy Burden of Obesity. The Economics of Prevention

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should not be included in the National Obesity Strategymore relevant to a

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Section 4. Proposed enablers for a national obesity strategy Proposed enablers for a national obesity strategy We are now going to ask you about the four proposed enablers for a national obesity strategy. The proposed enablers are:

1. Lead the way – collective commitment and action for overweight and obesity prevention and health equity across governments.

2. Better use of data – sharing knowledge and data and using evidence to develop policies and programs and make sure collective actions are effective.

3. Build the workforce – support development of an engaged, empowered and skilled workforce that can better support individuals and influence community actions and environments.

4. Invest for delivery – adequately funding sustainable interventions and preventative actions, and exploring economic policies and trade agreements to positively impact on overweight and obesity rates, communities and the environment.

We are interested in what you think of the strategies and ideas to guide action included under each of these proposed enablers. Please select a set of proposed enabler questions to complete by clicking on the ‘Answer’ button. After you have answered all of the enabler sections you would like to complete, the ‘Next’ button at the bottom of the screen will take you to the next part of the survey. Q35. Proposed Enabler 1: Lead the way – collective commitment and action for obesity prevention and health equity across governments For this proposed enabler, there is one proposed strategy with two ideas to guide action. These are discussed in detail on page 27 of the consultation paper. The proposed strategy for this enabler is: Build and sustain collective commitment to, and action for, comprehensive and contemporary obesity prevention and health equity efforts. Please rate the extent to which you think each of the following proposed ideas is important for guiding action under this strategy. You can use the comment boxes in the online survey to provide any feedback you might have about each idea.

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preventative actions, and exploring economic policies and trade agreements to positively impact on overweight and obesity rates,

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agreements to positively impact on overweight and obesity rates, communities and the environment.

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communities and the environment.

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Slightly important


Very important

Extremely important

I’m not sure

Implement strong governance systems to facilitate multiple efforts by many sectors

☐ ☐ ☒ ☐ ☐ ☐

Explore new collaborative ways of working with communities that create genuine partnerships, embed the right to self-determination and autonomy, co-develop solutions and elevate community voices to create change in their own communities

☐ ☐ ☐ ☒ ☐ ☐

Q36. Proposed Enabler 1: Lead the way – collective commitment and action for obesity prevention and health equity across governments Are there any additional strategies you think should be included to enable strong national leadership and governance to deliver better outcomes at the national, state/territory, regional and local levels? Please provide your comments in the space below. The Australian Beverages Council supports collaborative multi-sectoral community interventions that empower communities to create change. Successful examples are cited above (Q33, comments section) and include programs such as the OPAL program in South Australia.

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prevention and health equity across governments

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Q37. Proposed Enabler 2: Better use of data – sharing knowledge and data and using evidence to develop policies and programs and to make sure collective actions are effective For this proposed enabler, there are two proposed strategies, each containing a number of ideas to guide action. These are discussed in detail on pages 28 and 29 of the consultation paper. The first proposed strategy for this enabler is: Use evidence to inform policy and program development and implementation, and determine the effectiveness of collective actions. Please rate the extent to which you think each of the following proposed ideas is important for guiding action under this strategy. You can use the comment boxes in the online survey to provide any feedback you might have about each idea.


Slightly important


Very important

Extremely important

I’m not sure

Update Australian guidelines for healthy eating, physical activity and weight, ensuring they explicitly incorporate environmental sustainability, are based on the latest scientific evidence and are free from industry influence

☐ ☐ ☐ ☐ ☐ ☒

Conduct regular cross-sector monitoring and evaluation of a national obesity strategy to ensure accountability, continuous improvement and effectiveness of collective action, in consultation with national data agencies and data collection custodians

☐ ☐ ☐ ☐ ☒ ☐

Support research on obesity systems to grow the evidence ☐ ☐ ☐ ☐ ☒ ☐

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base, reduce gaps in knowledge and assess promising approaches

Co-develop evaluation and research approaches that align with community values to acknowledge the deep knowledge and experiences of people working to create change in their own communities and to ensure data sovereignty

☐ ☐ ☐ ☐ ☒ ☐

Co-develop evaluation and research approaches with Aboriginal and Torres Strait Islander people, utilising cultural and traditional knowledge

☐ ☐ ☐ ☐ ☒ ☐

Comments: Proposed Idea 1: Update Australian guidelines for healthy eating, physical activity and weight, ensuring they explicitly incorporate environmental sustainability, are based on the latest scientific evidence and are free from industry influence The response “Not Sure” is based on our partial support for the proposed idea as outlined below. It is the position of the Australian Beverages Council to support:

▪ The need to update Australian guidelines for healthy eating, physical activity and weight based on high quality up-to-date evidence. The current Australian Guide to Healthy Eating clearly identifies both core and discretionary foods and we see no need for this to change. For example, the inclusion of fruit juice (no added sugar) and flavoured milk as part of the core food groups e.g. one serving of fruit juice to be 125mL and one serving of fruit as 150g with the recommendation to consume fruit juice occasionally. The Health Star Rating system will further assist consumers with making healthier choices within the beverage category as it penalises both total sugars and saturated fats.

It is recommended that the updates are based on current consumer research to ensure the guidelines meet the changing and diverse needs of the Australian population. The consumer research report, Healthy Weight and Lifestyle commissioned by FSANZ in 2017 identified “a divergence in people’s perceptions of the value, relevance and credibility of a set of dietary guidelines for ‘all Australians’, distinguished mostly by people’s age/generation and their weight”. 1 Of relevance, is that older and less overweight participants were more supportive of a set of national guidelines

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Update Australian guidelines for healthy eating,

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physical activity and weight, ensuring they explicitly incorporate environmental on the latest scientific evidence and are free from industry

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on the latest scientific evidence and are free from industry

The response “Not Sure” is based on our partial support for the proposed idea as

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It is the position of the Australian Beverages

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and weight

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in helping them navigate the confusing and often contradictory healthy lifestyle information. In contrast, younger and healthier participants preferred more personalised and less prescriptive advice, viewing a single set of guidelines as outdated and impractical.

The Australian Beverages Council does not support:

▪ The inclusion of environmental sustainability under a National Obesity Strategy (as per comments, Q26). This strategy needs to be focused on the key long-term goal of preventing, reducing and stabilising overweight and obesity in Australia.

▪ The premise that the guidelines are “free from industry influence” which

implies that industry is not an important stakeholder for consultation and it detracts from the importance of multisectoral approaches taken in food and nutrition policy and regulations. This recommendation is at odds with the Ottawa Charter, the outcome of the First International Conference on Health Promotion, organized by the World Health Organization (WHO) in 1986. The Charter states that “...the prerequisites and prospects for health cannot be ensured by the health sector alone.”

▪ More importantly, health promotion demands coordinated action by all: by governments, by health and other social and economic sectors, by nongovernmental and voluntary organisations, local authorities, industry and academia. Industry can and should have a seat at the table as it is an important stakeholder with a valuable perspective on food supply issues related to guideline development.

It is the very strong view of the Australian Beverages Council and its Members that industry must be afforded the opportunity to contribute its expertise and to take part in all fora in the development and implementation of the National Obesity Strategy. Part of this engagement with industry should be a collaborative agreement to manage and monitor reformulation targets.

1 Kantar Public (2017). Healthy Weight and Lifestyle, Exploratory Research Report.

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he premise that the guidelines are “free from industry influence” which implies that industry is not an important stakeholder for consultation and i

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multisectoral approach

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rition policy and regulations. This recommendation is at odds with

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International Conference on Health

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he World Health Organization (WHO) in 1986. The

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he World Health Organization (WHO) in 1986. The Charter states that “...the prerequisites and prospects for health cannot be

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Charter states that “...the prerequisites and prospects for health cannot be ensured by the health sector alone.”

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ensured by the health sector alone.”

tion demands

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tion demands coordinated action by all

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coordinated action by allalth and other social and economic sectors, by nongovernmental

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alth and other social and economic sectors, by nongovernmental , local authorities

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, local authorities,

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, industry and academia.

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industry and academia.and should have a seat at the table as it is an

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and should have a seat at the table as it is an important stakeholder with a valuable

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important stakeholder with a valuable ply issues related to guideline development.

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ply issues related to guideline development.

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Members that industry must be afforded the opportunity to contribute its rtise and to take part in all fora in the development and imp

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rtise and to take part in all fora in the development and impof the National Obesity Strategy. Part of this engagement with industry

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of the National Obesity Strategy. Part of this engagement with industry should be a collaborative agreement to manage and monitor reformulation

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should be a collaborative agreement to manage and monitor reformulation

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targets.

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targets.

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Q38. Proposed Enabler 2: Better use of data – sharing knowledge and data and using evidence to develop policies and programs and to make sure collective actions are effective The second proposed strategy for this enabler is: Build and share knowledge so decisions are better informed. Please rate the extent to which you think each of the following proposed ideas is important for guiding action under this strategy. You can use the comment boxes in the online survey to provide any feedback you might have about each idea.


Slightly important


Very important

Extremely important

I’m not sure

Commit sustained funding to support data collection, shared data systems, enhanced sharing of effective and emerging initiatives, and regular population monitoring and surveillance of weight status and variables associated with overweight and obesity, including wider commercial, cultural and environmental determinants of obesity

☐ ☐ ☐ ☐ ☒ ☐

Boost participation rates in population monitoring and surveillance to ensure accurate and reliable statistics at sub-national levels and representativeness for at-risk population groups

☐ ☐ ☐ ☐ ☒ ☐

Investigate new data sources to supplement population monitoring and surveillance (e.g., supermarket transaction data, Google analytics)

☐ ☐ ☐ ☐ ☒ ☐

Use data to regularly update consumers, communities and ☐ ☐ ☐ ☐ ☒ ☐

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and regular population monitoring

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and regular population monitoring and surveillance of weight status

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and surveillance of weight status s associated with

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s associated with overweight and obesity, incl

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overweight and obesity, including

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uding wider commercial, cultural and

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wider commercial, cultural and environmental determinants of

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environmental determinants of

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stakeholders with independent, accurate and easily understood information

Use data to build connections between communities and the health, social sciences and environmental disciplines

☐ ☐ ☒ ☐ ☐ ☐

Support a collaborative analysis of research on interventions and strategies (from systematic reviews, and primary and grey literature) addressing healthy eating, physical activity and obesity-related outcomes for Aboriginal and Torres Strait Islander people and other population groups experiencing higher levels of overweight and obesity

☐ ☐ ☐ ☐ ☒ ☐

COMMENTS: The Australian Beverages Council strongly supports the need to “Investigate new data sources to supplement population monitoring and surveillance (e.g. supermarket transaction data, Google analytics)”. It is recommended that the proposed strategy “Build and share knowledge so decisions are better informed”, keeps up to date with:

1. The changes in the influences on food purchasing behaviour and the channels consumers engage with including: ▪ the exponential increase in online meal delivery systems like Uber Eats

and Deliveroo that are impacting on consumer choice with little or no information on the health or nutritional value of the food;

▪ sources of healthy lifestyle and nutrition information e.g. the impact of social media influencers on millennials views on food and health.

2. Consumer understanding, perceptions and motivations for healthier eating

and lifestyles: ▪ Up-to-date consumer research is essential to inform the final strategy

and actions to ensure targeted, meaningful communications as well as evaluation. Clearly, a ‘one-size fits all’ approach will not work. The need for targeted communications to accommodate the increasingly diversifying knowledge and understanding, perceptions and motivations of the Australian population with respect to healthy

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strongly supportsources to supplement population monitoring and surveillance (e.g.

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sources to supplement population monitoring and surveillance (e.g. supermarket transaction data, Google analytics)”

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supermarket transaction data, Google analytics)”

recommend

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recommended that

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ed that th

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the proposed

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e proposeddecisions are better informed”,

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decisions are better informed”,

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lifestyle behaviours was a key recommendation from the “Healthy Weight and Lifestyle” consumer research report. 1 The researchers identified five consumer segments based on their commitment to eating healthily and being physically active with specific intervention recommendations. For example: ▪ Priority 1 – Ambivalent. Represents 40% of the population and

has higher representation of males, younger people and mid to low household income. A multi-pronged approach was suggested to help this segment become more committed to achieving a healthier lifestyle, through a combination of motivation, incentives and inducement. Communication needs to: Reflect the younger demographic and be more contemporary; Have tailored executions for males and females; and depict people of a low and middle household income to ensure relevance.

▪ Priority 2 – Committed and Engaged. Represents 24% of the population and is characterised by very positive attitudes and behaviours. By comparison to the Ambivalent segment, the researchers recommended communication focused on positive “reinforcing and rewarding” while nudging them towards 4 serves of vegetables daily.

▪ Priority 3 – Struggling and Deniers. A challenging segment representing 37% of the population with the highest incidence of obesity. The researchers recommended that any messaging for this segment should focus on over-eating and portion control.

1 Kantar Public (2017). Healthy Weight and Lifestyle, Exploratory Research Report.

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les and females; and depict people of a low and

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les and females; and depict people of a low and levance.

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is characterised by very positive attitudes and

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researchers recommended communication focused on positive

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researchers recommended communication focused on positive g and rewarding” while nudging them towards 4 serves

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g and rewarding” while nudging them towards 4 serves

Struggling and Deniers

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Struggling and Deniers.

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. A challenging segment

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A challenging segment

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of the population with

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of the population withThe researchers recommended that any messaging fo

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The researchers recommended that any messaging fothis segment should focus on over

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this segment should focus on over

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1Q39. Proposed Enabler 2: Better use of data – sharing knowledge and data and using evidence to develop policies and programs and make sure collective actions are effective Are there any additional strategies you think should be included to strengthen evidence and data systems to help guide investment, assess impact, improve outcomes, and continue to grow the evidence base? Please provide your comments in the space below. The Australian Beverages Council strongly supports more regular Australian National Nutrition and Physical Activity Surveys as the last one was conducted eight years ago (2011-12) In order to develop meaningful evidence-based policy, it is important that the Australian Government, through the Australian Bureau of Statistics, conducts regular surveys of the Australian population to estimate current food and nutrient intakes, and changes over time. In a similar manner to the United States’ National Health and Nutrition Examination Survey (NHANES), it is recommended that government funding be allocated for national nutrition and physical activity surveys of all Australians aged 2+ years every three to five years. Currently, the national nutrition survey is carried out in Australia on a sporadic basis. As other stakeholders have noted, to compliment this research, it would be worthwhile reinstituting the collection of Australian Bureau of Statistics Apparent Consumption data for all core commodities. Q40.The Australian Beverages Council supports strong governance protocols to ensure the National Obesity Strategy meets its objectives while ensuring a multi-stakeholder approach is maintained. The creation of a Retailers’, Manufacturers’ and Suppliers’ Committee [RMSC] or similar is recommended to provide detailed feedback on each phase of the National Obesity Strategy and, where possible, assist in its implementation. The Australian Beverages Council would welcome the opportunity to support the non-alcoholic beverage industry on a committee of this nature by acting as a conduit between the non-alcoholic drinks industry and government.

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as the last one was conducted

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based policy, it is important that the

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based policy, it is important that the Australian Government, through the Australian Bureau of Statistic

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Australian Government, through the Australian Bureau of Statistic

current

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current food and nutrient intakes, and

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food and nutrient intakes, and

In a similar manner to the United States’ National Health and Nutrition Examination

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In a similar manner to the United States’ National Health and Nutrition Examination recommend

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recommended

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ed that

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that government funding

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government funding

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and physical activity

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and physical activity survey

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surveythree to five years. Currently, the national nutrition survey is carried out in Australia

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three to five years. Currently, the national nutrition survey is carried out in Australia on a sporadic basis. As other stakeho

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on a sporadic basis. As other stakeholders have

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lders have it would be worthwhile reinstituting the collection of Australian Bureau of S

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it would be worthwhile reinstituting the collection of Australian Bureau of SApparent Consumption data for all core commodities.

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Apparent Consumption data for all core commodities.

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Q42. Proposed Enabler 4: Invest for delivery - Adequately funding sustainable interventions and preventative actions, and exploring economic policies and trade agreements to positively impact on overweight and obesity rates, communities and the environment For this proposed enabler, there is one proposed strategy with four ideas to guide action. These are discussed in detail on page 31 of the consultation paper. The proposed strategy for this enabler is: Provide adequate investment in sustainable interventions that promote healthy weight. Please rate the extent to which you think each of the following proposed ideas is important for guiding action under this strategy. You can use the comment boxes in the online survey to provide any feedback you might have about each idea.


Slightly important


Very important

Extremely important

Provide additional funds for effective delivery of comprehensive, contemporary and sustained actions at an appropriate scale

☐ ☐ ☐ ☐ ☐

Explore new, innovative funding mechanisms for prevention of overweight and obesity, including a potential

☐ ☐ ☐ ☒ ☐

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te the extent to which you think each of the following proposed ideas is

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he online survey to provide any feedback you

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he online survey to provide any feedback you

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importantSlightly

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important

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delivery of

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prevention investment fund

Ensure formal and informal engagement of public health expertise in trade and investment agreement development processes

☒ ☐ ☐ ☐ ☐

Assess health impacts of trade agreements during negotiations to ensure they favour the production and distribution of healthy food and drinks and control that of unhealthy food and drinks

☒ ☐ ☐ ☐ ☐

Investigate ways of reorienting economic policies, subsidies, investment and taxation systems to best benefit healthy eating and drinking, active living, health outcomes, communities and the environment

☒ ☐ ☐ ☐ ☐

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Q43. Proposed Enabler 4: Invest for delivery - Adequately funding sustainable interventions and preventative actions, and exploring economic policies and trade agreements to positively impact on overweight and obesity rates, communities and the environment Are there any additional strategies you think should be included to provide adequate and sustainable investment in overweight and obesity prevention? Please provide your comments in the space below. Sustainability, trade policy and economic policy should be removed from the National Obesity Strategy. Sustainability is more relevant to a national nutrition policy. There is insufficient evidence to support its inclusion to reduce the prevalence of obesity and may result in unintended negative consequences. The inclusion of trade agreements and economic policy risk the National Obesity Strategy’s core objective. Section 5. Proposed implementation, monitoring, evaluation and reporting of a national obesity strategy Lastly, we would like to get your feedback on the proposed implementation and evaluation of a national obesity strategy. This is discussed in detail on pages 32 and 33 of the consultation paper. Q46. Proposed governance arrangements for a national obesity strategy The COAG Health Council will be responsible for strategy implementation, monitoring and progress reporting. While the strategy will be led by Health, to achieve the vision, Health will work with partners across government and the community. Accordingly, the COAG Health Council will be supported by:

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National Obesity Strategy. Sustainability is more relevant to a national nutrition

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policy. There is insufficient evidence to support its inclusion to reduce the

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policy. There is insufficient evidence to support its inclusion to reduce the prevalence of obesity and may result in unintended negative c

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prevalence of obesity and may result in unintended negative consequences.

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onsequences. inclusion of trade agreements and economic policy risk the National Obesity

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inclusion of trade agreements and economic policy risk the National Obesity

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Proposed implementation, monitoring, evaluation and

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Proposed implementation, monitoring, evaluation and a national obesity strategy

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e would

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like to get your feedback on the proposed implementation and

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• the Australian Health Ministers Advisory Council, and • a new cross-portfolio federal, state and local government committee with

representatives from essential supporting sectors. Partnerships with non-government organisations, private sector, population group representatives and community members will inform implementation of the strategy. The Australian Institute of Health and Welfare will support development of indicators and monitoring and reporting. Do you have any feedback about the proposed governance arrangements for a national obesity strategy? Please provide your comments in the space below. The Australian Beverages Council supports the creation of a Retailers’, Manufacturers’ and Suppliers’ Committee [RMSC] or similar and this structure is recommended to provide detailed feedback on each phase of the National Obesity Strategy and, where possible, assist in its implementation. Q47. Proposed implementation for a national obesity strategy Under the auspices of the Australian Health Ministers Advisory Council, it is proposed the new cross-portfolio committee will be responsible for developing an implementation plan that will focus on those strategies best pursued at a national level. This approach will be supported by implementation plans developed by each state and territory, in collaboration with local partners and in discussion with other jurisdictions to ensure breadth of coverage and coordination across Australia. The plans will include timeframes and responsibilities for implementation. Resources will be required for implementation. Do you have any feedback about the proposed implementation for a national obesity strategy? Please provide your comments in the space below. The Australian Beverages Council welcomes the opportunity to provide a unified position on each part of the implementation plan at the national, state and local levels.

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] or similar

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recommended to provide detailed feedback on each phase of the National Obesity

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ble, assist in its implementation.

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ble, assist in its implementation.

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ices of the Australian Health Ministers Advisory Council, it is

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ices of the Australian Health Ministers Advisory Council, it is proposed the new cross

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proposed the new cross-

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-portfolio committee will be responsible for developi

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portfolio committee will be responsible for developiimplementation plan that will focus on those strategies best pursued at a national

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implementation plan that will focus on those strategies best pursued at a national

This approach will

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be supported by implementation plans developed by each state

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be supported by implementation plans developed by each state and territory, in collaboration with local partners and in discussion with oth

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and territory, in collaboration with local partners and in discussion with oth

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jurisdictions to ensure breadth of coverage and coordination across Australia. The RTI Rele

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The creation of a Retailers’, Manufacturers’ and Suppliers’ Committee [RMSC] or similar is recommended to provide detailed feedback on each phase of the National Obesity Strategy and, where possible, assist in its implementation. Q48. Proposed monitoring, evaluation and reporting process for a national obesity strategy Monitoring the implementation of this strategy will require a coordinated national effort. A tiered national evaluation framework will monitor progress and achievements and include:

• indicators to show shorter-term progress • outcome measures aligned with priority areas, and • targets.

To ensure a transparent focus on equity, the framework will include indicators, outcomes and targets specifically for population groups who are unequally affected by overweight and obesity. Existing data sources will be utilised with potential for additional new measures. Both national measures and jurisdictional information will contribute, and results will be regularly reported to COAG Health Council and available to the public. Solutions to addressing overweight and obesity in Australia are not static. Incorporating feedback on barriers, enablers and effects of actions on a regular basis is necessary. Building a process of gathering information, reflecting and adapting will strengthen future action to ensure relevance and effectiveness. Do you have any feedback about how the strategy should be monitored, evaluated and reported? Please provide your comments in the space below. The Australian Beverages Council supports the need for a regular evaluation process and propose an annual progress report is publicly available online that includes an update on current initiatives, current actions against milestones, challenges and opportunities. It is essential that committees and working groups, comprised of government, industry, non-government organisations and academia, are created to develop the National Obesity Strategy and monitoring and evaluate its progress. The Australian Beverages Council welcomes the opportunity to work with stakeholders to provide industry data and trends, as appropriate, to support the objectives of the National Obesity Strategy.

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ure a transparent focus on equity, the framework will include indicators,

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ure a transparent focus on equity, the framework will include indicators, outcomes and targets specifically for population groups

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outcomes and targets specifically for population groups who are unequally affected

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who are unequally affected

ilised with potential for additional n

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ilised with potential for additional nBoth national measures and jurisdictional information will contribute, and results

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Both national measures and jurisdictional information will contribute, and results will be regularly reported to COAG Health Council and available to the public.

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will be regularly reported to COAG Health Council and available to the public.

Solutions to addressing overweight and obe

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Solutions to addressing overweight and obesity in Australia are not static.

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sity in Australia are not static. rporating feedback on barriers, enablers and effects of actions on a regular basis

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rporating feedback on barriers, enablers and effects of actions on a regular basis is necessary. Building a process of gathering information, reflecting and adapting will

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is necessary. Building a process of gathering information, reflecting and adapting will strengthen future action to ensure relevance an

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strengthen future action to ensure relevance an

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and reported?

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Each committee and working group, given the composition of these groups, should include: 1) A charter 2) Terms of reference 3) Code of conduct and complaints procedure 4) An anti-competition statement 5) Clear objectives and progress measurement Novel ways to convene committee meetings and working groups should be considered to improve the accessibility of stakeholders outside of capital cities, including webinars or Zoom meetings. Q49. Do you think targets are needed for the strategy? If so, what should they be? Please provide your comments in the space below. The Australian Beverages Council supports the need for development of targets to guide the Strategy. The development of the National Obesity Strategy needs to include the development of clear measurable goals with specific targets and timelines to provide a framework for the recommended strategies and ideas in a meaningful way. Currently, from reviewing the Consultation Paper, the goal of the strategy is unclear beyond to ‘reduce overweight and obesity’. The Australian Beverages Council recommends careful consideration of the feasibility of this goal given the key fact outlined in the Consultation Paper, “the number of adults living with obesity has doubled in the last 10 years”. Therefore, a more realistic goal might be “To halt any further increase in adults living with obesity”. In relation to childhood obesity, the prevalence of obesity can and should be reduced, with the strongest evidence supporting comprehensive, multi-faceted and system-wide intervention. There is evidence that these types of programs can be effective at improving diet and preventing obesity in both Australian children and in adolescent populations, and the effectiveness of systems-wide approaches likely reflects the highly complex and multifaceted nature of obesity. In addition, the Australian Beverages Council suggests development of specific goals for higher risk communities e.g. people living in the areas of most disadvantage to

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for the strategy

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for the strategy? If so, what should they be?

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? If so, what should they be?

Please provide your comments in

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the space below.


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The Australian Beverages Council support

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supports

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s the need for development of targets

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the need for development of targets he development of the

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he development of theinclude the development of

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include the development of clear

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clear measurable goals

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measurable goalsprovide a framework for the recommended

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provide a framework for the recommended

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meaningful way.

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meaningful way.

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ensure the recommended strategies and actions are targeted to address the needs of the specific community and/or consumer segment within the community. The Australian Beverages Council supports targeted approaches to reduce or prevent overweight and obesity with regard given to: o Remoteness and the distance from metropolitan areas; o Socio-economics; o The summary measure of disadvantage; o Occupation or industry of occupation; o Casual employees and shift or night workers; o Indigenous Australians (Indigenous Status); o Non-English-speaking background (NESB); o Income support recipients; o Barriers to accessing transport, healthcare or similar services; and o Highest education levels. Q50. Do you have any suggestions for what a national obesity strategy could be called? Please provide your comments in the space below. Obesity 2030: Working together for a lighter future Q51. Lastly, do you have any final comments or ideas regarding the proposed national obesity strategy? The Australian Beverages Council recommends that:

1. Additional work be carried out to define ‘unhealthy’ and ‘healthy’, and the industry supports the use of the revised Health Star Rating algorithm as a solution to define ‘healthier’ products.

2. Pricing measures between manufacturers and retailers be excluded from the National Obesity Strategy as these are agreements that operate in a functioning competitive market.

3. The prevalence of obesity can and should be reduced, with the strongest evidence supporting comprehensive, multi-faceted and system-wide intervention. There is evidence that these types of programs can be effective at improving diet and preventing obesity in both Australian children and in

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a nati

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onal obesity strategy


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king together for a lighter future

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king together for a lighter future

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adolescent populations, and the effectiveness of systems-wide approaches likely reflects the highly complex and multifaceted nature of obesity.

4. A collaborative approach between all stakeholders, including governments, food and beverage industry players and non-government health organisations, are needed to deliver comprehensive, system-wide models.

5. A coordinated approach should focus on reducing energy intake from all discretionary foods and not exclusively from certain non-alcoholic beverages.

6. Existing Government policies and programs, including the Health Star Rating and Healthy Food Partnership should be continued and their funding secured.

7. There is limited and weak evidence that sugar-sweetened beverage taxes are effective in reducing obesity, with consistent global evidence suggesting the introduction of a sugar-sweetened beverage tax has not any discernible impact on public health. A sugar-sweetened beverages tax may also have unintended consequences on the diet.

8. Recognition of the non-alcoholic beverage industry’s public commitments be integrated as part of the holistic food supply solution to address obesity in Australia, particularly voluntary initiatives that have been undertaken to help reduce intake of sugars.

9. Sustainability, trade policy and economic policy should be removed from the National Obesity Strategy. Sustainability is more relevant to a national nutrition policy. There is insufficient evidence to support its inclusion to reduce the prevalence of obesity and may result in unintended negative consequences. The inclusion of trade agreements and economic policy risk the National Obesity Strategy’s core objective.

Important comment about the nature of the long-form survey: The nature of the long-form survey presents some challenges in responding to the complex issue of overweight and obesity. The Australian Beverages Council understands that: 1. The ratings of strategies and sub-strategies in the long form survey allow the reviewer to see which strategies are most important and least important to respondents. 2. The ratings give additional context to the comments provided and will not be interpreted in isolation. 3. The rating scales also help the reviewer to dissect the details of the consultation paper, beyond feedback comments.

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sweetened beverage taxes are effective in reducing obesity, with consistent global evidence suggesting the

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sweetened beverage tax has not any discernible

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sweetened beverages tax may also have

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alcoholic beverage industry’s public commitments be

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alcoholic beverage industry’s public commitments be of the holistic food supply solution to address obesity

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of the holistic food supply solution to address obesityparticularly voluntary initiatives that have been undertaken to help

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particularly voluntary initiatives that have been undertaken to help

, trade policy and economic policy

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, trade policy and economic policytrategy. Sustainability is more relevant to a natio

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trategy. Sustainability is more relevant to a natiohere is

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here is insufficient

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insufficient evidence to support its inclusion to

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evidence to support its inclusion to reduce the prevalence of obesity and may result in unintended negative

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reduce the prevalence of obesity and may result in unintended negative

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4. The ratings will be used to split the analysis of the comments provided. For example, the reviewer can split the ideas and comments by those who rated a strategy as more important and those who rated it as less important. Given the broad nature of some of the strategies/ideas contained in the consultation paper, it is challenging to accurately reflect a position and it is imperative that all comments be considered as qualifying remarks to the respective positions expressed in the ratings boxes.

