Submissions

WACOSS Library

Food PolicySubmissions

Submission into Food Advertising

19 March 2024

Feasibility study on options to limit unhealthy food marketing to children: Policy options for public consultation

Response to the Australian Government Department of Health and Aged Care

Submission overview

In Australia, excess weight in children and adolescents is a significant public health challenge. One in four children aged 2-17 are overweight and one in twelve are obese. The impacts of excess weight can be significant and can result in poorer health and wellbeing, worse school performance, and increased risks of chronic disease in adulthood. Critically, for these children, excess weight is the result of obesogenic environments where the promotion and availability of unhealthy food drives poor diets and higher caloric intake. Considering this, WACOSS strongly supports efforts to change the environments in which we live, work and play to reduce children’s exposure to the power of unhealthy food marketing.

Responses to the consultation questions are provided below.

What is the most appropriate policy objective?

We strongly believe the policy objective should focus on improving diets and reducing the amount of unhealthy marketing children are exposed to. We believe the end goal of any reform should be to improve children’s dietary intake, and that achieving this goal relies on reducing the amount of unhealthy food marketing children are exposed to, and the persuasive content of marketing messages. Improvement in diet must be included as an objective to ensure policy and regulation is designed, and monitored, with this goal in focus.

We support improvement in diet being a medium-term objective of the policy but suggest it may be unlikely to see drastic change within a three to four year period. This outcome requires significant environmental and social change – beyond advertising restriction – as well as relevant support mechanisms to help families develop and maintain new dietary habits. Broader environmental change is particularly important for people living on low incomes, for whom healthy food behaviours are often inaccessible – either due to the high cost of nutritious food items, or limited access to the time, and in some instances the skills, required to purchase, store, and prepare healthy alternatives. Some environmental changes that would improve dietary patterns in this cohort include raising the rate of income support to ensure people can afford to put nutritious food on the table and supporting emergency relief organisations to provide families with healthy food items.

Finally, further work is needed to develop a monitoring framework for both the marketing and dietary objectives of the policy. We recommend this be done in consultation with public health experts. Key monitoring considerations include:

  • Better understanding of children’s dietary intakes will be needed to effectively monitor the effect of any changes. Comprehensive data on children’s dietary intake does not currently exist in Australia.
  • Improvement in diet should be defined by reference to the Australian Dietary Guidelines and should focus on decreasing the consumption of discretionary foods and foods high in added sugars/sodium and/or saturated fat.
  • Monitoring should consider Australian children both as a whole and in subgroups, such as children of different ages, Aboriginal and Torres Strait Islander children, children in low socio-economic groups, children with disabilities, children from cultural and linguistically diverse backgrounds and children in rural and remote areas.

Which policy approach has the greatest chance of achieving the policy objective(s)?

We strongly recommend, and support, a mandatory legislative approach. This approach is essential to ensure effective implementation of the reform.

We strongly oppose retaining the status quo and self-regulation. Allowing the processed food and advertising industries to set their own rules does not effectively protect children from exposure to unhealthy food marketing, as inevitably profits are prioritised over the health and wellbeing of our community. As set out in the consultation paper, the ineffective nature of self-regulation is supported by evidence from around the world and demonstrated by the weak rules that industry currently sets and monitors in Australia.

Which age definition is most appropriate?

We see it appropriate to define a child as under 18 years. We note that as food policy cuts across multiple portfolios a definition that aligns with other policy areas, such as health and education, is likely to achieve better and more integrated outcomes. A definition that includes children under 18 years aligns with broader Australian Government policies regulating and protecting children, including the Australian Government National Action Plan for the Health of Children and Young People. We also highlight the Australian Government’s recent response to the Privacy Act Review Report, where it said it would apply protections to all children under 18 years of age.

Additionally, as the consultation paper notes, children of all ages are negatively influenced by unhealthy food marketing. Children aged 14-18 years consume the highest amount of unhealthy food and increasingly use and engage more with screen-based media, with engagement increasing as children get older. High rates of screen-based media engagement increase children’s exposure to marketing of unhealthy foods and embeds their poor dietary habits. Resultantly, it is critical to include all children under the age of 18 in the policy. Any approach that does not do so, is not fit for purpose and is unlikely to achieve the policy objective.

