Submissions to the 2012 Review of the National Industrial Chemicals Notification and Assessment Scheme–Australian Food and Grocery Council (AFGC)

The Discussion Paper: Review of the National Industrial Chemicals Notification and Assessment Scheme (NICNAS)–June 2012 was released on 1 June 2012. Submissions were received betweeen 1 June and 27 July 2012. The comments received from this consultation process will be used to inform the government of stakeholder views.

Page last updated: 12 October 2012

PDF printable version of Australian Food and Grocery Council (AFGC) submission (PDF 162 KB)

Australian Food and Grocery Council—Submission

To: Department of Health and Ageing & Department of Finance and Deregulation

In Response To: Review of the National Industrial Chemicals Notification and Assessment Scheme (NICNAS)

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Preface

The Australian Food and Grocery Council (AFGC) is the leading national organisation representing Australia's food, drink and grocery manufacturing industry.

The membership of AFGC comprises more than 150 companies, subsidiaries and associates which constitutes in the order of 80 per cent of the gross dollar value of the processed food, beverage and grocery products sectors.

Figure 4.1: Composition of the industry's turnover ($2008-09)D
With an annual turnover of $108 billion, Australia's food and grocery manufacturing industry makes a substantial contribution to the Australian economy and is vital to the nation's future prosperity. The industry is similar in size to the mining sector.

Manufacturing of food, beverages and groceries in the fast moving consumer goods sector is Australia's largest and most important manufacturing industry. Representing 26 per cent of total manufacturing turnover, the sector1 is the second largest industry behind the Australian mining sector and accounts for over one quarter of the total manufacturing industry in Australia.

The growing and sustainable industry is made up of over 30,100 businesses and accounts for $46 billion of the nation's international trade. The industry spends $368 million a year on research and development.

The food and grocery manufacturing sector employs more than 312,000 Australians, representing about 3 per cent of all employed people in Australia, paying around $13 billion a year in salaries and wages.

Many food manufacturing plants are located outside the metropolitan regions. The industry makes a large contribution to rural and regional Australia economies, with almost half of the total persons employed being in rural and regional Australia2 . It is essential for the economic and social development of Australia, and particularly rural and regional Australia, that the magnitude, significance and contribution of this industry is recognised and factored into the Government's economic, industrial and trade policies.

Australians and our political leaders overwhelmingly want a local, value-adding food and grocery manufacturing sector.
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1. Introduction
2. Overall Position
3. General Comments
4. Specific Comments—Key Issues of Concern
5. Conclusion
6. Attachment 1—Response to Options
AFGC Members List as at 30 July 2012

1. Introduction

The Australian Food and Grocery Council (AFGC) welcome the opportunity to provide a written submission in response to the discussion paper on "Review of the National Industrial Chemicals Notification and Assessment Scheme (NICNAS)."

AFGC is ready to work with the Departments of Health and Ageing and Finance and Deregulation to ensure that this reform process provides genuinely better regulation and supports our members to innovate and achieve sustainable growth.

This submission is in three parts:
  1. Overall position and key recommendations;
  2. General comments; and
  3. Specific comments on key issues of concern.
The AFGC look forward to the outcomes of the Better Regulation review and the opportunity to participate in further consultation on regulation and management of industrial chemicals.
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2. Overall Position

AFGC supports the objective of the Better Regulation Ministerial Partnership Review of NICNAS to look at ways of enhancing the competitiveness of the Australian chemical industry as well as improving public health and safety and environmental outcomes.

AFGC supports the view that the current systems in place for the management of industrial chemicals in Australia are fragmented, lack clarity, and pose a significant and unsustainable burden on industry. Current systems do not support innovation which is critical to maintaining and growing a viable industry within in Australia.

AFGC supports reform of chemical regulation which is needed to address deficiencies in the current system.

AFGC believe that the the top priorities for an effective and functional chemical regulator are:
  • A regulator focused on its core business—chemical notification and assessment;
  • Risk assessment based on science and risk analysis principles;
  • Recognition of chemical assessments by other regulators;
  • Strengthened alliances and building scientific capability;
  • Transparent in risk assessment decisions, and
  • Consultative through stakeholder engagement contributing towards regulatory development.