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Katrina Crompton

From: @ausbev.org>Sent: Monday, 16 December 2019 8:19 AMTo: Simone BraithwaiteSubject: RE: National Obesity Strategy Submission

Many thanks, Simone. I received your voicemail, and apologise for the time it has taken to get back to you, but the mobile phone in the room isn’t from our group. Kind regards,

| Public Affairs Australian Beverages Council 2/2 Allen Street, Waterloo NSW 2017 T: + 61 2 9698 1122 I M: +

@ausbev.org www.australianbeverages.org

From: Simone Braithwaite <[email protected]> Sent: 16 December 2019 08:57 To: @ausbev.org>; Mark West <[email protected]> Cc: Elizabeth Good <[email protected]>; @ausbev.org> Subject: Re: National Obesity Strategy Submission Dear Thank you for this submission and your contribution to the national consultation process. I appreciate you sending this through. Simone Get Outlook for iOS

From: @ausbev.org> Sent: Friday, December 13, 2019 1:21:57 PM

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Simone Braithwaite <[email protected]>

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To: Mark West <[email protected]> Cc: Simone Braithwaite <[email protected]>; Elizabeth Good <[email protected]>;

@ausbev.org> Subject: National Obesity Strategy Submission Dear Mark, Simone and Liz, Many thanks for making the time to consult with us last week. We trust you found the discussion beneficial – we certainly did. The Australian Beverages Council has submitted its feedback on behalf of the non-alcoholic beverage industry via the consultation portal. Some references may have not appropriately linked in the response forms and we have attached the full document for noting. If you have any questions, please do not hesitate to contact us. We look forward to learning about the next stage of the National Obesity Strategy and supporting this important work. Kind regards,

| Public Affairs Australian Beverages Council 2/2 Allen Street, Waterloo NSW 2017 T: + 61 2 9698 1122 I M: +

@ausbev.org www.australianbeverages.org

********************************************************************************

This email, including any attachments sent with it, is confidential and for the sole use of the intended recipient(s). This confidentiality is not waived or lost, if you receive it and you are not the intended recipient(s), or if it is transmitted/received in error.

Any unauthorised use, alteration, disclosure, distribution or review of this email is strictly prohibited. The information contained in this email, including any attachment sent with it, may be subject to a statutory duty of confidentiality if it relates to health service matters.

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aseIf you have any questions, please do not hesitate to contact us. We look forward to learning about the next stage of the

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2/2 Allen Street, Waterloo NSW 2017

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2/2 Allen Street, Waterloo NSW 2017

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If you are not the intended recipient(s), or if you have received this email in error, you are asked to immediately notify the sender by telephone collect on Australia +61 1800 198 175 or by return email. You should also delete this email, and any copies, from your computer system network and destroy any hard copies produced.

If not an intended recipient of this email, you must not copy, distribute or take any action(s) that relies on it; any form of disclosure, modification, distribution and/or publication of this email is also prohibited.

Although Queensland Health takes all reasonable steps to ensure this email does not contain malicious software, Queensland Health does not accept responsibility for the consequences if any person's computer inadvertently suffers any disruption to services, loss of information, harm or is infected with a virus, other malicious computer programme or code that may occur as a consequence of receiving this email.

Unless stated otherwise, this email represents only the views of the sender and not the views of the Queensland Government.

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Katrina Crompton

From: NOS_SecretariatSent: Monday, 13 January 2020 8:58 AMTo: Engage Social Deck; Mel Butcher; Kate BowmakerCc: Simone Braithwaite; Elizabeth Good; NOS_SecretariatSubject: FW: Meeting notes - Aust Beverages Council re NOSAttachments: Meeting - 19-12-6 - Notes - ABCL.docx

Dear Kate and Mel, Please find attached some notes taken at a meeting between the Australian Beverages Council and the Preventive Health Branch. This meeting was requested by ABCL as an addition to their submission. Please could you review the notes in relation to the consultation analysis, and only include any issues that were NOT covered in the ABCL submission (long form survey). Let me know if you have any questions. Cheers Deanne

Deanne Wooden Senior Public Health Nutritionist Phone: 07 3328 9318 Address: 15 Butterfield Street, Herston, QLD 4006 Email: [email protected] Queensland Health Health and Wellbeing Unit, Preventive Health Branch, Prevention Division

www.health.qld.gov.au

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Please find attached some notes taken at a meeting between the Australian Beverages Council and the Preventive

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Please find attached some notes taken at a meeting between the Australian Beverages Council and the Preventive Health Branch. This meeting was requested by ABCL as an addition to their submission.

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aseHealth Branch. This meeting was requested by ABCL as an addition to their submission.

Please could you review the notes in relation to the consultation analysis, and only include any issues that were NOT

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asePlease could you review the notes in relation to the consultation analysis, and only include any issues that were NOT

15 Butterfield Street, Herston, QLD 4006

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15 Butterfield Street, Herston, QLD 4006 [email protected]

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[email protected]

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Health and Wellbeing Unit, Preventive Health Branch, Prevention Division

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Health and Wellbeing Unit, Preventive Health Branch, Prevention Division

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www.health.qld.gov.au RTI Rele

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From: Elizabeth Good <[email protected]> Sent: Friday, 10 January 2020 2:35 PM To: NOS_Secretariat <[email protected]> Subject: Meeting notes - Aust Beverages Council re NOS Hi Deanne As discussed, please find attached the notes from the meeting with Australian Beverages Council in December. Also saved at: Y:\PHB\GOVERNMENT RELATIONSHIPS\PROJECT\HW - COAG - Nat Obesity Strat – Consultation Apologies for not getting them typed pre-Christmas. Cheers Liz

Liz Good Senior Nutritionist (Monday, Thursday, Friday) My workplace has a flexible working policy – I work from home on Mondays 9.45am to 1.45pm and can be contacted by email. Phone: 07 3328 9248 Address: 15 Butterfield Street, Herston QLD 4006 Email: [email protected] Queensland Health Health and Wellbeing Unit, Preventive Health Branch, Prevention Division

www.health.qld.gov.au

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As discussed, please find attached the notes from the meeting with Australian Beverages Council in December.

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As discussed, please find attached the notes from the meeting with Australian Beverages Council in December.

Also saved at: Y:\PHB\GOVERNMENT RELATIONSHIPS\PROJECT\HW - COAG - Nat Obesity Strat – Consultation

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Also saved at: Y:\PHB\GOVERNMENT RELATIONSHIPS\PROJECT\HW - COAG - Nat Obesity Strat – Consultation

Apologies for not getting them typed pre-Christmas.

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Apologies for not getting them typed pre-Christmas.

My workplace has a flexible working policy – I work from home on Mondays 9.45am to 1.45pm

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My workplace has a flexible working policy – I work from home on Mondays 9.45am to 1.45pm and can be contacted by email.

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and can be contacted by email.

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07 3328 924815 Butterfield Street, Herston QLD 4006 RTI R

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Queensland’s Health Vision: By 2026 Queenslanders will be among the healthiest people in the world.

Queensland Health acknowledges the Traditional Owners of the land, and pays respect to Elders past, present and future.

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Prepared by Liz Good, Senior Nutritionist – 10 January 2019 Y:\PHB\GOVERNMENT RELATIONSHIPS\PROJECT\HW - COAG - Nat Obesity Strat - Consultation

National Obesity Strategy Public Consultation Notes from meeting with the Australian Beverages Council Limited (ABCL) on 6 December 2019 Attendees: • , Chief Executive Officer, Australian Beverages Council • , Public Affairs Manager, Australian Beverages Council • , Scientific and Regulatory Affairs Manager, Coca-Cola South Pacific • , Public Affairs Manager, Coca-Cola South Pacific • Senior Director, Public Policy, Government Affairs and Communications - Asia-Pacific,

PepsiCo • Mr Mark West, Executive Director, Preventive Health Branch; and Chair of National Obesity Strategy

Working Group • Ms Simone Braithwaite, Manager, Preventive Health Branch • Ms Liz Good, Senior Nutritionist, Preventive Health Branch

ABCL’s objectives for the meeting: • To introduce ABCL to the Queensland Government. • To discuss topics in National Obesity Strategy of interest. Will provide submission (long form).

Background: • ABCL has large members (e.g. Coca-Cola Amatil, Coca-Cola South Pacific, Pepsico, Asahi) and

small/medium members (e.g. Bundaberg Drinks, Cook Beverages). • ABCL is part of many global networks and has internal working groups – refer to presentation. • Key pillars have recently been updated. • ABCL instrumental in getting Qld’s container scheme up and running. The scheme works better in Qld

than other jurisdictions as learnt from other schemes. Industry/government – mutual benefits, being involved at the beginning.

• Advocate an industry role in all parts of the policy process, including decision points. Government-Industry-Consumer arrangement is important. 80/20 to get things on the board and don’t need to agree on everything.

• Sugar reduction pledge: ▪ About 85% of the market with 4 signatories. ▪ Looking at change from 2015 as had been talking for so long before the 2018 launch of the

pledge. ▪ 2020/2025 split of targets as needed a midpoint, reflected companies’ level of confidence to

reduce sugar, sugar level modelling known until 2020 when started discussing in 2015; 10-year timeframe too long.

▪ To date – more no / low sugar varieties, small pack sizes, canteens, marketing of no / low sugar varieties, vending machines, reformulation.

▪ New research on 20-year sales trend analysis – 1997-2011; 2012-2018 – just been submitted for publication.

▪ 25 recipes changes across industry – all by Coca-Cola South Pacific. ▪ Q1 2020 action – ‘supporting signatories’ – many smaller companies don’t have the product

breadth or depth to participate in the pledge. • Pepsico – ‘winning with purpose’ focus – people, planet, product; snack share is higher than drinks in

Australia. • Coca-Cola South Pacific – 17-20% of sales are water; Sprite 40% less sugar – long process to develop. • Queensland – 10,000 industry jobs, $1.2B contributed to economy. • Energy drink commitments:

▪ No sale into schools. Have a consuming facing website.

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y of interest. Will provide submission (long form).

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y of interest. Will provide submission (long form).

Cola Amatil, Coca

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Cola Amatil, Coca-

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-Cola South Pacific, Pepsico, Asahi) and

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Cola South Pacific, Pepsico, Asahi) and small/medium members (e.g. Bundaberg Drinks, Cook Beverages).

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small/medium members (e.g. Bundaberg Drinks, Cook Beverages).and has internal working groups

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and has internal working groups

ABCL instrumental in getting Qld’s container scheme up and running. The scheme works better in Qld

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ABCL instrumental in getting Qld’s container scheme up and running. The scheme works better in Qld than other jurisdictions as learnt from other schemes.

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than other jurisdictions as learnt from other schemes. Indus

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Indus

Advocate an industry role in all parts of the policy process, including decision points. Government

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Advocate an industry role in all parts of the policy process, including decision points. GovernmentConsumer arrangement is important. 80/20 to get things on the board and don’t ne

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Consumer arrangement is important. 80/20 to get things on the board and don’t ne

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Sugar reduction pledge:

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Sugar reduction pledge:About 85% of the market with 4 signatories.

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About 85% of the market with 4 signatories. Looking at change from 2015 as had been talking for so long before the 2018 launch of the

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reduce sugar, sugar level modelling known until 2020 when started discussing in 2015; RTI Rele

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timeframe too long.

Prepared by Liz Good, Senior Nutritionist – 10 January 2019 Y:\PHB\GOVERNMENT RELATIONSHIPS\PROJECT\HW - COAG - Nat Obesity Strat - Consultation

▪ Food Standards Code Standard 2.6.4 – toughest in world. ▪ Caffeine in a 250mL can equals caffeine in 1 cup of instant coffee. ▪ Adolescents – more caffeine from coffee than energy drinks. ▪ Males 19-34yr are key market. ▪ 2% of total market of non-alcoholic drinks – minimal growth (cf flavoured milk 2-3%, sports drinks

2%); water is key growth market. • Advertising standard:

▪ Revised in 2019 – now 14-year threshold – previously 12 year and 35% audience share. ▪ All media captured. Advertised directed to children. ▪ Compliance and enforcement process being developed.

• Support transparency.

Comments on National Obesity Strategy: • ABCL are excited by the strategy and want to play their part.

• Sugar-sweetened beverages taxation:

▪ Do not support a sugar tax. It is not good economic policy. It is not good for public health – limited evidence.

▪ Barry Popkin’s research on the Mexico tax showed that sustained reduction in consumption was not met; and that while the tax revenue decreased 1.6% in the first year, it came back to pre-tax levels and is now climbing again.

▪ In the UK, the tax kick-started reformulation, but the UK industry was lagging Australia in its reformulation efforts.

When asked what would work – need to be creative, bold, innovative; need to have discussions regarding alcohol and weight; include other industries (e.g. confectionery as have a higher contribution to discretionary food intake). • Compositional limits:

▪ Concerned that duplicates Healthy Food Partnership. ▪ Do not support compositional limits for beverages or as a general concept. ▪ Question what the link is to reducing obesity. ▪ Coca-Cola South Pacific have internal composition limits to meet the industry’s sugar reduction

pledge.

• Advertising restrictions: ▪ Already happening within industry self-regulation.

• Sustainability:

▪ There is a risk that is too broad – the strategy is about obesity. ▪ Should keep to level of Sustainable Development Goals – not focus on sustainability at sub-

strategy level.

• What does success look like? – reduction of obesity is ambitious and slowing growth would be a better target.

• Cane growing industry – Coca-Cola Amatil and Great Barrier Reef Partnership. 20% domestic sugar production – sugar-sweetened beverages is biggest user.

• Industry will keep offering choice and make products with sugar.

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aseeconomic policy. It is not good for public health

Barry Popkin’s research on the Mexico tax showed that sustained reduction in consumption was

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Barry Popkin’s research on the Mexico tax showed that sustained reduction in consumption was not met; and that while the tax revenue decreased 1.6% in the first year, it came back to pre

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not met; and that while the tax revenue decreased 1.6% in the first year, it came back to pre

started reformulation, but the UK industry was

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started reformulation, but the UK industry was

need to be creative, bold, innovative; need to have

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need to be creative, bold, innovative; need to have ; include other industries (e.g. confectionery as have

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; include other industries (e.g. confectionery as have

Concerned that duplicates Healthy Food Partnership.

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Concerned that duplicates Healthy Food Partnership.

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Do not support compositional limi

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Do not support compositional limits for beverages or as a general concept.

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ts for beverages or as a general concept.Question what the link is to reducing obesity.

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Question what the link is to reducing obesity.Cola South Pacific have internal composition limits to meet the industry’s sugar reduction

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Cola South Pacific have internal composition limits to meet the industry’s sugar reduction

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Prepared by Liz Good, Senior Nutritionist, PHB. For Mark West, Executive Director, PHB.

Meeting with Australian Beverages Council: 6 December 2019 Recent engagement / correspondence in Queensland • Met with Minister and CHO in March 2019 – industry pledge, labelling, HWQ • Correspondence 21 March 2019 (to MIN) – meeting follow-up (MIN Response 10/6) • Correspondence 24 April 2019 (to MIN) – advertising on government spaces (NRR) • Correspondence 30 October 2019 (to CHO) – labelling and HWQ (CHO Response 14/11)

National Obesity Strategy (ABC submissions available at PHB) • ABC attended the National Obesity Summit held on 15 February 2019 • ABC submission to the Federal Senate Select Committee into the Obesity Epidemic in Australia noted:

▪ the voluntary initiatives undertaken by their industry ▪ the importance of considering the total diet in contributing to obesity ▪ the multiple causes of obesity

• What we would like them to do: ▪ Consider how the non-alcoholic beverage industry can support the implementation of the NOS

Industry Sugar Reduction Pledge • ABC committed to a 20% reduction across portfolio by 2025 • 1 Jan 2015 to 31 Dec 2018 – 7% reduction (on-track to achieve target) – how achieved not reported • What we would like them to do:

▪ Encourage more of the industry to become signatories (only 4 companies are currently – Asashi Lifestyle Beverages, Coca-Cola Amatil, Coca-Cola Australia, PepsiCo))

▪ More transparency in reporting – e.g. how many products were reformulated and how much sugar was removed, how many new low/no sugar products were introduced and sold

Advertising to children • ABC revised self-regulation policy to prohibit any direct advertising of SSBs to those under 14 years • ABC advocated for diet drinks to be allowed to be advertised under the QG Policy (we are still awaiting

final decision from Min’s Office) • What we would like them to do:

▪ Further strengthen self-regulation advertising initiative, e.g. expand restriction to peak TV viewing times (not just designated children’s programming)

▪ Participate in any national discussions (FRSC-led work) Health Star Rating (ABC submissions available at PHB) • ABC will encourage ABC members to roll-out HSR across all products, coordinated with other labelling

changes (71% of products display stars or energy icon) • ABC want to change HSR calculator so that drinks have a greater distribution of stars to encourage

water consumption, while also positively representing low/no kilojoule drinks and juices with no added sugar

• What we would like them to do: ▪ Commit to roll-outing the stars on all products (once Forum response released)

Added sugar labelling (ABC submissions available at PHB) • ABC support consumer education and added sugars on NIP • ABC don’t support FOPL/pictorial labelling for added sugar • What we would like them to do:

▪ Participate in the FSANZ consultation (timing unknown) ▪ Implement any labelling change in a timely manner

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track to achieve target)

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track to achieve target) –

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– how achieved not reported

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how achieved not reported

Encourage more of the industry to become signatories (only 4 companies are

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Encourage more of the industry to become signatories (only 4 companies are Cola Australia, PepsiCo)

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Cola Australia, PepsiCo)e.g. how many products were reformulated and how much

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e.g. how many products were reformulated and how much how many new low/no sugar products were introduced and sold

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how many new low/no sugar products were introduced and sold

regulation policy to prohibit

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regulation policy to prohibit any

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any direct

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direct advertising of SSBs to those under 14 years

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advertising of SSBs to those under 14 yearsABC advocated for diet drinks to be allowed to be advertised under the QG Policy

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ABC advocated for diet drinks to be allowed to be advertised under the QG Policy

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Office)

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Office)What we would like them to do:

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What we would like them to do:Further strengthen self

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Further strengthen self-

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-regulation advertising initiative, e.g.

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regulation advertising initiative, e.g.viewing times (not just designated children’s programming)

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viewing times (not just designated children’s programming)Participate in any national discussions (FRSC

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Participate in any national discussions (FRSC

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water consumption, while also positively representing low/no kilojoule drinks and juices with no added

Prepared by Liz Good, Senior Nutritionist, PHB. For Mark West, Executive Director, PHB.

Health and Wellbeing Queensland • ABC would like an opportunity to be part of stakeholder process to review progress or inform future

direction and priorities of HWQ

NOS Strategies – ones of relevance / potential concern (greatest concern) • Limiting availability of unhealthy drinks – 1.2.2 (home/parents), 1.2.5 (sport & rec, community venues),

2.5.2 (catering, vending machines, cafes)

• Providing information to consumers – 2.1.1 (potential link to HSR, added sugar labelling), 4.6.1 (HSR universal), 4.6.2 (FOPL warning labels) – support HSR (want changes) but don’t support over-emphasising single nutrients or warning labels

• Reformulation (4.3.1), serving size limits (4.3.2), compositional limits (4.3.3) – supports reformulation

▪ as indicated in submission to HFP reformulation consultation: may want financial incentives to support these; would want to align with targets and timing of industry sugar pledge; would want to exclude some products (e.g. juice, diet drinks); would want changes to category definitions

▪ Confidential: • Eliminating unnecessary packaging (4.3.4) – relevance to multi-packs – potential long-term cost saving

for industry if implemented strategy

• Reducing unhealthy drink marketing (4.5) – further than what covered by self-regulation as goes beyond marketing directed to children and focuses on community-wide marketing

▪ Confidential:

• Sustainability indicators on packaging (4.6.5) – cost and regulatory burden to industry; consumer issue so further down food regulation hierarchy (not food safety or preventive health issue)

• Subsidising healthy drinks (4.7.1) – may be interested in who subsidising (industry or govt?)

• Pricing strategies to reduce consumption of SSBs (4.7.2, 4.7.4, 4.7.5)

• Removing Industry influence from ADGs (PE 2.1.1)

• Trade restrictions and taxation (PE 4.1.4, PE 4.1.5)

ABC Members

• Over 70 companies – producers of carbonated diet and regular soft drinks, cordials and concentrates, energy drinks, fruit juice and fruit drinks, functional non-alcoholic drinks, iced teas and coffees, mineral, spring, packaged water, and sports and isotonic drinks

• Qld-based members: ▪ Alchemy Cordial ▪ Bundaberg Brewed Drinks ▪ Bundaberg Sugar ▪ Cooks Soft Drinks ▪ Grove Fruit Juice ▪ Lactalis Australia (Pauls)

▪ Norco Foods ▪ Nu-Pure beverages ▪ Queensland Bottlers ▪ Red Kangaroo Beverages ▪ The Spring Waterman

irrelevant

irrelevant

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food regulation hierarchy (not food safety or preventive health issue)

4.7.1)

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AFGC SUBMISSION At 13 Dec 2019

1

AFGC SUBMISSION COAG HEALTH COUNCIL

Have your say on a national obesity strategy Consultation Paper

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2

PREFACE

T e s al a oo a o e o l s e lea g a o al o ga sa o e ese g s al a s foo a g o e a fa g s

T e e a e o e 180 e e o a es s s a es a asso a es o oge e o se 80 e e of e g oss olla al e of e o esse foo e e age a g o e o s se o s

o os o of s o e 2016 17

a a al o e e 2016 17 f a al ea of 131 3 ll o s al a s foo a g o e a fa g s a es a s s a al o o o e s al a e o o a s al o e a o s f e os e

T e e se a s s a a le s s a e of o e 36 000 s esses a a o s fo o e 72 5 ll o of e a o s e a o al a e T ese s esses a ge f o so e of e la ges

glo all s g f a l a o al o a es o s all a e e e ses I s a e 2 9 ll o a al es e 2016 17 o esea a e elo e

oo e e age a g o e a fa g oge e fo s s al a s la ges a fa g se o e ese g 36 e e of o al a fa g o e s al a

T e foo a g o e a fa g se o e lo s o e a 324 450 s al a s e ese g al os 40 e e of o al a fa g e lo e s al a

a foo a fa g la s a e lo a e o s e e e o ol a eg o s T e s a es a la ge o o o al a eg o al s al a e o o es al os 42 e e of e o al e so s e lo e e g al a eg o al s al a

I s esse al o e e o o a so al e elo e of s al a a a la l al a eg o al s al a a e ag e s g f a e a o o of s s s e og se

a fa o e o e o e e s e o o s al a a e ol es

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a fa g s a es a s s a al o o o e s al a e o o a s al o

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ll o a al es e 2016 17 o esea a e elo e

oo e e age a g o e a fa g oge e fo s s al a s la ges a fa g

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se o e ese g 36 e e of o al a fa g o e s al a

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se o e ese g 36 e e of o al a fa g o e s al a

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3

EXECUTIVE SUMMARY

T e s lease o o e o e Have your say on a national obesity strategy, Consultation Paper e o s l a o o g e eal o l T e s o e o s o g a es a e a e e g o es a o o g goo eal o as a

o ga sa o a olla o a o s al e e o a es

T e o s l a o s o ose s o e s oa a e ss es ega g o e e g a o es s al a a e o le T s s ss o fo ses o e a eas e e e a s e e s

a e e e se I o es a o e e of e s al a foo s s e e s e a effe e e gage e o a e a e e e of e s ea ess o o olla o a el go e e s a o e s a e ol e s o e a le aga s o es

T e o e e s also s o e so e e a le s ss o o a la as e s of s s a es I al o a es a e o a g o e e o al e e g a o ese o s o o o ol a es a el o s e s o e a e e o o s e T e a e also o g o s e s ools a fo a o a e o e s e o a e eal o es a s e e s a e a e all es e o e e flags a es s as e eal oo

Pa e s a e eal a Ra g s e R o le o e a e o e ease a es

T o g o e elo e a efo la o o o o ol eas es foo a e la ell g a es fo es o s le a e g o l e a olla o a o s o e e o a es o all a olle el e e a e e o s a e e ea ess

a a l o a e a o

e a eas es a e e o s o e e a e e se o es s e ol s I a es s as o efo la o a o o s e of foo s a e e ages o o l a e e o e al o a e e e o s e e g a e also o ease e a e of os e e s a e e

ose asso a e s o e e ese s e s o e o a e o go g o a o s a eg es e e eg la l a e e a g el es ase o e es

a a la le e e e a e o o o of s al a g fo esea e al a o of e e o s a o o g o g eg la a o al s e s s esse al o l e o le ge

ase fo es a e a o g e e e g of eso es

T e o es e o s l a o s l g of o es o e ss e of s s a a l T e s e s o e of effo s e foo s a e oa e o o e e e a of

foo o o o ess g a ag g a o s o o e e o e T e also e og ses a o e s e als a a e o a ess e g ga a e e s of o es s o ea o e o al ee s of e a e o g o s g ala e e s T s o l

se e a of e foo o s o o e e o e T e s s a g effo s o e e o o a a ag g s es o a ess o e o s o of e e g as ell as foo as age o e a l a R se gs e o a e o s e s e l e ee o es a

s s a a l o e e o s e o e s o e o s s e e a o e all a s a o f o e e o e e a o ose o o es

T e sol o o e l fa o al o le of o es es s o e a l of s a e ol e s a se o s o o oge e a s s e s a oa a e og ses e o le es a e a o s of e ss es T e e s o s l e lle a s e e e e fo ss g o a s gle e o s l s all l g o es o e s s a a l ss e

ell o s e e e e e ase a oa e e all la e s a e a ole s o g a o s s e a e s a eg ase o o l o o s also e s e a o a a s e a fo a The AFGC and the Australian food industry is ready and well-positioned to

be a key contributor and be involved at all stages of the development of the strategy.

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o o o ol a es a el o s e s o e a e e o o s e T e a e also o g

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aseo o o ol a es a el o s e s o e a e e o o s e T e a e also o g

o s e s ools a fo a o a e o e s e o a e eal o es a s

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e e s a e a e all es e o e e flags a es s as e eal oo

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Pa e s a e eal a Ra g s e R o le o e a e o e e

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la ell g a es fo es o s le a e g o l e a olla o a o s o e e o a es o all a olle el e e a e e o s a e e ea ess

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o a es o all a olle el e e a e e o s a e e ea ess

e a eas es a e e o s o e e a e e se o es s e ol s I a es s

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e a eas es a e e o s o e e a e e se o es s e ol s I a es s as o efo la o a o o s e of foo s a e e ages o o l a e e o e al o

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as o efo la o a o o s e of foo s a e e ages o o l a e e o e al o a e e e o s e e g a e also o ease e a e of os e e s a e e

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a e e e o s e e g a e also o ease e a e of os e e s a e e ose asso a e s o e e ese s e s o e o a e o go g

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ose asso a e s o e e ese s e s o e o a e o go g o a o s a eg es e e eg la l a e e a g el es ase o e es

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o a o s a eg es e e eg la l a e e a g el es ase o e es a a la le e e e a e o o o of s al a g fo esea e al a o of

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a a la le e e e a e o o o of s al a g fo esea e al a o of

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e e o s a o o g o g eg la a o al s e s s esse al o l e o le ge

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e e o s a o o g o g eg la a o al s e s s esse al o l e o le ge ase fo es a e a o g e e e g of eso es

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ase fo es a e a o g e e e g of eso es

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a ag g s es o a ess o e o s o of e e g as ell as foo as age


4

RECOMMENDATIONS

T e e o e s o o o e

T e o e e o es o o oss se o al olla o a e a e s s o a ess e o es ss e

e e e ase a oa e a l e o og a s a a es l g eg la

o o g of o la o foo a e a es o e e fo e s o s a o s a o assess o o es a ess g o es

o al effo s o o o e eal ea g ase o e ole of e ole foo a oa of e s al a e a el es a e a see g o l o s o of a la o

a ego es o e s s a e f g o s o eg la o la o o o g of e g o a foo a

o s o of l e a a l s o o a a e o s l a o s of e e e ase g el es e g s ool a ee

a eal a le s e a a o e foo la s a e

o e a s e g e e e a o o a e s/ a e s a s ool age l e a o g eo le a o o g e ole of o e foo s l e s e s e e e o ag g l fe lo g eal ea g a s

o s s e a o al eg la o o e e e g lo o le la ell g s esses a sell

ea o ea foo

self eg la o a oa o e a e g of foo o l e a e e e a g a o la s a l g o ess

a o o o o a a ag g sol o s a e e eal oo Pa e s

a e a ass s o s e s o ea a a o a e a a al of ffe e foo es T e ol a R s s e e a s s e e ase a al fo s o le e a

effe e as a ea s of el g o s e s o o s eal e s ol a o a o a e o a o of o s e foo s es o se o a a es

o al s e e a a la l eal o e s I a es a o a e a s e a a o eg la s al a eo le of all ages

a a l es

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e s al a e a el es a e a see g o l o s o of a la o

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e s al a e a el es a e a see g o l o s o of a la o

s a e f g o s o eg la o la o o o g of e g o a foo a

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o o a a e o s l a o s of e e e ase g el es e g s ool a ee

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o o a a e o s l a o s of e e e ase g el es e g s ool a ee a a o e foo la s a e

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a a o e foo la s a e

o e a s e g e e e a o o a e s/ a e s a s ool age l e a o g

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o e a s e g e e e a o o a e s/ a e s a s ool age l e a o g eo le a o o g e ole of o e foo s l e s e s e e e o ag g l fe lo g

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eo le a o o g e ole of o e foo s l e s e s e e e o ag g l fe lo g


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self eg la o a oa o e a e g of foo o l e a e e e a g

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self eg la o a oa o e a e g of foo o l e a e e e a g o la s a l g o ess

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o la s a l g o ess

a o o o o a a ag g sol o s a e e eal oo Pa e s

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a o o o o a a ag g sol o s a e e eal oo Pa e s a e a ass s o s e s o ea a a o a e a a al of ffe e foo es

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a e a ass s o s e s o ea a a o a e a a al of ffe e foo es

T e ol a R s s e e a s s e e ase a al fo s o le e

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T e ol a R s s e e a s s e e ase a al fo s o le e effe e as a ea s of el g o s e s o o s eal e s

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effe e as a ea s of el g o s e s o o s eal e s

ol a o a o a e o a o of o s e foo s es o se o a a es RTI Rele

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ol a o a o a e o a o of o s e foo s es o se o a a es o al s e e a a la l eal o e s RTI R

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o al s e e a a la l eal o e s RTI Rele

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I a es a o a e a s e a a o eg la s al a eo le of all ages RTI Rele

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I a es a o a e a s e a a o eg la s al a eo le of all ages a a l es RTI R

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a a l es


5

CONTENTS

I o o 6

P o ose s o e of e o s l a o 6

T e s al a foo s 6

o g l e a fa l es P o a ea 1 8

o l s g eo le a o es P o a ea 2 10

a l g a e l g P o a ea 3 10

l g a eal e a o e es l e foo s s e P o a ea 4 11

es a e l ol e a e 18

a a se a e e e 24

olle e o e 27

o l g o e s 30

PP I 1 o e foo s ass s s eal ea g 31

PP I 2 o a I a es 32

PP I 3 o s e a o a e als 35

PP I 4 Refo la o a I o a o 38

Refe e es 41

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aseolle e o e 27

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PP I 1 o e foo s ass s s eal ea g

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PP I 1 o e foo s ass s s eal ea g

