Warren, Amy --- "Environmental Impact Labels on Food Packaging in Australia: Practical and Politcal Challenges" [2022] UNSWLawJlStuS 26; (2022) UNSWLJ Student Series No 22-26

---

ENVIRONMENTAL IMPACT LABELS ON FOOD PACKAGING IN AUSTRALIA: PRACTICAL AND POLITCAL CHALLENGES

AMY WARREN

Climate change is becoming increasingly more important to the Australian public. This has been fuelled by recent climate-related disasters such as bushfires and flooding,^[1] increased awareness and advocacy among younger Australians,^[2] and international pressure for stronger policy commitments from federal governments.^[3] Food labels can help consumers make informed decisions about the impact of the food they consume. Specifically, environmental impact labels can contribute to more sustainable food practices by providing consumers with information enabling them to make more eco-friendly purchases; providing a way for companies to publicly commit to more environmentally-friendly production processes; and encouraging retailers to stock more sustainable products.^[4] Grocery products are the ideal candidate for environmental regulation because they are purchased in high volume by nearly every Australian household, and are a significant contributor to greenhouse gas emissions.^[5]

This article will examine the potential for environmental impact labels on food products in Australia and outline barriers to implementation. I will draw on global examples of current and emerging environmental impact labels, as well as the Australian experience of health labels. This article assumes that any environmental impact label implemented in Australia should be government-led and not driven by the private sector, as government assessments are perceived as more credible by consumers.^[6] Further, the number and diversity of eco-labels developed by the private sector can create confusion and lack of cohesion, and a government-led approach further ensures appropriate consultation with relevant stakeholders - such as manufacturers and farmers - is undertaken.

First, I will examine the practical challenges of what an environmental impact label should look like and how it should be introduced in Australia. Second, I will explore the significant barrier of limited political interest in climate change policy at a federal level. Finally, I will outline the impact that environmental labelling can have on consumer and company behaviours, and assess whether a labelling scheme can actually produce significant large-scale change.

I PRACTICAL CHALLENGES

A Measuring Environmental Impact

The first challenge for policymakers to consider is how environmental impact should be measured, and what factors should be taken into account in measuring impact. The most basic form of labelling involves measuring only the carbon footprint of foods. Such a label has been developed by the Carbon Trust and implemented in the United Kingdom.^[7] The Carbon Trust label aims to inform consumers of the amount of greenhouse gases emitted through the manufacturing of food products, in the form of grams or kilograms of carbon dioxide equivalents.^[8] In Australia, the George Institute have developed a planetary health star rating that similarly measures carbon footprint.^[9] Available through an app, this rating scores greenhouse gas emissions of Australian supermarket foods. While this provides a useful starting point for the development of a government label, a major criticism of carbon labels is that essential information about a product is left out by using only a single indicator to represent a complex reality.^[10]

Labels that incorporate other measures of environmental sustainability have a greater impact on consumer habits and are better received by the public. ^[11] More comprehensive labels may take into account carbon, water and nitrogen footprint, to provide a more holistic understanding of environmental impact.^[12] The French Eco-Score label takes into account additional quality criteria such as the environmental impact of food transport, recyclable packaging, country of origin of ingredients and seasonality.^[13] This design goes beyond simply encapsulating the production of food, but also the processes that see food reach supermarket shelves. Any Australian environmental impact label should aim to be as comprehensive as possible in the data it captures, to provide the most accurate reflection of the environmental impact of food products. The more holistic the environmental assessment, the more meaningful the label will be in improving environmental outcomes if it successfully influences consumer behaviour.

However, there are a number of technical barriers to data collection that must be addressed. The process of life cycle greenhouse gas analysis requires large amounts of resources.^[14] Carbon footprint (as well as nitrogen and water footprint) can vary dramatically between different products within the same category. For example, the greenhouse gas emissions from the production of one kilogram of beef can range from 26.8kg to 38.5kg based on differing farming practices.^[15] In order to produce accurate comparative data, extensive data collection and consultation with local and overseas farmers is required, which poses a significant logistical barrier. For this reason, the George Institute’s planetary health star rating can only calculate carbon footprint at a relatively high level of food category – for example, ‘breakfast cereals’ as opposed to ‘corn flakes’.^[16] This makes it difficult for consumers to use environmental impact labels to compare different foods within the same category. The French Eco-Score overcomes this barrier to some extent by relying on publicly available data on product Life Cycle Assessment produced by the Agribalyse database, and additional data that is self-reported by producers about packaging and ingredients.^[17] The Australian government is assisted by the fact that extensive local research has already been conducted into Life Cycle Assessment. In particular, the Australian Life Cycle Assessment Society has compiled an inventory of relevant energy and material inputs and environmental releases and fosters the development of methodology in Australia to overcome data comparison limitations.^[18] Further, as outlined above, the George Institute has already developed a database of Australian supermarket foods and their carbon emissions.^[19]