Which food classification approach has the greatest chance of achieving the policy objective(s)?

We support a food classification approach that includes all marketing of food brands strongly associated with unhealthy food products.

As explored in the discussion paper, if brand marketing is not included, companies that mostly sell unhealthy food will simply replace their unhealthy food advertising with advertising that prominently features their brand either alone or placed with a healthier food in their product line.

Resultantly, a lesser approach does not provide sufficient protections and will see children exposed to harmful marketing. For example, an approach that only includes unhealthy food will allow major fast-food brands, sugary drink companies, and confectionery companies to advertise in children’s social media feeds, on billboards and in prime-time television so long as the ads feature only the brand and not a product. Similarly, options that allow only healthy products will allow fast food chains to advertise their brand to children anywhere so long as a healthy product is in the advertisement – a product that the child may be very unlikely to purchase and doesn’t reflect the brand’s top selling items.

To support implementation, an appropriate definition of ‘brands strongly associated with unhealthy food’ will need to be developed. We recommend this definition is developed in consultation with public health experts and includes careful consideration of how it applies in practice to a range of brands. The brands of highest concern are well known brands that are frequent advertisers, are mostly known for unhealthy foods, and are likely to appeal to children.

Which food classification system do you prefer?

We support a definition of unhealthy food that:

  • reflects the Australian Dietary Guidelines and best captures foods that are discretionary and/or should be limited in accordance with the guidelines;
  • is category based, with clear categories of discretionary food that cannot be advertised at all, including sugary drinks, confectionery, desserts and ice‑creams, sweet snacks, drinks sweetened with non-nutritive sweeteners, fast food meals such as burgers, chips, pizzas, fried foods, pies, cakes and others;
  • applies appropriate nutrient thresholds to some food categories that can include healthy and unhealthy products, such as breakfast cereals and yoghurts; and
  • applies effectively to fast food and meals as well as packaged food.

To achieve this, the COAG National interim guide to reduce children’s exposure to unhealthy food and drink promotion (COAG guide) could be used as a starting point and expanded and refined in line with the above criteria. The Australian Government might also refer to other existing category and nutrient threshold-based models, such as the World Health Organization nutrient profile models, including one tailored to the Western Pacific Region.

Although the COAG guide is a good starting point, we do not support its use without further improvement. This is because it does not currently include several categories of unhealthy products, including those that are commonly marketed to children, for example high sugar breakfast cereals.

We strongly oppose the use of the Health Star Rating or the FSANZ Nutrient Profiling Scoring Criteria. These have not been designed for the proposed policy purpose and are unlikely to effectively align with the dietary guidelines, particularly as they permit some foods high in sugar/salt/saturated fat to achieve a high rating. Evidence shows these models are more likely than other models to permit foods to be marketed. For further information see: Watson WL, Khor PY, Hughes C. Defining unhealthy food for regulating marketing to children—What are Australia’s options? Nutrition & Dietetics. 2021;1–9, and Watson WL, Richmond K, Hughes C. Comparison of nutrition profiling models for food marketing regulation. Nutrition & Dietetics. 2023; 80(4): 372-376

Which option for restricting TV food advertising has the greatest chance of achieving the policy objective(s)?

We strongly support restricting all unhealthy food marketing on all broadcast media between 5.30am and 11pm. As outlined in the consultation paper, evidence shows the highest numbers of children watch TV during these hours, and the policy should actively protect children during peak times.

It is important to ensure that regulation is comprehensive, future proofed and extends to other platforms where there is evidence of exposure and impact. This includes platforms such as radio, cinema, streaming services, subscription and catch-up TV, movie services, podcasts, and music streaming services. Any regulation should be future proofed to ensure coverage of any developing, or emerging, digital technologies.

Which option for restricting online food marketing has the greatest change of achieving the policy objective(s)?

We support restricting all paid and non-paid unhealthy food marketing on online media. As the consultation paper outlines, children spend significant amounts of time online where they are exposed to, and negatively influenced by, large amounts of unhealthy food marketing.

Online or digital media is an important part of children’s lives and plays a significant role in their education, access to information, communication, and leisure time. As such, we do not support permission of paid or unpaid advertising of unhealthy food online, and instead recommend a broad restriction on all digital marking of unhealthy food.

