many uncertainties and risks with the voluntary approaches to recommend that pregnancy warning labels on packaged alcoholic beverages continue on a voluntary basis. A mandatory approach is the only option that can ensure that pregnancy warning labels are applied across all packaged alcoholic beverages (i.e. all types of packaged alcoholic beverages and domestic and imported products), in a manner that is likely to be understood by the target audience, and consistent with government advice. It is also the only option that provides for enforcement by the existing food enforcement authorities. Transition periods and stock-in-trade exemptions could be introduced to minimise the impact on industry as much as possible. Mandatory pregnancy warning labels recognises the significance of FASD and its impact on individuals, families and the community. Alcohol consumption during pregnancy affects a third-party (the unborn child) and regulation is necessary to help protect this vulnerable group. Mandatory warning labelling for packaged alcoholic beverages is consistent with mandatory pregnancy warning/advisory labels that are required under the Australia New Zealand Food Standards Code for products such as formulated caffeinated beverages and formulated supplementary sports foods. It is also consistent with labelling requirements for other products that are harmful to the developing fetus such as tobacco. The effectiveness of labelling in changing consumer behaviour varies across products; however governments’ approach to improving the information available to consumers is a key policy lever. It is expected that despite the uncertainty around how many FASD cases mandatory labelling will prevent, and to what extent, the change in both occurrence and level of drinking in pregnant women will outweigh the cost of moving to mandatory labelling. This approach, in conjunction with other measures being funded by the Australian and New Zealand governments, is considered the approach most likely to shift the cultural norm by reminding pregnant women and their partners, friends and families of the hazards of drinking while pregnant. It is therefore the approach most likely to result in a reduction in the incidence and severity of FASD. Implementation It is recommended that the Forum request that FSANZ develop a mandatory labelling standard for pregnancy warning labels on packaged alcoholic beverages. In implementing the preferred option it is recommended FSANZ give consideration to including a two to three year transition period to minimise impacts on industry in introducing mandatory pregnancy warning labels. It is recommended that FSANZ give consideration to stock-in-trade exemptions so that products that have already been packaged and labelled prior to the end of the transition period would not have to change their label. Label design
The Siggins Miller evaluation reported that both industry and public health sectors support a minimum standard set by government for consistent content, size, and placement of pregnancy health warning labels. Opportunity for communication experts, the public and consumer and public health organisations to have input into Government style guide. Some industry groups (a minority) that submitted to the targeted consultation have indicated support for this option. Could potentially increase variation in pregnancy warning labels in the market with some industry groups following the status quo, and others adopting the new style guide. Cost and workload for Government to develop the style guide. Option 2- Mandatory Opportunity to address the issues identified in this paper such as consumer misunderstanding, contradictory messages and requirement to visit a website. Level playing field for industry as all industry need to comply with the mandatory requirements. Open and transparent process for establishing the requirements for pregnancy warning labels. Consistent with other pregnancy advice on food labels such as formulated caffeinated beverages and formulated supplementary sports foods which require mandatory statements to advise that the products are not recommended/suitable for pregnant women. Consistent with the way other teratogens such as tobacco and some medications are required to carry mandatory warning labels. The Australia New Zealand Food Standards Code applies to both Australia and New Zealand and Cost to industry for compliance (the extent of which will depend on how the requirements in the proposed Australia New Zealand Food Standards Code compare to current industry practices). For producers of smaller packages (e.g. 50ml bottles) it may not be physically possible to accommodate a pregnancy health warning without substantial change to the current package / labelling. Increased workload for regulators. Cost and work for Government to introduce mandatory labelling into the Australia New Zealand Food Standards Code. Would require imported products to comply with the Australia New Zealand Food Standards Code requirements. Would require notification to the World Trade Organisation. However, there are clear public health
Several submissions advised that the warning should not be placed next to contradictory messages such as ‘enjoy responsibly’. Others proposed it should be located next to other consumer information such as standard drinks. Some industry submissions noted the need for flexibility with regard to position on the package to place the warning within the available space. Recommendations Consumer understanding of the current warning labels could be improved by increasing the size of the pictogram and text, using contrasting colours and legible fonts, changing the wording of the warning message, and using features such as borders and clear space around the warning to help the warning stand out and be distinctive from surrounding information on the label. Consumer testing should be undertaken to determine the most appropriate features of the pictogram. It is recommended that testing explores: image – beer versus wine glass; colour and contrast – black with red prohibition symbol; black with charcoal prohibition symbol (or vice versa); monotone with the line through the pregnant figure separated from the figure (e.g. in charcoal or black); and a range of other contrasting colours; size – the minimum size recommended by DrinkWise and Cheers versus various minimum percentages of the label; and location – proximity to other information on the label. The warning text should not be used on its own, but should be used in conjunction with the pictogram to explain why women should not drink when pregnant. Consumer testing of the warning text should explore: message – current DrinkWise messages; statements mandated internationally, such as in France: “Consumption of alcoholic beverages during pregnancy, even in small amounts, can have serious consequences for the child's health”; other statements such as “Don’t drink pregnant”; “Drinking while pregnant can hurt your baby”; “Alcohol harms your unborn baby”; “Drinking alcohol during pregnancy can cause birth defects”; statements including message not to drink when planning a pregnancy or when breastfeeding; and use of the word “WARNING”, “HEALTH WARNING”, or “GOVERNMENT WARNING”. size – minimum font size print – bold typeface versus plain; uppercase versus lower case; colour – black, red, charcoal; contrast – use of clear space around the message; different text and background combinations (e.g. black text on yellow background; red and black text on white background); and border – colour; size; width. The consumer testing should not be undertaken by industry in order to eliminate any perceptions of conflict of interest or bias. Ideally the warnings to be tested should be
developed by communication, behaviour change and health literacy experts. Warnings should be tested with the women of childbearing age, pregnant women and women planning a pregnancy, as well as those who influence their decision not to drink, such as partners and health professionals.