What is largely missing in Australia is government oversight and direction that would allow for a consolidated approach to measuring the environmental impact of food products. Much of the groundwork has already been laid, which makes the development and implementation of a comprehensive environmental impact food label significantly less challenging. As is clear from above, there are well-established international models that provide a useful framework for any label developed in Australia. If government resources are going to be invested into the development of an environmental impact label, it should be as holistic as possible to have the greatest impact on consumers habits.

B Label Design

Another key challenge for policymakers to consider is how the information captured by an environmental impact label is visually presented to consumers. How information is presented has a significant impact on what, if any, influence the label has on consumer habits.

Research from the public health sector has shown that the most effective nutrition labels are those with interpretive elements that ‘show judgement or recommendation’.^[20] Such labels can include multiple types of summary indicator formats, such as symbols, words and colour.^[21] Examples include a green tick that indicates a product is healthy,^[22] or a traffic light system that uses green, red and yellow colouring to indicate whether a product contains low, high or moderate quantities of unhealthy macronutrients.^[23] Increasingly, nutrition labels contain interpretive elements that evaluate product unhealthfulness, such as stop signs.^[24] These labels can also be useful at assisting consumers to select healthier products. While food labels may have important long-term goals, such as prevention of non-communicable disease or reduction of greenhouse gases, regulation also needs to promote explicit short-term goals, such as helping consumers choose healthier or more sustainable food options.^[25] Simple labels that utilise symbols and colour to indicate whether a product is good or bad are the easiest for consumers to understand and hence the most effective at influencing consumers to purchase healthier or more sustainable products.

Leach et al propose four different models for environmental impact labels: a star label, a stoplight label, a nutrition label add-on and a detailed comparison label.^[26] The star label is the simplest design and presents an average sustainable rating, ranging from zero stars (least sustainable) to three stars (most sustainable). The use of symbols is easy for consumers to understand, and the star system can encapsulate numerous types of environmental measures, such as nitrogen, carbon and water footprint.

The stoplight label colour-codes nitrogen, carbon and water footprints based on their sustainability rating, using green, red and yellow to indicate good, poor and moderate environmental impact.^[27] This design is also interpretative and easy for consumers to understand, and has been shown to be popular among Australian consumers.^[28] However, the traffic light system requires consumers to make a judgement about the overall sustainability of a product based on the ranking for each of the three individual categories. This may be attractive for consumers who are passionate about a particular area of sustainability, for example reducing their carbon footprint, but may be confusing for the majority of consumers who do not understand the difference between the three footprints.^[29]

The nutrition label add-on attaches the footprint results to the existing nutrition panel located on the back of the product. While this design positions environmental information alongside nutritional information and means more detail can be included,^[30] nutrition labels are typically located on the back or side of packaging and hence do not attract as much attention as a label that is on the front of the package. Consumers will be required to pick up the product and seek out the information, which makes it more difficult to compare products on the shelf and make an environmentally informed choice.

The detailed comparison label aims to make carbon, water and nitrogen footprints more understandable by translating them into more familiar metrics.^[31] For example, the carbon footprint weight of a product can be contextualised by comparing it to the emissions associated with driving a certain distance. While this design aims to increase consumer literacy of different environmental footprints, it is not effective as a colour or symbol-based label because it doesn’t rely on interpretative and visual design elements.