Which option for restricting outdoor food advertising had the greatest change of achieving the policy objective(s)?

We support restricting unhealthy food marketing on all outdoor media and recommend this be broadly defined to include all public spaces and events. This level of restriction ensures children can go about their daily lives, such as traveling to and from school or sport, without being exposed to unhealthy food marketing.

This policy should include all public outdoor advertising, including public transport vehicles, public infrastructure, education, healthcare, sporting and recreation facilities, cultural institutions, sporting, cultural and music events, and shopping centres. The policy should also extend to marketing on retail outlets and restaurants that can be seen from the street.

Do you support restricting marketing on food packaging?

We strongly support the restriction of child-directed marketing on unhealthy food packaging.

As outlined in the consultation paper, product packaging is a common and influential form of marketing to children, with cartoon characters and other common features having a strong appeal to children. The policy must ensure that unhealthy food products cannot use packaging that includes features likely to appeal to children, including images, activities, competitions, promotions, characters, or prizes.

Do you support restricting food sponsorship of sports, arts, and cultural events?

We strongly support restricting unhealthy food sponsorship of sports, arts and cultural events. Children should be able to play sport, watch their favourite sports stars, and go to cultural events without being exposed to the risks of unhealthy food marketing.

As outlined in the consultation paper, Australian children have significant engagement with sport as both players and as spectators. Unhealthy food sponsorship in sport is common at the community level and extensive at the professional level. To reduce the risk to children engaged in sport, this policy should stop sponsorship by brands strongly associated with unhealthy food at all levels.

We recognise the importance of children’s and community sport to population health, and the challenges of securing funding to community sport organisations. While, as the consultation paper notes, sponsorship income is not a major proportion of revenue for community sport organisations, we encourage government to consider and implement alternative funding proposals. In doing so, government must be sure that any marketing opportunities are not replaced by other harmful content, such as gambling.

The policy must also extend beyond to arts and cultural events to ensure the policy is future proofed and stop expansion of unhealthy food sponsorship into new areas.

Which options for restricting retail marking has the greatest chance of achieving the policy objective(s)?

We support the restriction of both placement and price-based promotion of unhealthy food within in-store and online retail environments. We recommend the introduction of:

  • restrictions to ensure that retailers cannot place unhealthy food in prominent locations in store, such as near the point of sale (checkouts) and at the ends of aisles, and online, such as at the top of search results or prominently featured on a webpage or mobile app; and
  • restrictions on price promotions designed to encourage purchasing of unhealthy foods. This should include restrictions on temporary price discounts and multibuys (eg. Buy 2 for $5) for unhealthy foods.

Any restrictions on retail marketing must apply equally to the in-store and online environments, including both apps and webpages.

Restrictions on price promotions are reflected in the National Obesity Strategy and restricted promotion of unhealthy food and drinks at the point of sale and end of aisle in prominent food retail environments is included in the National Preventive Health Strategy. Evidence shows that unhealthy food and drinks are more likely to be price promoted than healthier foods, with larger discounts applied, and that price promotions lead people to buy more unhealthy food than they usually would, and do not save consumers money overall (See the Obesity Evidence Hub page on unhealthy food price promotions for more detail on the evidence).

This policy could also be expanded to ensure it is future-proofed and captures all forms of unhealthy food marketing within in-store and online retail environments, such as on-shelf promotions, interactive displays and promotions within branded apps.

Although this policy focuses on unhealthy food, it is critically important that the Australian Government also introduces policies to increase affordability and accessibility of healthy foods across Australia, with particular focus on priority populations, including Aboriginal and Torres Strait Islander people, people living in low socio-economic conditions, and people living in rural and remote areas. We recognise that many families, particularly those living on low incomes, rely on price promotions to put food on their table. To ensure all families can access healthy foods, any restriction of price promotions must be coupled with strategies to ensure healthy alternatives are affordable. Additionally, changes must be supported by health literacy education that ensures families have the skills, and are empowered to, purchase, store, prepare and cook healthy alternatives.

Do you support restricting unhealthy food marketing ‘directed’ to children, in addition to the aforementioned policy options?