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als

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als

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Refo la o a I o a o 38

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6

INTRODUCTION T e el o es e o o o ese s s ss o o e eal o l Have your say on a national obesity strategy, Consultation Paper e o s l a o T e s ss o as e elo e o s l a o a e ese s e olle e e of e e s o e e s

a foo s e e e e e s T e s ss o a esses e l e foo s s ole e o go g effo s o e e le els of o e e g a o es s al a

la es s e o e of e e ole of e foo s o g oleso e safe foo e e a o o s e s ass s g e o o s eal e s

PROPOSED SCOPE OF THE CONSULTATION T e o es e o ose s o e of e o s l a o s oa e g a l fo se o

a a se o a e e o s e o ass g fo o a eas of s o g l e a fa l es o l s g eo le a o es e a l g a e l g a l g a eal e a

o e es l e foo s s e

I ee ee s o e oa as e a ses of o es a e o o e l fa o al T a sa e o s l a o as as oo e a e s gges g a a o al es a eg s o l e o ass

ss es fo oa asso a o s e e e of o es a a e ee e f e fo e e s e l le e e e of a a sa e l o e a s

SUSTAINABILITY T e s o gl s o s effo s a e e foo s o l e a o e e o e of foo o o o ess g s o a o s o T e eal s o e e

a e e s g ea a a l e ag e a a e of e e o e al effe s of g g foo o e a le of o s e s T a a a l o s e a o foo g o s e ee e foo g o s a a oss e a ge of o o eg o s e es of o ess g a a s o of foo o s o eo e s s a a l s l fa e e e o ass g g ee o se gases a e a a la l a se a s o o e s o la a e o ea a ag g a s a foo

as e a o a all s ages of e foo al e a o a l g e o s e o se e l e e s o s le s s a a l e a e a l e o foo o s a e se o ass s o s e s o ea a o e s s a a le a e I e o e of e a o al es a eg e s a a e of a e e e s gges s a e

e o e al a of foo s asso a e e l e e e of o es a o e s e f all a a la s le a sa e e a s as ee e f e a e efo e s o l e o s e e o of s o e fo s o s l a o

I e a se e of s e e e e ll fo s s s ss o a l o e ole of e foo s ass s g o s e s o a e eal e e a o es s l g a safe foo s s e a o e a s e e s o a a o e o o e o olla o a e a es o e e a o e a e s

THE AUSTRALIAN FOOD INDUSTRY T e s al a foo s a es e o o o s a al o s a f es o s of fa e s o o e e foo s s al a o s e s ea e e a o e a le e s

a es o e foo s s as ea a e eal o s f o g a s eese a a o s f o l a of o se a o e o s f o e a e of a al foo s e e f a

ege a les a s al a o es T e s also o es a a ge of s e o a foo s a o s e s a e o as a of a ala e e

T e ag e of s as s o l o e e es a e T e foo al e a f o ag l e o g foo a fa g a o e a l s o le I o o l a sfo s ag l al a

a e als o e le a of e s ll e s a le o s also o e s e as e a e a s o e f o s es of a es a a fa e o e a l o le s a o e a o T e e es l

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o g l e a

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o g l e a fa l es o l s g eo le a o es e a l g a e l g a l g a eal e a

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fa l es o l s g eo le a o es e a l g a e l g a l g a eal e a

ee s o e oa as e a ses of o es a e o o e l fa o al T a sa e

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aseee s o e oa as e a ses of o es a e o o e l fa o al T a sa e

o s l a o as as oo e a e s gges g a a o al es a eg s o l e o ass

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aseo s l a o as as oo e a e s gges g a a o al es a eg s o l e o ass

ss es fo oa asso a o s e e e of o es a a e ee e f e fo

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asess es fo oa asso a o s e e e of o es a a e ee e f e fo

e e s e l le e e e of a a sa e l o e a s

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e e s e l le e e e of a a sa e l o e a s

T e s o gl s o s effo s a e e foo s o l e a o e

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a e e s g ea a a l e ag e a a e of e e o e al effe s of g g foo o e a le of o s e s T a a a l o s e a o foo g o s e ee e

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foo o e a le of o s e s T a a a l o s e a o foo g o s e ee e foo g o s a a oss e a ge of o o eg o s e es of o ess g a a s o of

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foo g o s a a oss e a ge of o o eg o s e es of o ess g a a s o of o eo e s s a a l s l fa e e e o ass g g ee o se gases a e

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o eo e s s a a l s l fa e e e o ass g g ee o se gases a e l a se a s o o e s o la a e o ea a ag g a s a foo

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l a se a s o o e s o la a e o ea a ag g a s a foo as e a o a all s ages of e foo al e a o a l g e o s e

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as e a o a all s ages of e foo al e a o a l g e o s e

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o se e l e e s o s le s s a a l e a e a l e o foo o s

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o se e l e e s o s le s s a a l e a e a l e o foo o s a e se o ass s o s e s o ea a o e s s a a le a e

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a e se o ass s o s e s o ea a o e s s a a le a ea o al es a eg e s a a e of a e e e s gges s a e

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a o al es a eg e s a a e of a e e e s gges s a e e o e al a

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e o e al a of

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of foo s asso a e e l e e e of o es a o e

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foo s asso a e e l e e e of o es a o e of foo s asso a e e l e e e of o es a o e of

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of foo s asso a e e l e e e of o es a o e of

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s e f all a a la s le a sa e e a s as ee e f e

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s e f all a a la s le a sa e e a s as ee e f eo s e e o of s o e fo s o s l a o

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o s e e o of s o e fo s o s l a o

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7

s a s al a o s e s e o ea o a e a e of affo a le safe s s a a le o s a o e e foo s a s e l fes les a f o e a o s eal

e s

a o e o s e s e o e sa e o s o e seas a s o g e a o fo al safe a e o e all es o s le o o s al a o esse foo a e e age e o s ge e a e a o 26 ll o of o e ea ea f e e o g o s ass e as

e e a fo al foo s a a e s eases

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8

SUPPORTING CHILDREN AND FAMILIES – PRIORITY AREA 1

T e ag ees a l oo o e e g a o es s a ess g o le a s o s o ose o a ea 1 s o g l e a fa l es

a f o e o e s fo e ge e al elfa e of s a la l l e a le g o s ge e all a e e a o e e g a o ese l e a e o e l el o e o e o e e g a o ese a l s ease s of o sease I s o el g l e o a a eal e g s o ass s s effo s o e e a l o es e f e

HEALTHY EATING GUIDANCE P o g ge e al g a e o eal ea g fo l e s o e alle g g a a l s fo a

e easo s

T e e s g ea e a a l e o al e e e s s s a al eases e s as ell as e e g e a s as e g o a e elo s a l s e e

e e e s a la l fo e e g also a ge le els of s al a T e o le ge a e s a g of goo o s less a os a l s al o g a

e e a a o g age a e e so e of e s le o essages T e a e less a le o a al se a assess fo a o a a ges e e o e a

a a s e ef al o o e se o e ell e g a T e a l o a e es o s l a a e a o a e o es l g foo a e e age

o es s e e elo e e g g a e f o a e s a a e s

T e o olla o s s a so e ge e al l g e foo a e e age s s e f l of e l e a l of l e a e og se s o l ga o s o o e e

a o a e o es fo a o a o e o s

o e a s e g e e e a o s f a e al o a ess g o e s asso a e o e e g a o es T e s o s og a s a e o age e o s o of o e foo s e e f e foo g o s o e fo a o a e s a g a o e s al a

e a el es s a o o e s al a a s o as e es a o s a eal

I a la o e es e l e s e a o og a s s as e eal s I a e a e esse al s o g e g o of eal l e Live Life Well @ School a Crunch&Sip a e a es a e o age o s o of o e foo s f o e f e foo g o s

a a s ege a les a ea s a o e a o o o e fo e eal ea g foo e a a o a oo g a a e l g essages f o e s ool l f o

e ga e o ea 12

T e e also ee s o e a g ea e fo s o o o g e s o a e s/ a e s a o o a e s/ a e s a e os o as ole o els s o l fo s o o o g e ole of o e foo s

l e s e s a e a e s/ a e s e o le ge a s lls o offe eal e s a a o a e o o s es o e l e

The AFGC recommends continued and strengthened education of parents/carers and school-aged children and young people, and promoting the role of core foods in children’s diets thereby encouraging life-long healthy eating habits.

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aseP o g ge e al g a e o eal ea g fo l e s o e alle g g a a l s fo a

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aseP o g ge e al g a e o eal ea g fo l e s o e alle g g a a l s fo a

T e e s g ea e a a l e o al e e e s s s a al eases

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ase

T e e s g ea e a a l e o al e e e s s s a al eases e s as ell as e e g e a s as e g o a e elo s a l s e e

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ase

e s as ell as e e g e a s as e g o a e elo s a l s e e e e e s a la l fo e e g also a ge le els of s al a

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e e e s a la l fo e e g also a ge le els of s al a T e o le ge a e s a g of goo o s less a os a l s al o g a

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ase

T e o le ge a e s a g of goo o s less a os a l s al o g a e e a a o g age a e e so e of e s le o essages

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ase

e e a a o g age a e e so e of e s le o essages T e a e less a le o a al se a assess fo a o a a ges e e o e a

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ase

T e a e less a le o a al se a assess fo a o a a ges e e o e a a a s e ef al o o e se o e ell e g a

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ase

a a s e ef al o o e se o e ell e g a T e a l o a e es o s l a a e a o a e o es l g foo a e e age

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ase

T e a l o a e es o s l a a e a o a e o es l g foo a e e age o es s e e elo e e g g a e f o a e s a a e s

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ase

o es s e e elo e e g g a e f o a e s a a e s

T e o olla o s s a so e ge e al l g e foo a e e age s s e

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ase

T e o olla o s s a so e ge e al l g e foo a e e age s s e of

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of l e a e og se s o l ga o s o o e e

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l e a e og se s o l ga o s o o e e of l e a e og se s o l ga o s o o e e of

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of l e a e og se s o l ga o s o o e e of

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ase


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o e a s e g e e e a o s f a e al o a ess g o e s asso a e

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o e a s e g e e e a o s f a e al o a ess g o e s asso a e o e e g a o es T e s o s og a s a e o age e o s o of o e

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o e e g a o es T e s o s og a s a e o age e o s o of o e foo s e e f e foo g o s o e fo a o a e s a g a o e s al a

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foo s e e f e foo g o s o e fo a o a e s a g a o e s al a e a el

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e a el es

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es s a o o e s al a a s o as e es a o s a eal

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ase

s a o o e s al a a s o as e es a o s a eal

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ase

I a la o e es e l e s e a o og a s s as e eal s RTI Rele

ase

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eleas

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a a s ege a les a ea s a o e a o o o e fo e eal ea g


9

RIGOROUS DATA GATHERING T e s al a foo s as le e o l es o g o o e s a o l oo o es

s l e o e 1 ll o o el f e 2007 s al a l e s o a P s al e o e o a e fo a o o e le els of o e e g a o es a oss s al a T e a a a e a le e le els e e o lo ge s g la e o f e f e s es e e a e oo g g e eal of l e a s

o e e e a a s gges s a l oo o e e g a o es le els a e s ll s a le T e s al a eal e e o e a e e ale e of o e e g a o es l e age 5

17 ea s ease e ee 1995 a 2007 08 20 9 e e a 24 7 e e es e el a e e a e s a le o 2011 12 25 7 e e

a a f o also s gges s a e le els of l oo o es a e s ll ela el s a le see a le eal o e s

The prevalence of overweight and obesity in children has been relatively stable in NSW since 2007, with a current prevalence of 22.0% in 5-16 year old children (2017). However, the prevalence remains high and is a cause for concern

T e s al a foo s as also f e a a ge of e se o a a al ses of e s al a eal e a o al o a P s al e o o e a a o e

o al o o of s e f foo g o s a e ela o s o al a e g s a s

The AFGC recommends sustained funding to support regular population monitoring of weight, nutrition, and food and drink consumption of children and adults.

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aseThe prevalence of overweight and obesity in children has been relatively stable in NSW

RTI Rele

aseThe prevalence of overweight and obesity in children has been relatively stable in NSW

since 2007, with a current prevalence of 22.0% in 5-16 year old children (2017). However,

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asesince 2007, with a current prevalence of 22.0% in 5-16 year old children (2017). However,

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10

MOBILISING PEOPLE AND COMMUNITIES - PRIORITY AREA 2

T e o es e ee o e o e eo le a o es o a e os e e s o s a o e eal a e e o e a e s o o g eo le s o le ge a a e ess a

s lls o e a le eal ea g alo g e f g of ass e a a a g s s a ea

The AFCG recommends that government actions motivate and inspire awareness and skills to enable healthy eating, active lives and healthy social and cultural norms by people of all ages and weight status.

ENABLING ACTIVE LIVING – PRIORITY AREA 3

T e o es e ee o e o age g e le els of s al a g e a eas gl a o a e a g al so e a e fa e of a o e se e a l fes le o o es fo

e al o e e a e ee a e a e

T e as o e e se s a ea e e eless s al a foo e a eal o o es a e all e o e e l s o o es

ga s s a o o e e a o s see g o a ess o es s l e s s a al s o fo g ea e s al a o o es e s o a o e o oo a es fo

l e

The AFCG recommends that government actions motivate and inspire participation in regular physical activity by people of all ages and abilities.

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ENABLING ACTIVE LIVI

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ENABLING ACTIVE LIVING

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NG –

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– PRIORITY

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PRIORITY – PRIORITY –

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– PRIORITY –

T e o es e ee o e o age g e le els of s al a g e a eas gl

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T e o es e ee o e o age g e le els of s al a g e a eas gl a o a e a g al so e a e fa e of a o e se e a l fes le o o es fo

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ase

a o a e a g al so e a e fa e of a o e se e a l fes le o o es fo e al o e e a e ee a e a e

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ase

e al o e e a e ee a e a e

T e as o e e se s a ea e e eless s al a foo e a eal

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ase

T e as o e e se s a ea e e eless s al a foo e a eal o o es a e all e o e e l s o o es

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o o es a e all e o e e l s o o es

ga s s a o o e e a o s see g o a ess o es s l e s s a al

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ga s s a o o e e a o s see g o a ess o es s l e s s a al s o fo g ea e s al a o o es e s o a o e o oo a es fo

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s o fo g ea e s al a o o es e s o a o e o oo a es fo

The AFCG recommends that government actions motivate and inspire participation in

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The AFCG recommends that government actions motivate and inspire participation in

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regular physical activity by people of all ages and abilities. RTI Rele

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regular physical activity by people of all ages and abilities. RTI Rele

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BUILDING A HEALTHIER AND MORE RESILIENT FOOD SYSTEM - PRIORITY AREA 4

HELPING PEOPLE TO MAKE HEALTHY CHOICES T e l s e ee e a eal a e ee lo g e og se e foo s

T e s o s o ose o a ea 4 fo ses o a a o le ges e ole e foo s as el g o s e s o s eal e s fo e a le a o a e o o

s es a el o s e s o e a e e a e a o g o a o a g g e o s o fo a s o a e s as ose e e o al e e g o g fa a

a o a e s s es o slo e e g elease e lo l ae I e a a ass s o s e s o ea eal l a les of o a e foo a e e age o s a ass s o s e s e e a ee s a e e 1

T e foo s also el s eo le o a e e s o s o g e o s o of o fo a o o g o l e eso es a s a o e a l a o s

EMPOWERING CONSUMERS THROUGH INFORMATION FRONT OF PACK LABELLING P o g o o e e a e s a o a s e o el g o s e s oose foo s as a of a eal e a a o s o a e a e ea a ess o fo a o

ga e s al a foo s s e e e ea s ago o o e a o l f s o of Pa o a ell g oP s e e T s ol a og a alle e Daily Intake Guide I s

e a 2014 a ea e o o e 7200 o s all a o foo a ego es T e I o es o e al fo a o a o e e g a o e e s

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s as el g o s e s o s eal e s fo e a le a o a e o o

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s as el g o s e s o s eal e s fo e a le a o a e o o s es a el o s e s o e a e e a e a o g o a o a g g e

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ases es a el o s e s o e a e e a e a o g o a o a g g e

o s o fo a s o a e s as ose e e o al e e g o g fa a

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aseo s o fo a s o a e s as ose e e o al e e g o g fa a

a o a e s s es o slo e e g elease e lo l ae

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asea o a e s s es o slo e e g elease e lo l ae I

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o s e s o ea eal l a les of o a e foo a e e age o s a ass s

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aseo s e s o ea eal l a les of o a e foo a e e age o s a ass s

T e foo s also el s eo le o a e e s o s o g e o s o of o fo a o

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T e foo s also el s eo le o a e e s o s o g e o s o of o fo a o o g o l e eso es a s a o e a l a o s

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o g o l e eso es a s a o e a l a o s

EMPOWERING CONSUMERS THROUGH INFORMATION

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EMPOWERING CONSUMERS THROUGH INFORMATION FRONT OF PACK LABELLING

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FRONT OF PACK LABELLING P o g o o e e a e s a o a s e o el g o s e s oose foo s as

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P o g o o e e a e s a o a s e o el g o s e s oose foo s as a of a eal e a a o s o a e a e ea a ess o fo a o

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a of a eal e a a o s o a e a e ea a ess o fo a o

ga e s al a foo s s e e e ea s ago o o e a o l f s o of Pa

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ga e s al a foo s s e e e ea s ago o o e a o l f s o of Pa

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o a ell g oP s e e T s ol a og a alle e

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o a ell g oP s e e T s ol a og a alle e e a 2014 a ea e o o e 7200 o s all a o foo a ego es T e

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e a 2014 a ea e o o e 7200 o s all a o foo a ego es T e I o es o e al fo a o a o e e g a o e e s

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I o es o e al fo a o a o e e g a o e e s

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12

HEALTH STAR RATING T e as ee eg all ol e e es g a le e a o of e R s e T a

ol e e as l e e al s ss o s e o o eal a a o o e o g al P o e o ee a o g g o s o s o of foo o os o a a o allo

o ell g a follo g le e a o a a o o e eal a Ra g so o ee R

T e R s ase o e le els of e s a foo s e foo o ass s s o s e s o o a e s la o s foo a ego es o e o o s eal e e s

e 10 000 e e a foo o s a e a a e a e a a g o a e soo o e a a g e R s e o e o e a 130 ffe e o a es T s s a

e a le of o e foo s o g losel l eal o ga sa o s s as e National Heart Foundation a o s e o ga sa o s s as Choice, a e elo e

a es el g s al a s o a o eal e l fes les

T e o s e s e le e a o of e R s e as ee a s essf l l eal e e o a e s as e ee e e e a o s o s e s e s a se a

ge e all s e o a la ell g a as a es l e e s a e l el o a e o e a e o o s s e e a e of e s al a e a el es s a e eala

a g a el es T e R s e as ee e o se o e e a o o e o o s e s a e foo s as a s o a o e sele o of a eal e e

To a a s s a l o s s ess e o s e s a a o a e e e 5 ea Re e es l s as fe a ges as s e essa o o e e R s e ll a ges a a la l ose s le o o s e s e le e e s e e e a e e s T e

s e s f e o e as s of e e efle g o al s e e a /o o g e f o al of e s s e o o e g ea e s e e e ee o s o ass s o s e

o e a a ego of foo

o e a le as a of e R 5 ea Re e e o e a o 2 s e e o al of e e e g o o o f o e R s s e ea s e o fe o a a ego a e alle e

T ea se a o lo ge e a a of R s s e T s a e o es ea gf l f o of a fo a o fo o s e s el g e o o e e e g a e o g s e o a foo s l g fo a o o o o s e s o a s e o a foo o s o

e R s s e oes o l e

T e foo a e e age s ll o e o s o e R s e o g a a g s o go g ele a e ase o e es s e e le e s g s o s s e s e of

o g a a gla e o fo a o a allo s o s e s o a e o a so s o a ego es a sele e o es agg ega e ll es l eal e e s

The AFGC recommends that HSR system remains science based, practical for industry to implement and effective as a means of helping consumers to construct healthier diets.

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aseT e o s e s e le e a o of e R s e as ee a s essf l l eal

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aseT e o s e s e le e a o of e R s e as ee a s essf l l eal

e e o a e s as e ee e e e a o s o s e s e s a se a

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asee e o a e s as e ee e e e a o s o s e s e s a se a

ge e all s e o a la ell g a as a es l e e s a e l el o a e o e a

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asege e all s e o a la ell g a as a es l e e s a e l el o a e o e a

e o o s s e e a e of e s al a e a el es s a e eala

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asee o o s s e e a e of e s al a e a el es s a e eala

a g a el es T e R s e as ee e o se o e e

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asea g a el es T e R s e as ee e o se o e e

a o o e o o s e s a e foo s as a s o a o e sele o of a

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a o o e o o s e s a e foo s as a s o a o e sele o of a

To a a s s a l o s s ess e o s e s a a o a e e e

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To a a s s a l o s s ess e o s e s a a o a e e e es l s as fe a ges as s e essa o o e e R s e ll a ges

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es l s as fe a ges as s e essa o o e e R s e ll a ges a a la l ose s le o o s e s e le e e s e e e a e e s T e

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a a la l ose s le o o s e s e le e e s e e e a e e s T e s e s f e o e as s of e e efle g o al s e e a /o o g e

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s e s f e o e as s of e e efle g o al s e e a /o o g e f o al of e s s e o o e g ea e s e e e ee o s o ass s o s e

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f o al of e s s e o o e g ea e s e e e ee o s o ass s o s e

o e a le as a of e R 5 ea Re e e o e a o 2 s e e o al of e e e g

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o e a le as a of e R 5 ea Re e e o e a o 2 s e e o al of e e e g o o o f o e R s s e ea s e o fe o a a ego a e alle e

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o o o f o e R s s e ea s e o fe o a a ego a e alle e T ea se a o lo ge e a a of R s s e T s a e o es ea gf l f o of a

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T ea se a o lo ge e a a of R s s e T s a e o es ea gf l f o of a fo a o fo o s e s el g e o o e e e g a e o g s e o a foo s

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fo a o fo o s e s el g e o o e e e g a e o g s e o a foo s

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l g fo a o o o o s e s o a s e o a foo o s o

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l g fo a o o o o s e s o a s e o a foo o s o e R s s e oes o l e

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e R s s e oes o l e

T e foo a e e age s ll o e o s o e R s e o g a a g s

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T e foo a e e age s ll o e o s o e R s e o g a a g s o go g ele a e ase o

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o go g ele a e ase o e

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eo g a a gla e o fo a o a allo s o s e s o a e o a so s RTI R

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implement and effective as a means of helping consumers to construct healthRTI Rele

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implement and effective as a means of helping consumers to construct health


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MENU ENERGY LABELLING T e s e e Res a a e e s a e s o gl a e e e s o s o

le e e oa la ell g s e es f e o a es a e e e e e la ell g o s o s e e as o e e e T e e e a o al e e of fas foo e la ell g

s e es g l g e a

Menu labelling schemes are an example of a contribution from the food sector which has improved diet and the availability of healthier food options.

I a o e al a o es l s s o

…that the initiative was implemented well by industry and regulators, consumers noticed the new information in outlets, there was a shift towards consumers having a better understanding of average daily energy intake, and a significant reduction in kilojoules purchased was noticed.iii

The AFGC supports a consistent national regulation on menu energy (kilojoule) labelling in businesses that sell ready-to-eat-food.

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14

BETTER PRODUCTS I e 1970s o e s a o l s e ee sa a e fa a ea sease

le o e e elo e of ol sa a e a ga es

T e 1980s sa e e e of ea fas e eals a o e foo s e a f e o lo e e s of o el a e a e 1990s esse e e elo e of lo e fa l s o ol a o 50 e e of e a e

I al os e e foo a ego o es lo fa lo s ga lo sal

a e f e o g o e a e ee e elo e o o e o e o o s e s

e a ea e e s al a lea s e o l as ee e e o al of a s fa s

f o e foo s l so a e e a a e s o 40 e e lo e a o l eal ga a o

Re o e a o s see ase 1

T e foo s o o l e o es e s a a e asso a e sease s a s a esse al e s o foo s e g a s a e als e s eg la o o e s g a

e s es e e s o s o eal f o o e o s o a o a es a e a g l o e s a oss e o fol os o el e a e e age of e e e f o e e o e o s as ell as o ease g e e s s as ole g a s a e g so a

sa a e fa s

PORTION SIZE AND GUIDANCE e g ga lea g o o es s os s o gl asso a e e e g a e a la l e

a s e fo s al a e g s o e e a o e s o e a o a e f e fa a al o ol T e alle ge e efo e s o ass s o s e s o o s eal e s a ee

e e e g ee s

To a e of e fo s of a e o o s e s as ee o a e g a a a g a eal e g a /o e g s asso a e e s e s al a e al e a e

a oa s ee e s e f all o el o s e s a o ea g a o e e o al e e g ee s a a la l o ease e o s o of o e foo s a e e ages a o o s e e e g e se e oo foo s o e a o T s ll o o l o e a e e e e g a e also

ease os e e e e s a e e s asso a e e s a es all a o e o e ee s o e o e o e a e o s e s o a o o e e s

T s a oa s s o e e s al a eal e a a a s o s 35 e e e e g e s al a e o es f o foo s es e as s e o a 1 a f e foo g o foo s a e s g f a l e o s e

1 s e o a foo s a e ose e o e g e e e g fa so a s ga T e e s o es a l s e ef o a o ag ee e o a e e a o e f e

CASE STUDY 1. Trans-fats - an Australian success story

Background: The food industry introduced trans-fats into foods to replace saturated fats during the 1960s and 1970s. Trans-fats are produced when vegetable oils are processed to make them harder (less liquid) at room temperature. They found uses in margarines and products where hard animal fats had previously been used (e.g. shortening in pastry).

The Problem: In the early 1990s nutritional science indicated that some dietary trans-fats are a risk-factor for heart disease.

The Solution: The major oil producers in Australia agreed to change their processes to phase out trans-fats from all their fats and oil products. This carried across into the food manufacturing sector, significantly reducing the trans-fat levels in many processed foods where oil is an ingredient.

The Benefit: Dietary levels of trans-fats in Australia are

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T e foo s o o l e o es e s a a e asso a e sease s a s a esse al e s o foo s e g a s a e als e s eg la o o e s g a

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a esse al e s o foo s e g a s a e als e s eg la o o e s g a e s es e e s o s o eal f o o e o s o

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e s es e e s o s o eal f o o e o s oo e s a oss e o fol os o el e a e e age of e e e f o e e o e

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o e s a oss e o fol os o el e a e e age of e e e f o e e o e o s as ell as o ease g e e s s as ole g a s a e g so a

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o s as ell as o ease g e e s s as ole g a s a e g so a

PORTION SIZE AND GUIDANCE

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PORTION SIZE AND GUIDANCE e g ga lea g o o es s os s o gl asso a e e e g a e a la l e

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e g ga lea g o o es s os s o gl asso a e e e g a e a la l e a s e fo s al a e g s o e e a o e s o e a o a e f e

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a s e fo s al a e g s o e e a o e s o e a o a e f e fa a al o ol T e alle ge e efo e s o ass s o s e s o o s eal e s a ee

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fa a al o ol T e alle ge e efo e s o ass s o s e s o o s eal e s a ee e e e g ee s RTI R

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a oa s ee e s e f all o el o s e s a o ea g a o e e o al e e g ee s RTI Rele

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indicated that some dietary trans-fats are a risk-factor for

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indicated that some dietary trans-fats are a risk-factor for

: The major oil producers in Australia agreed

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ase: The major oil producers in Australia agreed

to change their processes to phase out trans-fats from all

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aseto change their processes to phase out trans-fats from all

their fats and oil products. This carried across into the food

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asetheir fats and oil products. This carried across into the food

manufacturing sector, significantly reducing the trans-fat

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asemanufacturing sector, significantly reducing the trans-fat

levels in many processed foods where oil is an ingredient.

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levels in many processed foods where oil is an ingredient.


