For those following the Definitions of Meat Senate inquiry with interest there are now well over 100 submissions published on the inquiry website.
The deadline to lodge public submissions has now closed and the committee is still uploading submissions that have been received. As of this afternoon some 125 submissions have now appeared, and more are expected to added this week, which all be viewed at this link.
For those without the time or inclination to read through them all – and it’s hard to imagine there are too many out there who do – we have attempted to distill down some of the key arguments commonly appearing in submissions on either side of the debate.
That is, the question of whether Australian food labelling regulations should allow meat descriptors to be used on plant-based protein products.
At some point in coming months the Rural and Regional Affairs and Transport Senate Committee will start holding regional public hearings in which stakeholders from either side of the issue will be invited to give face-to-face evidence (or appear via video depending on how COVID pans out) to the inquiry, and take questions from Senators.
We haven’t quite been able to reach through every submission ourselves yet but have considered a large number to provide a summary of some of the key arguments below. If you feel we’ve missed an important point let us know in the comment box below.
Meat sector: “Labelling is in dire need of tougher regulation”
Meat industry submissions draw strongly on the point that meat is widely trusted, valued and enjoyed by consumers, is seen as healthy, nutritional and natural, is underpinned by decades of investment and high production standards by producers and industry stakeholders. Manufacturers of non-meat alternatives are seen as taking advantage of food labelling loopholes and using meat descriptors and livestock images to capitalise on the valuable reputation and consumer standing of meat to market their own processed product.
It’s all about truth in labelling
A common theme of meat industry submissions is that this is simply a truth in labelling issue, and tougher regulation is needed to protect consumers and industries from food manufacturers trying to gain market share through imitation.
The Australian Meat Industry Council outlines the case in an extensive 27 page submission: “Manufactured plant protein (MPP) products that seek to artificially mimic natural red meat in appearance, taste, and/or texture must be expressly prevented from misappropriating meat category branding, including meat terminology and livestock images, which have been established through significant red meat and livestock industry levy investment over many decades.
Economist and former long-serving senior executive at Meat & Livestock Australia, Dr Peter Barnard, notes that the Food Standards Code adopts the commonly understood meaning of meat, defining it as “the whole or part of the carcass of any of the following animals, if slaughtered other than in a wild state: (i) buffalo, camel, cattle, deer, goat, hare, pig, poultry, rabbit or sheep; (ii) any other animal permitted for human consumption under a law of a State, Territory or New Zealand”.
“Plant-based products labelled as “meat” do not conform to this definition. They are masquerading as something that they are not in order to deceive consumers and attract sales,” Dr Barnard said.
Manufacturers of margarine are not allowed to call their product butter, Cunningham cattle Company noted, while polyester can’t be sold as wool or cotton even if it feels and looks like it, Rangleland Quality Meats points out.
“Consumers must be properly informed about what they are buying,” said the Livestock SA submission. “This means accurate and honest product labelling, particularly when plant-based producers are using comparative advertising for their plant-based products and make claims that they have the same health or protein benefits over red meat.”
The dairy sector was among the first to experience issues with non-dairy products labelling as dairy.
“The term ‘milk’, historically associated with a fresh and nutritious dairy product, is frequently misused to promote a wide range of new plant- and nut based drinks that have no dairy milk content.. which misleads consumers and falsely share the accomplishments of legitimate dairy products,” Dairy Connect wrote in its submission.
“Like the meat industry, labelling within this sector is in dire need of tougher regulation.”
Alternative proteins seeking to capitalise on value proposition built by years of investment in meat
AMIC’s submission estimated that around $7 billion in industry levy funds from producers and processors have been invested in developing and marketing Australia’s red meat category brands over a 25-year period.
The value proposition of Australian red meat as a safe, nutritious and healthy food has been hard won over decades by millions of dollars of investment by producers and members of the supply chain in world class industry systems, wrote Jim’s Jerky CEO and former Cattle Council national rising champion Emily Pullen.
Some alternative meat companies and brands are intentionally relying on misleading labelling and packaging to take advantage of a value proposition that does not belong to their products, Ms Pullen said.
