Frequently Asked Questions about the draft food reformulation targets

Public consultation on the draft food reformulation category definitions and targets is currently in progress.

Page last updated: 05 September 2018

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Frequently Asked Questions

The Healthy Food Partnership is a mechanism for government, the public health sector and the food industry to cooperatively tackle obesity, encourage healthy eating and empower food manufacturers to make positive changes.

The Healthy Food Partnership aims to improve the dietary habits of Australians by making healthier food choices easier and more accessible and by raising awareness of better food choices and portion sizes.

Five working groups were established, including the Reformulation Working Group which was tasked with developing food reformulation targets. Reformulation targets are just one component of the Healthy Food Partnership.

Yes, and the Government’s preferred approach is to work collaboratively with industry and actively encourage them to continue to make positive changes.

The previous Food and Health Dialogue achieved significant reductions in sodium across nine food categories. Similarly the Healthy Food Partnership provides a mechanism for Government and industry to work voluntarily together. The commitment made by industry to date, through previous initiatives and in designing the current proposed reformulation program, has proven that this approach is an effective way to improve the Australian food supply. Many manufacturers are already reformulating products – reformulation targets will provide guidance and a nudge to businesses not already participating, while providing clarity about the expected level change.

The Healthy Food Partnership recognises that many companies are already reformulating their products to improve nutritional quality and aims to build on (rather than replicate) these efforts, including through the previous Food and Health Dialogue. It is not the intention of the Healthy Food Partnership to disadvantage companies that are already reformulating, but to recognise and support their efforts to date, and encourage those companies that have yet to engage in reformulation activities to move towards improving the nutritional profile of their products. Targets will create certainty for industry of what they, and their competitors, should be aiming for.

Some members of the Australian Beverages Council have pledged to reduce sugar consumption from certain types of non-alcoholic beverages. As we understand it, this is a sales-weighed grouped portfolio target that (if met) will result in a 10% sugar reduction by 2020 and an additional 10% reduction by 2025 (i.e. 20% reduction in total) – both based on a January 1st 2016 baseline. The Australian Beverages Council has listed ten different methods which individually or cumulatively may be used to meet the 20% target, one of which is product reformulation.

In developing draft targets, the Reformulation Working Group (RWG) identified that, based on the Australian Health Survey (2011-12) ‘soft drinks and energy drinks’ contributed 17% of the population level intake of sugars, based on self-report. In terms of soft drinks and energy drinks, roughly two-thirds of products have sugar levels ≥10g/100 and would be required to reformulate in order to meet the draft target (based on data from FoodTrack considered by the RWG).

The draft reformulation targets for these products indicate the preferred position of the RWG for those products to be reformulated to reduce sugar content. This reformulation may contribute to companies meeting the targets set by the Australian Beverages Council.

Draft reformulation targets were determined by the Partnership’s Reformulation Working Group, based on data, as shown in the flow chart on page 11 of the Rationale. In addition, all food categories which had a reformulation target under the previous Food and Health Dialogue were considered for a Healthy Food Partnership target.

A number of food companies are involved in the Healthy Food Partnership and its working groups, as well as receiving updates through the Community of Interest. Emails have been sent to many of the major manufacturers of products in the food categories identified for draft reformulation targets, inviting them to participate in the consultation process.

Through the consultation period, questions may be sent to the Healthy Food Partnership Secretariat ( and answers will be posted on the website for the information if everyone.

During implementation, companies will be encouraged to sign up via the Healthy Food Partnership website, to make a public commitment to work towards the reformulation targets. This will be supported by awareness raising activities and recognition of companies who have signed up, made significant progress, or achieved the reformulation targets.

It is hoped that companies will reformulate as many of the in-scope products, for each food category, as possible, or to the greatest extent possible towards the target. Individual companies will determine the priority order for their products to be reformulated. From a public health perspective, the Healthy Food Partnership strongly encourages companies to reformulate those products whose combination of sales volume and nutrient profile make them the largest contributors of sodium, sugar, or saturated fat to the diet.

The Food and Health Dialogue sought to engage the largest players (based on market share) to determine and act upon targets for each nominated food category. The Healthy Food Partnership will aim to engage all relevant manufacturers in implementing the targets.

The Reformulation Working Group proposes a four year implementation period for each category, with all targets in place concurrently. Consultation is seeking feedback about this proposal.

It will be up to each individual company to determine how it will reformulate its products within the agreed timeframe. Companies may choose to work towards a target through a single reduction, or through multiple smaller reductions over the implementation timeframe. The implementation period allow time for research, product innovation, labelling changes, product shelf-life and for reformulation to occur in a staggered way to minimise the risk of sudden flavour and/or texture changes.

Companies will be asked to identify through the Healthy Food Partnership website that they are participating in the Partnership Reformulation Program. Companies will be asked to make a report on progress AT two years and AFTER four years of implementation (time period indicatively January 2019 – December 2020; and January 2021 – December 2022). Reports will be treated in the strictest confidence, with aggregated reporting of achievements made public via the Healthy Food Partnership website and de-identified data made available for the preparation of monitoring reports.

Public recognition of participating companies will be provided through media releases, the Healthy Food Partnership website and social media.

'recipe bases' or 'recipe concentrates' such as for flavouring a casserole, meatballs, stroganoff, stir fry; which are not sold as a 'sauce', are out of scope for the draft food reformulation targets. The Reformulation Working Group will consider further in the context of all submissions received how to clarify these definitions in the next stage of work.

These products were not included in the modelling of draft categories. At a broader level, if a dry product requires rehydration (e.g. turn gravy powder into gravy sauce), the target applies to the rehydrated product’s nutrient values.

Two inconsistencies have been identified within the documentation, and corrections published on the website and the consultation hub. These are on pages 39 and 48 of the ‘Rationale Document’ and within the consultation questions.

The proposed target for the Crumbed and Battered Proteins subcategory 1: Meat and poultry, was erroneously listed as 710mg/100g, rather than the CORRECT 450mg/100g. Please base your submissions for this category on 450mg/100g.

The proposed target for the Savoury snacks subcategory 4: Corn snacks was erroneously listed as 500 mg/100g, rather than the CORRECT 360mg/100g. Please base your submissions for this category on 360mg/100g.