15

T ese l e ege a les a leg es/ ea s f g a e eal foo s os l oleg a a /o g e eal f e a e es lea ea s a o l f s eggs of s a see s a

leg es/ ea s a l og eese a /o al e a es os l e e fa

e a oa o ass s o s e s o o e a e e a e s o g g a e o o a ges o o o s es

o a e se g s es o a o le a al o e e e es o es o o o ol o o o g a e ass s a e o o s e s e s eal e sele o

a les of e s a es a e fo a Appendix 1 a les l e e o ag g o o o ol o g o a es a a o e e T ea se a a g o el o s e s

e s a o of e e o e e a l a e o s o a

I al o a es a e also el g o a ess o o s e o g o a e o s e eso es Please see e es 2 a 3 f e s o ases e a les of o a o

g o o s e fo o s e s

T e eal oo Pa e s as e f e o o s e a o o o ol as o a eas s o og a e s of e e g e o o es of e og a e a a es e el e a les ll l e

lea e a e o foo o a es e fo of s es a e g es o a o a e se g s es o la els a la l fo e foo o s ase o e e g o e a o e

o al e a ol a se g s e a ge s a o s e e a o a e als s o g e s a e o se e s es Please see

e 3

e e e e e e e 2018 f o e Po o e o g o of e eal oo Pa e s fo o ell g e e e a la ge o o s es of o f e foo g o foo s a

s e o a foo a s ease o s o

o e sel as ee s o a e g la e s e ll lea o o s e s ea g s alle a o s e e a s a es

e o o s e eal oo Pa e s o l o e all o s e o ass s o s e s o ea a a o a e a of ffe e foo es l e

e e eg a o a o o o of a al a e o o o s e sele o e e o e e e of serves e a of e s al a e o eal a g o s e

e a o s also o a so e e s e s a g a le eo le s o e of o o s e a es o e e a a ee o al a e f o ea of e o e foo g o s a s e o a

foo s s o l e e g s la o e e of se es s gges e e fo al e e g ee s

o e eo le s o o s es a e s alle a e s al a e o eal a g se e s e a so e a e la ge ea s a so e eo le a ee o ea f o e f e foo g o s o e o less of e a o e s

lea e a al g a e o a o a e se g s es o a fo a s ella eo s foo o s fo e a le lasag e ea es a sl es o fe o a a e ase o

e e g o e a o e foo o es o a eal e o s s e es a l s e s e f e e e a o e e e o e a o s

e a o o f a o s o ass s o s e s o o e a e e a e s as e elo g s e f o es lea g o e e o es a e e e s a a o a f l a oa o e o g e ea s fo e a le s g s alle la es fo so e eals a g alf of eals olo e ege a les o sala f s a eas g a a e ess of ge a sa e es

lo g a s e a age foo s a el o s e s s g o o o ol e es o s o a eal e T s a l e

- s gges e se g s es o a a efle a o a e e o o o a eal e

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se g s es o la els a la l fo e foo o s ase o e e g o e a o e

o s e e a o a e als s o g e s a e o se e s es Please see

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o s e e a o a e als s o g e s a e o se e s es Please see

2018 f o e Po o e o g o of e eal oo

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2018 f o e Po o e o g o of e eal oo Pa e s fo o ell g e e e a la ge o o s es of o f e foo g o foo s a

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Pa e s fo o ell g e e e a la ge o o s es of o f e foo g o foo s a s e o a foo a s ease o s o

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s e o a foo a s ease o s o

o e sel as ee s o a e g la e s e ll lea o o s e s ea g s alle

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o e sel as ee s o a e g la e s e ll lea o o s e s ea g s alle a o s e e a s a es

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a o s e e a s a es

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e o o s e eal oo Pa e s o l o e all o s e o ass s o s e s o ea

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a a o a e a of ffe e foo es l e

e e eg a o a o o o of a al a e o o o s e sele o e

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e e eg a o a o o o of a al a e o o o s e sele o e

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e o e e e of

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e o e e e of serves

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servese a o s also o a so e e s e s a g a le eo le s o e of o o s e

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16

- se g s gges o ages o a a ll s a e a o a e o o s e a s gges o e eal o o e s o o o e e a e of o e foo s

- e s g a a ge of a s es a e a a la le o o s e s l g s gle o s alle o o a ag g

- g cut here’ l es o foo s e g a es a a s o a e o o s o s

- l g s oo s o o e o se ol eas g ools a ag g e g eas oo s a

- o o g o e e a s o ease a e of o e foo s as a a o ease a e a a e as ell as o e e e o e all e e g e s of a eal fo

e a le f es f o e a a e f ege a les a leg es ea o ea oleg a s ea fas e eals a l o s

e elo g a lea f a e o o ass s l e e a e s a a e g e s o sele

a o a e a o s of foo a e e ages o o s e ffe e se gs a e a of a ess g e l oo o e e g a o es ss e

The AFGC supports education, promotion and packaging solutions via the current Healthy Food Partnership initiative that assist consumers to eat an appropriate quantity of different food types

PRODUCT DEVELOPMENT AND REFORMULATION s e o sl o e s s ss o e foo s as a es a l s e a e o of offe g o a a s a e efo la e es o se o a a es o al s e e a

a la l eal o e s I e as o a es a e all o e e e l a e o e olle e a o s s as e e Healthy Food PartnershipError! Bookmark not defined. o e e a les of e foo s s o go g o e a effo s o ass s o s e s o eal

e s o g ffe e o fo a s a e s o e 4

QUICK SERVICE RESTAURANTS T e s al a e e Res a a R se o as ee a el s g a es o s o eal ea g a l s a l e I 2012 follo g e o o of a a o

lo o le e oa la ell g lea g R o a es olle o la ell g a o all o e s e all s al a s e e a le o l o a e e e e g o e of e ases a

ases fo e l e I a o o lo o le la ell g e a o R o a es o e o fo a o ega g e le els of sa a e fa so a s ga o o a e s es

s a o e a s a o g s o e o es

R o a es a e also e gage s g f a efo la o a es a oss e o fol os o e e e le els of sa a e fa a so ll a o R o a es a e s e e o l e se es l g o e a a 75 e e e o of sa a e fa le els o s s e e eal e ls P og a a e of T e ea o a o s al a T ese a es a e a e o a offe gs ese s o es so e o a es e o g e follo g

a e e e s e e ea s o g a ese a e o a s e f a a e o ee agg ega e a oss e se o

69 e e e o sa a e fa of e gge s 15 e e e o so a oss e a ge 21 e e e o so seaso e sal 58 e e e o s ga ge s 30 e e e o so ge s a 20 e e e o so eese

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e elo g a lea f a e o o ass s l e e a e s a a e g e s o sele

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e elo g a lea f a e o o ass s l e e a e s a a e g e s o sele a o a e a o s of foo a e e ages o o s e ffe e se gs a e a of

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The AFGC supports education, promotion and packaging solutions via the current Healthy

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PRODUCT DEVELOPMENT AND REFORMULATION

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s e o sl o e s s ss o e foo s as a es a l s e a e o of offe g o a a s a e efo la e es o se o a a es o al s e e a

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o a a s a e efo la e es o se o a a es o al s e e a a la l eal o e s I e as o a es a e all o e e e l a e

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a la l eal o e s I e as o a es a e all o e e e l a e o e olle e a o s s as e e

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o e olle e a o s s as e e Healthy Food Partnership

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Healthy Food Partnership

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e a les of e foo s s o go g o e a effo s o ass s o s e s o e

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e a les of e foo s s o go g o e a effo s o ass s o s e s o ee s o g ffe e o fo a s a e s o e 4

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e s o g ffe e o fo a s a e s o e 4

QUICK SERVICE RESTAURANTS

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QUICK SERVICE RESTAURANTS T e s al a e e Res a a R se o as ee a el s g a es o

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T e s al a e e Res a a R se o as ee a el s g a es o s o eal ea g a l s a l e I 2012 follo g e o o of a a o

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s o eal ea g a l s a l e I 2012 follo g e o o of a a o e oa la ell g

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e oa la ell g lea g R o a es olle o la ell g a o all o

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17

l e s eal offe gs Rs a e also e ol e a o R o a es offe g o o a o a e l e s e e s a eal o o s a e ol e a o o e foo s l g

a e e e fa l a 100 e e f e e e ages lle ea a sala a s a es of f a ege a les l g a le sl es e o a oes eas

o al s s al a as e o e a 1 in 3 Happy Meals sold include either a Seared Chicken Snack Wrap, apple slices, low-fat flavoured milk, fruit juice or water

T e s R o as ee s o gl e gage e eal oo Pa e s I s e ese e o e e e o ee a o e e s a e el e a e oo e e

o g o a Refo la o o g o o el el e a s e of ol a oo e e Ple ges a e g af efo la o a ge s

The AFGC supports and encourages voluntary innovation and renovation of products by the food industry in response to advances in nutritional science and particular public health concerns.

SETTINGS-BASED GUIDELINES – SCHOOL CANTEENS T e e s e o o o el a ess e a a e ala e o g e le e a o of se gs ase g el es s as s ool o o e a ee g el es T e a e a effe e a fo

e foo o es of l e a a l s o e fl e e e s ool o o la e se g e e ass s g e o o s e eal e s

ool a ee g el es a e ee ell s o e s I 2003 follo g e o o of Fresh Tastes @ School s ool a ee s a foo o a es efo la e e

o s o o e e o l es o o e o o s fo eal e o es s ool a ee s

T e s of e s o g e o e e a e e s e fo e a ee g el es a oss all s al a s a es a e o es T e e s o s e f o o al easo e s o l e ffe e e ee s o s so ass g a o al o s s e s o l e a o

The AFGC welcomes the opportunity to participate in national school canteen guideline consultations that are evidence-based and looks forward to work on other initiatives which may be developed.

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asefood industry in response to advances in nutritional science and particular public health

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SCHOOL CANTEENS

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se gs ase g el es s as s ool o o e a ee g el es T e a e a effe e a fo e foo o es of l e a a l s o e fl e e e s ool o o la e se g e e

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e foo o es of l e a a l s o e fl e e e s ool o o la e se g e e

ool a ee g el es a e ee ell s o e s I 2003 follo g e o o

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s ool a ee s a foo o a es efo la e e o s o o e e o l es o o e o o s fo eal e o es s ool

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o s o o e e o l es o o e o o s fo eal e o es s ool

T e s of e s o g e o e e a e e s e fo e a ee g el es

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s o l e ffe e e ee s o s so ass g a o al o s s e s o l e a o

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The AFGC welcomes the opportunity to participate in national school canteen guideline

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The AFGC welcomes the opportunity to participate in national school canteen guideline

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consultations that are evidence-based and looks forward to work on other initiatives which

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consultations that are evidence-based and looks forward to work on other initiatives which may be developed.

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may be developed.

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18

OBESITY AND THE PUBLIC POLICY DEBATE

T e o a e of a l g o es a o e e s a e a f o e loss of al of l fe fo als e os o e o s la ge

T e a e e foo s a e es o e o e l eal alle ge o g a o e e s e s e of o a le el a es olle e a o s a oss se o al olla o a e

a es es e s o g a ll g ess ee a es e o e a of e sol o a ess g e o es ss e o e a es o e e a e see e foo s e g a of e o le f o e sole a se of e o le T s o e o s o e of e a o a o a e alls o

eg la e e foo s a o a o of o o s a a es T e e e s o e o e o a e o ose eg la o es o ses as e a e s o e e e o a eal s e e o e les of goo ol a es a e eg la o

POTENTIAL REGULATORY LEVERS T e e a e f e o e al eg la o le e s a a e se o fl e e o s e s ea g a s a o so e e e ese a e al ea ee se s al a

1 Applying taxes to discretionary foods or their components e T a l es o o esse foo s a o f es foo s I e a o al e a les of a es o foo s o foo o o e s a e o a e o es le els

2 Restricting advertising, particularly to children e s al ea as ol a s

a es e R I a RI as es e ea l e I e a o al e a les of a e s g a s a es o s a e o a e o es le els

3 Restricting the sale of foods ool a ee g el es es e foo o es of l e e og s g e a e a a la l l e a le o la o g o T e s o s e se of

s ool a ee g el es

4 Mandated nutrition labelling e e a e al ea eg la o e e e s fo a o I fo a o Pa el la ell g o a age foo s a e ol a el a o e R la ell g also a s o s e s o a e fo e o es s o s e o g ol a s a s of e R o e a le e s s e o e ag le a es o o e al a o

5 Regulating the composition of foods e a e al ea o es lo e e g lo fa lo

s ga a lo sal a a s of a foo o s a f e a ges a e o g Reg la o o l s l e o e so e a oss l a foo o s o le el

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POTENTIAL REGULATORY LEVERS

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a o so e e e ese a e al ea ee se s al a

or their components

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a es o s a e o a e o es le els

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a es o s a e o a e o es le els

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19

FOOD TAXES T e e e e e of a l g s ga o fa a es o e o es as ee e e s essf l e g o es o o la I 2012 e a a ol s e a a of foo s ase o e sa a e

fa le els a ea e a se e a as so o la a o s e s e e g a oss e o e o a o la l e e a e ases e e a es e e s ga a es a e ee e eale o s a e oo o o o a es e of ago e o e s

so a a s e a s af e a e o effe 2017 e o s o la

eal e e s a o ag ee o e o e al effe e ess of foo a es e g o es T s s e a se s ff l o e e f al a e a es a a e o foo es a e effe s o e a a s s o o s e s s g o al e a e foo s e s es a e fo

a o s e s a e

e f o o e e e s e o ea e a s of sof o la ge s es l a e less o e lef o e o s e o eal e foo s a s al a s e e a

e ease e o s o of f a ege a les af e a s ga s ee e e e e ages s a

I ease e a e of a e foo s a e e ages e g a s fo a 124 ease a e e e g f o a e e e ages s as l s oo es a l s a es

a a o s g f a e o e e g a e f o s

e all e e a a a o e as g ea as a a e a e e s ag ee e a effe s a e l el o e o es a os a e e s s ff e e e e o s o a l a e effe o o es

o ell g of e effe s of a a o s s al a as l s e l 2016 T e o e all effe s as e o e a e e o es es e ass o s a a e fa o a le o e o osal T e o ell g

e s:

o of e e g f o s ga s e o la o e of 16 e a fo e 9 e a fo o e s s less a 0 2 e e of e a e age e o e e a l a e 8700 a e ale o a o 1g of s ga o o e a e of a eas oo of s ga

f e 25 ea s e a e age a 1 78 all ll e 320g l g e a e a e age o a 1 63 all 170g l g e

es a es o l o 0 7 e e a l e a 0 3 e e a l o e

T e ea l os sa gs fo e eal ge a e a all efe e os s os s ease la e as ea s a e s e f e o e el e

e e e e of e e a s ga a le e e a a 2014 e o e s la e o es effe s o foo a e efo e e e g o s o a o 1 66 g e a e ease o a o 60 e a o 0 7 e e of e a l e e g e e e

T e a o s o l e

…the impact of this tax on overall energy intake, dietary quality, and food purchase patterns, as well as how these changes relate to weight status, remains to be studied’

o s es o e e a e ee fo o g e o s a e e o all o e e g e so e o f e e o e o os o a e o o of e a o s e o as le o a s g f a e l e o es le els e o e e e a s a a o l eal alle ge

af s a s e l s e a e efo e o ee e e e esea e s a e I s o Te ol g o o o e o o a e o ass e I a o g 8 000 o se ol s 2013

e ea efo e e a a 2015 e se o ea o e a I a ea s o s o e a a a e s all effe o alo es o s e

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a e less o e lef o e o s e o eal e foo s a s al a s e e a

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a e l el o e o es a os a e e s s ff e e e e o s o a l a e effe o

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all 170g l g e


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ea s a e s e f e o e el e

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20

“There is no discernible difference across the years in BMI…If anything the tendency has continued to rise, albeit by a small quantity. It seems that so far the existing tax has not had a detectable decrease in BMI.”xviii

T e e Ta e e e a e e o e al se of a es o o f o s o e a o a o l e s

….very difficult to estimate spill over costs, if any, of identifiable foods or food types. In addition, any quantifiable health benefits of imposing the tax would need to be weighed against the loss to those people who are at low risk

I 2016 T e a a I s e elease a e o a fa o e o o of a a o s es e e fa o e e a o l a e al a o le els of o es e o e a o o s o o es le els I ee e o e

..no one ingredient causes all obesity….

I o e also e e fe eg ess e a e of e a s f g o e as s a al o g o l a lo e so o e o o g o e g ea es ese g o s o l e ef e os T s e o s

o s s e a s es a a e el a o e e o els o o e a l el o oss le e o I a o es a e a f o a a ga e e e o e of a a a g al ea ee

le e e

f e s f a o ese e e a a I s e as e o o o e a e a e a a e o l e e e o eal s e g g o g e fa a s al a a el ses

o e a e a es fo easo s of e o o eff e a ge a o o a g o g e f a e al e of sele el a g e o s of o e s a e al s g e o s e s a of o a e o o ese o o e e g o e ef e ole o as o a o

e all a e o l e a a es o a ge o s e e a o a e eff e a eg ess e sa a ag g lo e o e g o s a ose o s e s al ea a e g o e es e e a o

Pe a s s es s e o e e e o l s o s of a e e e o o ss o e e e eala s of eal 2017 loo g a e s e g of e e e ega g e

effe e ess of a s ga a T e e o s a ses e o l s o s s

Taxes do generally appear to be passed through to prices and some reduced demand is likely

Estimates of reduced intake are often overstated due to methodological flaws and incomplete measurement

Price elasticities from early studies with fundamental methodological flaws have later been used in a number of other studies to assess the impact of sugar taxes, resulting in significantly overestimated reductions in demand

There is insufficient evidence to judge whether consumers are substituting other sources of sugar or calories in the face of taxes on sugar in drinks

Studies using sound methods report reductions in intake that are likely too small to generate health benefits and could easily be cancelled out by substitution of other sources of sugar or calories

No study based on actual experience with sugar taxes has identified an impact on health outcomes

Studies that report health improvements are modelling studies that have assumed a meaningful change in sugar intake with no compensatory substitution, rather than being based on observations of real behaviour.

f all The evidence that sugar taxes improve health is weak.

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21

RESPONSIBLE ADVERTISING T e a a f o e 2007 s al a l e s o a P s al e as a all o a o fo e foo s a 2009 e la e e Res o s le l e s a e g I a e R I a e e e Res a a I a e fo Res o s le e s g o l e

RI o a g ol a o e s foo a R o a es o e a e g of foo o l e

T e o e es of e I a es a e o

Re e a e s g a a e g o a o s o l e fo foo a e e age o s a o o e ese eal e o es

se a e s g a a e g o a o s o l e o el o o e eal e a o es a eal l fes les a o gs s al a l e a

P o e a e e e es a e a e e fo o s e s o a se o e s ega g a e s g a a e g o a o s o l e fo foo a e e age o s a ss es of o o l a e o g a a s

T e R I a RI e ese a e s essf l self eg la o a oa e g e o ele s o e also a l o e a a o e a e a e ga es a e e e o

I a es l e f ll e e e o la s a l g o g a a s a a e a e e s of o s al a o l a e s o o e a e o e a all

s a es l of e o o of e R I a RI less a 1 e e of all foo a e e age a e se e s la e R I a RI s g a o es e e fo o s a o ee e eal o e e a a a e e s o g l e s T og a s o og a s fo

l e e ese e o e a 35 e e of e a e e

The AFGC supports and encourages a self-regulatory approach on the marketing of food to children that incorporates monitoring, and an independent and complaints handling process and auditor.

RESTRICTING PROMOTIONS

oo s a e e ages ase foo e a l s o es o e a s g f a o o of al s o al a l e a e e g a e oo s o g e a o o es o e ol e a foo e a l

e o e s a e eas gl o e o le e g a o e e e s a g of s o e e a o s

P e a o o o fo a o a fl e e ase e o s a o e I s al a e as e a e e a e see o o o s ease o 40 e e of o s ase o o o o a g s al a o e of e os g l o o e a e s e o l s o e s es o ses o

e o o o s a e ase o al s a es T e a l of e o o o s o fl e e a s o e o s f o o e a o a o e e e s o e s o e s easo o e

e al e s of e a s e a e of e o e se a al ffe e es

P e o o o s o a oss a a ge of foo a a ego es l g e o e f e foo g o s a s e o a foo s e e a l se g le o o o s a fl e e a s o e s e s o o ase e e s o e e e a ese a e g a es a e asso a e a eal o o e s as o e e g a o es T e s o a a e of e e e ase esea e o s a es a asso a o of e o o o es o a a o a g g e a a e s a e g s a s

es o of o o o of e a foo a a ego es o l e e a lea ef o a e a of ose foo a e s a e es o a l es s alle g g f o a

o al e s e e as ell as f o a a al le e a o a o o g e s e e es o of s a e a a e l a o s a o l e e la f a o of s al a o e o a o s e la

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a e s g a a e g o a o s o l e fo foo a e e age o s a

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ele s o e also a l o e a a o e a e a e ga es a e e e o

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e s of o s al a o l a e s o o e a e o e a all

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children that incorporates monitoring, and an independent and complaints handling

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children that incorporates monitoring, and an independent and complaints handling

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STRICTING PROMOTIONS

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o al a l e a e e g a e oo s o g e a o o es o e ol e a foo e a l e o e s a e eas gl o e o le e g a o e e e s a g of s o e

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e o e s a e eas gl o e o le e g a o e e e s a g of s o e

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The AFGC does not support restricting promotions of food and drinks in the absence of evidence- based research demonstrating a health outcome in relation to weight status and would require careful design and monitoring of its effectiveness.

WARNING AND ADVISORY LABELS T e a s e e s s o o g o s e s e fo a o e ee o a e a fo e o e a o e foo s e ea T s s o a o ass s o s e s o o s eal e s o ee e e e e e s I also el s e o a o o e al a a s

foo o s s as alle ge s a o e o o e s o e a e ole a o s e a so s a e e s a e o s fo se l g fo e a le e o s fo e a a o a e

al o e s g e safe a l g a o s o of foo s

e l e e s o e s e f as s o a ego se foo s s ase o a g es ol s of g / e /lo le els I e P e a el le e g ese o e al le els o o e

s o g s e f as s ee e a lea o o s e o f s o a e o e o s e s

T e s o gl o oses a fo of f o of a a so s a e e o a g la el ega g e le els of e a e s e g a e s ga so sa a e fa s al o ol a

e e g o e foo so s a e e s a e ese e e fo ases e e e e s e s of s g f a a e se eal o o es fo o s e s o s g o s of o s e s T e e s

s l o so s e f o o al as s o l s f e e elo e of a so s a e e s o a g la els o e s le els o eo e e e a e a al easo s s la ell g s l el o a se o f s o o o s e s e s la e alo g o e e la ell g s as e R

T e s e o e e a e ole of e a e s s as a e s ga s as a o e al s asso a e e as ee g ossl e agge a e o e e l l e e s o s e f

e e e s gges s s ga s o a e s ga s ossess e eal s s o a e s s a all s o ge e s of o e e g a o es e o a e o o e a o a es I eal s es o so alo e s o s e ffe g le els of a o e s o f e e g o e as e a e see la e

T e as o e a s e of la ell g as e o e al o o fl e R la ell g I a o e la ell g a also o fl e e P of l g o g e a a e s g

e o e la s s as e e s ga o so o fa a e o foo o s e s la s a e a e e o a so ela es o a s e f e o al a a of e o e I

e ase of s ga e e s e o e al fo e a le a e e s ga o e e a e s ga la s o e a e o o s e a g e e g o e e e al e off fo e g es o la s T s a es l o s e a le sal g e of la ell g s a e e s o l e e o o f e e e eg of foo o a es a a s foo

la ell g ge e all a oss l e foo eg la o s s e

The AFGC strongly opposes any form of front of pack advisory statement or warning label regarding the levels of certain nutrients (e.g., added sugar, sodium, saturated fats, alcohol and energy content) in food based on a lack of sound evidence, and conflict with the current HSR system.

REGULATING THE COMPOSITION OF FOODS

oo s al ea ell eg la e foo s s e safe a a o a el la elle fo fo e o e a s al a a age foo s ee o of ese e e e s o es a asso a e ll ess a e alle diet related disease o lifestyle related disease T e a e o alle food related disease I eal e e s o s gle foo o foo a ego a as ee s o gl l e o a

sease e le els e e a e asso a e eal o o es o l as o e of a fa o s o g o a eal o o e

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g / e /lo le els I e P e a el le e g ese o e al le els o o e s o g s e f as s ee e a lea o o s e o f s o a e o e o s e s

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ases o g s e f as s ee e a lea o o s e o f s o a e o e o s e s

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aseT e s o gl o oses a fo of f o of a a so s a e e o a g la el

ega g e le els of e a e s e g a e s ga so sa a e fa s al o ol a

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aseega g e le els of e a e s e g a e s ga so sa a e fa s al o ol a

e e g o e foo so s a e e s a e ese e e fo ases e e e e s e

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asee e g o e foo so s a e e s a e ese e e fo ases e e e e s e

s of s g f a a e se eal o o es fo o s e s o s g o s of o s e s T e e s

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s of s g f a a e se eal o o es fo o s e s o s g o s of o s e s T e e s s l o so s e f o o al as s o l s f e e elo e of a so

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s l o so s e f o o al as s o l s f e e elo e of a so s a e e s o a g la els o e s le els o eo e e e a e a al easo s s

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s a e e s o a g la els o e s le els o eo e e e a e a al easo s s la ell g s l el o a se o f s o o o s e s e s la e alo g o e e

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la ell g s l el o a se o f s o o o s e s e s la e alo g o e e

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s asso a e e as ee g ossl e agge a e

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o e e l l e e s o s e f

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o e e l l e e s o s e f s gges s s ga s o a e s ga s ossess e eal s s o a e s s a all

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s gges s s ga s o a e s ga s ossess e eal s s o a e s s a all s o ge e s of o e e g a o es e o a e o o e a o a es I eal

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s o ge e s of o e e g a o es e o a e o o e a o a es I eal s es o so alo e s o s e ffe g le els of a o e s o f e e g

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s es o so alo e s o s e ffe g le els of a o e s o f e e g o e as e a e see la e

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o e as e a e see la e

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T e as o e a s e of la ell g as e o e al o o fl e R la ell g

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T e as o e a s e of la ell g as e o e al o o fl e R la ell g I a o e la ell g a also o fl e

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I a o e la ell g a also o fl e e o e la s s as e e s ga o so o fa a e o foo o s e

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e o e la s s as e e s ga o so o fa a e o foo o s e s la s a e a e e o a so ela es o a s e f e o al a a of e o e I

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s la s a e a e e o a so ela es o a s e f e o al a a of e o e I e ase of s ga e e s e o e al fo e a le a e e s ga o e e a e s ga

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e ase of s ga e e s e o e al fo e a le a e e s ga o e e a e s ga la s o e a e o o s e a g e e g o e e e al e off fo e

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la s o e a e o o s e a g e e g o e e e al e off fo e g es o la s T s a es l o s e a le sal g e of la ell g s a e e s RTI R

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g es o la s T s a es l o s e a le sal g e of la ell g s a e e s o l e e o o f e e e eg of foo o a es a a s foo RTI R

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o l e e o o f e e e eg of foo o a es a a s foo la ell g ge e all a oss l e foo eg la o s s e RTI R

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la ell g ge e all a oss l e foo eg la o s s e

The AFGC strongly opposes any form of front of pack advisory statement or warning label RTI Rele

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ea sease fo e a le s l e o e a la l sa a e fa le els also o s al a o a o al o ol o s o a fa l s o T e a o al fa o s ea a eg la g foo s o e e sease o g e o s o alo e s l el o e s essf l

a ol a oa es o e ela e o o a le seases s fo s o o f g o s e e a o es a e a o s efo la o s ea a s o a ge e e l g

foo s l e a foo s efo la e e o s e oes o a e o o f as all s o e a al e a foo a e le e ef g f o a o e e Refo la o a e

s le ol a efo la o o a e go e e le a a o e l s

a a o e l s o s e f g e ss le a o s of a g e e a g e foo a so fo e foo a fa e s o efo la e f e a e foo o e a o e

a e

a a o e l s a e e o s f o legall e g sol e e fo a o es l e a o of ese a es o o e a es s o es a le o s e s o a fa e s o all fo so e foo o s e se of sal a s ga e fo s

e olog al f o s s as foo ese a o a s elf s a l

T e s o gl o oses eg la o of e e o os o of foo s as a ea s o o f o s e e a o es a e a o s es es e a o o s e a a e f ee o e e a e o e o e effe e ol a es o e e o s o of less eal foo s fo s a e o g la ell g a e a o o o g ol a efo la o T e all o

efo la e a o e o age efo la o as ee o s s e o g o e e ol s a e e s a g a e o e s l g e e a o s s Political Declaration on the Prevention and Control of Non-Communicable Diseasesxxvi e a o s e e al sse l 2018 a e s Global Action Plan for the Prevention and Control of Noncommunicable Diseases 2013–2020.

oo ol a a o al e a g el es e e a o e f l f e effe o foo o e s o efo la e o s o all a a o o la ell g go e e s e e foo o e s o ese o al fo a o a s a a e fo a o e a ag g of el g le

foo a o e a s a e o o s e s a o e o os o of foo s a s

ol a efo la o as ee e o se e as a e e o s a eg a as ee a o e e foo s s e l es l g a ges o e e o os o of a age foo s o a g o eso o a a e o os o al e l s

I s al a e go e e as es a l s e olla o a e a es o g foo o a es a a e ol a so o e s o foo efo la o a oss a e of

foo a ego es s as e oo a eal alog e a e e eal oo Pa e s

The AFGC recommends any initiative to promote healthy eating be based on the whole of diet, whole food approach of the Australian Dietary Guidelines rather than seeking to limit consumption of particular product categories or single nutrients.

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es l e a o of ese a es o o e a es s o es a le o s e s o

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es l e a o of ese a es o o e a es s o es a le o s e s o a fa e s o all fo so e foo o s e se of sal a s ga e fo s

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a fa e s o all fo so e foo o s e se of sal a s ga e fo s

T e s o gl o oses eg la o of e e o os o of foo s as a ea s o o f

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aseT e s o gl o oses eg la o of e e o os o of foo s as a ea s o o f

o s e e a o es a e a o s es es e a o o s e a a e f ee o

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aseo s e e a o es a e a o s es es e a o o s e a a e f ee o

e e a e o e o e effe e ol a es o e e o s o of less eal foo s fo

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asee e a e o e o e effe e ol a es o e e o s o of less eal foo s fo

s a e o g la ell g a e a o o o g ol a efo la o T e all o

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s a e o g la ell g a e a o o o g ol a efo la o T e all o efo la e a o e o age efo la o as ee o s s e o g o e e ol

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efo la e a o e o age efo la o as ee o s s e o g o e e ol s a e e s a g a e o e s l g e e a o s s

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s a e e s a g a e o e s l g e e a o s s the Prevention and Control of Non-Communicable Diseases

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the Prevention and Control of Non-Communicable Diseasesxxvi

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xxvi e a o s e e al sse l

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e a o s e e al sse l xxvi e a o s e e al sse l xxvi

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xxvi e a o s e e al sse l xxvi

Global Action Plan for the Prevention and Control of Noncommunicable

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Global Action Plan for the Prevention and Control of Noncommunicable

oo ol a a o al e a g el es e e a o e f l f e effe o foo o e s

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oo ol a a o al e a g el es e e a o e f l f e effe o foo o e s efo la e o s o all a a o o la ell g go e e s e e foo

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efo la e o s o all a a o o la ell g go e e s e e foo o e s o ese o al fo a o a s a a e fo a o e a ag g of el g le

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o e s o ese o al fo a o a s a a e fo a o e a ag g of el g le foo a o e a s a e o o s e s a o e o os o of foo s a s

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foo a o e a s a e o o s e s a o e o os o of foo s a s

ol a efo la o as ee e o se e as a e e o s a eg

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ol a efo la o as ee e o se e as a e e o s a eg as ee a o e e foo s s e l es l g a ges o e e

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as ee a o e e foo s s e l es l g a ges o e e o os o of a age foo s o a g o eso o a a e o os o al e l s

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o os o of a age foo s o a g o eso o a a e o os o al e l s I s al a e go e e as es a l s e olla o a e a es o g foo

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I s al a e go e e as es a l s e olla o a e a es o g foo es a a e ol a so o e s o foo efo la o a oss a e of

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es a a e ol a so o e s o foo efo la o a oss a e of foo a ego es s as e

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foo a ego es s as e oo a eal alog e

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oo a eal alog e

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The AFGC recommends any initiative to promote healthy eating be based on the whole of RTI Rele

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The AFGC recommends any initiative to promote healthy eating be based on the whole of RTI Rele

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diet, whole food approach of the Australian Dietary Guidelines rather than seeking to limit RTI Rele

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diet, whole food approach of the Australian Dietary Guidelines rather than seeking to limit consumption of particular product categories or single nutrients.RTI R

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consumption of particular product categories or single nutrients.RTI Rele

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DATA USE AND EVIDENCE

T e s o s e o ose e a le of s e g e g e e e e a a a s s e s o e e fo e s o s a o s a o assess o o es

I 2009 e a o al P e e e eal Tas fo e o le e e os o e e s e e a a o efo e o s e of o e e g a o es s al a o s gle fa o o g o of fa o s as e f e as e g s o gl asso a e a e efo e o e all g e eases e e g of s al a s f o se a a s olog al le el e g ga s a se o e ea g

ela e o a e e e e g o s e e ee s e e g e e e e e e a s o as o a lea s a als o ea a o e e e e g ee s a e e a e ffe e

a o e s o s e e ess ffe e als

o s al a e os o a e eal a o a a s f o e s al a eal e T e es l s s o a e a e age a l e e g lo o le a e as e ease fo o

e a o e e ee 1995 a 2011 12 T e a e age a l a e of s ga s a sa a e fa also e l e s g f a l g s e T s s gges s a e e a e fa o s o e a

ease e e g a e o g o g e le els of o es a oss e a o

EVIDENCE VERSUS PERCEPTION - SUGAR I e e ea s e e as ee a l eal fo s o s ga s gges o s a s a e a a la l o e sole e of o es T e s e e oes o s o s o os o I ee so e s es s gges a s ga o o e a la l s ose o a s f ose oes o la a dominant ole e g es o s le fo e se o e e g a o es e elo e o es

e e e e s e f l e a e s gges s a

Guidelines on dietary sugar do not meet criteria for trustworthy recommendations and are based on low-quality evidence. Public health officials (when promulgating these recommendations) and their public audience (when considering dietary behaviour) should be aware of these limitations.