In order to be effective, information about environmental impact must be presented in a manner that puts the values in context and clearly shows the implications of personal actions with respect to different footprints.^[32] Interpretative labels such as a star rating or traffic light system are preferrable as they hold the most meaning for consumers. Australia has already adopted a star rating system for nutrition labels, through the Health Star Rating. A five-year report published in 2019 showed that 83% of Australian consumers are aware of the Health Star Rating system and 77% of Australian consumers agree that the system makes identifying healthier products easier.^[33] The star rating model is one which the Australian public is already familiar with and largely trusts.^[34] It is also the preferred form of front of label packaging among Australian consumers.^[35] Leach et al’s model can be easily adapted to include a star rating ranging from zero to five stars to match that of the health star model. Further, the George Institute star rating system (which rates products from zero to five stars) provides a good starting point for the Australian government. The health and sustainability star rating labels could feature side by side on the front of packaging, making the nutritional and environmental features of a product clearly visible and easily understandable to consumers.

C Mandatory or Voluntary?

Voluntary labelling has a limited effect on the reduction of carbon emissions,^[36] and a mandatory system would have a significantly higher impact. The most obvious limitation of a voluntary system is that products with a low sustainability rating simply won’t have the rating displayed on their packaging. If companies can choose whether or not to comply with the labelling system, its effectiveness at influencing consumer behaviour is severely undermined. Examples of this are abundant in the health sector. Nestle infamously removed the health star rating from its Milo products after public health groups determined it should have a star rating of 1.5 out of 5, and not 4.5 out of 5 as Nestle claimed.^[37] If the health star system was made mandatory and included on unhealthy products as well as high-scoring healthy products, it would maximise public health gains arising from reformulation and changes in consumer behaviour.^[38] A review of the Health Star Rating in Australia found that the label could be ten times more effective at improving population health if made mandatory.^[39] There is some evidence that mandatory environmental impact labels are preferred by consumers, particularly those who strongly perceive the impact of climate change.^[40]

The potential for improved food production processes is another reason why a mandatory label is the preferred model. In New Zealand, a study of the health star rating found that 83% of products displaying the label had been reformulated to some extent to be healthier. However, only 5% of packaged foods in New Zealand displayed the health star rating – if the label was extended to all products, the health outcomes would be insurmountably larger.^[41] In Chile, products high in sugar, salt, calories or saturated fat are marked with a mandatory black stop sign. Within the first 18 months of the logo being introduced, more than 1500 products were reformulated.^[42] Coca-Cola created 32 new drinks so that 65% of its products available in Chile were low or sugar-free. If the same results translate to the sustainability sector, a mandatory environmental impact label may encourage manufactures to reconsider their production processes by increasing accountability, and will likely lead to more significant sustainability outcomes.

However, mandatory labels pose a number of legal issues relating to international trade laws. As a member state of the World Trade Organization, (‘WTO’) Australia is a party to the Agreement on Technical Barriers to Trade. Food is traded across borders, and so are food labels. Domestic labelling requirements may create ‘technical barriers’ to the free movement of packaged foods across borders under the Technical Barriers to Trade Agreement.^[43] Mandatory labelling schemes are more likely than voluntary schemes to be deemed inconsistent with WTO rules.^[44] In the context of nutrition labels, WTO members have raised concerns that mandatory interpretive labelling measures are likely to have a ‘significant effect’ on international trade, due to the fact that each domestic labelling system is unique. This poses challenges to exporters in other countries who need to comply with a novel system of food labelling for each export market.^[45] These concerns, along with the need for a ‘multiplicity of documents’ as evidence of conformity with regulation, could mean that mandatory labelling is deemed more trade restrictive than necessary.^[46] Where there is potential for less restrictive alternatives that achieve the same objectives, they must be adopted. In the context of food labels, it could be argued that a voluntary system could achieve the same objectives without the trade implications.

While the Technical Barriers to Trade Agreement does not explicitly refer to environmental labelling, it is broadly accepted by WTO members that the provisions of the Agreement apply to such labels.^[47] Thow et al suggest that a way to make implementation less burdensome and restrictive would be the use of stickers instead of labels, as stickers can be easily interchanged to accommodate for the different labelling requirements of different countries and don’t need to be integrated into the design of the product.^[48] While mandatory food labels present greater challenges for implementation, the benefit to be gained outweighs that of a voluntary scheme as they have greater influence on consumer and company behaviour. Further, there are steps that can be taken to mitigate any possible adverse legal consequences.