We believe it is important to include a specific restriction on marketing directed to children, in addition to other setting and media-based restrictions, to ensure there are no unintended or accidental gaps in the policy. This must include:

  • marketing that uses any feature or technique that is likely to appeal to children including images, activities, characters and prizes, including on product packaging.
  • marketing in any physical place or form of media that is primarily for children.
  • marketing sent or displayed directly to a child by email, text message or in any other way.

We support this only as a restriction in addition to other policy options. We do not support this option as a stand-alone policy.

Which media settings do you see as a top priority action?

Please rank in order from 1 (highest priority) to 7 (lowest priority).

  1. Online
  2. Broadcast media (TV, radio, cinema, podcasts, streaming services)
  3. Sponsorship
  4. Retail
  5. Outdoor
  6. Marketing ‘directed’ to children
  7. Food packaging

We strongly support a comprehensive policy that combines all elements recommended in our response together to effectively protect children from exposure to unhealthy food marketing. It is important to consider the likely shift in marketing practices that will occur if restrictions are introduced in one or two areas and not in others.

While priority should be given to the forms of marketing that children are most exposed to, and impacted by, we strongly recommend a comprehensive package of restrictions that are evidence-based and future-proofed. Our prioritisation is on the assumption that the policy options we have supported will be adopted in each media/setting.

Is there any other information you would like to share to inform the consultation process?

As the consultation paper outlines, there is clear evidence demonstrating that Australian children are exposed to high amounts of unhealthy food marketing as they go about their daily lives. This marketing negatively influences children’s dietary habits, impacting the food preferences, choices, and consumption. Comprehensive regulation to protect children from unhealthy food marketing is an important policy in creating a healthier food environment, supporting Australian children to grow up in a world that promotes their health and puts it above the processed food industry’s profits.

Regulation to protect children from unhealthy food marketing should form part of a comprehensive set of actions to improve diets and reduce overweight and obesity in Australia, guided by the National Preventive Health Strategy and the National Obesity Strategy.

Cost effectiveness

As the consultation paper outlines, there is clear evidence that policies to protect children from unhealthy food marketing are cost-effective. This outcome can be expected because of the significant costs linked to overweight and obesity, and diet‑related non-communicable disease incurred by both governments and individuals.

Effect on health equity

Policies to protect children from unhealthy food marketing are also highly likely to have a positive impact on health equity. As the consultation paper outlines, international evidence suggests that children of ethnic minority and lower socio‑economic position are at higher risk of exposure to unhealthy food marketing, and the impact of the marketing is likely to be higher for these children. This suggests policies to protect children from unhealthy food marketing are likely to have a positive impact on health equity. This is supported by Australian research finding that restrictions on food marketing to children on television were likely to have greater health benefits and greater health care cost savings for children of lower socio-economic position than for those of higher socio-economic position (Ref: Brown V, Ananthapavan J, Veerman L, Sacks G, Lal A, Peeters A, Backholer K, Moodie M. The Potential Cost-Effectiveness and Equity Impacts of Restricting Television Advertising of Unhealthy Food and Beverages to Australian Children. Nutrients. 2018 May 15;10(5):622. See also discussion about this in WHO Guideline: Policies to protect children from the harmful impact of food marketing: WHO guideline. Geneva: World Health Organization; 2023. Licence: CC BY-NC-SA 3.0 IGO.)

We understand that further analysis on the cost-effectiveness and health equity impacts of policy options will be conducted as part of this feasibility study and we strongly support this inclusion, and the inclusion of leaders, experts and children from priority cohorts.

Monitoring, evaluation and enforcement

We support the development of a comprehensive monitoring and evaluation framework as part of the policy design, and this should be subject to further consultation with public health and consumer organisations. The framework must be government led and the food and advertising industries should have no role in monitoring and evaluation, but should be required to provide data to inform it if required. Monitoring and evaluation must aim to assess implementation, understand impact, and consider improvements.

We also recommend the development of a strong enforcement framework.

Policy development and conflict of interest

Further policy development will be needed to translate these policy options into comprehensive regulation. This should be subject to further consultation with public health and consumer organisations. We recommend the development of a stakeholder engagement and conflict of interest policy to ensure that the detail of policy and legislation is developed without inappropriate influence from the processed food, advertising and related industries.

