Whole Grain Ingredient Content Claim
As outlined within the Code of Practice for Whole Grain Ingredient Content Claims, GLNC recommends manufacturers calculate whole grain content according to the Food Standards Code standard 1.2.10 and the Food Standard Australia New Zealand (FSANZ) guidance document Percentage Labelling of Food User Guide To Standard 1.2.10 – Characterising Ingredients and Components of Food. Guidance on the typical ratio fractions in common cereal grains and a list of grains that may be included in the calculation can be found here.
In consultation with the food industry and regulators, GLNC has developed the a set of worked examples for the calculation of whole grain content in accordance with Standard 1.2.10 and the User Guide Standard 1.2.10. The worked examples are provided for guidance only and can be access here.
With the launch of the Code of Practice for Whole Grain Ingredient Content Claims (the Code) GLNC is establishing an industry standard for the use of the word whole grain as two words. GLNC decided that it was best for the benefit of multi-national companies that we align with international usage of the term. This aligns with other international standards such as the AACC International (AACCI), who have developed an international characterisation for whole grain. We acknowledge that the Australian Dietary Guidelines and the Food Standards Code use one word and GLNC will be advocating for the adoption of two words when these documents are next reviewed, including the current P1025 review of the Food Standards Code.
The GLNC requirement for the use of two words in the content claim does not prevent manufacturers from using whole grain as one word when used elsewhere on pack or in advertising, including the name of the product. However, GLNC does encourage manufacturers to move towards the use of two words to enhance consistency.
Yes, whole grains plural may be used as an alternative to whole grain.
Does the Code create a definition of a whole grain food? Does this mean that foods that contain less than 8 grams per serve cannot be called whole grain?
Product names may continue to include the word whole grain even if they contain less than 8g whole grain per serve. According to the current Foods Standards Code and the current proposed amendment to the Code (P1025) a food sold as whole grain or whole meal need only meet the specification that it has whole grain as an ingredient. As a characterising ingredient the Food Standards Code requires the per cent whole grain be quoted in the ingredient list.
It is not the purpose of this claim to define a whole grain food or a whole grain core food. The purpose of the Code is to allow clear, consistent communication of the whole grain content of foods to encourage people to choose and eat whole grain foods. The AACC International recently announced a characterisation for whole grain food of 8 grams whole grain per 30 grams serve. Once the GLNC Code has had adequate time to be established as an industry standard, GLNC will consider expanding the Code to incorporate the whole grain characterisation and potentially advocating for incorporation into the ANZ Food Standards Code.
Yes, factual statements about whole grain ingredient content in grams or as a percentage of the finished food are permitted. The food must contain at least 8 grams of whole grain per manufacturer serve to carry a factual statement about whole grain ingredient content.
Statements that do not relate to the whole grain ingredient content of a food are outside the scope of the Code. Registered Users wishing to use statements other than the whole grain ingredient content claims or the permissible synonyms listed in Code or factual statements of content should do so in accordance with the Australia New Zealand Food Standards Code, applicable Australian consumer laws and other relevant legislation at Commonwealth, State or Territory level.
Adhering to the Code does not preclude the need for Registered Users to assess whole grain claims for each product. GLNC encourages Registered Users to seek legal advice in consideration of the overall impression of the claim, the product composition and all other relevant circumstances. Australian consumer laws should be considered when using claims to avoid misleading or deceptive conduct.
Why is the calculation of whole grain required? Does this require a Registered User to provide confidential product formulation information?
The calculation of whole grain content is required because there is no established laboratory analysis procedure to determine whole grain content of foods. This calculation provides a proxy for analysis. Additionally, GLNC is establishing a whole grain calculation method to ensure consistency in calculation of whole grain content across the industry.
On signing the Agreement to become a Registered User of the Code, both the Registered User and GLNC agree to be bound by a Non-Disclosure and Confidentiality Agreement.
