On the 24th July, 2023, Food Standards Australia New Zealand (FSANZ) called for public comment to clarify requirements with respect to carbohydrate and sugar claims on alcoholic beverages. Standard 1.2.7 in the Food Standards Code currently permits voluntary claims about carbohydrate content in alcoholic beverages. However, the Code lacks clarity around the extent of these content claims. FSANZ is proposing to amend the standard to clarify what content claims are permitted for carbohydrate and sugar on food containing more than 1.15% ABV.

Over the last decade there has been an increase in the prevalence of alcoholic beverages that carry nutrition content claims about sugar and/or carbohydrate according to Proposal P1049  (submission deadline: 4 September 2023). In 2020, FSANZ undertook a limited, qualitative survey of nutrition information on the labels of alcoholic beverages for sale at major liquor retail outlets and supermarkets. The actual claims on the labels (Table 2) found from the survey were “Low carb”, “Lower carb”, “X% less carbs”, “No carbs” and so on for carbohydrate claims, and “Low sugar”, “Lower sugar”, “X% less sugar”, “No sugar”, “Zero sugar” and so on for sugar claims.

In 2022, FSANZ undertook a rapid systematic review to examine the available evidence on consumer value, perceptions and behaviours in response to carbohydrate and sugar claims on alcoholic beverages and concluded that consumers generally have a poor understanding of the nutritional properties of alcoholic beverages. Therefore, sugar/carbohydrate claims may cause consumers to make inaccurate assumptions about alcohol and energy in alcoholic beverages.

The new draft (Draft variation to the Australia New Zealand Food Standards Code (Attachment A) ) clarifies the scope of labeling for carbohydrate and sugar claims for a food that contains more than 1.15% alcohol by volume. The draft variation also contains amendments, which if approved, would prohibit nutrition content claims about specifically named sugars (e.g. fructose) and about components of carbohydrate other than sugar (e.g. fibre) .

sugar means, unless otherwise expressly stated, any of the following:
(a) white sugar;
(b) caster sugar;
(c) icing sugar;
(d) loaf sugar;
(e) coffee sugar;
(f) raw sugar.

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(1) A nutrition content claim or health claim must not be made about:
(a) kava; or
(b) an infant formula product; or
(c) a food that contains more than 1.15% alcohol by volume, other than a nutrition content claim about:
(i) salt or sodium content of a food that is not a beverage;
(ii) carbohydrate content;
(iii) energy content;
(iv) gluten content;
(v) sugar content; or
(vi) sugars content.

(2) A nutrition content claim about sugars content of a food that contains more than 1.15% alcohol by volume must not name or refer to any specific sugars.
Example A nutrition content claim that refers to fructose is not permitted.

(3) A nutrition content claim about carbohydrate content of a food that contains more than 1.15% alcohol by volume must not name or refer to a component of carbohydrate other than sugar or sugars.

(See Standard 1.1.2 for the definition of sugars (pg9))

Additionally, this proposal includes overseas regulations such as EU, United States and Canada. If you consider exporting your products to Australia and New Zealand, it is recommended that you check your own country’s standards against those of Australia and New Zealand for better understanding.

F.Y.I. (the Japanese regulation)
Article 7 of the Food Labeling Standards: “A statement of the ability of a food to ensure the proper intake of certain nutrients/calories” (and “Appended Table 13”) (no sugar, low sugar, sugars X% off, etc.), Article 7 of the same Standards: “A statement that no sugars* is added” (no sugars added, no sugar used, etc.).
*: must be Monosaccharides of Disaccharides and confined to “non sugar alcohol”

Hiroyuki Kawai

Label bank Co., Ltd. CEO (Founder)
Born in Japan. Working on solving various issues related to food labeling operations. Also regularly gives lectures for various organizations in Japan.
Co-author of ‘Latest edition: Guide book Food Labeling Law and related business practical points – from scratch (Japanese version only)’ (DAI-ICHI HOKI CO., LTD/2019).