 

 

For further enquiries on this submission please contact Emily Hull, Senior Policy and Projects Officer, [email protected], 08 6381 5300.

Food PolicySubmissions

Fair Food WA joint Submission on Supermarket Prices

14 February 2024

Since the pandemic, the focus on major supermarkets and their relationship with consumers has gained significant attention. Australians rely heavily on supermarkets to supply them with food, groceries and essential items, making consumers vulnerable to their conduct. The current cost of living crisis has further highlighted this dependency and reignited concerns about supermarket pricing, which has been the subject of past inquires. We welcome Prime Minister Albanese’s announcement to the National Press Club on 25 January that the Australian Competition and Consumer Commission will lead a 12-month inquiry into supermarket prices. This is an important step in ensuring that the findings of the inquiry will lead to lasting benefits for Australian consumers.

Our submission to this Committee explores the impact of supermarket prices on Australian households, particularly those on the lowest incomes. We encourage the Committee to consider the consequences for consumers living with financial hardship and how supermarket pricing can contribute to increased food insecurity and overall disadvantage.

Recommendations

  • Ensure the recommendations of this inquiry consider food pricing in regional and remote areas.
  • Establish a routine mechanism for monitoring food and grocery prices nation-wide and make this data publicly available.
  • Empower a single department to oversee food related policy and ensure a coordinated response to issues impacting Australia’s food system.
  • Consider the effects of climate change on Australia’s food system and develop strategies to minimise the impact of subsequent issues such as high food and grocery prices.

Background

Fair Food WA (FFWA) and the WA Council of Social Service (WACOSS), welcome the opportunity to submit a response to the Senate Select Committee on Supermarket Prices.

FFWA is a collaborative group working together to address food insecurity in Western Australia (WA). Our membership is comprised of not-for-profit organisations, research institutes, advocacy groups, relevant government departments, and peak bodies that are committed to improving food security for all or are recognised as contributing to the food relief sector. This work is funded by Lotterywest and secretariat support is provided by WACOSS.

WACOSS is the peak body for the community services sector in Western Australia and works to create an inclusive, just and equitable society. We advocate for social and economic change to improve the wellbeing of Western Australians, and to strengthen the community services sector that supports them. WACOSS is part of a network consisting of National, State and Territory Councils of Social Service, who advance the interests of people on low incomes and those made vulnerable by the systems that have been put in place.

Last year, food insecurity impacted more than 388,000 Western Australian households.  Fair Food WA (FFWA) member organisations have reported the growing demand for food relief, including from people who are employed but are unable to keep up with the rising cost of living. Disaster events have highlighted the precarity of our food system for people living in regional and remote areas, and the latest state inquiry on food has revealed the devastating impact of hunger on children and young people. For those on the lowest incomes, food insecurity is likely to be entrenched and is the driver of a range of unacceptable health and social outcomes. Now more than ever, we need support from all sectors to tackle this complex problem.

This submission explores the link between the Terms of Reference and how supermarket prices contribute to food insecurity. FFWA defines food insecurity as the reduced or unreliable access to nutritionally appropriate or safe foods required for good health and wellbeing. Food insecurity is underpinned by four pillars: availability, access, utilisation and stability.  Of these, food access recognises that people should have the necessary economic and physical resources to obtain foods that meet their nutritional requirements. Food relief or food assistance, is the provision of low or no-cost food to people in need. Food relief may be provided to people as a one-off, or on an ongoing basis when the experience of food insecurity is entrenched. Emergency food may also be provided to people or communities following a disaster event. Food relief is delivered by not-for-profit emergency relief organisations in the community service sector and may include pre-prepared meals, food hampers and community meals.

Rising supermarket profits and the large increase in price of essential items

How the cost of food contributes to food insecurity

The high cost of supermarket items is contributing to financial hardship and putting many Australian households at risk of food insecurity. The WACOSS Cost of Living Report (2023), found that when coupled with increasing costs of living, low wage growth means many people, particularly those on minimum wage or government supports, are struggling to cover the cost of essentials.[1] The Australian Bureau of Statistics’ June Quarter data revealed that food prices have also risen 7.5 per cent on the previous year.[2]

This is having a significant impact on household food security. Foodbank Australia reported that in the past year, 3.7 million Australian households (36 per cent) experienced moderate to severe food insecurity.[3] Of these, 79 per cent reported that cost of living expenses (such as housing and food) was the primary reason for food insecurity.

