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Standards Management Section
Food Standards
Email: slo@foodstandards.gov.au
I wish to make a comment on Application A555 Initial Assessment Report:
Declaration of Antioxidants in Fats and Oils
I want manufacturers to
declare the presence of ALL food additives in their products, no matter how
small the amount, and whether or not the manufacturer believes that the
additives perform a technological function in the final product.
When we express concerns
about the health, behaviour and learning effects of particular food additives,
Ministers and FSANZ often tell us as consumers that we can read the label and
make informed decisions about the foods we buy. But without transparent and
complete labelling requirements, consumers are in fact denied this basic right.
I choose to avoid certain
food additives because of concerns about their long term safety or because I
personally know that some of these additives have an adverse effect on my own
or my children’s health, behaviour and learning. In particular I do not wish to
consume products which contain additives 310, 311, 312, 319, 320 and 321. These
additives are often not declared on the label because of the current 5%
labelling loophole in the legislation, making it very difficult to make sound,
safe decisions in my product choice.
Manufacturers also
frequently change the sources of their oils and, since there is no present
requirement to show these synthetic antioxidants on the label at under 5%, they
do not know or care whether these antioxidants are present. Therefore even if I
go to the trouble of ringing them I am frequently given no information or
incorrect information. The only solution is to require mandatory labelling for
these compounds.
I am most concerned about
the ubiquitous use of additive 320 BHA in products such as peanut butter,
biscuits, chips, crisps and some soymilks. This additive is prohibited in foods
for infants and young children in the Food Standards Code yet it is used widely
in foods such as these which young children often consume, without appearing on
the label.
BHA is also well known scientifically and observationally to trigger
asthma and urticaria in sensitive people and, with the rising rates of asthma
particularly in children, it is
important that labels make it possible for asthmatics and parents of asthmatic
children to clearly identify this additive in products for sale.
Yours truly