2.1. Key Recommendations

AFGC considers there are a number of key areas which must be given priority in the current review of Chemical Regulation and NICNAS to ensure that real gains and benefits are achieved. These are set out briefly below and discussed in further detail under Section 3.Top of page

2.1.1. Chemicals and Plastics Regulation Productivity Commission (PC) Research Report (2008)
Priority must be given to acting on the recommendations of The Productivity Commission's (PC) Research Report on Chemicals and Plastics Regulation (July 2008).

It is not productive to continue delaying or second-guessing the detailed consideration that was given to the recommendations.
2.1.2. The Regulatory Framework for Industrial Chemicals
  • AFGC propose that a high level structure is developed to provide a strategic overview for risk assessment of industrial chemicals and to gain clarity on the roles and responsibilities of the agencies involved.
  • AFGC propose the development of a National Chemical policy to provide overall structure and direction for the management of industrial chemicals in Australia.
  • The role and responsibilities of NICNAS need to be clarified in the context of overall management of chemical safety (PC Recommendation 4.3).
2.1.3. The regulation and administration of the Cosmetics Standard 2007
  • Cosmetics and cosmetic ingredients should be regulated separately to industrial chemicals.
  • Responsibility for administration and enforcement should be transferred from NICNAS to another agency (PC Recommendations 4.3 and 5.5).
2.1.4. New Industrial Chemicals
  • The regulation of new industrial chemicals should be harmonised with that of other advanced economies and trading partners including the US, EU, Canada and ASEAN.
  • NICNAS should focus on hazardous chemicals only and further options should be considered for the management of non-hazardous chemicals.
  • Consideration should be given to the development of a system for management of chemicals of low regulatory concern.
2.1.5. Existing Chemicals
  • The regulation of existing industrial chemicals should be harmonised with that of other advanced economies and trading partners including the US, EU, Canada and ASEAN.
2.1.6. Post Market Monitoring and Enforcement
  • AFGC does not support secondary notification.
  • NICNAS must maintain its focus on industrial and hazardous ingredients and not broaden its reach on formulated/finished goods.
2.1.7. Other Reforms
  • AFGC supports the use of international assessments to inform and streamline the risk assessment process.
  • There is an opportunity to reduce the time and lower the costs of regulation through notification only of certain low risk categories such as polymers, non-hazardous new chemicals and recognition of chemicals on international inventories.
2.1.8. Regulation Impact Statement (RIS)
  • AFGC supports the development of a comprehensive Regulation Impact Statement (RIS) to inform the final outcome of the review and ensure that the costs and benefits to all stakeholders are fully considered. 

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3. General comments

AFGC believes that an internationally competitive food and grocery industry supported by a robust and responsive policy and regulatory framework is critical to ensuring that our food and grocery supply is secure, that it meets the nutrition, health and safety needs of consumers and it is sustainable for the longer term.

AFGC considers that the vision for the food and grocery manufacturing sector should encompass the following two considerations:
  1. that all [relevant] needs of Australian consumers are met through the products available to them; and
  2. that the industries providing those products are as efficient and profitable as possible.
The first point goes to the important role of the food and grocery industry in supporting the health of consumers and their social and recreational needs. The second goes to the importance of these industries being as profitable as possible, employing Australians and generating wealth for the nation with minimal environmental impact.

AFGC support world class, efficient regulatory systems which encourage innovation and investment and ensures that Australia's manufacturing sector is sustainable. Australia needs a regulatory system that is efficient; transparent; accountable and predictable.

AFGC considers regulatory reform the most prominent and important policy lever which the Government can pull to assist the food and grocery industry meet the challenges it is now facing.

AFGC supports regulatory reform which results in efficient systems that reduce the regulatory compliance burden to industry; a streamlining of process and which encourages innovation and investment. The industry cannot support any increase in the cost of regulation and management of chemical safety; further red tape or impediments to innovation.

AFGC supports reform of chemical regulation which is needed to address deficiencies in the current system. The reforms need to encourage the development of modern, safe chemicals by removing barriers for companies to invest in cutting edge technologies and improve access to chemical products.Top of page

Regulatory reform must:
  • not diminish the level of protection for Australian industry;
  • meet community expectations for safety and sustainability;
  • minimise and prevent unnecessary regulatory burden on industry;
  • recognise the effect that regulation has on product availability and cost; and
  • recognise that Australia is part of a global market, and industry needs to leverage the new product development that occurs internationally, which necessitates a responsive and efficient regulatory system to bring new products to market in a timely manner.
3.1.1. Impact on the industry of increased costs
AFGC is concerned that the proposed reforms will not adequately address inefficiencies and costs in the current system, resulting in Australian manufacturers and suppliers being disadvantaged. This will, in turn, directly impact on the sustainability of Australian grocery manufacturers and suppliers through increased costs and lack of innovation.