Emergency relief organisations in Western Australia have also highlighted the cost of living impacts on people accessing their services. While emergency relief is typically provided to people on the lowest incomes, providers are also seeing a growing number of requests for assistance from working and middle-income households. In October 2023, the Financial Wellbeing Collective’s Emergency Relief and Food Access Service received 3,165 calls for assistance, compared to 2,275 calls in the same month in the previous year.

Local agencies are also being inundated with requests for assistance, with one service seeing a 30 per cent increase in demand. The St Vincent de Paul emergency relief call centre is receiving between 4,000 and 6,500 calls per month, which is around 2000 more calls than the monthly average in 2022. We continue to hear anecdotes of people queueing for assistance and providers being unable to meet this demand, meaning they have to turn away those in crisis.

WACOSS operates a free online directory of community service providers for people looking for assistance in WA, called WAConnect. The directory contains real time search results of emergency and community relief providers, including food relief, financial counsellors, emergency accommodation and other services. From January to October 2023, the directory saw 303,116 searches for services, from 55,330 people. Compared to the same period last year, the number of users increased by 18 per cent, the number of visits to the directory increased by 18 per cent, and the number of searches for services increased by 15 per cent (equivalent to 40,116 more searches for services). Food relief services were the most searched services during this period, totalling 31 per cent of all searches (94, 150 searches).

Food pricing in regional and remote areas

Food insecurity increases with remoteness in Australia,[4] with people living in remote communities experiencing the highest food prices across the country. The National Indigenous Australians Agency found that residents of remote communities pay, on average, 39 per cent more for supermarket supplies than those in capital cities.[5] It is expected that this disparity has only worsened from the time of analysis.

People living in remote communities are often limited to a single store for their food purchases,[6] meaning that they are unable to respond to high prices by shopping elsewhere and are particularly vulnerable to disruptions in supply. As such, the Australian Government agreed to consider the House of Representatives Standing Committee on Indigenous Affairs, recommendation for a real-time price monitoring and disclosure system across all remote community stores to monitor information about changes in price and patterns of consumption and supply.[7]

Given that people in regional and remote parts of the country already experience much higher supermarket prices, the Committee should consider how food prices impact people outside of capital cities and explore recommendations that reduce the impact of high food prices on people in regional and remote areas.

Recommendation: Ensure the recommendations of this inquiry consider food pricing in regional and remote areas.

Monitoring food and grocery prices

There is currently no routine system to monitor the cost of food and grocery items in Supermarkets across Australia. Growing inflation has contributed to higher food prices for consumers,[8] whilst global events, supply chain restrictions, weather conditions and climate related shocks, can also contribute to changes in food prices that are difficult to measure.[9]

A 2016 review of Australian food price and affordability monitoring tools, protocols and methods, found 59 instances of surveys on healthy food pricing.[10] Whilst these methods provided a snapshot of food prices at the time, the food pricing assessment methods lack comparability and none have been applied on a national scale.

Establishing a routine system to monitor the cost of food and grocery items across the country will enable transparent access to data including information about the farm-gate prices, wholesale prices and those set by supermarket retailers. This is critical to ensuring that food system policy minimises the risk of unequal market concentration.

Recommendation: Establish a routine mechanism for monitoring food and grocery prices nation-wide and make this data publicly available.

Improving food system policy responses

Australia has an opportunity to strengthen outcomes for our food system by coordinating policy responses across government departments. Successive governments have demonstrated an ongoing interest in food related issues but have taken a siloed approach to policy making.

Australia is a signatory to the International Covenant on Economic, Social and Cultural Rights (1975) and as such, recognises the right to an adequate standard of living, including food, water and housing (Article 11).[11] Article 11 states that signatories must take the appropriate steps to ensure the right to be free from hunger. It is therefore expected that all laws, policies and action plans led by the Australian Government will uphold the standards and principles related to the right to food.

