Open letter to Food Ministers’ Meeting

FSANZ decision to allow misleading sugar and carbohydrate claims for alcohol must be reviewed.

Dear Ministers,

Public health and consumer groups are deeply disappointed in the recent Food Standards Australia New Zealand (FSANZ) Board decision that gives the alcohol industry the green light to use misleading carbohydrate and sugar claims on alcoholic beverage labels and in broader marketing campaigns.

This decision disregards the significant harms alcohol fuels in our community and the scientific evidence that shows these claims can cause consumers to inaccurately perceive alcoholic products bearing claims as healthier and less harmful to health compared to the same product without claims. We believe this decision fails to meet FSANZ’s legislative objectives when setting food standards to protect public health and safety, to provide adequate information to enable consumers to make informed choices and, most notably, to prevent misleading or deceptive conduct. We are calling on Food Ministers to request a review of this decision in the interests of the health and safety of all Australians and New Zealanders.

As public health and consumer groups, who work to protect the health and wellbeing of our community, we strongly oppose nutrition content claims that are used to market alcoholic products. The misleading nature of carbohydrate and sugar claims and their use as a marketing tool may misguide people’s ability to make informed choices about alcoholic products and distract them from the harms that alcohol causes.

Alcohol is an inherently harmful substance. Across Australia and New Zealand thousands of people lose their lives or are hospitalised each year as a result of alcohol.[i][ii] Alcohol use is causally linked to over 200 disease and injury conditions,[iii] and alcohol is a Group 1 carcinogen, with strong evidence that alcohol use increases cancer risk in humans.[iv] Government public health advice in both nations is to limit alcohol intake,[v][vi] and all labelling and marketing standards set out in the Food Standards Code must support these recommendations.

In 2017, Food Ministers originally raised concerns that sugar content claims were potentially misleading consumers and being used to promote alcohol as a healthier choice.[vii] The scientific evidence, including the consumer research undertaken by FSANZ, consistently shows that nutrition content claims about carbohydrates and sugars mislead consumers to assess alcoholic products bearing claims as healthier, lower in energy and less harmful to health, compared to the same product without claims.[viii][ix][x][xi] 

Part of FSANZ’s decision to allow these claims appears to be due to the assessment that the misleading effect of the claims on consumers’ perceptions of the healthfulness of alcoholic beverages seen in the FSANZ research was small.[xii] We are concerned about this interpretation, given that when a small effect seen in a study is applied to the population, its impact can be significant.[xiii][xiv]

A new analysis from Cancer Council Victoria extrapolated survey estimates of perceptions of carbohydrate and sugar claims[xv] to the wider Australian population. This analysis estimates that “over 8.6 million Australian recent drinkers aged 18-65 years would mistakenly think that alcohol products labelled as low sugar or low carbohydrate are better for them.”[xvi]  

We believe the current decision fails to account for the broader implication of claims in wider marketing campaigns. This proposal, if gazetted, will allow the alcohol industry to use sugar claims, which are currently not permitted,[xvii] and continue to use carbohydrate claims as marketing tools for alcoholic products despite the evidence showing consumers can be misled by them. These claims are often used in marketing campaigns, seemingly to position alcoholic products as a good choice for those focused on their health and wellbeing: for example, ‘No carbs. No sugar. No guilt.’  This contradicts the evidence-based public health message that when it comes to alcohol, the healthiest choice is to reduce the amount of alcohol consumed.  The health and wellbeing of Australians and New Zealanders must be prioritised ahead of the profits of the multi-billion-dollar alcohol industry.

We acknowledge the extensive work on current alcohol labelling proposals, including mandatory energy labelling. However, the FSANZ Board’s decision to allow misleading and often attention-grabbing, front-of-pack claims may conflict with existing alcohol labelling measures implemented by FSANZ and those endorsed by the World Health Organization.[xviii] Essential information like alcohol content and pregnancy health warnings can help consumers make informed choices, while conversely carbohydrate and sugar claims cause consumers to inaccurately perceive products bearing claims as healthier, lower in energy, and less harmful compared to those without.

We believe the FSANZ Board decision fails to recognise the significant harms caused by alcoholic products, does not sufficiently prioritise public health and allows alcohol companies to mislead consumers. We urge Food Ministers to step in and ask FSANZ to review its decision to allow sugar and carbohydrate claims on alcohol products, to protect public health and safety and prevent the alcohol industry from misleading Australians and New Zealanders about the healthiness of alcoholic products.

[i] Lensvelt E, Gilmore W, Liang W, Sherk A, T. C. Estimated alcohol-attributable deaths and hospitalisations in Australia 2004 to 2015. Perth: National Drug Research Institute, Curtin University; 2018. Available from: http://ndri.curtin.edu.au/NDRI/media/documents/naip/naip016.pdf.