Currently the international competitiveness of the Australian manufacturing sector is under pressure due to:
  • rising input costs—raw materials, energy, transport costs are all going up;
  • exchange rate effects—the high Australian dollar makes manufacturers less competitive against imports in the domestic market and competition in export markets;
  • regulatory compliance costs; and
  • retail sector concentration.
These factors combine to erode margins and reduce profitability thereby compromising long term competitiveness.

The overall effect is a decline in margins and the profitability of the industry, limiting funds available (including from raising debt) for investment and reinvestment in new plant and new process i.e. in innovation. This limits the growth in productivity, i.e. becoming more efficient and effective, necessary to remain competitive in international markets.

The ultimate result is that the business case for companies to invest and re-invest in manufacturing in Australia is severely compromised. This leads to reduced levels of innovation, loss of competitiveness and business closures or relocation offshore.
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4. Specific Comments—Key Issues of Concern

AFGC has provided responses on the possible options for reform under Attachment 1, however, we defer to Accord for more detailed feedback.

AFGC do however; wish to highlight specific areas of concern which are set out in the following section.
4.1.1. Productivity Commission Review 2008
AFGC support the recommendations of the Chemicals and Plastics Regulation Productivity Commission (PC) Research Report (2008).

The Productivity Commission's (PC) research report provided a road map for reform—improving the efficiency and effectiveness of the chemicals and plastics industry, including a new governance framework to achieve better coordination of chemicals and plastics regulation. The road map was developed through a negotiated outcome which included all stakeholders: government, the community and industry.

While AFGC agree that it is appropriate to conduct a review of NICNAS and the ICNA Act, there is a need for action on the overarching management and regulation of chemicals in Australia. The PC report provided the road map and action is required to achieve genuine reform in this area.

AFGC consider that failure to act on the recommendations of The Productivity Commission's (PC) Research Report on Chemicals and Plastics Regulation (July 2008) is of major concern. Top of page

The 30 recommendations in the report were developed after an extensive consultation process and the lack of action or progress against these recommendations is not acceptable given the potential benefits for industry in a highly challenging and competitive market place.
4.1.2. The Regulatory Framework for Industrial Chemicals
The review fails to put in place reforms to clarify the roles and responsibilities of NICNAS. This is a fundamental issue which needs to be addressed as a priority in the reform of management of chemical regulation.
4.1.3. Regulation of Cosmetics
AFGC considers that cosmetics and cosmetic ingredients should be treated differently and separately to industrial chemicals as is the case in most other markets and is pleased the discussion paper recognises that specific requirements for chemicals in cosmetics are needed. Ingredients in cosmetics should be considered in the context of the cosmetic product and not an industrial chemical.

AFGC support the position that the regulation of cosmetics should be separate to that for industrial chemicals—they require a different regulatory framework.

AFGC supports removing cosmetic products and ingredients from the scope of industrial chemicals regulation and harmonising their treatment with that of the EU, ASEAN economies and New Zealand.

Consideration could be given to a system along the lines of the NZ EPA Group Standard—this has the benefit of being regulated but also recognizes other international regulations such as EU, IFRA code, etc.

Recognition of IFRA compliance would potentially negate the need for fragrance components to be on AICS.
4.1.4. New Industrial Chemicals
The industrial chemical regulatory systems of Europe, United States and Canada service combined populations of about 850 million people.

There is need for Australia to move away from arguing whether or not there are differences in methodologies or approaches and accept the outcomes of assessments from the major recognised regulatory systems.

Harmonising the regulatory treatment of new industrial chemicals with that of other advanced economies is efficient and recognises the fact that ANZ are very small markets. The current systems provide barriers to entry and a disincentive to manufacture in Australia and limiting sales potential compared with other countries.Top of page

Companies need access to new and innovative products to remain viable and able to compete. Like NZ, Australia is a small player in the world market and cannot afford to import products with unique requirements. Similarly local manufacturers are unable to buy or import specialized ingredients used in other major markets that are new to Australia without a huge regulatory burden.

