Country of Origin Food Labelling
SUBMISSION
Of the
NEW ZEALAND RETAILERS ASSOCIATION
to
FOOD STANDARDS AUSTRALIA NEW ZEALAND
In respect of
COUNTRY ORIGIN LABELLING OF FOOD
JULY 2004
INTRODUCTION
This summary submission is presented by the New Zealand Retailers Association.
BACKGROUND
The Association is the largest association representing the retail industry in New Zealand. Our membership includes the major supermarket and general merchandise chains, specialised chains, department stores and hundreds of owner operators spread throughout New Zealand.
Annual sales at retail total in excess of $50b. The industry employs some 325,000 people (17% of the workforce) in some 49,000 outlets throughout the country. We estimate our membership accounts for about 65% of general merchandise sales.
Annual sales by supermarkets totalled some $10.5b or 20.5% of total retail sales in 2003.
SUMMARY OF SUBMISSION
The Association wishes to confirm its support for voluntary requirements for country of origin labelling for packaged food. This view is consistent with our previous submissions on this issue, and supports the comprehensive submission filed by Progressive Enterprises Ltd. We also note that a similar submission supporting voluntary origin labelling has been filed by Business New Zealand.
COMMENT
There is, in our view, little demand for mandatory labelling of food.
The current Food Standards Code already requires the suppliers name and street address to be shown on food labels, and market research provided as part of the Progressive submission outline minimal interest in origin inquiries.
There are very few types of merchandise sold in New Zealand that require mandatory labelling. Generally speaking the provisions of the Fair Trading Act 1986 outline the need for clear and accurate labelling, and, we submit, that these rules are well understood by the trade given the very limited number of prosecutions brought against industry over the past twenty years for intentionally misleading or inaccurate labelling. Mandatory origin labelling is, in fact, only required for apparel and footwear, and we are unaware of any compelling demand by consumers for additional merchandise sectors to be subject to mandatory origin labelling requirements.
Origin labelling also raises questions over who is responsible for ensuring the accuracy of the content or product information of origin labels. Retailers are clearly responsible for ensuring that the merchandise they sell is in compliance with the law and meets consumer's expectations. But, outside of direct house brands, retailers are also clearly reliant on both manufacturers and importers providing them with accurate compositional, nutritional and general supplier details, and we would not expect responsible traders to sell merchandise that did not comply with these current legislative requirements.
The necessity for mandatory origin labelling for food was recently discussed at a meeting of the Grocery Industry Council, which comprises the major organisations representing the grocery industry in New Zealand. These parties include the NZ Food and Grocery Industry Council, NZ Retailers Association, Progressive Enterprises Ltd, Foodstuffs and NARGON.
There was no support evident amongst any of these industry members for mandatory origin labelling on the basis that:
- New Zealand is different to Australia in that it is highly dependent on imported ingredients in food. It was noted that accessibility, price and seasonality frequently mean that New Zealand manufacturers source from different countries during the year and mandatory labelling would, consequently, be impractical;
- there is confusion about the current origin labelling requirements in Australia;
- origin labelling is not a standards issue - it is a marketing issue and the need for mandatory labelling has been driven by political aspirations;
- origin labelling could reduce consumer choice;
- origin labelling should continue to be addressed under fair trading legislation;
- there are few consumer calls as to the origin of ingredients of food; and
- consumers do not obtain information solely from labels. Other forms of education such as point of sale material and the Internet are also used to provide information to consumers.
There is, at this stage, no cost benefit analysis that has been completed in respect of the proposal for possible mandatory labelling of food. Clearly that would be a major issue to manufacturers who have already undertaken substantial reviews of their labelling to ensure compliance with the Food Standards Code. Similar costs would flow to retailers in respect of house brands. However, it should be noted that further costs will likely arise as a consequence of the adoption of the revised packaging code which requires manufacturers to review new and existing packaging on replacement against the current NZ Code of Practice for the packaging of consumer goods, and any requirement for mandatory origin labelling would add yet another cost to the food cycle.
As a principle we believe the costs would likely exceed the benefits and it has yet to be demonstrated that there is a necessity for mandatory origin labelling of food in New Zealand.
We therefore are of the view that mandatory labelling of packaged food not proceed.
NZ Retailers Association
July 2004
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