D Further Regulatory Issues

Additional regulatory considerations include the need for a database of environmental impact factors (which may require university-supported research), and the creation of an independent body to monitor and enforce compliance.^[49] The establishment of a database is an expensive and time-consuming task, particularly if labels distinguish between different brands and products within the same categories, as this would require the collection of quantitative data from farms.^[50] Labelling regulations would need to be administered by a government body with the authority to monitor and enforce regulation, and structured, regular reviews would be required to ensure the labels are meeting their objectives and best practice standards.^[51] Sanctions for non-compliance such as fines, prison sentences or advertising restricts would need to be investigated and implemented.^[52] These all pose barriers to implementation.

II POLITICIAL VIABILITY

Another significant barrier to the implementation of environmental impact labelling in Australia is lack of political will. The federal government has a history of effectively using public resources to combat public health crises – from the implementation of mandatory plain packaging of cigarettes^[53] to the swift enforcement of lockdown and quarantine laws during the COVID-19 pandemic.^[54] The introduction of the star rating system to label the healthiness of foods is hence a non-controversial exercise of public health regulation, in a country that is well used to such intervention. Conversely, the Australian government has demonstrated significantly less enthusiasm when it comes to the development of significant climate change policy. At the Glasgow global climate summit, Australia’s policy response to climate change was ranked last in an assessment of 60 countries.^[55]The country that ranked first, Denmark,^[56] announced plans on 16 April 2022 to develop the world’s first government-funded climate label for food.^[57] A policy preference for a gas-fired economic recovery means that Australia is not on track to meet its 2030 emissions targets.^[58] Meanwhile the European Union, which is in the process of developing an Eco-Score label, have committed to becoming the first continent to be carbon neutral by 2050.^[59] The governments that have shown interest in environmental impact labelling are generally governments that are already taking proactive steps to reduce the impact of climate change through other policy initiatives. This poses a significant barrier in the Australian context, given the Australian government does not prioritise climate policy to the same extent.

Another significant feature of countries where environmental impact labelling has been introduced is high public interest in environmental issues and consumer awareness of labelling as an option to improve purchasing choices. More than half of European Union citizens would like to see the environmental impact of their food products indicated, and this has been a significant factor in the development of a unified Eco-Score label to apply across the European Union.^[60] Australian consumers have a similar interest in climate change, with 57% of consumers reporting it is important to them that the products they purchase are environmentally friendly.^[61] However, Australian consumers lack understanding of the impact that individual purchasing choices can have on the environment, with Sharp and Wheeler finding that Australian households have low pre-existing carbon knowledge.^[62] Increased consumer understanding of the environmental impact of food purchases may increase the political viability of a label scheme. By making food sustainability a topic at the forefront of consumer concern, there may be greater demand for a labelling scheme and any scheme will likely be more effective because consumers will better understand the significance of their purchasing habits.

Environmental impact labels should be positioned as one element of a broader suite of policies to increase consumer literacy on food sustainability and encourage more sustainable behaviours and practices around food. Increasing consumer understanding of and interest in food sustainability will help increase the political viability of a labelling scheme. Such efforts have already been undertaken by the private sector – for example, Coles and Woolworths voluntarily phasing out single use plastic bags in 2018^[63] – and greater efforts by the federal government to create a culture of food awareness will go even further in improving sustainability practices.

Mozaffarian et al have proposed a comprehensive policy package that the Australian government can implement to improve diet quality, of which food labelling is one aspect.^[64] Many of the policy strategies they suggest can also be applied to decreasing the environmental impact of individuals. The starting point for increased consumer literacy is education. Mozaffarian et al suggest the implementation of evidence-based mass media campaigns and the inclusion of nutrition and culinary skills in school curriculums.^[65] In the context of carbon footprinting, public education has also been recommended by Sureeyatanapas, Yodprang and Varabuntoonvit, who advocate for public information campaigns that emphasise the role consumers can play in decreasing global warming and the impact of industries through their personal choices.^[66] Similarly to the work that has already been done to measure the greenhouse gas emissions of Australian supermarket foods, much of the groundwork in the field of education has already been laid, and simply requires federal government backing to be more effective. OzHarvest have developed a curriculum-aligned education program called FEAST, aimed at students in years 5 and 6 that teaches students about food waste, sustainability and nutrition.^[67] Currently, this program is voluntary, but its incorporation into curriculums across Australia would significantly improve public understanding of food sustainability. Education programs such as this can be supplemented by mass media campaigns to reach all age groups.