Why are Registered Users required to notify GLNC of use of whole grain content claims and DTI statement use even when the GLNC name is not used?
In establishing the Code GLNC wishes to track the use of the claims on pack by Registered Users to demonstrate the uptake of the voluntary Code by industry.
Why are manufacturer serve sizes used instead of the serve sizes listed in the Australian Dietary Guidelines?
This is to assist the food industry by aligning with other content claim requirements. For example, to carry nutrient content claims such as ‘good source of fibre’ foods must contain a minimum amount of fibre per suggested serve size.
The purpose of the Code is to establish clear, consistent communication of the whole grain ingredient content of foods to assist consumers recognise, choose and eat foods that will contribute to their whole grain Daily Target Intake. Basing the whole grain ingredient content claims on serves that reflect the amount recommended on pack makes the information more accessible to the consumer. Consumer research indicates the portions eaten by Australians are closer to the serve size recommended on pack rather than the serve sizes in the Australian Dietary Guidelines.
GLNC consumer research has indicated that consumers prefer the amount of food to be specified in the explanatory information. For this reason the DTI statement requires manufacturers to state the amount of food rather than use the words ‘one serve’.
Why are the whole grain ingredient content claims three levels and not a single whole grain logo as used in other countries?
The purpose of the three levels is to provide a tool to help Australians understand that whole grain foods contain different levels of whole grain. Consumer research conducted by GLNC indicates the most effective at conveying this message is using the wording of the claims as stated in the Code together with the Daily Target Intake statement. The whole grain content levels in the Code align with the levels in the US-based Whole Grain Stamp of 8 grams and 16 grams.
The Code allows one level of claim for toddler foods, ‘contains whole grain’. This claim may be used on foods intended to be consumed exclusively or primarily by children aged 2 – 3 years as determined/defined by the manufacturer.
GLNC encourages the consumption of whole grain foods from a young age to establish healthy eating habits. However, as the serve sizes of foods designed for the toddler age group are smaller than for adults, it is prohibitive for small serve-size foods to contain 8 grams of whole grain. For example, a 13 gram cereal bar cannot feasibly contain 8 grams of whole grain.
To encourage whole grain intake in this age group the Code allows these foods to carry a statement if they contain a minimum of 4 grams per serve and also at least 8 grams per 30 grams.
Lower levels were considered for older children’s foods. Based on the DTI for children 4 – 8 years, the level required for children’s foods would be 6.7 grams per serve. Given this is not significantly less than 8 grams per serve it was decided it did not outweigh the risk of confusing consumers with multiple levels of content allowable for the claim ‘contains whole grain’. In addition, in consultation with the food industry it was decided it was too difficult to define foods that would be eaten by children as many of these grain foods, such as breakfast cereals or muesli bars, are often eaten by adults. While some examples are obviously made for children a number of other examples are less obvious and often eaten by adults and children alike.
The Code does not prevent the use of Daily Target Intake statements for children aged 4 – 8 years as long as the food contains 8g of whole grain per serve. These statements are included in the Code as alternatives to the adult statement.
Does the Code of Practice include a whole grain ingredient content claim or recommendation for infants (7 – 12 months)?
No, the Code of Practice does not include a specific whole grain ingredient content claim or recommendation for infants (7 – 12 months).
The Grains & Legumes Nutrition Council recommends the inclusion of some whole grain foods in to the diet of infants to promote healthy habits from a young age. While the Code of Practice does allow the use of whole grain ingredient content claims on foods intended to be consumed exclusively or primarily by toddlers 1-3 years old, in consultation with paediatric Accredited Practising Dietitians, GLNC determined that a specific whole grain ingredient content claim or recommendation for infants (7 – 12 months) in the Code of Practice is not appropriate.