Australian consumers have become sophisticated and want the newest and most innovative products. The current ingredient regulation framework impedes the introduction of products with innovative ingredients that are new to Australia.
4.1.5. Existing Chemicals
The regulation of existing industrial chemicals should be harmonised with that of other advanced economies and trading partners including the US, EU, Canada and ASEAN.
4.1.6. Post Market Monitoring and Enforcement
AFGC does not support secondary notification.

AFGC notes that there are a number of adverse event reporting systems already available: for consumer products there is a comprehensive mandatory product safety reporting scheme under the ACCC. It is inefficient to create another scheme, instead administrative options should be explored in ensuring that information provided to ACCC through mandatory notifications is subsequently provided to NICNAS for the purpose of follow-up action following ACCC investigation.

NICNAS must maintain its focus on industrial and hazardous ingredients and not to broaden its reach on formulated/finished goods.
4.1.7. Other Reforms
AFGC supports the use of international assessments to inform and streamline the risk assessment process.

There is an opportunity to lower the costs of regulation through notification only of certain low risk categories such as polymers, non-hazardous new chemicals and recognition of chemicals on international inventories. There are a range of known issues with the efficiency and effectiveness of the management of chemicals of low regulatory concern. At present it is not serving to meet the original policy intention, including optimally balancing risk-resource allocation.
4.1.8. Impact on Innovation
In the current economic climate (previously discussed), innovation is key to industry remaining strong and competitive. Barriers to innovation are a further burden and disincentive to industry to invest.Top of page

The pressures of performance and increasing competition will continue to compel all manufacturers to improve the effectiveness of investment in innovation. Excessive and unnecessary regulatory burden reduces incentive for innovation by industry, with negative consequences for investment in new products.

Australian companies are the ones who suffer the most from unnecessary delays and costs in the system with inefficiencies slowing the introduction of innovative new chemicals and adding to product prices. This in turn impacts on Australian companies through increased costs or reduced capacity to innovate.

AFGC is concerned that a failure to implement effective reforms will result in loss of existing products and discourage and delay introduction of new products for the following reasons:
  • Excessive and unnecessary regulatory burden reduces incentive for innovation by industry, with negative consequences for investment in new products;
  • Greater regulatory costs will remove products that have small markets.
The pressures of performance and increasing competition will continue to compel all manufacturers to improve the effectiveness of investment in innovation. Excessive and unnecessary regulatory burden reduces incentive for innovation by industry, with negative consequences for investment in new products. More importantly, Australian consumers are missing out on the innovation that other developed economies enjoy.

AFGC is concerned that the proposed reforms will not address the intrinsic problems with the current secondary notification system. This may result in loss of existing products and discourage or delay introduction of new products. This may be especially true for products that have small markets.

AFGC is also seeking assurance that confidentiality is maintained and commercially sensitive data is protected, this is important to give companies assurance that their investment in innovation will be protected.Top of page

5. Conclusion

The food and grocery manufacturing sector is Australia's largest manufacturing sector. As such it, expects Government to be mindful of, and responsive to, the changing dynamics and the potential impacts on the industry—particularly in the context of Government's overall policy agenda which should be to ensure Australians continue to have access to wholesome affordable food and grocery products, manufactured by a competitive and wealth generating industry.

The Australian food and grocery industry is finding business conditions particularly challenging due to a number of factors coming together at once to create a "perfect storm". Some can be directly influenced by Government policy; others are of a global nature. It is, however, no exaggeration to state that the well-being of the food and grocery manufacturing sector and the wellbeing of Australians are intricately linked.

AFGC supports a regulatory system that provides companies with the framework and direction to continue to provide better and more targeted products to meet the needs of consumers. AFGC also supports world class, efficient regulatory systems which encourage innovation and investment and which ensure that Australia's manufacturing sector is sustainable.

AFGC has identified a number of issues with respect to the review of NICNAS and urges the Better Regulation partnership to give full and urgent consideration to the recommendations set out in this submission.Top of page

6. Attachment 1—Response to Options

Discussion Paper: Review of the National Industrial Chemicals Notification and Assessment Scheme (NICNAS), June 2012

As previously stated, AFGC will defer to Accord for specific and detailed comment on the questions in the discussion paper.
Part 4—The regulatory framework for industrial chemicals (options A1—A3)
A1. AFGC do not see this recommendation as a priority. It is more important to implement the PC recommendation 4.3 first and subsequent to that, establish clear roles and responsibilities for NICNAS.