Another significant policy strategy suggested by Mozaffarian et al to improve diet quality is the implementation of food standards in schools and worksites.^[68] In schools, this includes free or reduced-price provision of fruit and vegetables, and an emphasis on kitchen gardens. In worksites, this includes providing incentives for healthier eating and offering healthier options at cafeterias and vending machines. To achieve an objective of more sustainable diets, policies in worksites could be amended to mandate that sustainable food options are served in cafeterias and vending machines. Kitchen gardens and food education are becoming increasingly more important parts of schooling – often as a result of state or territory government policy, for example the NSW sustainability and action process^[69] – and could be extended to a federal government-led program that includes awareness about foods that are bought or come from the supermarket, and not just foods that are grown at home or at school.

Increasing public awareness of the environmental impact that individual choices can have is important because most consumers do not recognise the environmental impact of their food choices, and even when they do, they tend to underestimate it.^[70] While labels can help consumers make informed choices, they need to understand the context behind the labels and have an appreciation for why their food choices are important. Introducing an environmental impact label to a market of consumers who have a high appreciation for the impact of their purchasing decisions makes such a label significantly more politically viable because it increases the likelihood of changed consumer behaviour.

III IMPACT ON CONSUMER AND COMPANY HABITS

A Consumer Habits

Above, I have detailed the practical and political challenges to the implementation of an environmental impact label. Now, I will explore whether an environmental impact label can meaningfully achieve objectives of changed consumer and company behaviours, and whether it is worth the investment of resources to address the barriers to implementation. There is significant research in the public health sphere indicating that nutrition logos can lead to healthier purchasing.^[71] A 2017 study from New Zealand found that among consumers who looked at health labels, the products purchased were much healthier than the products that were looked at and put back on the shelf.^[72] This suggests that nutrition labelling does influence consumers to purchase healthier products. The benefit of environmental impact labelling is less clear. A significant barrier to changed consumer behaviour is consumer confusion surrounding what labels mean, alongside price concerns, food purchasing habits, limited information and marketing and a lack of perceived personal benefit.^[73]

In the context of environmental impact labelling, there is potential for labelling to influence consumer purchasing. One study conducted in Australia involved labelling different products with a green, yellow or black label to indicate below average, near average and above average carbon footprints.^[74] Over a three-month period, sales of black-labelled products decreased by 6% and sales of green-labelled products increased by 4%.^[75] When green-labelled products were also the cheapest, there was a 20% shift from black-labelled products to green-labelled products. This suggests that while environmental impact is clearly a concern for some consumers, food purchases are largely driven by habit,^[76] and there are other factors such as cost that are often considered more important.

Consumers’ willingness to pay for products with a higher sustainability score depends on societal awareness of environmental issues.^[77] Consumers’ willingness to pay also depends on their understanding of the label, and one of the largest barriers to the effectiveness of environmental impact labelling having a positive impact on purchase behaviour is consumer confusion.^[78] Some studies have identified an attitude-behaviour gap among consumers, where the intention to purchase eco-friendly products did not necessarily result in an actual purchase.^[79] This has been attributed to confusion or lack of understanding about what the label indicates, leading consumers to ignore the label and be guided by their normal purchasing habits. The education strategies outlined above, along with the use of a simple, interpretative label that clearly identifies whether a product is good or bad in terms of environmental impact, should help to overcome these barriers.

B Company Habits

There is some evidence that nutrition labelling requirements can stimulate food manufacturers to reformulate their products towards healthier nutrient compositions. ^[80] A New Zealand study^[81] found that the health star rating effectively influenced the food industry to reduce sodium levels in breakfast cereals, breads and margarines. A Netherlands study showed that the Choices logo similarly saw a reduction in sodium levels, as well as reduction in added sugar in dairy products and increase of dietary fibre in processed meats and dairy products.^[82] This is significant because the production of healthier food products leads to consumers making healthier food choices, whether they are influenced by a label or not. The same benefit could apply to environmental labels – if a labelling scheme is able to influence companies to change their manufacturing processes to be more sustainable, the negative consequence of limited impact on consumer behaviour is outweighed by the fact that consumers may end up purchasing more sustainable products as a consequence of changed manufacturer behaviour.