The decision to exclude a specific whole grain ingredient content claim or recommendation for infants (7 – 12 months) is based on the following:
- Infants are highly variable in their development
- Most parents may not be aware of appropriate whole grain portions for infants, so if infants were fed large portion of whole grain this may result in high fibre intakes which may have detrimental effects:
- The main risk of high fibre intake for infants (especially insoluble fibre) is constipation and impaired absorption of iron in their diet which is a greater nutritional priority in this age group.
- Whole grains may also be satiating, which may impact an infant’s subsequent daily intake of breast milk/infant formula or solids
- Intact whole grains may pose a choking hazard to infants.
During the development of the whole grain ingredient content claims, GLNC held a Round Table consultation with cereal academics and public health experts. It was agreed that 8 grams per serve was an evidence-based and realistic minimum level to describe a food as ‘contains whole grain’. On the other hand, there is no evidence on which to base the 51% minimum percentage. The evidence on which the 48 gram Daily Target Intake is based uses a definition of whole grain food that varies in percentage whole grain content and in many cases is not recorded.
A recent audit of the whole grain foods on the market indicates that a 51% whole grain content criteria would prevent most of the foods currently on the market communicating the information that these foods can contribute towards the 48 gram Daily Target Intake (85% of foods containing between 8 and 16 grams of whole grain per serve would not meet the criteria of 51% whole grain).
In addition, a 51% whole grain content criteria is likely to hamper innovation, particularly in foods with a smaller serve size. If a smaller serve size food is not able to contain 51% whole grain there will be no incentive to encourage development of products with increased whole grain content.
A number of the whole grain studies use a definition of whole grain food as containing 25% whole grain. So this was also considered as potential criteria. However, the audit data indicates that most whole grain foods with less than 8 grams per serve whole grain have less than 25% whole grain. This suggests that 8 grams per serve is a reasonable reflection of percentage whole grain.
This is consistent with nutrient content claims as described in the Food Standards Code Standard 1.2.7. To carry nutrient content claims such as ‘good source of fibre’ foods do not need to meet any additional nutrient criteria other than a minimum fibre content. FSANZ decided not to apply the nutrient profiling scoring criterion (NPSC) to foods with nutrition content claims. This position is based on consumer research which indicates the presence of nutrition content claims on foods that do not meet the NPSC does not enhance purchase intention. This suggests a whole grain ingredient content claim on an energy-dense, nutrient-poor food is unlikely to mislead people to believe it is a healthy food. This is in agreement with consumer research conducted by GLNC.
An energy cap could potentially help control overconsumption of grain foods beyond the amounts recommended in the Australian Dietary Guidelines. However, GLNC is concerned the additional requirement of an energy cap would serve as a barrier to broad adoption of the claim which would hinder the public health benefit. Given the diversity of the grain food category, a single energy cap value is not appropriate for determining an ‘extra’ food. In addition, this may create confusion with initiatives already in place to help Australians make healthier choices. A number of public health initiatives such as the Swap It Don’t Stop It campaign and the 8,700kJ campaign are in place to help guide people to choose core foods rather than ‘extra’ foods.
GLNC recognizes the need for Australians to limit consumption of foods high in saturated fat, salt and sugar such as cakes, biscuits, pizzas and savoury snacks. Consequently, one of GLNC’s key messages is to encourage people to swap from ‘extra’ foods to core grain foods. To promote this key message products that carry the GLNC logo &/or certification are required to meet specific nutrient criteria. They must be a core food as defined by the Australian Dietary Guidelines and they must meet the Heart Foundation Tick Program’s Guidelines for Approved Products.
Do Registered Users need to adhere to the Code on their entire product range or just on the products they register?
Registered Users are required to register with GLNC all products that will carry the whole grain ingredient content claim or Daily Target Intake statement. Registered Users are not required to register products that do not carry the whole grain ingredient content claim or Daily Target Intake statement. However, GLNC will conduct an annual audit of the use of whole grain claims in the food supply and contact both Registered Users and non-Registered Users making claims on unregistered products to encourage registration. The use of whole grain claims by Registered Users on unregistered foods that do not meet the Code requirements will not be viewed favourably.