[ii] Chambers T, Mizdrak A, Jones AC, Davies A, Sherk A. Estimated alcohol-attributable health burden in Aotearoa New Zealand. Wellington, New Zealand; 2024. Available from: https://www.hpa.org.nz/sites/default/files/Alcohol%20Attributable%20Fractions%20report%20-%20finalF.pdf

[iii] Rehm J, Gmel GE, Gmel G, Hasan OSM, Imtiaz S, Popova S, et al. The relationship between different dimensions of alcohol use and the burden of disease—An update. Addiction. 2017;112(6):968-1001.

[iv] World Cancer Research Fund/American Institute for Cancer Research. Continuous Update Project Expert Report 2018: Alcoholic drinks and the risk of cancer. World Cancer Research Fund/American Institute for Cancer Research. Available from: https://www.wcrf.org/wp/content/uploads/2021/02/Alcoholic-Drinks.pdf

[v] National Health and Medical Research Council. Australian Guidelines to Reduce Health Risks from Drinking Alcohol. Commonwealth of Australia: Canberra; 2020 Available from: https://www.nhmrc.gov.au/about-us/publications/australian-guidelines-reduce-health-risks-drinking-alcohol

[vi] Health New Zealand. Low-risk drinking advice. 2011. Available from: https://www.alcohol.org.nz/help-and-support/advice/standard-drinks-and-legal-limits

[vii] Food Regulation Secretariat. Australia and New Zealand Ministerial Forum on Food Regulation Communiqué 24 November 2017. Available from: https://webarchive.nla.gov.au/awa/20230921130827/https://foodregulation.gov.au/internet/fr/publishing.nsf/Content/forum-communique-2017-November

[viii] Cao S, Tang C, Carboon I, Hayward C, Capes H, Chen YJM, et al. The health halo effect of ‘low sugar’ and related claims on alcoholic drinks: an online experiment with young women. Alcohol and Alcoholism. 2023;58(1):93-9

[ix] Haynes A, Talati Z, Keric D, Stafford J, Sartori A, Myers G, et al. The effect of low sugar and low carb claims on young adults’ perceptions of alcohol products [Confidential report provided to FSANZ and Food Ministers, July 2024]. East Melbourne: Centre for Behavioural Research in Cancer, Cancer Council Victoria; 2024.

[x] Food Standards Australia New Zealand. Alcohol Labelling Consumer Research Report. Consumer response to sugar claims. Carbohydrate claims and nutrition information panels on alcoholic beverage. FSANZ; 2024. Available from: https://www.foodstandards.gov.au/food-standards-code/proposals/P1049

[xi] Food Standards Australia New Zealand. Consumer Literature Review for P1049- Update. Consumer value, perceptions and behaviours in relation to carbohydrate and sugar claims on alcoholic beverages. FSANZ; 2025. Available from: https://www.foodstandards.gov.au/food-standards-code/proposals/P1049

[xii] Food Standards Australia New Zealand. Approval report- Proposal P1049. Carbohydrate and sugar claims on alcoholic beverages. FSANZ; 2025. Available from: https://www.foodstandards.gov.au/food-standards-code/proposals/P1049

[xiii] Matthay EC, Hagan E, Gottlieb LM, Tan ML, Vlahov D, Adler N, et al. Powering population health research: Considerations for plausible and actionable effect sizes. SSM Popul Health. 2021;14:100789.

[xiv] Carey EG, Ridler I, Ford TJ, Stringaris A. Editorial Perspective: When is a ‘small effect’ actually large and impactful? Journal of Child Psychology and Psychiatry. 2023;64(11):1643-7.

[xv] Haynes A, Ilchenko E, Dixon H, Morley B. Prevalence and predictors of misperceptions of ‘better for you’ alcohol products among Australian adult drinkers. Health Promotion International. 2024;39(6).

[xvi] Haynes A, Durkin S, Hickey K, Martin J. Misleading sugar and carbohydrate claims on alcohol products: Impact on the Australian population. East Melbourne: Centre for Behavioural Research in Cancer, Cancer Council Victoria. Available from: https://www.cancervic.org.au/research/behavioural/major-topics-projects/alcohol/better-for-you-features-of-alcohol-products-prevalence-and-impact.html

[xvii] Food Standards Australia New Zealand. Technical Assessment- Carbohydrate claims about food containing alcohol. FSANZ; 2018. Available from: https://www.foodstandards.gov.au/publications/Technical-Assessment-Carbohydrate-claims-about-food-containing-alcohol

[xviii] World Health Organization. Global alcohol action plan 2022–2030. Geneva: World Health Organization; 2024. Available from:  https://www.who.int/publications/i/item/9789240090101#:~:text=The%20plan%20outlines%20six%20key%20areas%20for%20action%3A,knowledge%20production%20and%20information%20systems%2C%20and%20resource%20mobilization.

PDF version: Open letter to FMM_sugar and carbohydrate claims on alcohol (P1049)_May 2025