The Brewers Association of Australia (Brewers) reiterates our full support for mandatory pregnancy labelling. We committed to mandatory labels in October 2018 to provide a clear warning not to drink while pregnant.
Our members have voluntarily carried pregnancy warning labels on all products since 2014. We already support key features of Food Standards Australia and New Zealand’s (FSANZ’s) proposed label, including:
- Increasing the size of the warning
- A box outline to highlight the warning
- New signal wording of ‘Pregnancy Warning’
- New written warning message that ‘Alcohol can cause lifelong harm to your baby’ to accompany the familiar pictogram of a pregnant woman holding a drink with a line through her silhouette.
We do not support mandatory colours.
Labels must be clear and stand-out, but FSANZ’s proposed mandatory colours are not necessary to achieve those objectives and come at a huge, unreasonable cost to consumers and producers – exceeding $400 million and more in ongoing costs.
Ministers identified this unreasonable impost in March this year when the Ministerial Food Forum (the Forum) directed FSANZ to review its original recommendation because of problems mandating colours causes.
These unreasonable and unnecessary costs are even more concerning as the entire community is dealing with the tremendous economic impact of COVID-19, which is decimating large parts of the beverages and hospitality sectors and the jobs they provide.
The same public health benefit is achieved without unreasonable cost by developing sensible, high contrast colour guidelines, which are consistent with the obligations imposed by the Food Code.
The proposed label, which Brewers support except for the mandatory colours, will be the largest of all the mandatory information that alcohol containers are required to have. For example, the proposed label will be larger and more readable than alcohol content information and number of standard drinks that appear on alcohol containers.
As we have previously made clear, Brewers enthusiastically supports mandatory pregnancy warning labels and moving to them expeditiously. Despite Ministers and the industry wanting to move quickly to mandatory labels, we are puzzled that FSANZ has sought to provide a longer transition period but still maintain the mandatory colours.
Brewers can move to the new mandatory label within two years, rather than three years proposed by FSANZ, if the Forum endorses sensible colour contrast guidelines.
All producers have provided detailed information about the high cost burden of mandating colours, so we are disappointed this information has been dismissed by FSANZ.
We want mandatory labels and are prepared for the additional costs imposed. But we don’t support mandatory colours that pose significant and unreasonable additional costs for all consumers of alcohol beverages and producers.
We seek the support of Governments to achieve a sensible compromise that achieves a strong, readable and impactful label that does not impose unreasonable costs.
Australian brewers normally contribute $16 billion to the economy and support 100,000 full time jobs. We hope that Ministers support that activity and those jobs and, in doing so, recognise our offer to move to a mandatory label more quickly if the unreasonable costs associated with the proposed mandatory colours can be replaced by sensible colour contrast guidelines.