There is certainly scope for environmental impact labels to encourage more environmentally friendly food production processes. The Carbon Trust has developed a Reducing C02 certification that is available to companies that can demonstrate proof of reduced C02 emissions every two years.^[83] The Carbon Trust claims that companies with this certification have reported considerable cost savings due to the improvement of energy and resources efficiency across the supply chain, creating incentive for companies to support such a label.^[84] In addition, a favourable environmental impact label can help companies differentiate their brand and create a ‘green’ image that resonates with particular groups of consumers and helps to promote brand trust.^[85] However, positive company image gained from the Carbon Trust label has not translated to improved sales and market advantages for most companies. Companies’ ‘green’ image was only valued by specific groups of people and not widely by the general public. Lack of social awareness has been identified as the biggest barrier to continuing the Reducing C02 certification.^[86] As outlined above, this limitation can be addressed by viewing an environmental impact label as one policy in a suite of regulations including education campaigns to increase public awareness of the need for greater environmental sustainability.

IV CONCLUSION

The introduction of environmental impact labelling poses a number of regulatory, political and consumer issues. These barriers mostly stem from the technical difficulty of implementing such a label, and lack of consumer awareness and understanding of food sustainability and eco labelling in Australia. There are countless examples from across the globe of environmental impact labels that have already been implemented and are in the process of being developed. Further, there have already been efforts from the private and not for profit sector in Australia to measure the environmental impact of supermarket foods and increase consumer awareness of food sustainability. Much of the groundwork has already been laid for the implementation of an environmental impact label in Australia, and simply requires coordinated federal government support and direction to have significant impacts on environmental sustainability. Increasing consumer awareness of, and support for, environmental food issues may help to increase the political viability of introducing an environmental impact label in Australia.

---

^[1] Mike Foley, ‘CSIRO Study Proves Climate Change Driving Australia’s 800% Boom in Bushfires’, The Sydney Morning Herald (online, 26 November 2021) <https://www.smh.com.au/politics/federal/csiro-study-proves-climate-change-driving-australia-s-800-percent-boom-in-bushfires-20211126-p59cgr.html>.

^[2] Emily Laurence, Heath Parkes-Hupton and Nibir Khan, ‘School Strike for Climate Rally Draws Students to Kirribilli House Calling for Greater Action Climate Change’, ABC News (online, 25 March 2022) <https://www.abc.net.au/news/2022-03-25/nsw-floods-highlighted-school-strike-for-climate/100938942>.

^[3] Graham Readfearn, ‘Australia’s New Climate Pledge to UN Criticised for Not Improving on 2030 Target’, The Guardian (online, 5 January 2021) <https://www.theguardian.com/australia-news/2021/jan/05/australias-new-climate-pledge-to-un-criticised-for-not-improving-on-2030-target>.

^[4] MQB Tan, RBH Tan and HH Khoo, ‘Prospects of Carbon Labelling – A Life Cycle Point of View’ (2014) 72 Journal of Cleaner Production 76, 80.

^[5] Anne Sharp and Meagan Wheeler, ‘Reducing Householders’ Grocery Carbon Emissions: Carbon Literacy and Carbon Label Preferences’ (2013) 21(4) Australasian Marketing Journal 240, 242.

^[6] Alexandra Jones et al, ‘Front-of-Pack Nutrition Labelling to Promote Healthier Diets: Current Practice and Opportunities to Strengthen Regulation Worldwide’ (2019) 4(6) BMJ Global Health 1, 10.

^[7] Carbon Trust, ‘Product Carbon Footprint Label’ (Web Page, 2022) <https://www.carbontrust.com/what-we-do/assurance-and-certification/product-carbon-footprint-label>.

^[8] Panitas Sureeyatanapas, Kanittha Yodprang and Viganda Varabuntoonvit, ‘Drivers, Barriers and Benefits of Product Carbon Footprinting: A State-of-the-Art Survey of Thai Manufacturers’ (2021) 13(12) Sustainability 6543, 6546.

^[9] The George Institute, ‘FoodSwitch’ (Web Page, 2022) <https://www.georgeinstitute.org/projects/foodswitch>.

^[10] Tan, Tan and Khoo (n 4) 86.

^[11] Allisson Leach et al, ‘Environmental Impact Food Labels Combining Carbon, Nitrogen, and Water Footprints’ (2016) 61 Food Policy 213, 215.

^[12] Ibid.

^[13] Eco-Score, ‘Présentation’ (Web Page, January 2022) <https://docs.score-environnemental.com/v/en/>.