Food policy responses are led by multiple government departments and have been the focus of several recent inquiries. These include the Inquiry into Food Security in Australia (2022), Select Committee on Cost of Living (2023), Inquiry into Food Pricing and Food Security in Remote Indigenous Communities (2020), Food and Grocery Code of Conduct Review (2023-2024) and of a similar nature, the Inquiry into the Competitiveness of Retail Prices for Standard Groceries (2008). Research into Australia’s food system found that 11 government departments contribute to National food policy, each focused on individual aspects of the food system. Whilst these activities demonstrate the importance of addressing food related issues, the inability to establish cross-sector strategies does little to address the underlying causes of the issue and is likely to contribute to flow on effects to other parts of the food system.

Established in response to the COVID-19 pandemic, the Supermarket Taskforce demonstrated the value of a collaborative approach to issues impacting the food system. The Taskforce became a mechanism for supporting industry cooperation with the aims of stabilising consumer confidence, maintaining equitable access to food, and minimising the negative impacts of the pandemic on the supermarket industry and consumers. Membership included government agencies, private sector entities, and community relief organisations. The Taskforce was able to achieve several positive outcomes, such as imposing industry limits on items subject to excess demand, supporting the supply of certain goods to regional and remote Australia, and establishing a remote food security working group. Responses such as the interagency taskforce can achieve shared outcomes for issues of a national scale if they have a clearly defined purpose that is integrated within a systems focused strategy. FFWA propose that the Committee investigate the establishment of a single agency to coordinate food system policy in Australia. The department would be responsible for overseeing the integration of a national food system framework that achieves positive outcomes for producers, suppliers, retailers and consumers and can explore issues such as supermarket pricing within the context of the National food system.

Recommendation: Empower a single department to oversee food related policy and ensure a coordinated response to issues impacting Australia’s food system.

Other related matters

 How climate impacts the food system

Every segment of Australia’s food system is vulnerable to the impacts of climate change. Starting with production, the changing climate is impacting the food grown on farms across Australia. Weather conditions such as high temperatures or decreased rainfall, create seasonal variance and can hinder crop growth and overall yield.[12] For the livestock industry, weather affects forage growth and the health of livestock, exposing them to heat stress, parasites and disease.[13]

Along the supply chain, food transport is highly vulnerable to disruptions. This may be caused by the breakdown of physical infrastructure following an extreme weather event, or where cold storage refrigeration is unavailable or unsuitable in high temperatures.[14]

There is also a growing body of research exploring the impact of climate change on pest control, and how the nutritional value of crops is being compromised by rising temperatures. In addition to the social and health impacts of food scarcity, declining food availability will result in consumers having to pay more for food and groceries at the supermarket checkout.[15]

The IPCC has concluded that the likelihood of severe weather and climate extreme events is increasing. This is exposing populations to reduced food security and affected water security.[16] Planning for the inevitable impact of climate change on our food system is a necessary step to address the risk of rising food and grocery prices.

Recommendation: Consider the effects of climate change on Australia’s food system and develop strategies to minimise the impact of subsequent issues such as high food and grocery prices.

The relationship between emergency relief organisations and major supermarkets

Emergency relief organisations across Australia work closely with major supermarkets to support people experiencing food insecurity. Of the three major food distribution organisations in Western Australia, Woolworths partners with Ozharvest whilst Coles holds partnerships with Secondbite and Foodbank (who also receive donations from Aldi, Costco and Woolworths Nationally). Through these partnerships, major supermarkets reduce their food waste and donate surplus food and essential items to charity food organisations to distribute to community partners. Whilst these partnerships are vital to the impact of the food relief sector, emergency relief providers supporting people in financial hardship remain subject to high supermarket prices in other ways.

Emergency relief organisations provide food and material assistance to people in financial hardship. To provide flexible assistance that meets the needs of community members, providers will offer different types of assistance. Emergency relief organisations often purchase large quantities of staple products that are used to cook pre-prepared meals or are provided directly to their clients. Some agencies will also purchase supermarket gift cards, giving clients the choice to select the required food and grocery items direct from supermarket shelves. Whilst Coles offer not-for-profit organisations a 5 per cent discount on bulk orders of gift cards through their business platform, there are otherwise no discounts available to emergency relief organisations to reduce the cost of goods that are passed onto the most vulnerable people in the community.

