Labelling

The Foundation is calling for the implementation of health warning labels and additional consumer information on alcohol products and alcohol product packaging.

Evidence shows that if alcohol product labelling is implemented properly with mandated regulations on the specifics of health warning label messages, design, and application; this policy has the potential to both increase awareness and change behaviour by targeting the consumer at both the point of sale and point of consumption.

In 2010, the Australia and New Zealand Food Regulation Ministerial Council (the Ministerial Council) undertook a comprehensive review of food labelling law and policy in Australia and New Zealand. The final report entitled Labelling Logic was presented to the Ministerial Council on 28 January 2011. The report made four recommendations on alcohol product labelling, including recommendations on the application of health warning labels and nutrition information panels.

The Foundation has prepared a policy position paper in response to recommendations made by Labelling Logic in favour of alcohol product labelling. This policy position paper has been endorsed by the Executive of the National Alliance for Action on Alcohol.

The Foundation’s position

Alcohol products should be subject to at least the same regulatory requirements as food products to ensure that the consumer is appropriately informed in accordance with Australian Consumer Law and more specific food labelling laws. The provision of such information is particularly important given the harmful consequences associated with excessive alcohol consumption.

Health warning labels should be mandatory on all alcohol products and product packaging in Australia. There should be a suite of health warning messages (at least 5) and one of the health warning messages should always relate to the risks of drinking alcohol during pregnancy. The warning messages should be rotated to ensure that consumers are exposed to a variety of messages. In order to target the largest number of consumers, health warning messages should cover a range of alcohol-related harms, including short-term and long-term harms, social harms, and the harms caused by alcohol to people other than the drinker.

Health warning labels should comprise text and a symbol. This will ensure that the health warning messages reach a broad audience and are understood by consumers with a range of literacy levels as well as consumers from culturally and linguistically diverse backgrounds.

We support a range of design features that are based on international research on the salience of health warning labels. We believe that health warning labels should be placed on the front of the alcohol product container, horizontally oriented, and separated by a prominent black border. The size, font, and application of health warning labels should be consistent on all alcohol products. The message text should be preceded by the words ‘HEALTH WARNING’ and the health warning label should take up a significant proportion of the alcohol product label to ensure clear visibility. The specific percentage of space that the health warning label commands on the container surface should be determined by the size of the container, product label size, and salience. A minimum size of font and label should be specified to ensure visibility.

In addition to health warning labels on the front of alcohol product containers, we also support the implementation of mandatory nutrition information panels and a list of ingredients. The back label should also include the energy content per 100 mL.

The implementation of health warning labels should be accompanied by a comprehensive public education campaign, using various forms of media, to reinforce the messages contained on the health warning labels. We believe that the costs of designing both the health warning labels and the public education campaign should be borne by Government and administered by the Australian National Preventive Health Agency. The costs of implementing the health warning labels on alcohol products and packaging should be borne by the alcohol industry.

The Foundation believes that health warning labels should be evaluated for their effect on attitudes and behaviours, and should be reviewed at least every three years.