Why does the certification for whole grain foods include the recommendation ‘make at least half your grains whole grain or high fibre’ and not the Australian Dietary Guidelines recommendation of ‘mostly wholegrain and/or high cereal fibre varieties’?
GLNC believes that ‘mostly’ is not an adequate target for consumers. GLNC continues to advocate for a quantified amount of whole grain or high fibre grain food per day in the Australian Dietary Guidelines to provide consumers with a clear goal.
Consumer research indicates that Australians are, on average, eating two serves of whole grain food per day which is only one third of their total serves of grain each day. So a goal of at least half is likely to increase the whole grain and high fibre grain food intake of many Australians. It also leaves room in a balanced diet for refined and lower fibre core grain foods such as white rice and plain pasta that are culturally important and provide variety.
Why is the GLNC certification statement ‘Enjoy grain foods 3 – 4 times a day’ and not ‘six serves a day’?
GLNC’s key grain food message is ‘Enjoy grain foods 3-4 times a day and make at least half your grains whole grain or high fibre’. This is an interpretation of the Australian Dietary Guidelines recommendation.
GLNC has intentionally not used the six serves a day message.
Consumer research indicates the portions eaten by Australians are larger than the Australian Dietary Guidelines. This may help to explain why research also indicates that Australians perceive the Dietary Guideline recommendation as too many serves. GLNC believes this may be because people interpret this to mean to eat grains on six occasions each day. As a result GLNC developed a grain message that aligns with Australian meal patterns.
Registered Users have the option to use the GNLC logo without the certification statement. They may also use the Dietary Guidelines recommendation in labels without breaching the Code.
GLNC’s key legumes message if to ‘Enjoy legumes 2 – 3 times a week’. This was developed because the Australian Dietary Guidelines do not include a recommendation for the number of times a week people should eat legumes.
Research indicates for health benefits people should eat legumes at least four times a week and a growing body of evidence suggests every day. However, the GLNC consumption study indicates that only 22% of Australians eat legumes regularly and on average less than one third of one serve per day. The main reasons people don’t eat legumes is because they are not familiar with cooking methods and they are worried about side effects.
In developing our key message, GLNC sought a goal that was attainable for Australians. As a result, the GLNC education resources explain that while 2 – 3 serves a week is a good start, to get the health benefits people should eat aim for at least 4 times a week.
As a Registered User of the Code do I need approval to use the whole grain ingredient content claim or DTI statement on labels?
Registered Users are required to register with GLNC all products that will carry the whole grain ingredient content claim or Daily Target Intake statement. This is once–off notification only and approval from GLNC is not required. The use of the whole grain ingredient content claim or Daily Target Intake Statement on specific labels or advertising does not require GLNC approval.
The use of the GLNC logo has two advantages. Consumer research indicates it adds credibility to the claims. It also allows manufacturers to leverage GLNC’s health promotion charity status. However, as GLNC is not an endorsing body according to the Food Standards Code Standard 1.2.7 foods making health claims are still required to meet Nutrient Profiling Scoring Criteria.
Why do non-whole grain foods need to be high in fibre to carry the certification? Why not a source of fibre?
For consistency with the requirement for high in whole grain, high fibre was adopted. This also reflects the Australian Dietary Guidelines recommendation of high fibre grain foods.
Encouraging foods with 16 grams of whole grain allows people to meet the 48 gram DTI with three serves of whole grain. This leaves room for grain foods that are not whole grain but can still be part of a balanced diet such as high fibre breakfast cereal, low GI foods like pasta, or foods that are commonly part of a healthier eating pattern such as white rice.
This also encourages improvement in the food supply. Of all whole grain products currently on shelf, 87% are eligible to carry the claim ‘contains whole grain’. However, only 65% are eligible to carry a ‘high in whole grain’ claim.
