FSANZ P1066 – Review of Formulated Supplementary Foods for Young Children
23 July 2026
Executive summary
AFGC does not support the proposed regulatory framework to young child formula (YCF) as presented in the first call for submissions to P1066 – Review of young child formula. The proposed restrictions on nutrition content claims, health claims, stage labelling and other representations would limit truthful and non-misleading information that may help caregivers understand product composition and make informed choices. These claims are already regulated under Standard 1.2.7 and must be substantiated, not misleading and consistent with the overall diet. The consultation material does not demonstrate that broad prohibitions are necessary, proportionate or the least restrictive way to address the issues identified.
The proposal also raises important trade and competitiveness concerns. Divergence from international approaches, particularly where other markets permit claims or manage comparable products through general food law, may increase compliance complexity, reduce label harmonisation, restrict cross-border e-commerce, and disadvantage Australian and New Zealand products in export markets. These impacts have not been adequately identified or quantified in the preliminary cost-benefit analysis.
Industry feedback indicates that the proposed framework may reduce incentives to invest in YCF science, product innovation and the ANZ market more broadly. Over time, this may reduce consumer access to advanced, science-based formulations and weaken the commercial case for future manufacturing, supply chain and employment investment in Australia and New Zealand.
However, AFGC is supportive a proportionate regulatory framework that improves caregiver understanding of the age suitability, intended purpose, composition and safe use of YCF. AFGC also supports regulatory clarity where it is evidence-based, practical for industry and consistent with the supplementary role of the product. Any additional requirements should be targeted to demonstrated risks and should not unnecessarily restrict lawful, truthful and substantiated information.
AFGC recommends that FSANZ refine Proposal P1066, so any new requirements are proportionate, evidence-based and targeted to demonstrated risks, while recognising the supplementary role of YCF. FSANZ should also use the next-stage CRIS to revise the cost-benefit analysis, so it better reflects the YCF market and the proposal’s likely practical impacts.