In Western Australia, there are more than 300 agencies providing emergency relief assistance, many of which are volunteer run and do not have the resources to establish food donation pathways or ongoing partnerships with major supermarkets. With a growing number of Australians relying on the support of emergency relief organisations, the high cost of supermarket items is straining already insufficient emergency relief funding and limiting the amount of support that can be provided by relief agencies to people in need.

FairFood WA member organisations

  • Curtin University Public Health Advocacy Institute
  • Foodbank WA
  • Food Community Project (Edith Cowan University)
  • Margaret Court Community Outreach
  • Ozharvest WA
  • Secondbite WA
  • St Vincent de Paul Society WA
  • The Salvation Army WA
  • WA Local Government Association
  • Western Australian Council of Social Service

For more information about this submission, contact Ashleigh Gregory, Community Relief and Resilience Coordinator, [email protected], 08 6381 5300.

References

[1] Hansen, G. & Hull, E. (2023). Cost of Living 2023 Report. Western Australian Council of Social Service.

[2] Australian Bureau of Statistics. (2023). Consumer Price Index -Australia (September Quarter 2023).

[3] Foodbank Australia (2023). 2023 Foodbank Hunger Report.

[4] Landrigan, T., Kerr, D., Dhaliwal S., & Pollard C. (2018). Protocol for the Development of a Food Stress Index to Identify Households Most at Risk of Food Insecurity in Western Australia. International Journal of Environmental Research and Public Health,16(1), 79.

[5] House of Representatives Standing Committee on Indigenous Affairs. (2020). Report on food pricing and food security in remote Indigenous Communities.

[6] Ibid.

[7] Ibid.

[8] Australian Bureau of Statistics. (2023). Consumer Price Index, Australia (September Quarter 2023).

[9] The World Bank. (2024). Food Security Update. Global Food and Nutrition Security Dashboard.

[10] Lewis, M. & Lee, A. (2016). Costing ‘healthy’ food baskets in Australia – a systematic review of food price and affordability monitoring tools, protocols and methods. Public Health Nutrition, 19 (16), 2872-2886.

[11] Australian Human Rights Commission. International Covenant on Economic, Social and Cultural Rights.

[12] Department of Primary Industries and Regional Development. (2020). How wheat yields are influenced by climate change in Western Australia. (Article)

[13] Department of Primary Industries and Regional Development. (2022). Climate change and broadacre livestock production in Western Australia. (Article)

[14]   Farmers for Climate Action. (2022). Fork in the Road: Impacts of Climate Change on our Food Supply. (Report).

[15] Department of Foreign Affairs and Trade. (2024). Improving food and water security. Online.

[16] IPCC, 2023: Summary for Policymakers. In: Climate Change 2023: Synthesis Report. Contribution of Working Groups I, II and III to the Sixth Assessment Report of the Intergovernmental Panel on Climate Change.

 

Submissions

Submission on the ATCO Gas access arrangement

28 November 2023

Access Arrangement for the Mid-West and South-West Gas Distribution System

The Western Australian Council of Social Service (WACOSS) welcomes the opportunity to make a submission to the Economic Regulation Authority on ATCO Gas’s proposed revisions to the Access Arrangement for the Mid-West and South-West Gas Distribution System (AA6).

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PublicationsSubmissions

A Brighter Future – Stronger communities across a vast state: State Budget Submission 2024-2025

27 October 2023

Foreword

Many Western Australian households are facing hard times, unsure how they will see their way through the next year or two. They are worried about being able to provide for their loved-ones most basic needs and scared that no matter how hard they work and how carefully they scrimp and save, they may fall behind their financial commitments and risk losing everything.

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PublicationsSubmissions

State Budget Submission Summary 2024-2025

27 October 2023

Our State Budget Submission analysis and recommendations address gaps in services, identify supports that need to be bolstered, and charts the systemic changes required for a strong and fair Western Australia.  (more…)

Submissions

Gas Compendium Submission

28 September 2023

WACOSS welcomes the opportunity to make a submission to the Economic Regulation Authority on the draft decision for the 2023 Review of the Gas Customer Licence Obligations (Compendium). (more…)

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