Table 4: Policy options for pregnancy warning labels on packaged alcoholic beverages Policy option Description Examples Pros Cons Option 1a) Status quo. Industry discretion is permitted in which labelling to apply to products, with one option to use the DrinkWise or Cheers label designs, or any other label design. Current situation. DrinkWise and Cheers also increase efforts in promoting the uptake, and use of consistent warning labels amongst industry groups. Overall use of these labels is currently relatively high; however some sectors need further encouragement to adopt the labels. Minimal cost to industry, as many products are already using the labels. The policy is consistent with international arrangements where companies have signed up to voluntary labelling commitments. using the DrinkWise and Cheers labels supports a level of consistency in labelling, it does not fully overcome the variation in labelling styles and wording that has been observed. This can lead to consumer confusion and misinterpretation. The DrinkWise text also promotes a message that the ‘safest option’ is not to drink alcohol which is not consistent with New Zealand Government guidelines, and research shows the message can be Changes to alcohol labelling elements (e.g. potential energy content labelling, or labelling introduced by industry in response to consumer demand e.g. ‘gluten free’ or recycling messages) could compete for space with pregnancy warning labels and may reduce the uptake of the voluntary pregnancy labels. Current situation where some products do not display the pregnancy
misinterpreted by some consumers. Certain groups (such as craft and premium beer producers in Australia) may continue to not use the pregnancy warning labels. warning labels may continue. It is possible that current momentum to adopt voluntary labelling may not be sustained. Current high level of voluntary uptake may be related to industry awareness of current monitoring and evaluation activities. Option 1 b) industry Groups such as DrinkWise or Alcohol Beverages Australia in Australia could introduce a approach for industry to adopt the pregnancy warning labels. In New Zealand, this would likely be the role of industry bodies (who would have to work together), or Responsible Children’s Marketing Initiative (RCMI) and the Quick Service Restaurant Initiative for Responsible Advertising and Marketing to Children (QSRI) from the Australian Food and Grocery Council (AFGC). AFGC manages the RCMI and QSRI in line with the Australian As above. Limited work for Government in applying and enforcing the scheme. Industry may be more proactive in placing warnings on packaging. As Government role is limited in ensuring effective and consistent labelling. Messages that may not be consistent As Not all industry groups or companies may elect to be signatories to such an agreement. regulated
an overarching group such as Cheers. The industry group(s) could develop a code of practice that alcohol producers voluntarily sign up to. Alternatively, Food Standards Australia New Zealand (FSANZ) may also develop a code of practice, as part of its functions. The code of practice would require signatories to commit to presenting pregnancy warning labels on all the packaged alcoholic beverages that they produce. The code of practice would outline the how the pregnancy warning labels would be presented to ensure that the message is clear, consistent with government recommendations, and understood by the target audiences. The code of practice may also encourage signatories to provide other health information on product labels. The industry group that leads the code of practice would be responsible for administering and enforcing the code of practice, Competition and Consumer Commission’s Guidelines for developing effective voluntary industry codes on conduct. This includes regular monitoring of compliance with the initiatives, the effectiveness of the initiatives in achieving their objectives and the commissioning of independent reviews. In New Zealand the Advertising Standards Authority has a Code for Advertising and Promotion of Alcohol, which requires all alcohol advertising and promotion to adhere to the principles and guidelines contained in the Code. The Association of New Zealand Advertisers is responsible for administering the advertising industry’s voluntary system of all alcohol advertisements. Another example is the European Beer Pledge, where members of an association representing European brewers has committed to taking action to improve consumer information by providing, among Reputational benefit to manufacturers who become signatories to the code of practice. with Government guidelines may continue to be used. Current situation where some products do not display the pregnancy warning labels may continue. Unless NZ and Australia industry agree on this approach, it is not a completely joint system for labelling.
the pregnancy health warning labels. products do not display the pregnancy warning labels may continue. Option 2: Mandated through the Australia New Zealand Food Standards Code. The prescribed warning label would be the one shown to be most effective (see section 4) and may include a warning pictogram, or text or both. If this were to be introduced, it would be more efficient and to do so at the same time as any other changes to alcohol labelling. Transition period included to time for industry to adopt new regulations and reduce costs associated with labelling changes. elements of alcohol labels are under Parts 1.2 and 2.7 of the Code, including: alcohol by volume standard drink labelling specific representations about alcoholic beverages (e.g. low alcohol) nutrition information requirements (when a claim is made regarding energy, carbohydrate or gluten). Mandatory labelling could overcome the identified barriers to pregnancy warning labels, and maintain or increase current levels of labelling coverage. The second Australian evaluation reported that both industry and public health sectors support a minimum standard set by government for consistent content, size, and placement to be applied to the pregnancy health warning labels. All consumers of alcohol will be provided with consistent, understandable messages about not drinking alcohol during pregnancy. If this translates Cost to industry for compliance. In particular, the Australian evaluation noted that, for 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. Does not acknowledge strong industry efforts to introduce pregnancy Any new mandatory labelling requirements may have implications. However, there are clear public health reasons for having this labelling, and some countries (such as France) have mandated pregnancy warning labels and pictogram. There could also be allowances made for other countries messaging, e.g. if there is a mandatory warning message
to behaviour change, women choosing not to drink alcohol during pregnancy prevents FASD. More consistent labelling and greater coverage of pregnancy warning labels, including in product categories that are currently identified as having limited use of the voluntary labelling. Reduces the possibility that use of pregnancy warning labels will decrease over time, or be ‘pushed-off’ labels by other labelling initiatives. Many producers are already voluntarily meeting the of providing these warnings (assumes no change to current wording and pictogram warning labels). labelling voluntarily. Even with mandatory labelling, 100% compliance may not be achieved if a robust compliance scheme was not also introduced. in another country, then this is acceptable for the Australia/NZ market. If a mandatory standard is made, the time taken to develop the standard and put it into place may mean that the voluntary efforts disappear in the interim.