^[14] Tan, Tan and Khoo (n 4) 77.

^[15] Ibid 86.

^[16] The George Institute (n 9).

^[17] Eco-Score (n 13).

^[18] Australian Life Cycle Assessment Society, ‘Objectives’ (Web Page) <https://www.alcas.asn.au/objectives>.

^[19] The George Institute (n 9).

^[20] Jones et al (n 6) 4.

^[21] Ibid.

^[22] Such as the health label used in Israel: Maayan Jaffe-Hoffman, ‘Ministry of Health to Mark “Recommended “Foods with Green Check Mark’’, The Jerusalem Post (online, 6 July 2019) <https://www.jpost.com/health-science/ministry-of-health-to-mark-recommended-foods-with-green-check-mark-594692>.

^[23] Such as the health label used in the United Kingdom: Food Standards Agency, ‘Check the Label’ (Web Page, 23 January 2020) <https://www.food.gov.uk/safety-hygiene/check-the-label>.

^[24] Such as black stop signs used in Chile on food packaging that is high in sugar, salt, calories or saturated fat: Andrew Jacobs, ‘In Sweeping War on Obesity, Chile Slays Tony the Tiger’, The New York Times (online, 7 February 2018) <https://www.nytimes.com/2018/02/07/health/obesity-chile-sugar-regulations.html>.

^[25] Jones et al (n 6) 5.

^[26] Leach et al (n 11) 219.

^[27] Ibid 217.

^[28] Ibid 215.

^[29] Ibid 214.

^[30] Ibid 215.

^[31] Ibid 219.

^[32] Hans-Jürgen Schmidt, ‘Carbon Footprinting, Labelling and Life Cycle Assessment’ (2009) 14(1) The International Journal of Life Cycle Assessment 6, 6.

^[33] MP Consulting, Health Star Rating System Five Year Review Report (February 2019) 26.

^[34] Ibid.

^[35] Ibid 27.

^[36] Zaina Gadema and David Oglethorpe, ‘The Use and Usefulness of Carbon Labelling Food: A Policy Perspective from a Survey of UK Supermarket Shoppers’ (2011) 36(6) Food Policy 815, 820.

^[37] Lexi Metherell, ‘Nestle Removes Milo’s 4.5 Health Star Rating in Response to Criticism from Public Health Groups’, ABC News (online, 1 March 2018) <https://www.abc.net.au/news/2018-03-01/milos-4.5-health-star-rating-stripped-away-by-nestle/9496890>.

^[38] Laxman Bablani et al, ‘The Impact of Voluntary Front-of-Pack Nutrition Labelling on Packaged Food Reformulation: A Difference-in-Differences Analysis of the Australasian Health Star Rating Scheme’ (2020) 17(11) PLOS Medicine 1, 15.

^[39] Ibid.

^[40] Hyeyoung Kim, Lisa A House and Tae-Kyun Kim, ‘Consumer Perceptions of Climate Change and Willingness to Pay for Mandatory Implementation of Low Carbon Labels: The Case of South Korea’ (2016) 19(4) International Food and Agribusiness Management Review 129, 130.

^[41] Cliona Ni Mhurchu, Helen Eyles and Yuen-Hyang Choi, ‘Effects of a Voluntary Front-of-Pack Nutrition Labelling System on Packaged Food Reformulation: The Health Star Rating System in New Zealand’ (2017) 9(8) Nutrients 918, 931.

^[42] Jacobs (n 24).

^[43] Anne Marie Thow et al, ‘Nutrition Labelling is a Trade Policy Issue: Lessons from an Analysis of Specific Trade Concerns at the World Trade Organization’ (2018) 33(4) Health Promotion International 561, 562.

^[44] Ibid 567.

^[45] Ibid 566.

^[46] Ibid.

^[47] World Trade Organization, ‘Labelling’ (Web Page 2022) <https://www.wto.org/english/tratop_e/envir_e/labelling_e.htm>.

^[48] Thow et al (n 43) 566.

^[49] Jones et al (n 6) 14.

^[50] Leach et al (n 11) 221.

^[51] Jones et al (n 6) 14.

^[52] Ibid 15.

^[53] Australian Government Department of Health, ‘Tobacco Plan Packaging’ (Web Page, 30 January 2020) <https://www.health.gov.au/health-topics/smoking-and-tobacco/tobacco-control/tobacco-plain-packaging>.