T e s al a foo a e e age se o a e s e a e of oo a a s s al a e eala

Experts generally agree that eating excess kilojoules (energy) contributes to weight gain. Being overweight or obese increases the risk of chronic health problems like high blood pressure, type 2 diabetes and heart disease. Sugar provides the same amount of energy or kilojoules (kJ) per gram as other forms of digestible carbohydrates such as starch found in breads, rice and pasta. However some foods have a lot of sugar. It’s important to remember that eating too much of any food can contribute to weight gain

l os all e e e g e e o es f o e a o e s fa o e al o ol a a o a e s a a s ga e e s f o e a al s g o e a a f o

o e 130 000 als e o s a e a e e a a es of all a o e s e e os el asso a e o ass e I a o e eas es of a os e o ela o as

g es fa follo e o e a s a T e o ela o s ga as e lo es a e e a a e e o e e fo o al e e g s ga as ega e T a s e so s e al

e e g a e ose g es s ga a e a e lo es I T e a o s of e s o e e a e

…policy makers are being encouraged to specifically target sugar intake in order to combat obesity.

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a e eal a o a a s f o e s al a eal

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a e eal a o a a s f o e s al a eal T e es l s s o a e a e age a l e e g lo o le a e as e ease fo o

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e a o e e ee 1995 a 2011 12 T e a e age a l a e of s ga s a sa a e fa

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asee a o e e ee 1995 a 2011 12 T e a e age a l a e of s ga s a sa a e fa

T s s gges s a e e a e fa o s o e a

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e e g a e o g o g e le els of o es a oss e a o

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ase e e g a e o g o g e le els of o es a oss e a o

EVIDENCE VERSUS PERCEPTION - SUGAR

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EVIDENCE VERSUS PERCEPTION - SUGAR I e e ea s e e as ee a l eal fo s o s ga s gges o s a s a e

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I e e ea s e e as ee a l eal fo s o s ga s gges o s a s a e a a la l o e sole e of o es T e s e e oes o s o s o os o

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a a la l o e sole e of o es T e s e e oes o s o s o os o s gges a s ga o o e a la l s ose o a s f ose

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s gges a s ga o o e a la l s ose o a s f ose ole e g es o s le fo e se o e e g a o es

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ole e g es o s le fo e se o e e g a o es

s e f l e a e s gges s a

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s e f l e a e s gges s a

Guidelines on dietary sugar do not meet criteria for trustworthy recommendations and

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Guidelines on dietary sugar do not meet criteria for trustworthy recommendations and are based on low-quality evidence. Public health officials (when promulgating these

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are based on low-quality evidence. Public health officials (when promulgating these recommendations) and their public audience (when considering dietary behaviour)

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recommendations) and their public audience (when considering dietary behaviour) should be aware of these limitations.

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should be aware of these limitations.

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T e s al a foo a e e age se o a e s e a e of oo a a s s al a e

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T e s al a foo a e e age se o a e s e a e of oo a a s s al a e eala

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eala

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Experts generally agree that eating excess kilojoules (energy) contributes to weight gain. RTI Rele

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Experts generally agree that eating excess kilojoules (energy) contributes to weight gain. Being overweight or obese increases the risk of chronic health problems like high blood RTI R

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Being overweight or obese increases the risk of chronic health problems like high blood pressure, type 2 diabetes and heart disease. Sugar provides the same amount of energy or RTI R

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pressure, type 2 diabetes and heart disease. Sugar provides the same amount of energy or RTI Rele

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kilojoules (kJ) per gram as other forms of digestible carbohydrates such as starch found in RTI Rele

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breads, rice and pasta. However some foods have a lot of sugar. It’s important to remember


25

o l e

Focusing public health interventions and messages on sugar may detract from the need to reduce overall energy consumption and could, paradoxically, increase fat consumption.

T e l eal fo s o s ga s s so e es e e e o a ge s e f foo s o a g s ga s es e a la of e e e ase a e o e al fo e e ega e o o es

e e a le s ea fas e eal a o e foo e o e e e s ea fas e eals a e f e e l a ge e ela o o l eal a o a o o e e g a o es s a eg es e R a e eal oo Pa e s efo la o age a s all o e as s of o al s ga s o e T s s e o as e e e e ase e o s a g ea fas e eal o s o s asso a e e e o a e e eal l g a

lo e e ale e of o e e g a o es P l eal s a eg es a a ge ea fas e eals a e e o e al o s o age o s o of ese o a o e foo s a o e o g e a es of o e e g a o es

s s e a l e a e e e s g e sa e e o olog se fo e e e Re e s s o g e s fo eg la ea fas e eal o s o as asso a e a s g f a l lo e s of o e e g a o es alo gs e o e o s e s a a g ea e l el oo of ee g e o e e e a es

Regular breakfast cereal consumption is associated with a lower body mass index and less risk of being overweight or obese. A 12 per cent lower risk of being overweight or obese was found for both adults and children.

Presweetened breakfast cereals do not increase the risk of overweight and obesity in children.

Consumption of pre-sweetened breakfast cereals does not increase daily total sugars intake in children and adolescents.

T ese f gs a e ell s o e se o a a al ses of e s al a eal e a o al o a P s al e fo

Australian adults who ate breakfast cereal had a significantly smaller waist circumference, were more likely to be a healthy weight and were less likely to be overweight or obese, than those who ate other breakfasts.

Australian adults who ate breakfast cereal had the lowest daily intake of added sugars – 10 per cent lower than those who ate other foods for breakfast and 26 per cent lower than breakfast skippers. This is consistent with the finding that most Australians (62% of adults and 62% of children) consumed breakfast cereals with less than 15g total sugars per 100g (including the sugars from fruit ingredients).

For Australian children, there was no difference in weight among children who ate breakfast cereal and those who ate other breakfasts.

For Australian children, there was no difference in added sugars intakes or energy intakes between children that ate breakfast cereal (regardless of its level of sweetening) and children that ate other breakfast foods.

Added sugars from breakfast cereal accounted for less than one per cent of the daily energy intakes in the diets of children (0.8%) and of adults (0.7%) who ate breakfast cereal.

Breakfast cereal eaters were also more likely to meet their nutrient requirements, especially for fibre and whole grains which is associated with chronic disease risk reduction. Therefore, penalising these foods could have additional consequences

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s g e sa e e o olog se fo e e e Re e s

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ase s g e sa e e o olog se fo e e e Re e s

s o g e s fo eg la ea fas e eal o s o as asso a e a

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ases o g e s fo eg la ea fas e eal o s o as asso a e a

s g f a l lo e s of o e e g a o es alo gs e o e o s e s a a g ea e

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ases g f a l lo e s of o e e g a o es alo gs e o e o s e s a a g ea e

Regular breakfast cereal consumption is associated with a lower body mass index an

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Regular breakfast cereal consumption is associated with a lower body mass index an

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less risk of being overweight or obese. A 12 per cent lower risk of being overweight or

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less risk of being overweight or obese. A 12 per cent lower risk of being overweight or

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obese was found for both adults and children.

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obese was found for both adults and children. obese was found for both adults and children.

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obese was found for both adults and children.

Presweetened breakfast cereals do not increase the risk of overweight and obesity in

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Presweetened breakfast cereals do not increase the risk of overweight and obesity in

Consumption of pre-sweetened breakfast cereals does not increase daily total sugars

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Consumption of pre-sweetened breakfast cereals does not increase daily total sugars intake in children and adolescents.

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intake in children and adolescents.

T ese f gs a e ell s o e se o a a al ses of e s al a eal

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T ese f gs a e ell s o e se o a a al ses of e s al a eal e a o al o a P s al e fo

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e a o al o a P s al e fo

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Australian adults who ate breakfast cereal had a significantly smaller waist

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Australian adults who ate breakfast cereal had a significantly smaller waist circumference, w

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circumference, were more likely to be a healthy weight and were less likely to be

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ere more likely to be a healthy weight and were less likely to be overweight or obese, than those who ate other breakfasts.

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overweight or obese, than those who ate other breakfasts.

Australian adults who ate breakfast cereal had the lowest daily intake of added sugars

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Australian adults who ate breakfast cereal had the lowest daily intake of added sugars – 10 per cent lower than those who ate other foods for breakfast and 26 per cent lower

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– 10 per cent lower than those who ate other foods for breakfast and 26 per cent lower than breakfast skippers.RTI R

eleas

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than breakfast skippers.of adults and 62% of children) consumed breakfast cereals with less than 15g total RTI R

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of adults and 62% of children) consumed breakfast cereals with less than 15g total RTI Rele

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sugars per 100g (including the sugars from fruit ingredients). RTI Rele

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sugars per 100g (including the sugars from fruit ingredients).

For Australian children, there was no difference in weight among children who ate RTI Rele

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For Australian children, there was no difference in weight among children who ate


26

T s e a le e o s a es e o a e of e s g ol e o e a o s a e e a e eal s a eg es a e s o gl s o e e e e e e ase

T e s o s e s a e e e e ase o e la es s e f e e e a o o e eal ea g a e s

T e e ess e a s l s fo s e o es e a e o a a la e s ga s so o sa a e fa as o g a a ee a ess g e ss e To o e o e e e

Nutritional nit-picking has been unsuccessful in improving public health. Nutrient based interventions are generally ineffective…Dietary pattern recommendations are more likely to show success in improving cardiovascular health.

s s o a o o s e e l fa o al a e of o es as o ose o a s gle a e o og a o a ess e ss e

The AFGC recommends an evidence-based approach on regular monitoring of population food and nutrient intake to better inform decisions, actions and to assess outcomes in addressing obesity.

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The AFGC recommends an evidence-based approach on regular monitoring of population

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The AFGC recommends an evidence-based approach on regular monitoring of population better inform decisions, actions and to assess outcomes in

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COLLECTIVE COMMITMENT

T e s o s e o ose e a le of s o g a o al lea e s a go e a e o e effe e a ge o g fos e g olla o a e a e s s

T e s o gl s o s olla o a e oss se o al a es as e a fo a a ess g e see gl a a le o le of o es e a o al le el s a oa as a a e of s esses a e al ea ee es e a o e e 2007 Australian

Children’s Nutrition and Physical Activity Survey efo la o a es e e Food and Health Dialogue

T e as also o e o e e e eal a ea as a a a o e Premier’s Council for Active Living a ee sla Fast Choices Reference Groups, the Healthy Food Partnership Executive Committee and working groups and the Health Star Rating Advisory Committee and Technical Advisory Group

PARTNERSHIPS WITH GOVERNMENT ess e s al a o e e s a e e og se e al e of o g a e s e

foo s a l eal se o o o e e o a eal s a s of s al a s

T e foo s o e losel e e o s R / lla o e e a e l eal se o o g e oo a eal alog e T s a e o e e 2009 g g oge e foo s a l eal o ga sa o s a oo a e a ego a ego foo efo la o og a a a e e e o s sal a sa a e fa foo o s

o e e e l e e e oal o o e e e eal oo Pa e s a o e la e 2015 as e o e e e le fo oss se o al olla o a o all se o s of e foo

s e ese e a s a fa e s se e es a a s a e a le s as ell as a e l eal se o o g g o s a e e a g o a e

e o e a o s a ll a ess o o s e l g a s es a e g e o se g s es a e e elo e of ol a se g s e goals ol a efo la o of a ge foo a ego es a oa ase o s e e a o

T e al e of oss se o al og a s of s e s o el e og se a e o age as a of e s Global Action Plan for the Prevention and Control of Non-communicable

diseases 2013-2020xxxix olla o a o a oss se o s s e os effe e a o a e a s s e s a oa o o le o le s l e o es e e s l s e o s s gle e o o e s e f s all a oa es a e l el o a ess e e l g e s

To a ge eal e a o a a ge of go e e s o ga sa o s a als ee o o oge e a oo a e a o a a e o le f o a ffe e a gles a a

fle le a s l g s s e s g a s s e s a oa es s o s ea g e o e s a ass s eo le o a e e e eal e s o s a a o o sease

T e o a e of e gag g a oss se o s as ee es a e os e e l a 2018 e e a a o o e s fo e o l eal sse l s 71s ee g el e e e 2018

T e e s s a e

We further encourage the private sector to produce and promote more food and beverage products consistent with a healthy diet including by reformulating products, especially those products with the largest impacts on health, to provide healthier options that are affordable and accessible for all and that follow appropriate nutrition facts and labelling standards, including information on sugars, salt and fats and, where relevant, trans-fat content. We also encourage the private sector to reduce the exposure of and impact on children of

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Fast Choices Reference Groups, the Healthy Food Partnership Executive Committee and working groups and the Health Star Rating

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Healthy Food Partnership Executive Committee and working groups and the Health Star Rating

PARTNERSHIPS WITH GOVERNMENT

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ess e s al a o e e s a e e og se e al e of o g a e s e

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ess e s al a o e e s a e e og se e al e of o g a e s e foo s a l eal se o o o e e o a eal s a s of s al a s

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foo s a l eal se o o o e e o a eal s a s of s al a s

T e foo s o e losel e e o s R / lla o e e a e l eal

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T e foo s o e losel e e o s R / lla o e e a e l eal T s a e o e e 2009 g g oge e

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T s a e o e e 2009 g g oge e foo s a l eal o ga sa o s a oo a e a ego

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foo s a l eal o ga sa o s a oo a e a egoefo la o og a a a e e e o s sal a sa a e fa foo o s

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efo la o og a a a e e e o s sal a sa a e fa foo o s

o e e e l e e e oal o o e e e eal oo Pa e s a o e

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o e e e l e e e oal o o e e e eal oo Pa e s a o e la e 2015 as e o e e e le fo oss se o al olla o a o all se o s of e foo

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la e 2015 as e o e e e le fo oss se o al olla o a o all se o s of e foo s e ese e a s a fa e s se e es a a s a e a le s as

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s e ese e a s a fa e s se e es a a s a e a le s as ell as a e l eal se o o g g o s a e e a g o a e

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ell as a e l eal se o o g g o s a e e a g o a e e o e a o s a ll a ess o o s e l g a s es a e g e o se g

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e o e a o s a ll a ess o o s e l g a s es a e g e o se g s es a e e elo e of ol a se g s e goals ol a efo la o of a ge foo

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s es a e e elo e of ol a se g s e goals ol a efo la o of a ge foo

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a oa ase o s e e a o

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a oa ase o s e e a o

T e al e of oss se o al og a s of s e s o el e og se a e o age as

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T e al e of oss se o al og a s of s e s o el e og se a e o age as a of e s

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a of e s Global Action Plan for the Prevention and Control of Non-communicable

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Global Action Plan for the Prevention and Control of Non-communicable diseases 2013-2020

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diseases 2013-2020xxxix

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xxxix olla o a o a oss se o s s e os effe e a o a e a s s e s

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olla o a o a oss se o s s e os effe e a o a e a s s e s xxxix olla o a o a oss se o s s e os effe e a o a e a s s e s xxxix

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xxxix olla o a o a oss se o s s e os effe e a o a e a s s e s xxxix

a oa o o le o le s l e o es e e s l s e o s s gle e o o e s e RTI Rele

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a oa o o le o le s l e o es e e s l s e o s s gle e o o e s e RTI Rele

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f s all a oa es a e l el o a ess e e l g e s RTI Rele

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f s all a oa es a e l el o a ess e e l g e s

To a ge eal e a o a a ge of go e e s o ga sa o s a als ee o o RTI Rele

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oge e a oo a e a o a a e o le f o a ffe e a gles a a


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marketing of foods and non-alcoholic beverages, consistent with WHO recommendations and guidance, and in accordance with national legislation, policies, and relevant international obligations.

T e s o s s s a e e s e e o g a s al a s ell a a e all e a eas fo a o e f e I foo la ell g foo efo la o a es o s le a e g o

l e e s al a foo s a e o a le el olle el e e a olla o a o o e e a es as a s o g a o a e o es a l s e o e a ea s

T e se lo al I s e s Overcoming Obesity: An initial economic analysisxl s o e s a a oa also a g o o o ol efo la o a a a la l of e e g e se o s as e os a f l e e o s a ea of e a es o s a a es T e e o o se e

a

Capturing the full potential impact is likely to require commitment from government, employers, educators, retailers, restaurants, and food and beverage manufacturers, and a combination of top-down corporate and government interventions and bottom-up community-based ones.

T e also o s e s a olla o a e a oa es o a ess g ss es s as o es a e e o s a e e al e a effe e ess

The AFGC recommends the Government continues to work within cross-sectoral collaborative partnerships to address the obesity issue.

THE SHARED CHALLENGE T o g o s s ss o e as a e e o o e o e e s el o e a s el e a a o s a e e foo s olle el a e of a e s s

o e e a o e s a e ol e s es o se o a a es o al s e e a e s g le els of e ela e s a o es I a o e a les of s e f o a le el

a es a e also ee o e ea of e ese s a a g le es o se o o e l eal alle ge as ell as a g ea e e a f o o s e s fo e o s e fo a s o

ass s e o eal e s

o e a s e e s e o go g o e s a o o es a e e eal

T e o a o la s e o a e of e ss e a e alle ge e ese s o o e e s es a asso a e ll eal la es a a e a le e o e o

as a ole T s a fes s as geo g eal ge s a o e o a e o la o le el I also e a s a g e o al s al a s e o g e al of l fe T e e s a a sol e e a e e efo e of s o g a e e e s g e e a e o of e e

eas g le els of o e e g a o es e s al a o la o

e g s e a o e e a a s e l fa o al ae olog of o es l o g a a e as le el e e e g / e e g o a a g e a s al fa o s s as a a le ge e s

a oss e o la o a o e se e a l fes le a la l a o a o e o ass e a e a a e a s o a e a s os e e l e g o s ee e a e a of e fa o s

o ela e o e e g a o es

es s also o ela e so o e o o s a s a e a o le els a e of o se l e T e e a e e e s gges o s a o es s o s l e a le f o e f el of e ge e s see s a a l s ge e e ess o a e fl e e a e al o al s a s

T e as o e a e o a of ese fa o s s s ss o as s e o e e e se of e o ga sa o a s e e s o o e a al a al s s of e ela e

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Capturing the full potential impact is likely to require commitment from government,

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Capturing the full potential impact is likely to require commitment from government, employers, educators, retailers, restaurants, and food and beverage manufacturers, and a

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employers, educators, retailers, restaurants, and food and beverage manufacturers, and a combination of top-down corporate and government interventions and bottom-up community-

RTI Rele

asecombination of top-down corporate and government interventions and bottom-up community-

T e also o s e s a olla o a e a oa es o a ess g ss es s as o es a e

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aseT e also o s e s a olla o a e a oa es o a ess g ss es s as o es a e

The AFGC recommends the Government continues to work within cross-sectoral

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The AFGC recommends the Government continues to work within cross-sectoral

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collaborative partnerships to address the obesity issue.

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collaborative partnerships to address the obesity issue.

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THE SHARED CHALLENGE

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THE SHARED CHALLENGE T o g o s s ss o e as a e e o o e o e e s el o

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T o g o s s ss o e as a e e o o e o e e s el o e a s el e a a o s a e e foo s olle el a e of a e s s

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e a s el e a a o s a e e foo s olle el a e of a e s s o e e a o e s a e ol e s es o se o a a es o al s e e a e

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o e e a o e s a e ol e s es o se o a a es o al s e e a e s g le els of e ela e s a o es I a o e a les of s e f o a le el

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s g le els of e ela e s a o es I a o e a les of s e f o a le el a es a e also ee o e ea of e ese s a a g le es o se o o e l

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a es a e also ee o e ea of e ese s a a g le es o se o o e l eal alle ge as ell as a g ea e e a f o o s e s fo e o s e fo a s o

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eal alle ge as ell as a g ea e e a f o o s e s fo e o s e fo a s o

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ass s e o eal e s

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ass s e o eal e s


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T e o a o la s e o a e of e ss e a e alle ge e ese s o

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T e o a o la s e o a e of e ss e a e alle ge e ese s o o e e s es a asso a e ll eal la es a a e a le e o e o

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o e e s es a asso a e ll eal la es a a e a le e o e o ole T s a fes s as geo g eal ge s a o e o a e o la o RTI R

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ole T s a fes s as geo g eal ge s a o e o a e o la o le el I also e a s a g e o al s al a s e o g e al of l fe T e e s a RTI R

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le el I also e a s a g e o al s al a s e o g e al of l fe T e e s a a sol e e a e e efo e of s o g a e e e s g e e a e o of e e RTI R

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a sol e e a e e efo e of s o g a e e e s g e e a e o of e e eas g le els of o e e g a o es e s al a o la o RTI R

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eas g le els of o e e g a o es e s al a o la o


29

o a e of ese ss es a e ag e of e al o o s o o e e g a o es s al a

T e as o e a e o s l a o as a se a of ese ss es a o oses so e e a s s of a ess g e a of e o e e a e ase o o es s asso a o s

ee oo e alle ges s as le els o e a o e s o T e s o s ose ss es e g a esse e oa e l ol o e as ese a o s a o e e g

l e a a o al es a eg

T e o s o e e ea l e s s ss o ll s a e ell e s e s e s as a e al ea o eo e e a s e e s a e o e o o g o see a s o a e f e a ges a o a e o e s e s a o e o e o e a e s o eal ea g o s e s o

s al a a a e s o s al a o esse foo o s a e e o e

ga s s a o of o le a e a s e ef a le o olla a a s gle s le a o o e e o s o go g o sol e s al a s o es ss e o ll a o a o of a o s l le e e e of e effe e ess s f e o es al s g f a l

I es g effo s fo se o a s gle e o a ego of foo ef es log a s o e o e f a e al o al s o a all foo s a e o o a e o ea e s a o e sel

eal e s a e a e f o foo s a e ge e all e e e as eal l a el o s e s e e e e a e of e e s s ll g o s e s o e e ea g a s

e o age o a e o s f o e s s e e

T e s o s a s a eg o o a es

1 ea e o o o of e s al a e o eal a g

2 o e esea o e ge e o e al a s olog al e a s s lea o o es o s a a s a e e goo e g o ol o e s o e f a es a

e g ga o s a a a e of o l 500 1000g / ea fo os eo le

3 e elo g o el a oa es o o a e e o a e of o o s e a e a o eo le ea o s e e of foo s T s ol es a s e f e s a g of e o s e e e e e fl e g as g e s o s a la l ela o o o le o a o a a o g fo ge e a o al a e s

4 ess g e o a e of s al e e se e a e a e of ge e al eal a ell e g P s al e e se a es a a g al o o o e e e g / e e g o

e a o e g s all f o es s s a al eal e ef I o e s aga s a a ge of a e se eal o o es asso a e o e e g a o es l g a e es e e s o ea sease os eo o os s a e al ll ess

5 o e s o fo e olla o a e a e s a oa as a e o s a e effe e ess s al a o g a es s as e R f o of a o la ell g s e e

6 Re e a a g e s as e s e e e a e ase o s a oa g e g 10 ea s o of a e a a a e ee s e se e

7. o g a o e a o al o s e T e os e e o la o le el a a s f o e s al a eal e as l s e f e ea s ago Pe o s e s a e

esse al o o a g e a a a e fo eal ol go g fo a .

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a o o e e o s o go g o sol e s al a s o es ss e o ll a o a o of

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a o o e e o s o go g o sol e s al a s o es ss e o ll a o a o of a o s l le e e e of e effe e ess s f e o es al s g f a l

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a o s l le e e e of e effe e ess s f e o es al s g f a l

I es g effo s fo se o a s gle e o a ego of foo ef es log a s o e o e

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aseI es g effo s fo se o a s gle e o a ego of foo ef es log a s o e o e

f a e al o al s o a all foo s a e o o a e o ea e s a o e sel

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asef a e al o al s o a all foo s a e o o a e o ea e s a o e sel

eal e s a e a e f o foo s a e ge e all e e e as eal l a el

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aseeal e s a e a e f o foo s a e ge e all e e e as eal l a el

o s e s e e e e a e of e e s s ll g o s e s o e e ea g a s

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aseo s e s e e e e a e of e e s s ll g o s e s o e e ea g a s


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ea e o o o of e s al a e o eal a g

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ea e o o o of e s al a e o eal a g

o e esea o e ge e o e al a s olog al e a s s lea o

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o e esea o e ge e o e al a s olog al e a s s lea o o es o s a a s a e e goo e g o ol o e s o e f a es a

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o es o s a a s a e e goo e g o ol o e s o e f a es a e g ga o s a a a e of o l 500 1000g / ea fo os eo le

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e g ga o s a a a e of o l 500 1000g / ea fo os eo le

e elo g o el a oa es o o a e e o a e of o o s e a e

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e elo g o el a oa es o o a e e o a e of o o s e a e a o eo le ea o s e e of foo s T s ol es a s e f e s a g of e

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a o eo le ea o s e e of foo s T s ol es a s e f e s a g of e o s e e e e e fl e g as g e s o s a la l ela o o o le

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o s e e e e e fl e g as g e s o s a la l ela o o o le o a o a a o g fo ge e a o al a e s

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o a o a a o g fo ge e a o al a e s

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ess g e o a e of s al e e se e a e a e of ge e al eal a

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ess g e o a e of s al e e se e a e a e of ge e al eal a ell e g P s al e e se a es a a g al o o o e e e g / e e g o

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ell e g P s al e e se a es a a g al o o o e e e g / e e g o e a o e g s all f o es s s a al eal e ef I o e s aga s a RTI R

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e a o e g s all f o es s s a al eal e ef I o e s aga s a a ge of a e se eal o o es asso a e o e e g a o es l g RTI R

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a e es e e s o ea sease os eo o os s a e al ll ess RTI Rele

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a e es e e s o ea sease os eo o os s a e al ll ess


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CONCLUDING COMMENTS

T e as el o e e o o o o e o e o s l a o e fo of s ss o

o s a g s e o es ss e a e o ess of f g a sol o s o le a e s a a e a s ss o ll o a e o e e o le el all of e ss es e

I ll see o a ess I ee e es o ses o e o s l a o a ell ea a e of e a e s ll ee o e o s e e T e s a s ea o o e f e la f a o o fee a as e elo e of e a o al es a eg o ee s

For further information about the contents of this submission contact:

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APPENDIX 1 – HOW THE FOOD INDUSTRY ASSISTS HEALTHY EATING FRONT OF PACK [NUTRITION] LABELLING I o e 2006 e s a l I a e e

as e f s s ag ee f o of a o la ell g s e e o e o ass s o s e s o sele eal e s s las a 2010 as

fo o e o o e 7200 o s a oss all a o foo a ego es

I 2014 s a o e e e l e elo e Health Star Rating s e o es f e

e e e a e o o s e s o ass s e e a o es T e R o a ea s o o e

10 000 o s a o es o e s o e s go e e l eal a o s e g o s

T e s ses a a ge of o e e e e eal a s a s ols o ass s o s e s o

a e eal o es ese l e

The Australian Industry Group’s Be Treatwise

The Glycaemic Index Foundation

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APPENDIX 2 – COMPANY INITIATIVES

T e follo g a e e a les of e a a es foo o a es a e le e e o o e o s e s o e fo a o

2.1 ALLEN’S – SPECIFIC PORTION ADVICE Po o a e s e g o e o al os all es le o fe o a a e s s o e o a off a essag g

Keep the smiles going by enjoying the right portion combined with physical activity.

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2.2. MILKY BAR – SHARE AND RE-CLOSE Pa ag g s es g e o e a le eseal g a essag g e o ages e 1 o o o g a f e s a g of e o

Chocolate blocks are perfect for sharing. Break off 1 row for a delicious treat, then share or re-close for later

ff a essag g also s o a o a e o o s e fo o ola e.

https://www.nestle.com.au/kitkat#1

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2.3 COMPANY WIDE COMMITMENTS o el I e a o al as o e glo all o ease s o o o olle o s 25 2020 T s ea s o e all a e o o o s less a 840 200 al l 2017 o el I e a o al a e ee e e a ge a ea of s e le a e g 39

all o o o olle o o s s 11 of e e e e o a e

I a o o all a e s gle se e o s o a es se a ag g ools s as e seala le a e lose o l se e o o s o o e o s e s a o a ool o a e so e a sa e e es fo la e a fo a o a o s g e o a s a g a

so al o as o ee elo e eel a eseal a ag g o e 2009 fo a a l fa l lo o o e o a o e a o e o as o o e o age o s o s of

s alle o o s ls ese g f es ess

2.4 BAKING MELTS – RECIPE PORTION GUIDANCE ON INGREDIENTS

es l Po o a e as also ee e e e o g e e s se e es o a e e a o a e o o s es e se g e f s e e e

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RECIPE PORTION GUIDANCE ON

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RECIPE PORTION GUIDANCE ON

es l Po o a e as also ee e e e o g e e s se e es o a e e

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es l Po o a e as also ee e e e o g e e s se e es o a e e a o a e o o s es e se g e f s e e e

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a o a e o o s es e se g e f s e e e

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2.5 UNCLE TOBYS MUESLI BAR – PORTION CONTROL

T ass s s o s e o o e a e e e e g a e ese g e o s gle se e a ag g o eo e o g lea o o s e e o s f e g a e o a se g s o e

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APPENDIX 3 CONSUMER EDUCATION MATERIALS

3.1 PORTION CONTROL RESOURCES es l Po o a e as also ee e e e o fo a o a o s e oo le

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INTERACTIVE RESOURCES https://www.mondelezinternational.com/impact/well-being-snacks

I 2016 o el I e a o al os e a f l a g al s ss o o oogle a go s al a a e eala as a of a glo al a e f l ess o f l s a g s a o

e g a a e of e foo o e ea g fo s g o e as e a e e o e a e o g as a s a o s as oss le o g so a el a sla e o e e ea g a s

T e sess o s e lo e o eo le e e a l g e o e of f l ess o ea g a s a g T e also s sse o a o a l e o ele g el o s e s o g

fo a o e a o a o a o o a e f l foo o es

T s og a ela es o o ea g a a o g a f l a oa o e o g ea s a s s o e a f l ea g ool a a e se eal ofess o als o s e s a e lo ees. T ese eso es a e ase o s e f esea a e ee e elo e

o s s a a e es g e o e eas l e s oo a a al fo eal ofess o als a o s e s // eal o s a f l o /

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o s s a a e es g e o e eas l e s oo a a al fo eal ofess o als a

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o s s a a e es g e o e eas l e s oo a a al fo eal ofess o als a

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APPENDIX 4 REFORMULATION AND INNOVATION

4.1 UP&GO – SUGAR REDUCTION P Re e ga s a e a le of a o o a o o o e o s e s a lo e

s ga o e P Re e ga o a s 1/3 less s ga a eg la P le s ll e g lo sa a e fa

4.2 YOPLAIT RANGE – SUGAR REDUCTION & PORTION CONTROL FOR CHILDREN o a s efo la e e Yoplait Petit Miam a ge o a e 30% less sugar than the

average flavoured yoghurt eal f a e goo ess of l a a o a e se g s e fo s.

