Joint Submission to Food Standards Australia New Zealand Proposal P1067: HSR System

Australia is one of the world’s most culturally diverse nations. More than half of Australians are either born overseas or have a parent born overseas, and more than one in five Australians speaks a language other than English at home. Multicultural communities experience well documented barriers to accessing health information, including language barriers, varying levels of health literacy, different understandings of nutrition and preventive health, and differing levels of familiarity with Australia’s food system. Women, and particularly those with primary caring responsibilities, are typically the household’s main interpreters of food and health information. For multicultural women, this role intersects with settlement related barriers such as developing English proficiency, unfamiliarity with the Australian food and health system, and, for some, visa related precariousness, making an equity lens in HSR implementation especially important.

The Collaborative and AMWA welcome the opportunity to provide a submission on Proposal P1067 and broadly supports the proposal to mandate the HSR (HSR) system. We consider mandatory front-of pack nutrition labelling an important preventative health reform that has the potential to improve consumer decision-making and population health outcomes. The evidence presented by Food Standards Australia New Zealand (FSANZ) demonstrates that the voluntary system has not achieved sufficient uptake to maximise the public health benefits of front-of-pack nutrition labelling. A mandatory approach is likely to improve consistency across food supply, strengthen broad consumer confidence and provide a more uniform basis for comparing similar food products.

From a multicultural health perspective, however, mandating the HSR system should be viewed as the beginning of reform rather than its completion. A mandatory label alone will not necessarily translate into equitable health outcomes. Front-of-pack labelling is only effective when consumers understand and trust the health information presented. This is particularly crucial given some multicultural communities experience a higher prevalence of obesity and cardiometabolic risk. The proposal also represents an opportunity to contribute to reducing health inequities experienced across Australia’s multicultural communities. While health outcomes vary considerably between communities, many experience higher rates of diet-related chronic disease, earlier onset of cardiometabolic conditions, or barriers to accessing preventive health information and services. A mandatory HSR system should be viewed not only as a food labelling reform, but also as a preventive health intervention. Embedding an equity lens throughout implementation will help ensure the communities that could benefit most are not those least able to access or act on the information provided.

For this reason, The Collaborative and AMWA believe the proposal would be strengthened by adopting a more explicit multicultural and health equity lens throughout its evidence base, implementation strategy, and evaluation framework. AMWA’s Health Thematic Working Group has consistently identified health literacy, trust, language and settlement-related barriers as key determinants of multicultural women’s ability to access and act on health information. Without this, the proposal risks falling short of its own public
health objectives by only improving access to nutrition information for some Australians