GLNC’s mission is to promote grains and legumes as part of a balanced diet. To support this mission, the message to swap from foods high in saturated fat and salt to core foods underpins all GLNC education campaigns.
In line with this key GLNC message, foods may only carry the GLNC logo or certification statement if they are core foods as defined by the Australian Bureau of Statistics 2011-12 Australia Health Survey User Guide.
The Code requires the fibre in grain foods be ‘predominantly cereal fibre’. What percentage of cereal fibre is considered ‘predominantly’?
The requirement in the Code for the fibre to be predominantly from cereal fibre aligns with the Australian Dietary Guidelines recommendation for ‘grain foods, mostly whole grain and / or high cereal fibre varieties’. It also aligns with the GLNC definition of a high fibre grain food that underpins our key messages.
GLNC has intentionally not specified the proportion of fibre form cereals because it is not possible by total dietary fibre analysis to determine the fibre contribution from cereal. In a similar way, the Food Standards Code does not define the amount of a characterising ingredient required to make an ingredient content claim.
GLNC does not wish to make this requirement restrictive to the food industry. However, as with the interpretation of the Characterising Ingredient regulations, GLNC may deem a very low cereal fibre content to be misleading. This will be at the discretion of GLNC in consultation with the Steering Committee and as part of the regular review of cereal fibre content of products on shelf.
Why has the FSANZ Nutrient Profiling Scoring Criteria (NPSC) been chosen to assess eligibility for certification?
The Nutrient Profiling Scoring Criterion (NPSC) is designed as a single cut off value to determine if a food can carry a health claim, and was deemed an appropriate industry accepted criterion to use when assessing eligibility for certification.
GLNC seeks nominations from the food industry and key stakeholders for specific positions on each Committee every two years. Both Registered Users and non-Registered Users are able to nominate. Nominees need to demonstrate capability to meet specified selection criteria and provide details of standing interests. The Committees operate on a majority vote basis so as to remove any effect of conflict of interest. As outlined in the Code, if a conflict of interest is identified during the complaints process the Complaints Committee Member will be removed from the process for the identified complaint.
The Steering Committee and Code Manager will review the Code every three years in consultation with the food industry and key stakeholders as appropriate. The 2015 review of the Code became effective on 1 July 2016. When reviewed, registered Users and the food industry will be advised of changes by 31 May.
GLNC will regularly audit whole grain ingredient content and whole grain claims on grain foods in the food supply. This will be conducted category-by-category in a rolling audit process. Manufacturers of products that do not comply with the Code will be made aware of the Code and encouraged by GLNC to remove claims. Manufacturers of products not registered with GLNC will be encouraged to become Registered Users. GLNC will also use this data to monitor changes in the use of whole grain claims and whole grain content of the Australian food supply over time.
GLNC is aware that new food formats may need to be considered when reviewing the Code. Consideration of new food formats will be role of the Code Steering Committee in consultation with the food industry.
Details of the communications strategy that underpins the Code are not included in the Code. GLNC will be undertaking a phased communications strategy to communicate the use of the elements of Code to the food industry initially, followed by health care professionals and consumers. For more information on the communications strategy please contact the GLNC Code Manager.
The period for removal of whole grain ingredient content claims and GLNC logo &/or certification depends on if the Registered User chooses to withdraw registration of a product from the Code or is required to withdraw due to a breach.
If a Registered User chooses to withdraw the registration of a product, they will be allowed a period of six months following its withdrawal to update its labels to remove all references to the Code, GLNC and its logo, the Certification Mark and other GLNC certification statements. A longer period may be agreed by the Code Manager and the Registered User.
Where the Registered User’s participation in the Code has been terminated by GLNC following a breach of the Code by the Registered User, GLNC may determine that reference to GLNC is removed from labels earlier than six months. The length of time will be determined by the severity of the breach. However, the time to remove labels will always be at least one month.