“As the producer of a consumer-facing, branded product, I know our packs are the window to our consumers. Producers of manufactured plant proteins also know this. Studies show that consumers make a purchasing decision in just 2.6 (3) seconds in the grocery aisle. In those few beats, consumers use pack design, imagery, and prominent wording to ascertain what it is that they are purchasing. If a consumer needs to spend longer really reading a package to locate a qualifying statement regarding the actual contents of that pack, then that packaging is inherently misleading – and designed to be so.”
“Let common sense prevail – meat is meat!”
“I would implore the inquiry to let common sense prevail – meat is meat!” wrote agricultural Consultant Simon Winter.
Consumers being misled and confused
Dr Peter Barnard said evidence exists both in Australia and overseas that consumers are being confused. In the United States a study by the National Cattlemen’s Beef Association (NCBA) showed that less than half of 1,800 consumers surveyed understood that “plant-based beef” was intended to describe an entirely vegetarian or vegan food product.
Similarly, in Australia research by Pollinate of ,000 consumers showed that over 60 percent of those surveyed mistook at least one plant-based product as containing animal meat. One occasion even I was confused and unintentionally purchased a product that was not real meat”.
A study commonly pointed to by the plant-based sector to demonstrate that there is no confusion at consumer level, conducted by Life Health Foods and Food Frontier, still showed that 9pc of Australian consumers had purchased a plant-based meat product they did not intend to purchase, some meat sector submissions pointed out.
Tougher labelling laws are needed to protect consumers from being misled into unintentionally purchasing an inferior product made to sound or look like real meat, AMIC’s submission recommends.
“A strengthening of Australia’s regulatory and enforcement framework is urgently required to protect the past, current and future industry investment into meat category branding. A more stringent regulatory and enforcement framework, coordinated between federal and state regulators, with mandatory protections for traditional meat terminology and livestock images should be prescribed.”
Meat is a natural product, alternative proteins ultra-processed
The AMIC submission said manufactured protein products are ultra-processed products containing numerous chemical additives, and, due to its composition and heavy processing, should be considered in the category of “a discretionary food”.
“There is now substantial and increasing evidence that ultra-processed foods are deleterious for health,” Dr Peter Barnard wrote. “Systematic reviews and meta-analyses show associations between ultra-processed food intake and increased risk of several chronic conditions, especially obesity and cardiometabolic outcomes.”
Cunningham Cattle Company said plant based manufactured products contain a wide variety of chemicals and ingredients, and by using the words ‘meat’ or ‘beef’ in their marketing material they are surreptitiously claiming a chemical free product.
Prominent meat exporter Richard Rains wrote that it was disappointing that plant-based manufacturers “have to denigrate real meat in order to promote their own. If it was as good that they purport it to be, it should be able to sell o its own credentials.”
Legislators and courts in Europe and the US have taken a strong stance to protect terms such as milk from misuse, as well as other products such as champagne.
While the plant-based industry is held up as a major opportunity for Australian farmers, most products available in Australia are either imported or made in Australia using imported ingredients.
Imported products were threatening the Government’s vision of agriculture reaching $100 billion farm gate value by 2030. “Policy makers must recognise the sheer size of the economic contribution that the red meat and livestock industry provides to achieving the $100 billion farm gate value, as Australia’s largest agricultural industry,” AMIC said.
Stephen Kelly, managing director of Sutcliffe Meats which operates 10 retails stores in Sydney and the NSW Central Coast, point to hypocrisy in plant-based industry messaging:
“There will always be considerable commentary on the environmental pros and cons of both sectors, however in my view the plant based sector uses both arguments to denigrate the livestock and meat industries rather than promote the virtues of their own industry.
“Despite this criticism, the plant based “meat” sector continually makes use of descriptors used by the livestock and meat industries to promote and sell their products.
“This use of “meat” descriptors for plant based products is currently unregulated, misleading to consumers, and exploiting the monies spent by the Australian Meat & Livestock industry in promoting meat products.”
Richard Rains further noted that “meat is nature’s miracle”, with cattle and sheep able to produce food for humans from grazing lands that is not fit for any other food producing purpose. “They turn cellulose into protein that nourishes and sustains us. Meat is nature’s miracle. We should continue to embrace it.”