A2. AFGC supports this option.
AFGC propose that a high level structure is developed to provide a strategic overview for risk assessment of industrial chemicals and to gain clarity on roles and responsibilities of involved agencies.

Any initiative in this area would need to be under pinned by a National Chemical policy to provide overall structure and direction.

A3. AFGC support this recommendation in principle.

AFGC Support a review however, as per our response to A1, it is more important to implement the PC recommendation 4.3 first and subsequent to that, review existing and new MOUs required as a result of a National Chemical policy.
Part 5—New industrial chemicals (options B1-B6)
B1. Notification and Assessment categories

AFGC supports a review of the number assessment categories for exemptions, permits and certificates and a review of current volume thresholds, data requirements and applicability criteria such that they are consistent and harmonised with that of other advanced economies and trading partners including the US, EU, Canada and ASEAN.

AFGC support is conditional on there being no increase in costs or regulatory burden which should be assessed as part of the proposed RIS.

The scope of management of industrial chemicals should be restricted to hazardous chemicals only. Annual reporting for small volumes of chemicals should be eliminated—this is an unnecessary burden on industry.

B2. Exemptions

AFGC would support new or expanded exemptions consistent with that of other advanced economies and trading partners including the US, EU, Canada and ASEAN. Non hazardous chemicals should be exempt.

There should be a reduction or elimination of reporting requirements; increase in the range of exemptions and reduced risk management requirements for low risk chemicals. For example: exemptions for new chemicals that would have an annual/12 month volume of ≤1000 kg.

B3. Permits and Assessment CertificatesTop of page

AFGC would support measures to enhance the efficiencies in the screening process but this must not add further cost to the process and there must be measures in place to ensure that the process is adhered to by NICNAS.

B4. Assessment Certificates

AFGC would support streamlining of the assessment process having regard to models operating in other advanced economies.

These powers give risk manager status which was never intended and duplicates the role of other risk managers.

AFGC supports the PC recommendation 4.3 in relation to limiting the role of NICNAS to scientific assessment of the hazards and risks of industrial chemicals.

AFGC does not support NICNAS having risk management responsibility.

B5. AFGC do not agree with the linking of the first recommendation under B5 to PC recommendation 4.4—they do not appear to be related.

AFGC do not support the options put forward under B5.

B6. AFGC support but note that changes to the ICNA Act should not add complexity and should not be aligned to NICNAS's role of risk assessor.
Part 6—Existing industrial chemicals (options C1-C6)
C1. Assessment process for PECs

AFGC supports the intention of C1. Whatever process is used, it must enable a more rapid and flexible process.

C2. AFGC questions this recommendation when the Inventory Multi-tiered Assessment and Prioritisation (IMAP) framework has recently been introduced.

C3. Any initiative to broaden NICNAS powers must not add further cost to the process and there must be measures in place to ensure that the process is adhered to by NICNAS—AFGC does not support NICNAS having broader powers.

C4. AFGC supports removal of the general power for NICNAS to impose conditions of use on chemicals after a chemical has been entered on AICS. Top of page

AFGC does not support the other sub points under C4.

C5. AFGC does not support this option and is concerned that it would add further cost and resource burden to industry.

C6. AFGC support but note that a more strategic review and consequent high level changes would be more effective than ad hoc changes to specific areas.

Part 7—Post market monitoring and enforcement (Options D1-D3)
D1. Secondary Notification Process

AFGC does not support secondary notification.

D2. Adverse Effects reporting

AFGC does not support option D2. There are a number of adverse event reporting systems already available: for consumer products there is a comprehensive mandatory product safety reporting scheme under the ACCC. It is inefficient to create another scheme.

NICNAS must maintain its focus on industrial and hazardous ingredients and not to broaden its reach on formulated/finished goods.

D3. AFGC has no objection in-principle to this option, however notes that compliance requirements should be proportional to risk.

Part 8—Other reforms—release of information and confidential commercial information (Options E1-E2)
E1. AFGC does not support this option.

E2. AFGC does not support this option.Top of page

Part 8—Other reforms—use of foreign schemes/ international assessments (Options F1-F2)
F1. AFGC strongly supports this option—it is appropriate for Australian agencies to accept hazard assessments from first world economies.

F2. AFGC supports this option.

Part 8—Other reforms—chemicals in articles (Options G1-G2)
G1. AFGC support the implementation of PC recommendation 4.3 first and subsequent to that, establish clear roles and responsibilities for NICNAS.