T s o la Pe a efo la o e o e 120 o es of a e s ga f o e foo s l 2017 fo e ea os la

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SUGAR REDUCTION & PORTION CONTROL

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SUGAR REDUCTION & PORTION CONTROL

Yoplait Petit Miam

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Yoplait Petit Miam a ge o a e

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a ge o a e eal f a e goo ess of l a a o a e se g s e fo

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eal f a e goo ess of l a a o a e se g s e fo

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4.3 PEPSICO AUSTRALIA SNACKS - SATURATED FAT AND SODIUM REDUCTION Pe s o s al a as e e l a ge e oo g o l fo all s a o s a a s o s al a a ola o l s g f a l e g e sa a e fa o e o os Tos os a a le o lla

s T s es ge R gs a ee os

o so e of e o a s o a s e sa a e fa o e as ee e e as as 86 Pe s o s al a s o e o e g e a e s ga s sa a e fa a so Pe s o s o s fo ss e o s e s

s s a e e s f o s al a a ola o l 2018 a s as o olle o o e es of e o fol o

Pe s o s al a s also e o ess of oll g o e ol a eal a Ra g o f o of a a ag g fo all of s s a foo s eal a Ra gs ll e o 67 of Pe s o s

s al a s a o s e e of 2019 o a o ee go e e g el es of 70 2023

DORITOS ORIGINAL SALTED 170g

NUTRITIONAL INFORMATION

R I P R P 6 3

R I I 27g o 11 s

e age a

Pe se g

a l I a e

e se g

e age a

e 100g

R 570 7 2110

PR T I 2 2g 4 8 2g

T T T

T R T

TR

P T R T

T R T

6 3g

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0 1g

1 7g

3 8g

9

3

23 2g

2 7g

0 2g

6 4g

14 0g

R R T

R

17 2g

0 3g

6

0

63 7g

1 0g

I 117 g 5 435 g

P T I 51 g 189 g

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4.4 MARS – INCREASED VEGETABELS, WHOLEGRAINS AND LEGUMES

a s eal ell ess Re o 2019 e a ls glo al es l s a e e efo la o f o of a la ell g a eases o s o of oleg a s e

s //a s a s o / a e a s/foo

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// a s go a /a ss a s/a s sf/ oo / 20 e /4364 0 55 011 201112 a 20 ea es o s o 20of 20 e 20 ga s 20

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o Resea s al a ea fas o e a s a o a e a f ee s ga s a e

se o a a al s s of e 2011 12 a o al o a P s al e e e e e 2016

a e oo e o ell T Pe o P ea fas a ea fas e eal o e a I s I a o e a ga I a es a o o e eas es a o g a a o all Re ese a e a le of

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TIME TO WEIGH IN

Have your say on a national obesity strategy PLEASE NOTE: THIS WORD VERSION OF THE SURVEY IS FOR REFERENCE PURPOSES ONLY. PLEASE SUBMIT YOUR RESPONSE VIA THE ONLINE SURVEY AT https://www.surveygizmo.com/s3/5291207/national-obesity-strategy-long-survey

The Australian Industry Group provided their submission via the long survey form. The responses to their survey have been extracted from the data base and pasted in the corresponding question below. Answering questions was not compulsory.

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PLEASE NOTE: THIS WORD VERSION OF THE SURVEY IS FOR REFERENCE PURPOSES ONLY.

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PLEASE NOTE: THIS WORD VERSION OF THE SURVEY IS FOR REFERENCE PURPOSES ONLY. PLEASE SUBMIT YOUR RESPONSE VIA THE ONLINE SURVEY AT

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PLEASE SUBMIT YOUR RESPONSE VIA THE ONLINE SURVEY AT

https://www.surveygizmo.com/s3/5291207/national-obesity-strategy-long-survey

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https://www.surveygizmo.com/s3/5291207/national-obesity-strategy-long-survey

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The Australian Industry Group provided their submission via the long survey form. The

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The Australian Industry Group provided their submission via the long survey form. The responses to their survey have been extracted from the data base and pasted in the

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responses to their survey have been extracted from the data base and pasted in the

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corresponding question below. Answering questions was not compulsory.

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corresponding question below. Answering questions was not compulsory.


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Introduction The Australian community is invited to take part in a national consultation to inform a national obesity strategy. This consultation runs from 4 November to 15 December 2019 and is being conducted by The Social Deck on behalf of the Council Of Australian Governments (COAG) Health Council. This survey is one of the ways you can have your say. While completing this survey you may want to refer to the consultation paper. The consultation paper provides details of the proposed framework and ideas for consideration to be included in a national obesity strategy. There is also a shorter version of the consultation paper.

About the survey

This survey is most relevant to organisations or interested individuals who want to have their say about the specific ideas and strategies being considered for inclusion in a national obesity strategy.

The survey will close at 11:59 pm on Sunday, 15 December 2019.

This survey includes some questions that ask you to rate items on a scale and other questions that ask you to write about your views, suggestions and feedback on specific strategies and ideas that are outlined in the consultation paper. It is designed to enable you to submit comments about each of the proposed strategies if you want to.

The survey may take at least 45 minutes to complete, or longer if you provide comments on specific strategies. There is also a shorter survey available, which will only take approximately 20 minutes to complete. The shorter survey is for members of the public.

The survey is in six parts, which includes:

Section 1. Proposed timeframe and scope for a national obesity strategy Section 2. Proposed principles to guide a national obesity strategy Section 3. Proposed priority areas and strategies for a national obesity strategy Section 4. Proposed enablers for a national obesity strategy Section 5. Proposed implementation, monitoring, evaluation and reporting of a

national obesity strategy Section 6. Questions about you

If you wish, you can complete the survey in stages. On the bottom right of each page of the survey, there is an option to supply an email address to save your progress. A unique link will be emailed to you that will allow you to return where you left off. Email addresses entered for this purpose are not saved with your responses to the survey. Please note that,

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shorter version of the

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This survey is most relevant to organisations or interested individuals who want to have

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This survey is most relevant to organisations or interested individuals who want to have their say about the specific ideas and strategies being considered for inclusion in a national

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their say about the specific ideas and strategies being considered for inclusion in a national


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This survey includes some questions that ask you to rate items on a scale and other

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This survey includes some questions that ask you to rate items on a scale and other questions that ask you to write about your views, suggestions and feedback on specific

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questions that ask you to write about your views, suggestions and feedback on specific strategies and ideas that are outlined in the consultation paper. It is designed to enable you

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strategies and ideas that are outlined in the consultation paper. It is designed to enable you to submit comments about each of the proposed strategies if you want to.

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to submit comments about each of the proposed strategies if you want to.

The survey may take at least 45 minutes to complete, or longer if you provide comments on

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The survey may take at least 45 minutes to complete, or longer if you provide comments on specific strategies. There is also a

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specific strategies. There is also a shorter survey

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shorter survey

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approximately 20 minutes to complete. The shorter survey is for members of the public.

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approximately 20 minutes to complete. The shorter survey is for members of the public.

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The survey is in six parts, which includes:

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depending on which email service you use, these emails can take up to a few hours to come through to your inbox. This survey is being conducted in accordance with the Privacy Act 1988. You can access The Social Deck’s research privacy policy here.

Support to help you complete the survey

If you have difficulty understanding the survey and need a translator or interpreter, please call the Translating and Interpreting Services (TIS National) on 131 450 and ask them to contact The Social Deck on 0491 617 118.

The National Relay Service (NRS) is a service for people who are deaf, hard of hearing and/or have a speech impairment. If you need help contacting us, the NRS can assist. To contact the NRS visit https://www.communications.gov.au/what-we-do/phone/services-people-disability/accesshub/national-relay-service or call the following numbers: • TTY — 133 677 • Speak and Listen — 1300 555 727 • SMS relay — 0423 677 767

If any of the questions or content in the survey/s cause you distress, you can end the survey at any time. If you or someone you know is in crisis or feeling distressed and needs support, call Lifeline on 13 11 14 or Beyond Blue on 1300 224 636. The Butterfly Foundation supports anyone concerned by an eating disorder or body image issues on 1800 334 673.

If you have any questions or concerns about the survey, please email [email protected]

How will responses be used?

Findings from the survey will be collated and included in a report to inform the development of a national obesity strategy.

You will be required to consent to having information published or used publicly.

If you are an organisation completing this survey, you will be required to provide the name of your organisation and your responses may be attributed to your organisation. A list of organisations who completed the survey may be published online and in the consultation report.

Organisations will also be required to provide a contact name and email address so that we can contact them about this consultation if required. Names and email addresses will not be published or shared with any third parties.

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and/or have a speech impairment. If you need help contacting us, the NRS can assist. To

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contact the NRS visit https://www.communications.gov.au/what-we-do/phone/services-

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people-disability/accesshub/national-relay-service or call the following numbers:

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people-disability/accesshub/national-relay-service or call the following numbers:

If any of the questions or content in the survey/s cause you distress, you can end the survey

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If any of the questions or content in the survey/s cause you distress, you can end the survey at any time. If you or someone you know is in crisis or feeling distressed and needs support,

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at any time. If you or someone you know is in crisis or feeling distressed and needs support, call Lifeline on 13 11 14 or Beyond Blue on 1300 224 636. The Butterfly Foundation supports

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call Lifeline on 13 11 14 or Beyond Blue on 1300 224 636. The Butterfly Foundation supports anyone concerned by an eating disorder or body image issues on 1800 334 673.

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anyone concerned by an eating disorder or body image issues on 1800 334 673.

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If you have any questions or concerns about the survey, please email

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If you have any questions or concerns about the survey, please email [email protected]

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[email protected]

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Thank you for completing the survey. Consent to participate in this survey. By participating in this survey, you indicate that:

You have read the above information; Your participation in this survey is voluntary; You consent to your responses being included in public reports; and You are at least 14 years of age.

Q1. Do you wish to continue with this survey?

1. Yes (skip to Q2) 2. No (if you select no, you will be exited from the survey)

Q2. Are you completing this survey on behalf of an organisation or as an interested individual?

1. On behalf of an organisation 2. As an interested individual

Q3. What is your organisation’s main role or interest in a national obesity strategy? You may select all that apply.

1. We are a health or medical organisation 2. We are a research organisation 3. We are an education institution 4. We are a government organisation 5. We are a business that sells and/or markets food/drinks/produce 6. We are an organisation that represents businesses that sell and/or market

food/drinks/produce 7. We are a health/fitness/sport/wellness organisation 8. We represent a particular population group 9. Other (please specify)

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No (if you select no, you will be exited from the survey)

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No (if you select no, you will be exited from the survey)

Q2. Are you completing this survey on behalf of an organisation or as an interested

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Q3. What is your organisation’s main role or interest in a national obesity strategy? You

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Q4. What is your main role or interest in a national obesity strategy? You may select all that apply.

1. I am a health professional 2. I am an academic or researcher 3. I am employed by federal, state or territory, or local government 4. I am a business owner 5. I work in a health promotion organisation 6. I work for a business that sells and/or markets food/drinks/produce 7. I work for an organisation that represents businesses that sell and/or market

food/drinks/produce 8. I work in the health/fitness/sport/wellness industry 9. I am a teacher/educator 10. I am an interested member of the community 11. Prefer not to say 12. Other (please specify)

Q5. Many people and organisations have a diverse range of views on what should be included in a national obesity strategy. To ensure transparency throughout the consultation process, it is important to consider these views in the context of any relevant interests.

As you are answering this survey on behalf of an organisation, please provide the name of your organisation in the space below. This information is required.

Australian Industry Group (Ai Group)

Q6. Please provide a contact name and email address for your organisation so that we may contact you about this consultation process if required. Your contact details will only be used for the purpose of this consultation and will not be shared with any third parties. Once again, this information is required.

Name: Nil response

Email

We are now going to ask you a series of questions about the proposed framework and ideas that could be included in a national obesity strategy. These are outlined in more detail in the consultation paper.

The framework and ideas have been informed by the following sources: Senate Select Committee Inquiry into the Obesity Epidemic in Australia (2018); National Obesity Summit (February 2019);

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Q5. Many people and organisations have a diverse range of views on what should be

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Q5. Many people and organisations have a diverse range of views on what should be included in a national obesity strategy. To ensure transparency throughout the

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included in a national obesity strategy. To ensure transparency throughout the consultation process, it is important to consider these views in the context of any relevant

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consultation process, it is important to consider these views in the context of any relevant

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As you are answering this survey on behalf of an organisation, please provide the name of your organisation in the space below. This information is required.

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your organisation in the space below. This information is required.


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Please provide a contact name and email address for your organisation so that we

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may contact you about this consultation process if required. Your contact details will only

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may contact you about this consultation process if required. Your contact details will only be used for the purpose of this consultation and will not be shared with any third parties.

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be used for the purpose of this consultation and will not be shared with any third parties. Once again, this information is required.

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Two commissioned evidence reports (Population-level strategies to support healthy weight and Addressing the social and commercial determinants of healthy weight);and

A practice review of state and territory, international, global and consensus strategies and statements.

Section 1. Proposed timeframe and scope for a national obesity strategy Q7. Timeframe of a national obesity strategy It is proposed that a national obesity strategy will guide action over the next 10 years – from 2020 to 2030. Do you think this timeframe is too short, about right, or too long?

1. Too short 2. About right 3. Too long 4. I’m not sure

Q8. Timeframe of a national obesity strategy Why do you think the proposed timeframe of 10 years is (pipe response from previous question)? The evidence brief confirms that Australia's overweight and obesity rates have escalated over the last 40 years. It will take longer than 10 years to truly turn the tide, however a phased 10 year approach certainly is in the right direction. However, a sustained effort beyond 10 years, as a second stage will further embed lifestyle change.

Q9. The proposed scope of a national obesity strategy

Page 9 of the consultation paper outlines the proposed scope of a national obesity strategy. This includes:

Government leadership for a whole-of-society response - The strategy will be a unifying framework, to enable genuine partnerships, improved collaboration and shared responsibility. It will identify strategies for Commonwealth and State and Territory governments, as well as the community and other key stakeholders including, non-government organisations and the private sector.

Prevention is the focus – The strategy will focus on primary and secondary preventive actions that promote and support healthy eating, regular physical activity and a healthy weight for all. Prevention actions benefit everyone, by helping to make the healthy option the easiest option. This includes actions to address environmental and social influences.

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2020 to 2030. Do you think this timeframe is too short, about right, or too long?

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2020 to 2030. Do you think this timeframe is too short, about right, or too long?

Why do you think the proposed timeframe of 10 years is (pipe response from previous

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Why do you think the proposed timeframe of 10 years is (pipe response from previous

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The evidence brief confirms that Australia's overweight and obesity rates have escalated

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The evidence brief confirms that Australia's overweight and obesity rates have escalated over the last 40 years. It will take longer than 10 years to truly turn the tide, however a

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over the last 40 years. It will take longer than 10 years to truly turn the tide, however a phased 10 year approach certainly is in the right direction. However, a sustained effort

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phased 10 year approach certainly is in the right direction. However, a sustained effort beyond 10 years, as a second stage will further embed lifestyle change.

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beyond 10 years, as a second stage will further embed lifestyle change.

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The proposed scope of a national obesity strategy

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The proposed scope of a national obesity strategy

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Outside the scope of a national obesity strategy are:

• Actions to manage and address underweight; and • Tertiary prevention actions (e.g., treatment of obesity and/or obesity-related

complications). To what extent do you agree or disagree with each of the following components in the proposed scope for a national obesity strategy?

Strongly disagree

Somewhat disagree

Neither agree nor disagree

Somewhat agree

Strongly agree

I’m not sure

The strategy should encourage government leadership for collaborative, whole-of-society action.

☐ ☐ ☐ ☐ ☒ ☐

The strategy should identify actions for Commonwealth and State and Territory governments.

☐ ☐ ☐ ☐ ☒ ☐

The strategy should identify actions that will involve non-government organisations and other community stakeholders.

☐ ☐ ☐ ☐ ☒ ☐

The strategy should identify actions that will involve the private sector.

☐ ☐ ☐ ☐ ☒ ☐

The strategy should focus on primary and secondary preventive actions that promote and support healthy eating, regular physical activity and a healthy weight for all.

☐ ☐ ☐ ☐ ☒ ☐

The strategy should not focus on tertiary prevention actions to treat overweight and obesity.

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The strategy should not focus on actions to manage and address ☐ ☐ ☐ ☐ ☒ ☐

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underweight.

Q10.

Thinking specifically about the proposed scope for a national obesity strategy, is there anything you would change, add or remove? Please provide your suggestions about the proposed scope in the space below.

Please note there are many opportunities to comment on specific strategies and ideas proposed to be included in the strategy throughout the survey.

It is suitable for a National Obesity Strategy to be underpinned using the full range of instruments, from regulatory through co-regulatory and self-regulatory and voluntary mechanisms.

In the next sections we will ask you a series of questions related to each of the components of the proposed framework for action:

Five proposed principles that will guide development and implementation of a national obesity strategy.

Four proposed priority areas and the specific strategies included under each of these priority areas.

Four proposed enablers that will help support sustained implementation of a national obesity strategy.

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In the next sections we will ask you a series of questions related to each of the components

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In the next sections we will ask you a series of questions related to each of the components

Five proposed principles that will guide development and implementation of a

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Five proposed principles that will guide development and implementation of a

Four proposed priority areas and the specific strategies included under each of

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Four proposed priority areas and the specific strategies included under each of

Four proposed enablers that will help support sustained implementation of a

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Four proposed enablers that will help support sustained implementation of a national obesity strategy.

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national obesity strategy.


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Figure 1. Proposed framework for a national obesity strategy Section 2. Proposed principles to guide a national obesity strategy Q11. The proposed guiding principles for a national obesity strategy We are interested in what you think of the five proposed guiding principles for a national obesity strategy. They are described in detail on pages 11 and 12 of the consultation paper.

Please rate how important you think each of the following proposed principles are for guiding the development and implementation of a national obesity strategy.


Slightly important


Very importa

nt

Extremely important

I’m not sure

People First - the strategy is person-centred, meaning it recognises the unique situations, experiences and strengths of individuals

☐ ☐ ☐ ☐ ☒ ☐

Equity - the strategy will promote equity, acknowledging some people and groups need

☐ ☐ ☐ ☐ ☒ ☐

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Figure 1. Proposed framework for a national obesity strategy

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Figure 1. Proposed framework for a national obesity strategy


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The proposed guiding principles for a national obesity strategy

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We are interested in what you think of the five proposed guiding principles for a national obesity strategy. They are described in detail on pages 11 and 12 of the consultation paper.

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obesity strategy. They are described in detail on pages 11 and 12 of the consultation paper.

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additional supports to achieve good health

Collective and Sustained Action - the strategy will promote partnerships and ongoing shared commitment from government and other key stakeholders

☐ ☐ ☐ ☐ ☒ ☐

Evidence-Based - the strategy will be informed by up-to-date evidence and promising or emerging strategies

☐ ☐ ☐ ☐ ☒ ☐

Sustainable Development - the strategy will align with the pillars of sustainable development: economic growth, social equity and environmental protection.

☐ ☐ ☐ ☐ ☒ ☐

Q12.


Thinking about the five proposed guiding principles, is there anything you would change, add or remove? Please provide your comments in the space below.

Whilst understanding the need to be bold, ambitious and aspirational we must also be realistic in relation to what is achievable, including in the context of a sustained funding commitment.

Section 3. Proposed priority areas and strategies for a national obesity strategy

The proposed priority areas and strategies for a national obesity strategy

We are now going to ask you about the four proposed priority areas for a national obesity strategy. The proposed areas are:

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Thinking about the five proposed guiding principles, is there anything you would change,

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add or remove? Please provide your comments in the space below.

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add or remove? Please provide your comments in the space below.

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1. Supporting children and families – starting early to support healthy weight throughout life

2. Mobilising people and communities – using knowledge, strengths and community connections to enable healthy weight

3. Enabling active living – supporting a way of life that helps people move more throughout the day

4. Building a healthier and resilient food system – producing and promoting healthier food and drinks with little impact on the environment

We are interested in what you think of the strategies included under each priority area. You can answer questions relating to all four of these priority areas, or just chose the areas that interest you most.

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Q13. Proposed Priority 1: Supporting children and families – starting early to support healthy weight throughout life For this priority area, there are three proposed strategies, each containing a number of ideas to guide action. These are discussed in detail on pages 14 to 16 of the consultation paper.

The first proposed strategy for this priority area is:

Support prospective and new parents to be healthier at the time of conception and during pregnancy, and to optimise the healthy development of their children during the first 1000 days.

Please rate the extent to which you think each of the following proposed ideas is important for guiding action under this strategy.

You can use the comment boxes to provide any feedback you might have about each idea.

Remember that you can rate and comment on all of the ideas, or you can skip to the next section if you do not want to provide feedback on a particular area.


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Provide healthy eating and drinking support and physical activity support for pre-conception and during pregnancy, including specific approaches for prospective parents who are, or at risk of becoming, overweight or obese during pregnancy

☐ ☐ ☐ ☐ ☒ ☐

Provide support for mothers to breastfeed and continue to breastfeed by implementing the National Breastfeeding Strategy

☐ ☐ ☐ ☐ ☒ ☐

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pregnancy, and to optimise the healthy development of their children during the first

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and drinking support and

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and drinking support and physical activity support

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Explore policy options to strengthen protection of infants and families from excess availability and marketing of breast milk substitutes Refer to Comment 1 below

☐ ☐ ☐ ☒ ☐ ☐

Strengthen healthy eating and physical activity guidance and support for mothers and fathers after birth as they transition and adjust to their new roles as parents

☐ ☐ ☐ ☐ ☒ ☐

Provide guidance to parents, carers and families on appropriate healthy eating and physical activity for infants (e.g., appropriate introduction of solids, responsive feeding, portion size, screen time, motor skill development)

☐ ☐ ☐ ☐ ☒ ☐

1. Breast milk substitutes are essential alternatives - although generally breast is best is recognised. Families that use breast milk alternatives should not be made to feel it is an inferior choice when it may be the best choice in the circumstances.

Q14.

Proposed Priority 1: Supporting children and families – starting early to support healthy weight throughout life

The second proposed strategy for this priority area is:

Enable parents, carers and families to encourage lifelong healthy habits for children and young people.


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Breast milk substitutes are essential alternatives - although generally breast is best is

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Breast milk substitutes are essential alternatives - although generally breast is best is recognised. Families that use breast milk alternatives should not be made to feel it is an

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recognised. Families that use breast milk alternatives should not be made to feel it is an

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inferior choice when it may be the best choice in the circumstances.

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inferior choice when it may be the best choice in the circumstances.


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You can use the comment boxes in the online survey to provide any feedback you might have about each idea.


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Provide guidance to parents, carers and families on appropriate healthy eating and physical activity for children and young people (e.g., appropriate nutrition, portion size, screen time, sleep and regular physical activity)

☐ ☐ ☐ ☐ ☒ ☐

Support parents, carers and families to purchase, prepare and enjoy healthy food and drinks, whilst limiting unhealthy food and drinks. Refer to Comment 1. below

☐ ☐ ☐ ☐ ☒ ☐

Encourage parents, carers and families of children and young people to use parks and recreation facilities, role model active transport and active living, be active with children (co-participation) and restrict screen time

☐ ☐ ☐ ☐ ☒ ☐

Develop fun peer and community activities that enable adolescents to engage in physical activity, including a focus on the role of fathers

☐ ☐ ☐ ☐ ☒ ☐

Encourage greater availability of healthy food and drinks, whilst also limiting unhealthy food and drinks, at sporting, recreation and community venues, facilities, clubs and events.

☐ ☐ ☐ ☐ ☒ ☐

Increase availability of, and equitable access to, appropriate programs that support weight

☐ ☐ ☐ ☐ ☒ ☐

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recreation facilities, role model

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recreation facilities, role model active transport and active living,

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active transport and active living, be active with children (co-

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be active with children (co-participation) and restrict screen

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Develop fun peer and community

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management for children, young people and their families

1. Improving nutrition and health literacy by bringing to life the Australian Dietary Guideline and Australian Guide to Health Living (and physical activity recommendations) is highly recommended - a whole of diet focus is important.

Q15.



Enable early childhood education and care settings and schools to adopt whole of facility approaches that better support children to develop healthy eating and physical activity habits and skills.




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Enhance leadership, professional knowledge, relevant policies and practices, curriculum design and delivery aligned with national guidelines, and partnerships within and beyond the early childhood education and care and school community Refer to Comment 1. below

☐ ☐ ☐ ☐ ☒ ☐

Establish partnerships to deliver programs where necessary (e.g., healthy breakfast programs, healthy school canteens and childcare menus, active play programs) Refer to Comment 2. below

☐ ☐ ☐ ☐ ☒ ☐

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approaches that better support children to develop healthy eating and physical activity

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Enable after-hours use of school facilities to expand available, accessible and affordable physical activity options and destinations for families and communities Refer to Comment 3. below

☐ ☐ ☐ ☐ ☒ ☐

Support safe, active travel to and from early childhood education and care settings and schools through infrastructure and behaviour change programs in collaboration with local communities. Refer to Comment 4. below

☐ ☐ ☐ ☐ ☒ ☐

Investigate policy and community-led options to extend student retention in schools across the Australian compulsory education period, including focused strategies for Aboriginal and Torres Strait Islander children and children from other priority groups

☐ ☐ ☐ ☐ ☒ ☐

1. Top down, bottom up nutrition and health literacy (incorporating activity) is important to empower and upskill on a population wide basis.

2. Many of these partnerships currently exist. Identifying the gaps and opportunities to leverage existing, targeted programs is supported.

3. Better deployment of government facilities capitalised on existing resources. 4. Incidential activity (and free play) are without a cost impediment and therefore

accessible to all.

Q16.


Thinking about the strategies you just read for supporting children and families, are there any additional strategies or you think should be included to start early to support healthy weight throughout life?

Please provide your comments in the space below. The three proposed strategies are listed again below if you need to re-read these.

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Top down, bottom up nutrition and health literacy (incorporating activity) is important

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Top down, bottom up nutrition and health literacy (incorporating activity) is important

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to empower and upskill on a population wide basis.

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to empower and upskill on a population wide basis. Many of these partnerships currently exist. Identifying the gaps and opportunities to

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Many of these partnerships currently exist. Identifying the gaps and opportunities to leverage existing, targeted programs is supported.

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leverage existing, targeted programs is supported. Better deployment of government facilities capitalised on existing resources.

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Better deployment of government facilities capitalised on existing resources.

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The up-skilling of nutrition, health and activity literacy is instrumental to change generational behaviour as is starting early.


Support prospective and new parents to be healthier at the time of conception and during pregnancy, and to optimise the healthy development of their children during the first 1000 days.

Enable parents, carers and families to encourage lifelong healthy habits for children and young people.

Enable early childhood education and care settings and schools to adopt whole of facility approaches that better support children to develop healthy eating and physical activity habits and skills.

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facility approaches that better support children to develop healthy eating and

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Q17. Proposed Priority 2: Mobilising people and communities – using knowledge, strengths and community connections to enable healthy weight For this priority area, there are five proposed strategies, each containing a number of ideas to guide action. These are discussed in detail on pages 17 to 19 of the consultation paper.


Improve people’s knowledge, awareness and skills to enable healthy eating, facilitate active lives and foster healthy social and cultural norms, regardless of their weight.




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Provide information, education and skill-building programs and initiatives aligned with Australian guidelines for healthy eating, physical activity and sedentary behaviour

☐ ☐ ☐ ☐ ☒ ☐

Develop and fund ongoing national mass media campaigns to shift expectations, beliefs and social norms, whilst minimising weight-related stigma

☐ ☐ ☐ ☐ ☒ ☐

Partner with Aboriginal and Torres Strait Islander people to develop and deliver culturally appropriate and safe social marketing and supporting programs

☐ ☐ ☐ ☐ ☒ ☐

Partner with culturally and linguistically diverse (CALD) groups to develop and deliver culturally appropriate and safe support programs for early migrants

☐ ☐ ☐ ☐ ☒ ☐

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active lives and foster healthy social and cultural norms, regardless of their weight.

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active lives and foster healthy social and cultural norms, regardless of their weight.


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initiatives aligned with Australian

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initiatives aligned with Australian guidelines for healthy eating,

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guidelines for healthy eating, physical activity and sedentary

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physical activity and sedentary

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Develop and fund ongoing

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Partner with people with disability to develop and deliver initiatives to improve healthy eating and physical activity that are accessible and responsive

☐ ☐ ☐ ☐ ☒ ☐

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Q18. Proposed Priority 2: Mobilising people and communities – using knowledge, strengths and community connections to enable healthy weight The second proposed strategy for this priority area is: Engage and support local communities, groups and organisations to develop and lead their own healthy eating and physical activity initiatives through responding to local need, embedding participation and building community capacity. Please rate the extent to which you think each of the following proposed ideas is important for guiding action under this strategy. You can use the comment boxes in the online survey to provide any feedback you might have about each idea.


