Label Review Guide Australia – Food Category Milk – Pauls 2L Milk Smarter White 2% Fat – 20th May 2018

Pauls 2L Milk Smarter White 2% Fat Front Bottle

Pauls 2L Milk Smarter White 2% Fat Front Bottle

Pauls 2L Milk Smarter White 2% Fat Back Bottle

Pauls 2L Milk Smarter White 2% Fat Back Bottle

 

 

 

 

 

 

 

 

 

 

 

Pauls 2L Milk Smarter White 2% Fat Back

Pauls 2L Milk Smarter White 2% Fat Back

Pauls 2L Milk Smarter White 2% Fat Front

Pauls 2L Milk Smarter White 2% Fat Front

 

 

 

 

 

 

 

 

  1. Prescribed Name, Name or Description of Food – Official name on the label for this product is on the back as ‘HOMOGENISED PASTEURISED 2% FAT MILK’. On the front label it has the words ‘SMARTER WHITE MILK’ with the first two words coloured yellow and the last word coloured white.  This statement is a registered trade mark (1546065) for the words not the style, shape, colour etc.  Is this misleading consumers as having the word ‘milk’ a different colour to separate itself from the trade mark?  At least the statement ‘Full Cream Taste’ is all in the same colour.  The food standards code 2.5.1 gives the definition of milk and skim milk.  In 2.5.1-4 has a requirement of retail sale as cow’s milk which this product does not comply due to milk fat levels being less than 32 g/kg.
  2. Company Name and Address – Pauls the brand and the company Parmalat Australia clearly labelling with the physical address.
  3. Weights and Measures Declarations – Clear and correct 2L on the front of the label. The ‘2L’ on the back and the red ‘2’ behind the barcode is extra information.  Having the 2L on the back label is helpful for manufacturing to quickly check the correct label is applied.
  4. (Production) Lot Identification – Codes printed on the bottle face. EST NO. is also part of the lot identification which is the export establishment number that produces edible prescribed goods for export.  As per the Export Control (Milk and Milk Products) Orders 2005 the registration number of the establishment at which the milk and milk product are last prepared (other than handled, loaded or stored) before being exported.  Why have establishment numbers when the product is sold in Australia?  The date and lot identification machine at manufacturing is set up to comply with domestic or export to reduce errors.
  5. (Shelf Life) Date Marking – This product has a use-by date, for a food for sale, means the date after which it is estimated that the food for sale should not be consumed because of health or safety reasons. No year is given for less than 3 months from the date the day and month must be present.  However as the month is expressed in letters the day ‘21’ could be in any order.
  6. Directions of Use and Storage – As this is a ‘use by’ product the storage information is important and has clear temperature range.
  7. Country of Origin – This product was purchased before the new Country of Origin labelling and the ‘Product of Australia’ is correct.
  8. Nutrition, Health and Related Claims – ‘Only 2% Fat’ claims is made on the front and back of the bottle. This is correct as the nutrition information panel has the total fat per 100mL at 2.0g.  The second claim on the pack is in the ingredients listing as ‘reduced fat milk (2.0% fat)’.  This meets the definition of a nutrition content claim as per section 1.1.2-9 and comparative claims 1.2.7-16.  In table S4-3 fat is column 1, reduced is column 3 and therefore have this statement on pack ‘The food contains at least 25% less fat than in the same amount of *reference food’.  The reference food can be in this case ‘milk’ and the percentage could be adjusted to 37.5%.
  9. Nutrition Information Requirements – The nutrition information panel meets all requirements. Calcium is also listed in the table as it is not in section S4-3 it may only state the specified amount of the property (Calcium) in a specified amount of that food.  The recommended dietary intake for this property in S-3 is shown in column 3; 800mg.
  10. Characterising Ingredients and Components of Food – NA
  11. List of Ingredients – Two ingredients used in this product; Reduced fat milk (2.0% fat), milk solids. As per the Australia New Zealand Food Standards Code 10-2 Generic names of ingredients and conditions of their use milk solids may be used to describe (a) milk powder, skim milk powder or dried milk products; or (b) any 2 or more of the following ingredients: (i) whey; (ii) whey powder; (iii) whey proteins; (iv) lactose; (v) caseinates; (vi) milk proteins; (vii) milk fat.
  12. Warning and Advisory Statement – Milk is listed in the ingredients list which is an allergy. As per Food Standard 1.2.3 table S9-2 this product is milk that contains no more than 2.5% m/m fat and the corresponding advisory statement ‘the product is not suitable as a complete milk replacement for children under 2 years’.  The start of the advisory statement is missing the words ‘the product is’ on the label.
  13. Legibility Requirements – No issues
  14. Other Information (Open) Marketing claims – ‘100% Australian Milk’ claim on front of pack.  As per point 7 this product is product of Australia and therefore Australian milk.