G2. AFGC would support a strategic review of the ICNA Act rather than an adhoc review of specific elements.
Part 8—Other reforms—chemicals in cosmetics (Option H1-H2)
H1. AFGC support this option

AFGC agree that transferring the administration and enforcement of Cosmetics to the ACCC is a logical and positive step towards simplifying the fragmented regulation of cosmetics. ACCC already has responsibility for consumer product safety, cosmetic product ingredient labelling and the substantiation of efficacy and consumer claims, and the avoidance of therapeutic claims.

H2. AFGC does not support this option.

Part 8—Other reforms—Import and export of chemicals under the Stockholm and Rotterdam Conventions (Option I1-I2)
I1. AFGC support this option.

I2. AFGC does not support this option; it is inconsistent with the recommendation of the PC.
Part 8—Other reforms—Governance—Committees (Option J1)
J1. AFGC support PC recommendation 4.2—the establishment of a technical advisory committee to provide advice to the Director, NICNAS. This option can be explored more fully once the roles and responsibilities of NICNAS have been defined.
Part 8—Other reforms—Governance—Relationship with the Department of Health and Ageing (DoHA) (Option K1)
K1. AFGC support this option.Top of page

AFGC Members List as at 30 July 2012

  • Arnott's Biscuits Limited
  • Australian Blending Company P/L
  • Barilla Australia Pty Ltd
  • Beak & Johnston Pty Ltd
  • Beechworth Honey Pty Ltd
  • Beerenberg Pty Ltd
  • Bickfords Australia
  • Birch and Waite Foods Pty Ltd
  • Body Science International
  • Bronte Industries Pty Ltd
  • Bulla Dairy Foods
  • Bundaberg Brewed Drinks Pty Ltd
  • Bundaberg Sugar Limited
  • Byford Flour Mills T/a Millers Foods
  • Byron Food Services
  • Campbell's Soup Australia
  • Canon Foods
  • Cantarella Bros Pty Ltd
  • Carman's Fine Foods Pty Ltd
  • Cerebos (Australia) Limited
  • Cheetham Salt Ltd
  • Christie Tea Pty Ltd
  • Church & Dwight (Australia) Pty Ltd
  • Clorox Australia Pty Ltd
  • Coca-Cola Amatil (Aust) Limited
  • Coca-Cola South Pacific Pty Ltd
  • Colgate-Palmolive Pty Ltd
  • Coopers Brewery Limited
  • Danisco Australia Pty Ltd
  • Devro Pty Ltd
  • DSM Food Specialties Australia Pty Ltd
  • Earlee Products
  • Eagle Boys Pizza
  • FPM Cereal Milling Systems Pty Ltd
  • Ferrero Australia
  • Fibrisol Services Australia Pty Ltd
  • Fonterra Brands (Australia) Pty Ltd
  • Food Spectrum Group
  • Freedom Foods
  • Frucor Beverages (Australia)
  • General Mills Australia Pty Ltd
  • George Weston Foods Limited
  • GlaxoSmithKline Consumer Healthcare
  • Go Natural
  • Goodman Fielder Limited
  • Gourmet Food Holdings
  • H J Heinz Company Australia Limited
  • Harvest FreshCuts Pty Ltd
  • Healthy Snacks
  • Hoyt Food Manufacturing Industries P/L
  • Hungry Jack's Australia
  • IGEA Group
  • Jalna Dairy Foods
  • JBS Australia Pty Limited
  • Johnson & Johnson Pacific Pty Ltd
  • Kellogg (Australia) Pty Ltd
  • Kerry Ingredients Australia Pty Ltd
  • Kimberly-Clark Australia Pty Ltd
  • Kraft Foods Asia Pacific
  • Laucke Flour Mills
  • Lindt & Sprungli Australia
  • Lion Dairy and Drinks
  • Madura Tea Estates
  • Manildra Harwood Sugars
  • Mars Australia
  • McCain Foods (Aust) Pty Ltd
  • McCormick Foods Aust. Pty Ltd
  • McDonald's Australia
  • Merisant Manufacturing Aust. Pty Ltd
  • Metarom Australia
  • Mrs Mac's Pty Ltd
  • Murray Goulburn Co-operative
  • Myosyn Industries
  • Nerada Tea Pty Ltd
  • Nestlé Australia Limited
  • Nutricia Australia Pty Ltd
  • Ocean Spray International Inc
  • Only Organic 2003 Pty Ltd
  • Parmalat Australia Limited
  • Patties Foods Pty Ltd
  • Pfizer Consumer Healthcare
  • Popina (Vic) Pty Ltd
  • Procter & Gamble Australia Pty Ltd
  • Queen Fine Foods Pty Ltd
  • QSR Holdings
  • Reckitt Benckiser (Aust) Pty Ltd
  • Red Bull Australia
  • Rosella Foods Pty Ltd
  • Sandhurst Fine Foods
  • Sanitarium Health and Wellbeing
  • Sara Lee Australia
  • SCA Hygiene Australasia
  • Schweppes Australia
  • Sensient Technologies
  • Simplot Australia Pty Ltd
  • Solaris Paper
  • Spicemasters of Australia Pty Ltd
  • Steric Pty Ltd
  • Stuart Alexander & Co Pty Ltd
  • Subway
  • Sugar Australia Pty Ltd
  • SunRice
  • Tasmanian Flour Mills Pty Ltd
  • Tate & Lyle ANZ
  • The Smith's Snackfood Co.
  • The Vege Chip Company
  • The Wrigley Company
  • Tixana Pty Ltd
  • Unilever Australasia
  • Vital Health Foods (Australia) Pty Ltd
  • Ward McKenzie Pty Ltd
  • Yakult Australia Pty Ltd
  • Yum Restaurants International