Slightly important


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Extremely important

I’m not sure

Invest in targeted community capacity building initiatives that activate leadership, drive innovation and support a collective impact approach to create health promoting community places and spaces Refer to Comment 1. below

☐ ☐ ☐ ☐ ☒ ☐

Identify a diverse range of local leaders to ‘champion’ place-based healthy eating and physical activity initiatives and develop a supportive nationwide network and learning community Refer to Comment 2. below

☐ ☐ ☐ ☐ ☒ ☐

Ensure local communities have access to health promoting sponsorship options for events and sport, and are empowered and informed to consider the impact of unhealthy sponsorship choices Nil response

☐ ☐ ☐ ☐ ☐ ☐

1. This should be a building capacity exercise, recognising efforts are already underway.

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community places and spaces

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community places and spaces Refer to Comment 1. below

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Refer to Comment 1. below

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Identify a diverse range of local

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leaders to ‘champion’ place-based healthy eating and physical

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2. Within the 10 year strategy (and beyond) a phased approach is required - targeting the highest priorities to educate and mobilise behaviour change.

Q19. Proposed Priority 2: Mobilising people and communities – using knowledge, strengths and community connections to enable healthy weight The third proposed strategy for this priority area is: Support all people who are at risk of becoming overweight to access effective weight management interventions without fear of judgement. Please rate the extent to which you think each of the following proposed ideas is important for guiding action under this strategy. You can use the comment boxes in the online survey to provide any feedback you might have about each idea.


Slightly important


Very important

Extremely important

I’m not sure

Evidence-based weight management interventions, ensuring a range of delivery modes and accessibility for all, regardless of age, living location, cultural background and income Refer to Comment 1. below

☐ ☐ ☐ ☐ ☒ ☐

Advocate for increased intensity of action for population groups experiencing higher levels of overweight and obesity, through effective co-designed behaviour change programs

☐ ☐ ☐ ☐ ☒ ☐

Support those experiencing weight stigma and discrimination and ensure all actions promote positive discussion of weight and prevent weight-related stigmatisation

☐ ☐ ☐ ☐ ☒ ☐

1. Will the strategy achieve ALL.

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ensuring a range of delivery

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ensuring a range of delivery modes and accessibility for all,

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modes and accessibility for all, regardless of age, living location,

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regardless of age, living location, cultural background and income

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cultural background and income Refer to Comment 1. below

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Q20. Proposed Priority 2: Mobilising people and communities – using knowledge, strengths and community connections to enable healthy weight The fourth proposed strategy for this priority area is: Support health and social services to prioritise the prevention of obesity-related chronic disease. Please rate the extent to which you think each of the following proposed ideas is important for guiding action under this strategy. You can use the comment boxes in the online survey to provide any feedback you might have about each idea.


Slightly important


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Extremely important

I’m not sure

Support better collaboration between sectors dealing with unemployment, social protection and health

☐ ☐ ☐ ☐ ☒ ☐

Develop labour and social policies that provide secure and decent work for all

☐ ☐ ☐ ☐ ☒ ☐

Raise incomes of the poorest groups to reflect the real cost of healthy living and increase access to improved living conditions and opportunities for healthy behaviours

☐ ☐ ☐ ☐ ☒ ☐

Provide professional development for clinicians to support the improvement of healthy eating and physical activity behaviours in their patient/clients Refer to Comment 1. below

☐ ☐ ☐ ☐ ☒ ☐

Enable early identification of unhealthy weight gain (including modest weight gain) for patients/clients, with a focus on life course transition points often associated with weight gain and

☐ ☐ ☐ ☐ ☒ ☐

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Develop labour and social policies

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Raise incomes of the poorest

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groups to reflect the real cost of healthy living and increase access

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healthy living and increase access to improved living conditions and

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people from at-risk population groups

Increase the availability of, and clarity of referral pathways to, evidence-based weight management treatments (including community-led programs)

☐ ☐ ☐ ☐ ☒ ☐

1. See attached submission to the previous Senate Obesity Inquiry and latest submission to the HSR consultation - setting out the confectionery industry initiatives to support consumers' enjoyment of confectionery in line with dietary guidelines - sometimes and in small amounts. The industry's approach to front of pack labelling is recognised by many NGOs and consumers as providing useful information with respect to energy and portion in the context of a healthy diet and lifestyle. It is viewed a a practical tool for the medical profession to engage patients/clients and communicate.

Q21.

Proposed Priority 2: Mobilising people and communities – using knowledge, strengths and community connections to enable healthy weight


Enable and support workplaces, healthcare facilities and tertiary institutions to lead by example by creating health promoting places of excellence.




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Adopt best-practice breastfeeding policies and practices (e.g., workplace facilities, maternity leave, flexible work times to allow for breastfeeding)

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Adopt policies and practices that promote and prioritise physical ☐ ☐ ☐ ☒ ☐ ☐

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consumers' enjoyment of confectionery in line with dietary guidelines - sometimes and

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in small amounts. The industry's approach to front of pack labelling is recognised by

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many NGOs and consumers as providing useful information with respect to energy and

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portion in the context of a healthy diet and lifestyle. It is viewed a a practical tool for

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portion in the context of a healthy diet and lifestyle. It is viewed a a practical tool for the medical profession to engage patients/clients and communicate.

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the medical profession to engage patients/clients and communicate.

Proposed Priority 2: Mobilising people and communities – using knowledge, strengths and

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community connections to enable healthy weight


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example by creating health promoting places of excellence.


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activity, increase access to healthy food and drinks, and limit access to, or remove unhealthy food and drinks through catering, vending machines, cafes and canteens Refer to Comment 1. below

Design buildings that support and encourage healthy behaviours (e.g., stairs, kitchen facilities, end-of-trip facilities, storage, standing desks) Refer to Comment 2. below

☐ ☐ ☐ ☒ ☐ ☐

Create physical environments, policies and programs that incentivise and support active travel to work Nil response to tick box, made comment below at Comment 3.

☐ ☐ ☐ ☐ ☐ ☐

Offer flexible work options to reduce travel time, freeing up time for meal planning/preparation and physical activity Nil response to tick box, made comment below at Comment 4.

☐ ☐ ☐ ☐ ☐ ☐

Offer or facilitate access to multi-component, non-discriminatory programs and information to support healthy eating, physical activity and healthy weight Nil response to tick box, made comment below at Comment 5.

☐ ☐ ☐ ☐ ☐ ☐

1. The balance between energy in (in the context of making healthier choices easier) and energy out (through physical activities) put simply is the essence of the imbalance.

2. Are important considerations for new facilities, but need to be factored in over the long term.

3. Ditto, as above. Again, need to be factored in over the long term. 4. In theory this sounds good. However, making this the norm will take time to adjust

commercial reality and perceptions. 5. People need to have the motivation to access and clinicians need to support. There is

evidence of some dentists providing oral health education to young families with dental

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planning/preparation and physical

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comment below at Comment 4.

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check-ups as part of the appointment. Similar approaches could be adopted by other medical professions.

Q22. Proposed Priority 2: Mobilising people and communities – using knowledge, strengths and community connections to enable healthy weight Thinking about the strategies you just read for mobilising people and communities, are there any additional strategies you think should be included to mobilise people and communities to use knowledge, strengths and community connections to enable healthy weight? Please provide your comments in the space below. The five proposed strategies are listed again below if you need to re-read these. Nil response


Improve people’s knowledge, awareness and skills to enable healthy eating, facilitate active lives and foster healthy social and cultural norms, regardless of people’s weight.

Engage and support local communities, groups and organisations to develop and lead their own healthy eating and physical activity initiatives through responding to local need, embedding participation and building community capacity.

Support all people who are at risk of becoming overweight to access effective weight management interventions without fear of judgement.

Support health and social services to prioritise the prevention of obesity-related chronic disease.


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to use knowledge, strengths and community connections to enable healthy weight?

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to use knowledge, strengths and community connections to enable healthy weight?

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Improve people’s knowledge, awareness and skills to enable healthy eating, facilitate

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Improve people’s knowledge, awareness and skills to enable healthy eating, facilitate active lives and foster healthy social and cultural norms, regardless of people’s

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active lives and foster healthy social and cultural norms, regardless of people’s

Engage and support local communities, groups and organisations to develop and

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Engage and support local communities, groups and organisations to develop and lead their own healthy eating and physical activity initiatives through responding to

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lead their own healthy eating and physical activity initiatives through responding to local need, embedding participation and building community capacity.

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local need, embedding participation and building community capacity.

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Support all people who are at risk of becoming overweight to access effective weight

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Support all people who are at risk of becoming overweight to access effective weight management interventions without fear of judgement.

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management interventions without fear of judgement.

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Support health and social services to prioritise the prevention of obesity-related chronic disease. RTI R

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Q23. Proposed Priority 3: Enabling active living – supporting a way of life that helps people move more throughout the day For this priority area, there are two proposed strategies, each containing a number of ideas for guiding action. These are discussed in detail on pages 20 and 21 of the consultation paper.






Slightly important


Very important

Extremely important

I’m not sure

Develop and maintain infrastructure that grows participation in sport, active recreation, walking, cycling and public transport use to encourage individuals and families to be active together

☐ ☐ ☐ ☐ ☒ ☐

Create a culture that promotes active travel through safe walking networks, drinking water stations and pedestrian prioritisation; cycling networks with reduced crash risk; storage and end-of-trip facilities; and efficient, accessible and regular public transport systems with strong connectivity and after-hours service Refer to Comment 1. below

☐ ☐ ☐ ☐ ☒ ☐

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recreation, walking, cycling and

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recreation, walking, cycling and public transport use to encourage

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public transport use to encourage individuals and families to be

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individuals and families to be

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Create a culture that promotes

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active travel through safe walking networks, drinking water stations RTI R

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networks, drinking water stations and pedestrian prioritisation; RTI R

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Apply integrated urban (and regional) design and transport policy, regulations and guidelines to create built environments that prioritise active living for people of all ages and abilities Refer to Comment 2. below

☐ ☐ ☐ ☐ ☒ ☐

Conserve and develop open spaces, green networks, recreation trails and ecologically diverse natural environments that enable active interaction with nature Refer to Comment 3. below

☐ ☐ ☐ ☐ ☒ ☐

Make communities safe with people-friendly spaces that favour people over motorised transport, and crime prevention strategies, such as community policing techniques, peer-led outreach programs and lighting Refer to Comment 4. below

☐ ☐ ☐ ☐ ☒ ☐

Ensure strategic infrastructure policies and plans prioritise investment in public transport, walking and cycling infrastructure

☒

Consider fiscal policies to reduce driving and increase active travel and the availability and quality of recreation and sport facilities and opportunities

☐ ☐ ☐ ☐ ☒ ☐

1. These are long term initiatives that require progressive evolution. 2. These are long term initiatives that require progressive evolution. 3. These are long term initiatives that require progressive evolution. 4. These are long term initiatives that require progressive evolution.

Q24.

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investment in public transport,

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investment in public transport, walking and cycling infrastructure

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walking and cycling infrastructure

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Consider fiscal policies to reduce

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Consider fiscal policies to reduce driving and increase active travel

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driving and increase active travel and the availability and quality of

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and the availability and quality of recreation and sport facilities and RTI R

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recreation and sport facilities and opportunities RTI R

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opportunities RTI Rele

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These are long term initiatives that require progressive evolution.


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Proposed Priority 3: Enabling active living – supporting a way of life that helps people move more throughout the day The second proposed strategy for this priority area is: Motivate and inspire participation in regular physical activity by people of all ages and abilities. Please rate the extent to which you think each of the following proposed ideas is important for guiding action under this strategy. You can use the comment boxes in the online survey to provide any feedback you might have about each idea.


Slightly important


Very important

Extremely important

I’m not sure

Provide a range of fun, local and social active living options that match the interests of various ages and abilities, engage local communities and organisations, and build social cohesion Nil response

☐ ☐ ☐ ☐ ☐ ☐

Partner with Aboriginal and Torres Strait Islander people, people living in regional and remote areas, people with disability, and people experiencing disadvantage, to develop targeted interventions that increase the availability, accessibility and affordability of physical activity opportunities and reduce barriers to active living Nil response

☐ ☐ ☐ ☐ ☐ ☐

Support regular participation initiatives in public spaces that engage large portions of the community (e.g., fun runs) Nil response

☐ ☐ ☐ ☐ ☐ ☐

Offer free or low-cost access to encourage use of public transport, walking and cycling infrastructure, recreation opportunities, natural

☐ ☐ ☐ ☐ ☐ ☐

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Partner with Aboriginal and Torres

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Partner with Aboriginal and Torres Strait Islander people, people

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Strait Islander people, people living in regional and remote

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living in regional and remote areas, people with disability, and

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areas, people with disability, and people experiencing disadvantage,

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people experiencing disadvantage, to develop targeted interventions

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to develop targeted interventions that increase the availability, RTI R

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that increase the availability, accessibility and affordability of RTI R

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accessibility and affordability of physical activity opportunities and RTI R

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physical activity opportunities and reduce barriers to active living RTI R

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environments, sports and active living programs (e.g., subsidies, public liability insurance scheme for cyclists, rental equipment, participation incentives, and after-hours use of public and school sport and recreation facilities) Nil response

Build physical literacy and promote community-based active events using sustained, evidence-based social marketing Refer to Comment 1. below

☐ ☐ ☐ ☐ ☒ ☐

1. As previously noted, nutrition, health and physical literacy are critical components that are needed for the mass population. The former Life Be in It campaign is an example as are sun smart campaigns. However, they need sustained, multi level commitment including funding. Program longevity will have the most effective cut through. Message needs consolidation and simplicity (too many messages at one time will dilute effectiveness and confuse people).

Q25.

Proposed Priority 3: Enabling active living – supporting a way of life that helps people move more throughout the day

Thinking about the specific strategies you just read for enabling active living, are there any additional strategies you think should be included to support a way of life that helps people move more throughout the day?

Please provide your comments in the space below. The two proposed strategies are listed again below if you need to re-read these.

Nil response



Motivate and inspire participation in regular physical activity by people of all ages and abilities.

Q26.

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are needed for the mass population. The former Life Be in It campaign is an example as

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are needed for the mass population. The former Life Be in It campaign is an example as are sun smart campaigns. However, they need sustained, multi level commitment

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are sun smart campaigns. However, they need sustained, multi level commitment including funding. Program longevity will have the most effective cut through. Message

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including funding. Program longevity will have the most effective cut through. Message needs consolidation and simplicity (too many messages at one time will dilute

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needs consolidation and simplicity (too many messages at one time will dilute

Proposed Priority 3: Enabling active living – supporting a way of life that helps people

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Proposed Priority 3: Enabling active living – supporting a way of life that helps people move more throughout the day

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move more throughout the day

Thinking about the specific strategies you just read for enabling active living, are there any

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Thinking about the specific strategies you just read for enabling active living, are there any additional strategies you think should be included to support a way of life that helps people

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additional strategies you think should be included to support a way of life that helps people move more throughout the day?

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move more throughout the day?

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again below if you need to re-read these. RTI Rele

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again below if you need to re-read these.


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Proposed Priority 4: Building a healthier and more resilient food system – producing and promoting healthier food and drinks with little impact on the environment For this priority area, there are seven proposed strategies, each containing a number of ideas to guide action. These are discussed in detail on pages 22 to 25 of the consultation paper.

Remember that you can rate and comment on all of the strategies, or you can skip to the next strategy if you do not want to provide feedback on a particular area.


Ensure our food system favours the production, processing and manufacture of healthy and sustainable products.




Slightly important


Very important

Extremely important

I’m not sure

Ensure planning and management policies for land and sea use safeguard food system resilience and productivity

☐ ☐ ☐ ☒ ☐ ☐

Develop innovative solutions to efficiently use natural resources, maximise biodiversity, minimise wastage, enable business growth and address climate change

☐ ☐ ☐ ☒ ☐ ☐

Ensure economic policies make production and manufacturing of healthy foods and drinks, such as fresh fruit and vegetables, attractive

☐ ☐ ☐ ☐ ☒ ☐

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Ensure planning and management

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Ensure planning and management policies for land and sea use

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policies for land and sea use safeguard food system resilience

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safeguard food system resilience ☐

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Develop innovative solutions to

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Develop innovative solutions to efficiently use natural resources,

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efficiently use natural resources, maximise biodiversity, minimise RTI R

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maximise biodiversity, minimise wastage, enable business growth RTI R

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wastage, enable business growth and address climate change RTI R

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and address climate change RTI Rele

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Q27. Proposed Priority 4: Building a healthier and more resilient food system – producing and promoting healthier food and drinks with little impact on the environment The second proposed strategy for this priority area is: Increase the availability of healthy, more sustainable food and drinks in the places we live and work. Please rate the extent to which you think each of the following proposed ideas is important for guiding action under this strategy. You can use the comment boxes in the online survey to provide any feedback you might have about each idea.


Slightly important


Very important

Extremely important

I’m not sure

Create easier access to healthy food and drinks in local residential communities through:

urban agriculture (e.g., community garden initiatives and encouraging home gardens);

urban design (e.g., density of fast food outlets and proximity to schools and community services; access to supermarkets and smaller food businesses); and

other local community actions (e.g., local food markets, healthy food supply at community events)

☐ ☐ ☐ ☒ ☐ ☐

Encourage land use planning policies that protect high-quality agricultural land on the urban fringe and ensure that planning decisions achieve the policy intent

☐ ☐ ☐ ☒ ☐ ☐

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initiatives and encouraging

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initiatives and encouraging

urban design (e.g., density

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urban design (e.g., density of fast food outlets and

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of fast food outlets and proximity to schools and

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proximity to schools and community services;

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community services; access to supermarkets

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access to supermarkets and smaller food

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and smaller food businesses); and RTI R

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businesses); and other local community RTI R

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other local community actions (e.g., local food RTI R

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actions (e.g., local food markets, healthy food RTI R

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Establish policies on food and drink procurement, catering, and provision across all government departments and settings to encourage healthy eating and drinking Refer to Comment 1. below

☐ ☐ ☐ ☒ ☐ ☐

1. The Australian confectionery industry supports healthy eating and healthy lifestyles, including the provision of activity. The industry is actively engaged in supporting consumers understanding of the place for confectionery (as a discretionary food choice) in the context of a healthy diet and lifestyle (in line with the Australian Dietary Guidelines) alongside physical activity and will continue to do so. There is a place for discretionary foods to be enjoyed.

Q28.

Proposed Priority 4: Building a healthier and more resilient food system – producing and promoting healthier food and drinks with little impact on the environment


Make processed food and drinks healthier and more sustainable by limiting energy and nutrients of concern.




Slightly important


Very important

Extremely important

I’m not sure

Work in partnership with industry to establish and monitor reformulation targets for food and drink manufacturers, retailers and caterers

☐ ☐ ☐ ☒ ☐ ☐

Develop national targets to reduce serving sizes of unhealthy food and drinks in food service and retail settings, particularly for food and drink items designed for children

☐ ☐ ☐ ☒ ☐ ☐

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in the context of a healthy diet and lifestyle (in line with the Australian Dietary

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in the context of a healthy diet and lifestyle (in line with the Australian Dietary Guidelines) alongside physical activity and will continue to do so. There is a place for

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aseGuidelines) alongside physical activity and will continue to do so. There is a place for

Proposed Priority 4: Building a healthier and more resilient food system – producing and

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promoting healthier food and drinks with little impact on the environment


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Make processed food and drinks healthier and more sustainable by limiting energy and

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Make processed food and drinks healthier and more sustainable by limiting energy and


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have about each idea.

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have about each idea. have about each idea.

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Explore setting compositional limits for nutrients of concern (e.g., sodium, saturated fat, added sugar and/or energy content) across a range of food and drink types Refer to Comment 2. below

☐ ☐ ☐ ☒ ☐ ☐

Reduce food waste during manufacturing and processing and eliminate unnecessary packaging Refer to Comment 3. below

☐ ☐ ☐ ☒ ☐ ☐

1. The Australian confectionery industry has had in place an industry agreed serving size (founded on the Australian Dietary Guidelines and Australian Guide to Healthy Eating that recommends a discretionary serve is about the amount that provides 600kJ) for about a decade. With the establishment of the Health Star Rating System this agreement was recognised (agreed by the FoFR) and embedded in the HSR System - recognising the importance of energy and portion size (and the industry's Be treatwise program introduced in 2006) in the context of confectionery.

2. The Health Food Partnership (HFP) Reformulation Working Group identified the reformulation targets for confectionery should focus on portion size and consulted on that basis. Given the limited nutrient reformulation capacity for confectionery - this approach has long been recognised by the industry - as noted in the above discussion - thereby (as the industry has) supported the important role of energy and consumption (ie portion) in the context of confectionery. Other jurisdictions eg Public Health England have taken this direction to 'reformulate' around energy per portion.

3. These initiatives are important as companions in the production of food and manufacturers are taking responsible steps independently to reduce waste, reuse resources and work toward a circular economy.

Q29.


The fourth proposed strategy for this priority area is:

Support targeted interventions that increase the availability, accessibility and affordability of healthy food and drinks for rural and remote communities, communities experiencing disadvantage and Aboriginal and Torres Strait Islander people.


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aseThe Australian confectionery industry has had in place an industry agreed serving size

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(founded on the Australian Dietary Guidelines and Australian Guide to Healthy Eating

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ase(founded on the Australian Dietary Guidelines and Australian Guide to Healthy Eating

that recommends a discretionary serve is about the amount that provides 600kJ) for

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that recommends a discretionary serve is about the amount that provides 600kJ) for about a decade. With the establishment of the Health Star Rating System this

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about a decade. With the establishment of the Health Star Rating System this agreement was recognised (agreed by the FoFR) and embedded in the HSR System -

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agreement was recognised (agreed by the FoFR) and embedded in the HSR System - recognising the importance of energy and portion size (and the industry's Be treatwise

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recognising the importance of energy and portion size (and the industry's Be treatwise program introduced in 2006) in the context of confectionery.

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program introduced in 2006) in the context of confectionery. The Health Food Partnership (HFP) Reformulation Working Group identified the

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The Health Food Partnership (HFP) Reformulation Working Group identified the reformulation targets for confectionery should focus on portion size and consulted on

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reformulation targets for confectionery should focus on portion size and consulted on that basis. Given the limited nutrient reformulation capacity for confectionery - this

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that basis. Given the limited nutrient reformulation capacity for confectionery - this approach has long been recognised by the industry - as noted in the above discussion -

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approach has long been recognised by the industry - as noted in the above discussion - thereby (as the industry has) supported the important role of energy and consumption

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thereby (as the industry has) supported the important role of energy and consumption (ie portion) in the context of confectionery. Other jurisdictions eg Public Health England

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(ie portion) in the context of confectionery. Other jurisdictions eg Public Health England

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have taken this direction to 'reformulate' around energy per portion.

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have taken this direction to 'reformulate' around energy per portion. These initiatives are important as companions in the production of food and

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These initiatives are important as companions in the production of food and manufacturers are taking responsible steps independently to reduce waste, reuse

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manufacturers are taking responsible steps independently to reduce waste, reuse resources and work toward a circular economy.

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resources and work toward a circular economy.


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Slightly important


Very important

Extremely important

I’m not sure

Encourage good quality, culturally appropriate, healthy food availability and affordability in stores, workplaces and institutions in rural and remote communities

☐ ☐ ☐ ☒ ☐ ☐

Investigate partnership arrangements with large supermarkets to offset the price of healthier food and drinks in communities experiencing disadvantage and small remote stores Nil response

☐ ☐ ☐ ☐ ☐ ☐

Celebrate cultural knowledge and diversity by using a self-determination approach to find the best solutions for reducing common barriers to healthy food and drink access, selection and preparation Nil response

☐ ☐ ☐ ☐ ☐ ☐

Build on existing housing initiatives to improve community and household food preparation and storage facilities Nil response to tick box but comment is below.

☐ ☐ ☐ ☐ ☐ ☐

1.This could be provided through nutrition literacy

Q30.



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determination approach to find

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determination approach to find the best solutions for reducing

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the best solutions for reducing common barriers to healthy food

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common barriers to healthy food and drink access, selection and

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and drink access, selection and

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Build on existing housing

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and household food preparation and storage facilities RTI R

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and storage facilities Nil response to tick box but RTI R

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Reduce exposure to unhealthy food and drink marketing and promotion. Please rate the extent to which you think each of the following proposed ideas is important for guiding action under this strategy. You can use the comment boxes in the online survey to provide any feedback you might have about each idea.


Slightly important


Very important

Extremely important

I’m not sure

Reduce unhealthy food and drink marketing on publicly-owned or managed settings (e.g., public transport infrastructure) Nil response to tick box, made comment below at Comment 1.

☐ ☐ ☐ ☐ ☐ ☐

Explore options to reduce unhealthy food and drink advertising prominence in places frequently visited by large numbers of people, especially children (e.g., vending machines, supermarket checkouts and aisles, entertainment venues) Nil response to tick box, made comment below at Comment 2.

☐ ☐ ☐ ☐ ☐ ☐

Explore options to reduce unhealthy food and drink sponsorship and marketing associated with sport and major community events Nil response to tick box, made comment below at Comment 3.

☐ ☐ ☐ ☐ ☐ ☐

Restrict unhealthy food and drink advertising during peak television viewing times for children Nil response to tick box, made comment below at Comment 4.

☐ ☐ ☐ ☐ ☐ ☐

Restrict promotions using devices that appeal to children (e.g. toys, games) Nil response to tick box, made comment below at Comment 5.

☐ ☐ ☐ ☐ ☐ ☐

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supermarket checkouts and aisles,

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supermarket checkouts and aisles,

Nil response to tick box, made

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comment below at Comment 2.

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Explore options to reduce

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unhealthy food and drink sponsorship and marketing

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community events Nil response to tick box, made RTI R

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Partner with relevant industry stakeholders to introduce user controls that can limit exposure to digital advertising of unhealthy food and drinks. Nil response to boxes, made comment below at Comment 6.

☐ ☐ ☐ ☐ ☐ ☐

1. In the context of the Responsible Children's Marketing Initiative. 2. In the context of the Responsible Children's Marketing Initiative. 3. Caution the sudden detriment of potentially withdrawing valuable sponsorship that underpins the provision of sports and community events. 4. In the context of the Responsible Children's Marketing Initiative. 5. In the context of the Responsible Children's Marketing Initiative. 6. Breaches in controls are minimal and typically go beyond direct activation by food industry. However, the food industry has control measures in place to review irregularities.

Q31.


The sixth proposed strategy for this priority area is:

Increase the availability and accessibility of information to support the consumer to make a healthier choice at the time of purchasing food or drinks.




Slightly important


Very important

Extremely important

I’m not sure

Continue to strengthen the uptake of the Health Star Rating system towards universal implementation and continue to consider options for the ongoing enhancement of the system. Refer to Comment 1. below

☐ ☐ ☐ ☒ ☐ ☐

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industry. However, the food industry has control measures in place to review irregularities.

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Introduce front of pack nutrition warning labels for nutrients of concern (e.g., added sugar, sodium, saturated fats, alcohol, high energy content) to complement the Health Star Rating system Nil response to tick box, made comment below at Comment 2.

☐ ☐ ☐ ☐ ☐ ☐

Support multi-component interventions to improve nutrition information and increase accessibility and prominence of healthier options in supermarkets Nil response to tick box, made comment below at Comment 3.

☐ ☐ ☐ ☐ ☐ ☐

Adopt consistent national regulation on menu energy (kilojoule) labelling in businesses that sell ready-to-eat-food Nil response to tick box, made comment below at Comment 4.

☐ ☐ ☐ ☐ ☐ ☐

Consider adoption of sustainability indicators that provide clear consumer information on the environmental impacts of food and drink products Refer to Comment 5. below

☒ ☐ ☐ ☐ ☐ ☐

1. Supported. However the confectionery industry remains concerned that the HSR five year review recommended removal of HSR graphic option 5 (energy icon) meaning that the minimum requirement to participate in the HSR System requires stars (Option 4). Despite the FoFR's agreement when it met on 15 November 2019, the confectionery industry remains concerned due to the impact of high stars on some confectionery product, eg 4 stars, which is contrary to the objectives of the HSR System. See background paper attached for more information. The HSR System should be reognised for the role it plays.

2. In the absence of the detail of this sub-strategy, it's likely to confuse consumers. For example a high HSR combined with a 'warning' about energy, sugar or fat is likely to communicate conflicting messages. Additionally, small pack space limitations exist as does the potential for an increasing number of messages that in the end will be ignored.

3. Improved understanding of currently available nutrition information ought to be a focus. 4. The value of energy per serve/portion information is acknowledged by the ongoing

pursuit of menu board labelling. The confectionery industry, therefore, draws the parallel to HSR energy per serve/portion in the context of confectionery that has been

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information on the environmental

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information on the environmental impacts of food and drink

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impacts of food and drink


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rejected, and which we are concerned about, due to the potential prevalence of high stars on some confectionery (in a potentially growing category).

5. Although we have previously acknowledged that sustainability is a 'companion' strategy to the NOS manufacturers are taking responsible steps to ensure waste reduction, reuse, etc in a circular economy.

Q32. Proposed Priority 4: Building a healthier and more resilient food system – producing and promoting healthier food and drinks with little impact on the environment The seventh proposed strategy for this priority area is: Explore policy options related to the price of food and drinks to help shift consumer purchases towards healthier options. Please rate the extent to which you think each of the following proposed ideas is important for guiding action under this strategy. You can use the comment boxes in the online survey to provide any feedback you might have about each idea.


Slightly important


Very important

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I’m not sure

Subsidise healthy food and drinks (e.g., fruit, vegetables and water), potentially including transport subsidies to remote communities Nil response

☐ ☐ ☐ ☐ ☐ ☐

Consider emerging evidence and policy approaches that use price to reduce consumption of sugar-sweetened beverages and high sugar snacks Nil response to tick box, made comment below at Comment 1.

☐ ☐ ☐ ☐ ☐ ☐

Consider using price to reduce consumption of alcoholic beverages, potentially through a uniform volumetric tax and/or a floor price Nil response

☐ ☐ ☐ ☐ ☐ ☐

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Subsidise healthy food and drinks

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(e.g., fruit, vegetables and water), potentially including transport

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potentially including transport subsidies to remote communities

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Restrict temporary price reductions (e.g., half-price, multi-buys) on unhealthy food and drink products. Nil response to tick box, made comment below at Comment 2.