^[54] Australian Government Department of Health, ‘Restrictions, Lockdowns and Stay at Home Orders’ (Web Page, 23 December 2021) <https://www.health.gov.au/health-alerts/covid-19/restrictions-and-lockdowns>.

^[55] Graham Readfern, ‘Australia Ranked Last of 60 Countries for Policy Response to Climate Crisis’, The Guardian (online, 10 November 2021) <https://www.theguardian.com/environment/2021/nov/09/australia-ranked-last-of-60-countries-for-policy-response-to-climate-crisis>.

^[56] Climate Change Performance Index, Results: Monitoring Climate Mitigation Efforts of 60 Countries Plus to EU – Covering 92% of the Global Greenhouse Gas Emissions (Report, November 2021) 7.

^[57] Flora Southey, ‘Denmark “First Country in the World” to Develop its Own Climate Label for Food’, Food Navigator (online, 19 April 2022) <https://www.foodnavigator.com/Article/2022/04/19/denmark-first-country-in-the-world-to-develop-its-own-climate-label-for-food>.

^[58] ‘Australia’, Climate Action Tracker (Web Page, 15 September 2021) <https://climateactiontracker.org/countries/australia/#:~:text=The%20Australian%20government%20has%20ramped,Australia%20is%20%E2%80%9CHighly%20Insufficient%E2%80%9D>.

^[59] BBC News, ‘EU Unveils Sweeping Climate Change Plan’ (online, 14 July 2021) <https://www.bbc.com/news/world-europe-57833807>.

^[60] BUEC, ‘One Bite at a Time: Consumers and the Transition to Sustainable Food’ (Survey Analysis, June 2020) 4.

^[61] CHOICE, ‘Eco Labels – Too Many, and Too Confusing?’ (online, 24 August 2021) <https://www.choice.com.au/shopping/packaging-labelling-and-advertising/labelling/articles/greenwashing-eco-labels>.

^[62] Sharp and Wheeler (n 6).

^[63] Australian Associated Press, ‘Supermarket Ban Sees “80% Drop” in Plastic Bag Consumption Nationwide’, The Guardian (online, 2 December 2018) <https://www.theguardian.com/environment/2018/dec/02/supermarket-ban-sees-80-drop-in-plastic-bag-consumption-nationwide>.

^[64] Dariush Mozaffarian et al, ‘Role of Government Policy in Nutrition – Barriers to and Opportunities for Healthier Eating’ (2018) 361 BMJ Global Health 1.

^[65] Ibid 3.

^[66] Sureeyatanapas, Yodprang and Varabuntoonvit (n 8) 6558.

^[67] OzHarvest, ‘Education’ (Web Page, 2022) <https://www.ozharvest.org/education/>.

^[68] Mozaffarian et al (n 64) 4.

^[69] NSW Department of Education, ‘Sustainable Action Process’ (Web Page, 12 June 2020) <https://education.nsw.gov.au/teaching-and-learning/curriculum/sustainability/sustainability-action-process>.

^[70] Adrian R Camilleri et al, ‘Consumers Underestimate the Emissions Associated with Food but are Aided by Labels’ (2019) 9 Nature Climate Change 53.

^[71] Ellis L Vyth et al, ‘Front-of-Pack Nutrition Label Stimulates Healthier Product Development: A Quantitative Analysis’ (2010) 7(65) International Journal of Behavioral Nutrition and Physical Activity 1.

^[72] Mhurchu, Eyles and Choi (n 41).

^[73] Leach et al (n 11) 215.

^[74] Jerome K Vanclay et al, ‘Customer Response to Carbon Labelling of Groceries’ (2011) 34 Journal of Consumer Policy 153.

^[75] Ibid 156.

^[76] Tan, Tan and Khoo (n 4) 87.

^[77] Leach et al (n 11) 221

^[78] Ibid.

^[79] Tan, Tan and Khoo (n 4) 87.

^[80] Mhurchu, Eyles and Choi (n 41) 918.

^[81] Ibid.

^[82] Vyth et al (n 71) 4.

^[83] Kim, House and Kim (n 40) 131.

^[84] Sharp and Wheeler (n 6) 244.

^[85] Sureeyatanapas, Yodprang and Varabuntoonvit (n 8) 6552.

^[86] Ibid.