Associate & *Affiliate Members

  • Addisons
  • Australian Pork Limited
  • ACI Operations Pty Ltd
  • Allens Arthur Robinson
  • Amcor Fibre Packaging
  • *ASMI
  • AT Kearney
  • Baker & McKenzie
  • *Baking Association Australia
  • Benchmarking for Performance
  • Bizcaps Software
  • Brisbane Marketing
  • CHEP Asia-Pacific
  • CSIRO Food and Nutritional Sciences
  • *CropLife
  • CROSSMARK Asia Pacific
  • Dairy Australia
  • Ettlin International
  • FACTA (Food Allergen Control Training Analysis)
  • *Food & Beverage Importers Ass.
  • Food Liaison Pty Ltd
  • *Foodservice Suppliers Ass. Aust.
  • *Food industry Association QLD
  • *Food Q
  • Foodbank Australia Limited
  • *Grains & Legumes Nutrition Council
  • Grain Growers
  • Grant Thornton
  • GS1
  • Harris Smith
  • IBM Business Cons.
  • Infosys
  • innovations & solutions
  • KPMG
  • King & Wood Mallesons
  • Legal Finesse
  • Linfox Australia Pty Ltd
  • Logan Office of Economic Dev.
  • Meat and Livestock Australia Limited
  • Monsanto Australia Limited
  • New Zealand Trade and Enterprise
  • Pacific Strategy Partners
  • *PLMA Australia/ New Zealand
  • QLD DEEDI
  • Red Rock Consulting
  • Rentokil Initial
  • RQA Product Risk Institute
  • Simons Green Energy
  • Six Degrees Executive
  • Spectrum Automation
  • StayinFront Group Australia
  • Strikeforce Alliance
  • Swire Cold Storage
  • Swisslog Australia Pty Ltd
  • Tetra Pak Marketing Pty Ltd
  • The Food Group Australia
  • The Nielsen Company
  • Touchstone Cons. Australia Pty Ltd
  • Visy Pak
  • Wiley & Co Pty Ltd

PSF Members

  • Amcor Packaging Australia
  • Bundaberg Brewed Drinks Pty Ltd
  • Schweppes Australia Pty Ltd
  • Coca-Cola Amatil (Aust) Limited
  • Lion Dairy and Drinks
  • Owens Illinois
  • Visy Pak
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Australian Food and Grocery Council
Level 2, Salvation Army House
2–4 Brisbane Avenue
Barton ACT 2600

Locked Bag 1
Kingston ACT 2604

T: (02) 6273 1466
F: (02) 6273 1477

AFGC's Website

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1Fast moving consumer goods includes all products bought almost daily by Australians through retail outlets including food, beverages, toiletries, cosmetics, household cleaning items etc.
2Department of Foreign Affairs and Trade—About Australia




A full list of all 2012 submissions can be viewed at June 2012 submissions to the review of NICNAS.