☐ ☐ ☐ ☐ ☐ ☐

Explore and consider options for incorporating the cost of obesity and greenhouse gas emissions into the price of food and drinks Refer to Comment 3. below

☒ ☐ ☐ ☐ ☐ ☐

1. Higher pricing (taxing) has not been conclusive in reducing long term consumption of sugar. There may be a short term reduction in consumption, but over time it is not sustained. Sales figures from Mexico showed an initial drop but within a year sales returned to pre-tax levels. Substitution of taxed goods with un-taxed foods is a further consideration. Noticable effects are not being found in other markets either and are unlikely to work in Australia. Additionally, overall sugar consumption is declining independent of a tax. The confectionery industry's initiatives are designed to ensure consumers understand the role of confectionery in a healthy diet, provide more smaller portion packs, reduced sizing, etc.

2. This is the space of retailers. 3. Government investment in preventative health should be considered an investment in

the future. Environmental considerations should be incorporated in environmental policy.

Q33.


Thinking about the specific strategies you just read for building a healthier and more resilient food system, are there any additional strategies or recommendations you think should be included to produce and promote healthier food and drinks with little impact on the environment?

These might include strategies that help people overcome specific challenges they encounter when making decisions about the food and drinks they consume.

Please provide your comments in the space below. The seven proposed strategies are listed again below if you need to re-read these.

Nil response

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sugar. There may be a short term reduction in consumption, but over time it is not

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sustained. Sales figures from Mexico showed an initial drop but within a year sales

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returned to pre-tax levels. Substitution of taxed goods with un-taxed foods is a further

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consideration. Noticable effects are not being found in other markets either and are

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consideration. Noticable effects are not being found in other markets either and are unlikely to work in Australia. Additionally, overall sugar consumption is declining

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unlikely to work in Australia. Additionally, overall sugar consumption is declining independent of a tax. The confectionery industry's initiatives are designed to ensure

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independent of a tax. The confectionery industry's initiatives are designed to ensure

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consumers understand the role of confectionery in a healthy diet, provide more smaller

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consumers understand the role of confectionery in a healthy diet, provide more smaller

Government investment in preventative health should be considered an investment in

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Government investment in preventative health should be considered an investment in the future. Environmental considerations should be incorporated in environmental

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the future. Environmental considerations should be incorporated in environmental


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promoting healthier food and drinks with little impact on the environment RTI Rele

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Ensure our food system favours the production, processing and manufacture of healthy and sustainable products.

Increase the availability of healthy, sustainable food and drinks in the places we live

and work.

Make processed food and drinks healthier and more sustainable by limiting energy and nutrients of concern.

Support targeted interventions that increase the availability, accessibility and

affordability of healthy food and drinks for rural and remote communities, communities experiencing disadvantage and Aboriginal and Torres Strait Islander people.

Reduce exposure to unhealthy food and drink marketing and promotion.

Increase the availability and accessibility of information to support the consumer to

make a healthier choice at the time of purchasing food or drinks.

Explore policy options related to the price of food and drinks to help shift consumer purchases towards healthier options.

Q34. Priority areas Before we move on to the next section of the survey, do you have any other feedback about the four priority areas you have just read about:

1. Supporting children and families – Starting early to support healthy weight throughout life

2. Mobilising people and communities – Using knowledge, strengths and community connections to enable health weight

3. Enabling active living – Supporting a way of life that helps people move throughout the day

4. Building a healthier and resilient food system – Producing and promoting healthier food and drinks with little impact on the environment

Please provide your comments in the space below. Nil response

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Support targeted interventions that increase the availability, accessibility and

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communities experiencing disadvantage and Aboriginal and Torres Strait Islander

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make a healthier choice at the time of purchasing food or drinks.

Explore policy options related to the price of food and drinks to help shift consumer

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Explore policy options related to the price of food and drinks to help shift consumer purchases towards healthier options.

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purchases towards healthier options.

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Section 4. Proposed enablers for a national obesity strategy Proposed enablers for a national obesity strategy We are now going to ask you about the four proposed enablers for a national obesity strategy. The proposed enablers are:

1. Lead the way – collective commitment and action for overweight and obesity prevention and health equity across governments.

2. Better use of data – sharing knowledge and data and using evidence to develop policies and programs and make sure collective actions are effective.

3. Build the workforce – support development of an engaged, empowered and skilled workforce that can better support individuals and influence community actions and environments.

4. Invest for delivery – adequately funding sustainable interventions and preventative actions, and exploring economic policies and trade agreements to positively impact on overweight and obesity rates, communities and the environment.

We are interested in what you think of the strategies and ideas to guide action included under each of these proposed enablers. Please select a set of proposed enabler questions to complete by clicking on the ‘Answer’ button. After you have answered all of the enabler sections you would like to complete, the ‘Next’ button at the bottom of the screen will take you to the next part of the survey. Q35. Proposed Enabler 1: Lead the way – collective commitment and action for obesity prevention and health equity across governments For this proposed enabler, there is one proposed strategy with two ideas to guide action. These are discussed in detail on page 27 of the consultation paper.

The proposed strategy for this enabler is:

Build and sustain collective commitment to, and action for, comprehensive and contemporary obesity prevention and health equity efforts.



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skilled workforce that can better support individuals and influence community

Invest for delivery – adequately funding sustainable interventions and

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preventative actions, and exploring economic policies and trade agreements to

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asepreventative actions, and exploring economic policies and trade agreements to

positively impact on overweight and obesity rates, communities and the

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asepositively impact on overweight and obesity rates, communities and the

We are interested in what you think of the strategies and ideas to guide action included

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We are interested in what you think of the strategies and ideas to guide action included

Please select a set of proposed enabler questions to complete by clicking on the ‘Answer’

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Please select a set of proposed enabler questions to complete by clicking on the ‘Answer’

After you have answered all of the enabler sections you would like to complete, the ‘Next’

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button at the bottom of the screen will take you to the next part of the survey.

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Proposed Enabler 1: Lead the way – collective commitment and action for obesity

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Proposed Enabler 1: Lead the way – collective commitment and action for obesity prevention and health equity across governments

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Slightly important


Very important

Extremely important

I’m not sure

Implement strong governance systems to facilitate multiple efforts by many sectors

☐ ☐ ☐ ☒ ☐ ☐

Explore new collaborative ways of working with communities that create genuine partnerships, embed the right to self-determination and autonomy, co-develop solutions and elevate community voices to create change in their own communities

☐ ☐ ☐ ☒ ☐ ☐

Q36.


Are there any additional strategies you think should be included to enable strong national leadership and governance to deliver better outcomes at the national, state/territory, regional and local levels?


Nil response

Q37.

Proposed Enabler 2: Better use of data – sharing knowledge and data and using evidence to develop policies and programs and to make sure collective actions are effective

For this proposed enabler, there are two proposed strategies, each containing a number of ideas to guide action. These are discussed in detail on pages 28 and 29 of the consultation paper.

The first proposed strategy for this enabler is:

Use evidence to inform policy and program development and implementation, and determine the effectiveness of collective actions.

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Are there any additional strategies you think should be included to enable strong national

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Are there any additional strategies you think should be included to enable strong national

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leadership and governance to deliver better outcomes at the national, state/territory,

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leadership and governance to deliver better outcomes at the national, state/territory,


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Please rate the extent to which you think each of the following proposed ideas is important for guiding action under this strategy. You can use the comment boxes in the online survey to provide any feedback you might have about each idea.


Slightly important


Very important

Extremely important

I’m not sure

Update Australian guidelines for healthy eating, physical activity and weight, ensuring they explicitly incorporate environmental sustainability, are based on the latest scientific evidence and are free from industry influence. Nil response to tick box, made comment below at Comment 1.

☐ ☐ ☐ ☐ ☐ ☐

Conduct regular cross-sector monitoring and evaluation of a national obesity strategy to ensure accountability, continuous improvement and effectiveness of collective action, in consultation with national data agencies and data collection custodians

☐ ☐ ☐ ☒ ☐ ☐

Support research on obesity systems to grow the evidence base, reduce gaps in knowledge and assess promising approaches

☐ ☐ ☐ ☒ ☐ ☐

Co-develop evaluation and research approaches that align with community values to acknowledge the deep knowledge and experiences of people working to create change in their own communities and to ensure data sovereignty

☐ ☐ ☐ ☒ ☐ ☐

Co-develop evaluation and research approaches with Aboriginal and Torres Strait Islander people, utilising cultural and traditional knowledge

☐ ☐ ☐ ☒ ☐ ☐

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improvement and effectiveness of

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improvement and effectiveness of collective action, in consultation

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collective action, in consultation with national data agencies and

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with national data agencies and data collection custodians

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data collection custodians

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Support research on obesity

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Support research on obesity systems to grow the evidence

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systems to grow the evidence base, reduce gaps in knowledge

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base, reduce gaps in knowledge and assess promising approaches

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and assess promising approaches

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1. Up to date and evidence based data is important for policy, regulatory and non-

regulatory interventions. We question the specific incorporation of environmental sustainability, which are environmental issues (or consumer lead). Industry, as do other stakeholders, have an important role to play and contribution to make in development of any regulatory/non-regulatory intervention. We therefore, are strongly opposed to the notion of industry exclusion.

Q38. Proposed Enabler 2: Better use of data – sharing knowledge and data and using evidence to develop policies and programs and to make sure collective actions are effective The second proposed strategy for this enabler is: Build and share knowledge so decisions are better informed. Please rate the extent to which you think each of the following proposed ideas is important for guiding action under this strategy. You can use the comment boxes in the online survey to provide any feedback you might have about each idea.


Slightly important


Very important

Extremely important

I’m not sure

Commit sustained funding to support data collection, shared data systems, enhanced sharing of effective and emerging initiatives, and regular population monitoring and surveillance of weight status and variables associated with overweight and obesity, including wider commercial, cultural and environmental determinants of obesity

☐ ☐ ☐ ☐ ☒ ☐

Boost participation rates in population monitoring and surveillance to ensure accurate and reliable statistics at sub-national levels and representativeness for at-risk population groups

☐ ☐ ☐ ☒ ☐ ☐

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Build and share knowledge so decisions are better informed.

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support data collection, shared data systems, enhanced sharing of

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data systems, enhanced sharing of effective and emerging initiatives,

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effective and emerging initiatives, and regular population monitoring

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Investigate new data sources to supplement population monitoring and surveillance (e.g., supermarket transaction data, Google analytics)

☐ ☐ ☐ ☒ ☐ ☐

Use data to regularly update consumers, communities and stakeholders with independent, accurate and easily understood information

☐ ☐ ☐ ☒ ☐ ☐

Use data to build connections between communities and the health, social sciences and environmental disciplines

☐ ☐ ☐ ☒ ☐ ☐

Support a collaborative analysis of research on interventions and strategies (from systematic reviews, and primary and grey literature) addressing healthy eating, physical activity and obesity-related outcomes for Aboriginal and Torres Strait Islander people and other population groups experiencing higher levels of overweight and obesity

☐ ☐ ☐ ☒ ☐ ☐

1. Commitment to sustained and matching funding to the NOS is critical for success.

Q39.

Proposed Enabler 2: Better use of data – sharing knowledge and data and using evidence to develop policies and programs and make sure collective actions are effective

Are there any additional strategies you think should be included to strengthen evidence and data systems to help guide investment, assess impact, improve outcomes, and continue to grow the evidence base?


Current scientific and evidence based data is essential to underpin the NOS, for its evaluation and evolution.

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population groups experiencing

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Commitment to sustained and matching funding to the NOS is critical for success.

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Commitment to sustained and matching funding to the NOS is critical for success.

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Q40. Proposed Enabler 3: Build the workforce – support development of an engaged, empowered and skilled workforce that can better support individuals and influence community actions and environments For this proposed enabler, there is one proposed strategy with four ideas to guide action. These are discussed in detail on page 30 of the consultation paper.


Empower and strengthen a skilled workforce to better support individuals and influence community actions and environments that increase healthy weight, whilst reducing obesity stigma, blame and discrimination.




Slightly important


Very important

Extremely important

I’m not sure

Strengthen the confidence and competence of primary health, allied health, and other health professionals to prevent unhealthy weight gain among patients; recognise and address overweight and obesity; and understand stigma, blame and the mental health implications of overweight and obesity

☐ ☐ ☐ ☒ ☐ ☐

Increase health workforce understanding of equity and social justice, and cultural and language competency to respond to the diverse needs of the Australian community

☐ ☐ ☐ ☒ ☐ ☐

Support the continued growth and development of the Aboriginal ☐ ☐ ☐ ☒ ☐ ☐

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and Torres Strait Islander workforce

Embed health promotion and equity into vocational and tertiary training for essential supporting sectors

☐ ☐ ☐ ☐ ☒ ☐

Q41.

Proposed Enabler 3: Build the workforce – support development of an engaged, empowered and skilled workforce that can better support individuals and influence community actions and environments

Are there any additional strategies you think should be included to develop an engaged, empowered and skilled workforce that can better support individuals and influence community actions and environments?


Can only agree.

Q42.

Proposed Enabler 4: Invest for delivery - Adequately funding sustainable interventions and preventative actions, and exploring economic policies and trade agreements to positively impact on overweight and obesity rates, communities and the environment

For this proposed enabler, there is one proposed strategy with four ideas to guide action. These are discussed in detail on page 31 of the consultation paper.


Provide adequate investment in sustainable interventions that promote healthy weight.



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Slightly important


Very important

Extremely important

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Provide additional funds for effective delivery of comprehensive, contemporary and sustained actions at an appropriate scale

☐ ☐ ☐ ☐ ☒ ☐

Explore new, innovative funding mechanisms for prevention of overweight and obesity, including a potential prevention investment fund Refer to Comment 1. below

☐ ☐ ☐ ☐ ☒ ☐

Ensure formal and informal engagement of public health expertise in trade and investment agreement development processes Nil response

☐ ☐ ☐ ☐ ☐ ☐

Assess health impacts of trade agreements during negotiations to ensure they favour the production and distribution of healthy food and drinks and control that of unhealthy food and drinks Nil response to tick box, made comment refer to Comment 2. below

☐ ☐ ☐ ☐ ☐ ☐

Investigate ways of reorienting economic policies, subsidies, investment and taxation systems to best benefit healthy eating and drinking, active living, health outcomes, communities and the environment Refer to Comment 3. below

☐ ☐ ☐ ☐ ☒ ☐

1. Governments need to invest in prevention initiatives as an investment in future health. Preventative activities are often less tangible and have less visible impact but more cost effective than cost of managing and treating overweight and obesity.

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3. Governments need to invest in prevention initiatives as an investment in future health. Preventative activities are often less tangible and have less impact but more cost effective than cost of managing and treating overweight and obesity.

Q43. Proposed Enabler 4: Invest for delivery - Adequately funding sustainable interventions and preventative actions, and exploring economic policies and trade agreements to positively impact on overweight and obesity rates, communities and the environment Are there any additional strategies you think should be included to provide adequate and sustainable investment in overweight and obesity prevention? Please provide your comments in the space below. Nil response

Section 5. Proposed implementation, monitoring, evaluation and reporting of a national obesity strategy

Lastly, we would like to get your feedback on the proposed implementation and evaluation of a national obesity strategy.

This is discussed in detail on pages 32 and 33 of the consultation paper.

Q46.

Proposed governance arrangements for a national obesity strategy

The COAG Health Council will be responsible for strategy implementation, monitoring and progress reporting.

While the strategy will be led by Health, to achieve the vision, Health will work with partners across government and the community.

Accordingly, the COAG Health Council will be supported by:

the Australian Health Ministers Advisory Council, and a new cross-portfolio federal, state and local government committee with

representatives from essential supporting sectors.

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Partnerships with non-government organisations, private sector, population group representatives and community members will inform implementation of the strategy. The Australian Institute of Health and Welfare will support development of indicators and monitoring and reporting. Do you have any feedback about the proposed governance arrangements for a national obesity strategy? Please provide your comments in the space below. There is frequent criticism of the role of the private sector/industry in policy development. This criticism is unfounded given the important role the food industry plays in implementation. Q47. Proposed implementation for a national obesity strategy Under the auspices of the Australian Health Ministers Advisory Council, it is proposed the new cross-portfolio committee will be responsible for developing an implementation plan that will focus on those strategies best pursued at a national level. This approach will be supported by implementation plans developed by each state and territory, in collaboration with local partners and in discussion with other jurisdictions to ensure breadth of coverage and coordination across Australia. The plans will include timeframes and responsibilities for implementation. Resources will be required for implementation. Do you have any feedback about the proposed implementation for a national obesity strategy? Please provide your comments in the space below. A coordinated national plan supported by state and territory jurisdictions is supported.

Q48.

Proposed monitoring, evaluation and reporting process for a national obesity strategy

Monitoring the implementation of this strategy will require a coordinated national effort. A tiered national evaluation framework will monitor progress and achievements and include:

indicators to show shorter-term progress outcome measures aligned with priority areas, and targets.

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that will focus on those strategies best pursued at a national level.

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To ensure a transparent focus on equity, the framework will include indicators, outcomes and targets specifically for population groups who are unequally affected by overweight and obesity. Existing data sources will be utilised with potential for additional new measures. Both national measures and jurisdictional information will contribute, and results will be regularly reported to COAG Health Council and available to the public. Solutions to addressing overweight and obesity in Australia are not static. Incorporating feedback on barriers, enablers and effects of actions on a regular basis is necessary. Building a process of gathering information, reflecting and adapting will strengthen future action to ensure relevance and effectiveness. Do you have any feedback about how the strategy should be monitored, evaluated and reported? Please provide your comments in the space below. Nil response

Q49.

Do you think targets are needed for the strategy? If so, what should they be?


A staged approach with phased implementation and targets is appropriate. Targets need to be evidence based and achievable, assessed and reviewed periodically and adjusted as required.

Q50.

Do you have any suggestions for what a national obesity strategy could be called?


It is acknowledged that negative stigma is attached to 'obesity' at the same time 'obesity' used in the name of the strategy overtly places a clear focus.

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Q51. Lastly, do you have any final comments or ideas regarding the proposed national obesity strategy? I would like to attach a copy of a paper the Australian Industry Group Confectionery Sector prepared in relation our concerns regarding high HSR stars on confectionery, as a consequence of the FoFR supporting HSR review Recommendation 2. A second attachment is an extract from the Ai Group Confectionery Sector's submission to the Senate Obesity Inquiry, which details many of the initiatives the confectionery industry has achieved over an extended period of time - since introducing Be treatwise in 2006, the industry agreed serve size in 2009, HSR in 2014 in addition to the industry's commitment to consumer nutrition/labelling information, commitment to more smaller packs, ie 250 calorie portions and more treat size, with a migration to more 200 calorie and 100 calorie portions and consumer education - see www.betreatwise.info which includes a new video segment explaining Be treatwise and role of confectionery, portion and activity.

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About You In which state or territory is your organisation or business located?

1. Australian Capital Territory 2. New South Wales 3. Northern Territory 4. Queensland 5. South Australia 6. Tasmania 7. Victoria 8. Western Australia 9. Australia wide 10. International

Q62. About You How would you best describe the location you live in?

1. A capital city 2. A regional city or town 3. A rural or remote town or area 4. Prefer not to say

Q63. About You How would you best describe the location of your organisation or business?

1. A capital city 2. A regional city or town 3. A rural or remote town or area

Q64. About You We value the thoughts of people who have lived experience of overweight or obesity; however, the following question is optional. How would you best describe your current weight?

1. Underweight 2. About the right weight

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3. A little overweight 4. Very overweight 5. Prefer not to say

Thank you for taking the time to share your valuable feedback. This is the final page of the survey – please click the submit button below. The national obesity strategy Working Group will use your feedback to shape a national obesity strategy. The COAG Health Council will consider the strategy in late 2020. A report on the outcomes of the consultation will also be made publicly available.

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NOS - long form surveyResponse ID:1235 Data

6. Consent to participate in this survey

1. By participating in this survey, you indicate that:You have read the preceding information;Your participation in this survey is voluntary; You consent to your responses being included in public reports; andYou are at least 14 years of age.Do you wish to continue with this survey?

Yes

7. Organisation or individual?

2. Are you completing this survey on behalf of an organisation or as an interested individual?


8. Main role

3. What is your organisation's main role or interest in a national obesity strategy? You may select all that apply.

Other (please specify): Our members manufacture raw sugar (non food grade) and/or grow sugarcane

9. Main role

What is your main role or interest in a national obesity strategy? You may select all that apply.

10. Name of your organisation

4. Many people and organisations have a diverse range of views on what should be included in a national obesity strategy. To ensure transparency throughout the consultation process, it is important to consider these views in the context of anyrelevant interests.

As you are answering this survey on behalf of an organisation, please provide the name of your organisation in the spacebelow.

This information is required.

Australian Sugar MIlling Council and CANEGROWERS Ltd

11. Organisation contact details

5. Please provide a contact name and email address for your organisation so that we may contact you about thisconsultation process if required.

Your contact details will only be used for the purpose of this consultation and will not be shared with any third parties. Onceagain, this information is required.

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Contact name:

6. Contact email:

13. Section 1. Proposed timeframe and scope for a national obesity strategy

7. Timeframe of a national obesity strategy

It is proposed that a national obesity strategy will guide action over the next 10 years – from 2020 to 2030.

Do you think this timeframe is too short, about right, or too long?

About right


Timeframe of a national obesity strategy

Why do you think the proposed timeframe of 10 years is About right?


8. To what extent do you agree or disagree with each of the following components in the proposed scope for a nationalobesity strategy?

Stronglydisagree

Somewhatdisagree

Neitheragree

nordisagree

Somewhatagree

Stronglyagree

I'mnot

sure

The strategy should encourage government leadershipfor collaborative, whole-of-society action.

X

The strategy should identify actions for Commonwealthand State and Territory governments.

X

The strategy should identify actions that will involve non-government organisations and other communitystakeholders.

X

The strategy should identify actions that will involve theprivate sector.

X

The strategy should focus on primary and secondarypreventive actions that promote and support healthyeating, regular physical activity and a healthy weight forall.

X

The strategy should not focus on tertiary preventionactions to treat overweight and obesity.

X

The strategy should not focus on actions to manage andaddress underweight.

X

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9. Thinking specifically about the proposed scope for a national obesity strategy, is there anything you would change, addor remove?

Please provide your suggestions about the proposed scope in the space below.

Please note there are many opportunities to comment on specific strategies and ideas proposed to be included in thestrategy throughout the survey.

We strongly support the development of the strategy and we are keen to be involved, not least to support the Queenslandcommunities that are dependent on the sugar industry, but who are also impacted by obesity. While prevention is key, we feelmitigating the affects for people who are currently overweight or obese should still be a focus. Ideally the strategy wouldtarget: • General public prevention• Prevention and mitigating of impacts of at-risk groups.. The strategy will need to be tailored to suit each community.We note the inclusion in these survey questions of a number of additional areas that may be better defined as 'out of scope' toensure the strategy is focused and able to define and measure clear targets/goals. Trade policy and sustainable developmentare important topics that are contentious and have the potential to distract and delay the objectives of this obesity preventionstrategy. We also believe it will be important to include agribusiness, farmers, ingredient manufacturers and the food supplychain in all aspects of the strategy.

18. Section 2. Proposed principles to guide a national obesity strategy

10. Please rate how important you think each of the following proposed principles are for guiding the development andimplementation of a national obesity strategy.

Not at allimportant

Slightlyimportant

Moderatelyimportant

Veryimportant

Extremelyimportant

I'mnot

sure

People First - the strategy is person-centred, meaningit recognises the unique situations, experiences andstrengths of individuals

X

Equity - the strategy will promote equity,acknowledging some people and groups needadditional supports to achieve good health

X

Collective and Sustained Action - the strategy willpromote partnerships and ongoing sharedcommitment from government and other keystakeholders

X

Evidence-Based - the strategy will be informed by up-to-date evidence and promising or emergingstrategies

X

Sustainable Development - the strategy will alignwith the pillars of sustainable development: economicgrowth, social equity and environmental protection.

X

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11. Thinking about the five proposed guiding principles, is there anything you would change, add or remove?


While a worthy principle, there is a risk that sustainable development goals could become a distraction from the core aims ofthe strategy.

21. Section 3. Proposed priority areas and strategies for a national obesity strategy

Please select a priority area to complete by clicking on the 'Answer' button.

After you have answered all of the sections you would like to complete, the 'Next' button at the bottom of the screen willtake you to the next part of the survey.

22. Proposed Priority 1: Supporting children and families – starting early to support healthy weightthroughout life

12. Please rate the extent to which you think each of the following proposed ideas is important for guiding action under thisstrategy.


Remember that you can rate and comment on all of the ideas, or you can skip to the next section if you do not want toprovide feedback on a particular area.

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Comments

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Provide healthy eating and drinkingsupport and physical activity support forpre-conception and during pregnancy,including specific approaches forprospective parents who are, or at riskof becoming, overweight or obeseduring pregnancy

X

Provide support for mothers tobreastfeed and continue to breastfeedby implementing the NationalBreastfeeding Strategy

X

Explore policy options to strengthenprotection of infants and families fromexcess availability and marketing ofbreast milk substitutes

X

Not surethere is

evidence tosuggest thisis an issue

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communitiesin Australia

Strengthen healthy eating and physicalactivity guidance and support formothers and fathers after birth as theytransition and adjust to their new rolesas parents

X

Provide guidance to parents, carersand families on appropriate healthyeating and physical activity for infants(e.g., appropriate introduction of solids,responsive feeding, portion size,screen time, motor skill development)

X




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Provide guidance to parents, carersand families on appropriate healthyeating and physical activity for childrenand young people (e.g., appropriatenutrition, portion size, screen time,sleep and regular physical activity)

X

Support parents, carers and families topurchase, prepare and enjoy healthyfood and drinks, whilst limitingunhealthy food and drinks.

X

Do we havea definition of

unhealthyfoods? Is this

a helpfuldistinction?

Do we meantreats or

discretionaryfoods/drinks?

Encourage parents, carers andfamilies of children and young peopleto use parks and recreation facilities,role model active transport and activeliving, be active with children (co-participation) and restrict screen time

X

Develop fun peer and communityactivities that enable adolescents toengage in physical activity, including afocus on the role of fathers

X

Encourage greater availability ofhealthy food and drinks, whilst alsolimiting unhealthy food and drinks, atsporting, recreation and communityvenues, facilities, clubs and events.

X

Increase availability of, and equitableaccess to, appropriate programs thatsupport weight management forchildren, young people and theirfamilies

X




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venues, facilities, clubs and events.

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Increase availability of, and equitable

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Enhance leadership, professionalknowledge, relevant policies andpractices, curriculum design and deliveryaligned with national guidelines, andpartnerships within and beyond the earlychildhood education and care andschool community

X

Establish partnerships to deliverprograms where necessary (e.g., healthybreakfast programs, healthy schoolcanteens and childcare menus, activeplay programs)

X

Enable after-hours use of school facilitiesto expand available, accessible andaffordable physical activity options anddestinations for families and communities

X

Support safe, active travel to and fromearly childhood education and caresettings and schools throughinfrastructure and behaviour changeprograms in collaboration with localcommunities

X

Investigate policy and community-ledoptions to extend student retention inschools across the Australiancompulsory education period, includingfocused strategies for Aboriginal andTorres Strait Islander children andchildren from other priority groups

X


15. Thinking about the strategies you just read for supporting children and families, are there any additional strategies oryou think should be included to start early to support healthy weight throughout life?

Please provide your comments in the space below. The three proposed strategies are listed again below if you need to re-read these.

We agree it is important to provide clear information that is well understood by everyone – starting early with young familiesshould assist them to understand the importance of eating well and keeping active. The definition of 'healthy' as opposed to'unhealthy' foods is not clear here (although the paper is presumably discussing discretionary 'treats,' any food consumed invast quantities or improperly prepared could be deemed as unhealthy) so measures requiring the availability of some foods tobe limited need to be carefully considered.

26. Proposed Priority 2: Mobilising people and communities – using knowledge, strengths and communityconnections to enable healthy weight

12. Please rate the extent to which you think each of the following proposed ideas is important for guiding action under this

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Thinking about the strategies you just read for supporting children and families, are there any additional strategies orRTI Rele

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you think should be included to start early to support healthy weight throughout life?

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Please provide your comments in the space below. The three proposed strategies are listed again below if you need to re-

strategy.


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Provide information, education and skill-building programs and initiatives alignedwith Australian guidelines for healthyeating, physical activity and sedentarybehaviour

X

Develop and fund ongoing national massmedia campaigns to shift expectations,beliefs and social norms, whilstminimising weight-related stigma

X

Is thereevidenceto support

thispotentially

costlyapproachto drive

behaviourchange?

Partner with Aboriginal and Torres StraitIslander people to develop and deliverculturally appropriate and safe socialmarketing and supporting programs

X

Partner with culturally and linguisticallydiverse (CALD) groups to develop anddeliver culturally appropriate and safesupport programs for early migrants

X

Partner with people with disability todevelop and deliver initiatives to improvehealthy eating and physical activity thatare accessible and responsive

X




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develop and deliver initiatives to improve

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develop and deliver initiatives to improvehealthy eating and physical activity that

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healthy eating and physical activity thatare accessible and responsive

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Invest in targeted community capacitybuilding initiatives that activateleadership, drive innovation and supporta collective impact approach to createhealth promoting community places andspaces

X

Identify a diverse range of local leadersto 'champion' place-based healthy eatingand physical activity initiatives anddevelop a supportive nationwide networkand learning community

X

Ensure local communities have access tohealth promoting sponsorship options forevents and sport, and are empoweredand informed to consider the impact ofunhealthy sponsorship choices

X




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Evidence-based weight managementinterventions, ensuring a range ofdelivery modes and accessibility for all,regardless of age, living location, culturalbackground and income

X

Advocate for increased intensity of actionfor population groups experiencinghigher levels of overweight and obesity,through effective co-designed behaviourchange programs

X

Support those experiencing weightstigma and discrimination and ensure allactions promote positive discussion ofweight and prevent weight-relatedstigmatisation

X


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28. Proposed Priority 2: Mobilising people and communities – using knowledge, strengths and community

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Advocate for increased intensity of action



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Support better collaboration betweensectors dealing with unemployment,social protection and health

X

Develop labour and social policies thatprovide secure and decent work for all

X

Raise incomes of the poorest groups toreflect the real cost of healthy living andincrease access to improved livingconditions and opportunities for healthybehaviours

X

Provide professional development forclinicians to support the improvement ofhealthy eating and physical activitybehaviours in their patient/clients

X

Enable early identification of unhealthyweight gain (including modest weightgain) for patients/clients, with a focus onlife course transition points oftenassociated with weight gain and peoplefrom at-risk population groups

X

Increase the availability of, and clarity ofreferral pathways to, evidence-basedweight management treatments(including community-led programs)

X




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2020-21 Disclosure Log

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Transcript of 2020-21 Disclosure Log