Alternative protein: “There is no confusion”
A common thread of alternative protein submissions is that their products do not threaten red meat (although the founder of one of the sector’s biggest manufacturers, Impossible Foods, has repeatedly stated it is his mission to remove all animals from the food system by 2035), but are an essential solution to help provide the protein requirements of a growing world population.
The submissions also emphasise the issue of confusion, arguing that as long as their products use words like “plant-based” or “vegetable-based” or “non-meat” then consumers will not be confused by the inclusion of words like meat, beef, chicken, pork and images of livestock on their packagaing.
Food processing giant Sanitarium says plant-based protein products meet a specific consumer need and as such provide an important consumer choice.
“Key reasons for consuming plant-based meat alternatives are that consumers are looking for healthier or more nutritious options, or foods that are more environmentally friendly or due to animal welfare concerns,” the Sanitarium submission states.
‘We’re aiming to copy meat, and we want consumers to know it’ is the primary candid message from Impossible Foods.
“Our entire reason for existence is to make delicious food from plants that replicates the taste, texture, and aroma of meat from animals, and we want consumers to know it.
“We would never try to trick consumers into thinking they were eating meat from livestock – we do the exact opposite by clearly emphasizing to consumers that our food comes from plants. That is the whole point.”
If labelling laws change, plant based products won’t sell
Impossible Foods submission states that if it isn’t able to accurately describe its non-meat product in words consumers understand, “they won’t buy it”.
“Calling the burger “plant-based meat,” or telling consumers that it is “made from plants” combined with the minced beef appearance of the burger, lets home cooks know what to do with the product when they unwrap it: cook it like they would minced beef.
“If we were prohibited from using common food terms consumers understand, consumers will have a more difficult time understanding how to prepare our products when they take them home.”
“Similarly, “pork” describes a specific sensory experience, and if we were to rename Impossible Pork Made from Plants to “Impossible White Protein Made From Plants,” consumers would wonder if it will taste like pork, chicken, turkey, etc
Ketjil Hansen, founder of the Delicou brand which manufactuers a range of plant based seasoning and alternative meat products, said in his submission that Australian consumers are not confused or conflicted by the clear labelling of plant-based protein products, and there is a clear incentive from the meat industry to attempt to squash competition.
He also said that if labelling laws changed, his own business would be negatively affected.
“Should Delciou have to update our packaging to remove the ‘PLANT BASED CHICKEN/BEEF/PORK’, it would be devastating to our profitability and brand identity.
“It would cost upwards of $200,000 to commission new artwork, write-off existing packaging, and re-photograph and update our digital assets including our website. Furthermore, we believe sales of this range would be impacted significantly, potentially 50% or more, if customers are not able to clearly identify what animal-based meats they are intended to replace.
“Sales decreases this substantial would prevent Deliciou’s ability to perform in the Australian market, therefore all manufacturing and head office jobs would need to be off-shored to regions of the world that would support sales, for example the USA and UK.”
Another alternative protein manufacturer, Fry Family Food Co, submitted under the name of “LIVEKINDLY Collective” emphasised that it prominently labels its products as plant-based and vegan on front of packaging. “We do not use livestock images. Changing the name of our products will require a change of packaging, and extensive communication to customers to ensure they can identify plant-based products.”
Most submissions supporting current labelling laws say there is no confusing being caused by their labelling, pointing to studies such as market research by Colmar Brunton, 91 percent of Australians have never mistakenly purchased a plant-based product thinking it was its meat-based counterpart or vice versa.
“There is no evidence that consumers are confused by what “plant-based meat” means,” said Impossible Foods.
“Consumers understand that turkey bacon comes from turkey, cauliflower rice comes from cauliflower, and peanut butter comes from peanuts. “Plant meats” come from plants just like coconut meat comes from coconuts and nut meat comes from nuts. No one is confused that coconut meat comes from an animal even though there is ‘meat’ in the name. It is properly qualified that the product is from coconuts. The same can be said of ‘plant meats’ and ‘plant-based meat’”
Some submissions arguing against changes to current labelling laws argue that plant-based meats are more environmentally friendly and healthier, while suggesting the industry will provide a growth opportunity for Australian food manufacturers and farmers.
Some submitters also suggested that calls for truth in labelling should lead to meat products show images of dead animals in their packaging.