Proposed warning statements for substances (eg, allergens) in medicines that may cause undesirable reactions

This should apply to any product that contains aspartame or aspartame-acesulphame salt.

This should apply to products containing aspartame or aspartame-acesulphame salt which both are sources of phenylalanine. Therefore the warning statement should be ie “Contains phenylalanine”.
This will then be consistent with the FSCode Sched 9-2

The list should be extended to include potassium and calcium benzoates

Benzoates Includes: Benzoic acid, calcium benzoate, potassium benzoate and sodium benzoate

'Fish' normally refers to fin fish in general, including freshwater and marine fish. At the current time, because of lack of clarity in the Food Code, molluscs are often included under 'fish' in food labelling (it is likely molluscs will be added as a separate allergen in the Food Code under P1044). Also New Zealand consumers are probably more familiar with hoki, hapuka, salmon, snapper etc than ‘Cod’ or ‘Halibut’.

In the Food Code galactose is only required to be in Nutirtion information panel (NIP) when a lactose claim is made

For consistency with FSCode Std 1.2.3 -4 NZFS recommends
Gluten
Includes:
cereals containing gluten, namely, wheat, rye, barley, oats and spelt and their hybridised strains

The cereal containing gluten should also be declared eg gluten from wheat

The FScode does not include this exemption when lactose is obtained from milk, ie the label does not require the ‘contains milk product’ statement

All milk and milk products should require a statement not just those listed. Perhaps worth clarifying if exhaustive list given.

This should refer to bee pollen?

Is the intention to mean bee pollen is so this should refer to bee pollen?

Unless there a medical reason to include this.

What about ther forms of potassium?

Is there a safety reason for requiring this sweetener to be declared?

If saccharin is included in the list, saccharin should also be included
Ie
Saccharin
Includes:
Saccharin
Saccharin calcium
Saccharin sodium

Unless there is a medical reason to include this.

What about other forms of sodium?

Add other sorbates ie
Sorbic acid and sorbic acid salts
Includes:
Sorbic acid, calcium, sodium, potassium sorbate

What the safety risk is with using this sweetener? It has been evaluated for safety by the WHO/FAO JECFA for use in food.Eg does it interact with one or more medicines?

FSCode (Std 1.1.2-2) sugars are listed as:
(a) monosaccharides and disaccharides; and
(b) otherwise—means any of the following products, derived from any source:
(i) hexose monosaccharides and disaccharides, including dextrose, fructose, sucrose and lactose;
(ii) starch hydrolysate;
(iii) glucose syrups, maltodextrin and similar products;
(iv) products derived at a sugar refinery, including brown sugar and molasses;
(v) icing sugar;
(vi) invert sugar;
(vii) fruit sugar syrup;
but does not include:
(i) malt or malt extracts; or
(ii) sorbitol, mannitol, glycerol, xylitol, polydextrose, isomalt, maltitol, maltitol syrup, erythritol or lactitol.

Agree that honey could also be listed

To be consistent with the FSCode Std 1.2.3-4 the declaration should be for added suplhites in concentrations of 10mg/kg. The list should also include potassium sulphite, and potassium bisulphite. Also it is the practice in New Zealand and Australia to use the “ph” spelling of sulphite and sulphur, hence “sulphur dioxide”, “sodium bisulphite” etc

ie
Sulphites
Includes:
Potassium bisulphite
Potassium metabisulphite
Potassium sulphite
Sodium bisulphite
Sodium metabisulphite
Sodium sulphite
Sulphur dioxide

“For all classifications, including prescription, and all uses with added suplhites in concentrations of 10mg/kg”. (For consistency with FSCode Std 1.2.3-4)

correct spelling to "Sulphites"

Suggest to list the nine tree nuts associated with allergies in NZ and Aust as examples. Ie
Tree nuts and tree nut products
Includes: almond, Brazil nut, cashew, hazelnut, macadamia, pecan, pine nut, pistachio and walnut excluding coconut.

FSANZ’s preliminary view as part of the plain English labelling proposal P1044 to specifically declare each of the nine tree nuts implicated in food allergy. This would enable individuals with allergies only to certain tree nuts to safely choose from a broader range of foods. The approach would also be consistent with the general approach taken by EU, the US and Canada.

It would be worth considering to declare the tree nut concerned. This would enable individuals with allergies only to certain tree nuts to safely choose products with tree nuts they are not allergic to.

It is not clear why some of the substances have been included, noting that the list includes substances which are permitted internationally for use as food additives. These include:
•    colour: tartrazine,
•    intense sweeteners: sucralose, saccharin, (noting that aspartame is required to have the warning about phenylalanine ( this would also apply to aspartame-acesulphame K)),
•    sugar alcohols (due to laxative effects?),
•    preservatives: benzoates, hydroxyl benzoic acids esters, sorbic acid and salts

We note there the aim is to align with similar labelling requirments made by the Australian TGA and that no further information was made available by the TGA during or after their 2014 consultation.

We have noted some inconsistencies in the list and with the requirements under the joint Australia New Zealand Code.