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Senator Susan McDonald
Senate Standing Committees on Rural and Regional Affairs and Transport
PO Box 6100
Parliament House
Canberra ACT 2600

Re: Definitions of meat and other animal products

Dear Senator McDonald,

GrainGrowers is a voice for Australian grain farmers with grower members across Australia. We work to build a more sustainable and profitable grains industry for the benefit of Australian grain farmers. GrainGrowers welcomes this opportunity to provide a submission on the Definitions of Meat and Other Animal Products to the Senate Rural and Regional Affairs and Transport Legislation Committee.

The Australian grains sector is a powerhouse of regional Australia with 22,000 farm businesses growing on average 45 million tonnes of grains, oilseeds and pulses each year for domestic and global customers. The Australian agricultural sector is striving to reach $100 billion farmgate value by 2030, up from a current value of $61 billion with the broader agribusiness supply chain striving to reach $300 billion. As one of Australia’s largest agricultural industries, the grains sector will be critical in reaching that ambitious goal.

Plant-Sourced Meat Industry: Opportunities and Risks
Despite achieving high sales growth rates, the plant-sourced meat analogues market is currently small when compared to its animal-sourced counterpart reaching a mere 0.3% of fresh meat volume sales and 0.4% of value sales1, although studies indicate that the potential for growth varies greatly between countries2. Protein mainly in the form of soy extract is imported, often from countries that are much more highly subsidised. Significant varietal improvement is required for soy to out-perform other crops in the Australian farming context. Further, Australia lacks the capacity of appropriate processing facilities. However, with the development of this market, domestic processing capabilities are set to be improved in order for plant-based protein production to have a more sustainable and marketable place in the market while potentially providing further employment opportunities.

The development of the local plant-based alternatives market would see increased demand of locally produced grains, pulses and oilseeds, which is particularly important when considering the uncertainty regarding international market volatility and trade tariff impositions by overseas trade partners. Another domestic option for these commodities allows for a more diversified market portfolio in the long term. Therefore, allowing for the natural development of this industry in Australia would benefit Australian grain and pulse farmers.

The vast majority of grain farmers operate mixed-farming enterprises, using this diversified production model to manage risks, be they due to climatic conditions or market fluctuations. These mixed-farming models generally operate with a synergy between grain and pulse production, and rearing livestock. In addition, around 20% of Australia’s grain production is used for domestic animal-based protein production as a staple feed source3 with an upward trend due to the effects of drought and an increased demand for grainfed beef from key international markets. It can be inferred then that a negative effect on the marketability of animal-based proteins would have a negative effect on the demand for grain as a feed source.

Regulation and definitions
Growing consumer interests, particularly in the EU and US markets, have led to legislative reform on this topic. The Good Food Institute (GFI), an organisation advocating for alternative proteins, has recently been granted observer status in the Codex Alimentarius Commission by the FAO4, allowing participation in developing standards for the alternative protein sector and attendance of meetings of individual Codex committees relevant to that sector. Given the importance of the Codex on global food trade, this is a clear indication that global food regulations on alternative proteins are changing. Australia needs to maintain regulations up to date with consumer preferences to allow for greater market penetration.

Under Food Standards Australia New Zealand (FSANZ) Code – Standard 2.2.1, meat is defined as:
“the whole or part of the carcass of any of the following animals, if slaughtered other than in a wild state:
(i) buffalo, camel, cattle, deer, goat, hare, pig, poultry, rabbit or sheep;
(ii) (ii) any other animal permitted for human consumption under a law of a State, Territory or New Zealand; and does not include:
a. (i) fish; or
b. (ii) avian eggs; or
c. (iii) foetuses or part of foetuses”.

FSANZ further expands on the requirements for sale of meat-derived products, stating that they must contain meat as a base ingredient. However, as stated in the FSANZ Submission, Section 1.1.1—13 of the Code states that:
“these compositional requirements must be satisfied in any sale in which a purchaser is
likely to assume that the food being sold was one of the meat-derived products listed
(e.g. a sausage) unless the context makes clear this is not the intention”

“this not just applicable to meat and plant-based foods, it applies across the food supply
(e.g. a beverage named as ‘ginger beer’ does not need to comply with Code
requirements for beer, as ‘ginger’ provides the context of the beverage)”.

Therefore, under the Code, analogue products such as ‘vegan sausage’ are not covered by the compositional requirements stated under Standard 2.2.1 of the Code.

Commentary from the then Commonwealth Office of Legislative Drafting and Practice (OLDP) on Standard 1.2.2, further to consideration of Proposal P1025 - Code Revision, notes that “the standard allows food to be named in ways that are technically untrue i.e. plant based milk is not actually milk, provided the product contains additional information to help indicate the true nature of the product e.g. soy milk”. OLDP recommended the standard be amended to prevent outcomes of this kind. FSANZ did not adopt the recommendation as focus was reportedly aimed at the legal efficiency of the Code rather than the outcomes it delivers5.

According to the Australia and New Zealand Ministerial Forum on Food Regulation6,

“Australian Consumer Law prohibits a business from making false or misleading representations about goods or services (Competition and Consumer Act 2010 (Cth) Schedule 2, s29)”;

GrainGrowers’ Position

GrainGrowers believes that the current provisions in Australia are not adequate and do lead to confusion and unfair outcomes for all stakeholders involved.

Regarding food labelling reforms, GrainGrowers supports the submission of the proposed principles provided by the NFF7 :

  • A fair and balanced regulatory environment for meat, dairy, and plant-based protein sectors.
  • Food labelled with an animal product descriptor must be derived from an animal.
  • Minimum regulated standards that prohibit:
    • plant protein descriptors that contain any reference to animal flesh or products; and
    • the use of livestock images on plant protein packaging or marketing materials.

Care must be taken that any regulatory changes to the labelling definitions of either end-products, be they plant- or animal-based, do not negatively impact growers, their livelihoods, and their day-to-day operations. Any claims placed on the label of a product should be scientifically supported so that consumer confusion and misinformation is avoided.

To conclude, GrainGrowers seeks the development of a fair regulatory environment for both animal- and plant-based protein sectors and believes that a solution that fosters an amicable environment between those sectors would ultimately benefit Australian farmers and consumers. The ensuing regulatory environment should not impede on future innovation and market capture and should allow for better outcomes for a market of rapidly changing customer preferences as we move into the future.

Should you require any further information, please contact GrainGrowers’ General Manager for Policy and Advocacy, Zachary Whale on (02) 9286 2000 or

Yours sincerely,

David McKeon
Chief Executive Officer

  1. MLA (2020) State of the Industry Report via
  2. AgriFutures (2020) The changing landscape of protein production: opportunities and challenges for Australian
    agriculture via
  3. GrainGrowers (2021) State of the Australian Grains Industry 2021 (unpublished) granted
  4. Good Food Institute (2021) via
  5. Food Regulation Standing Committee (FRSC). May 2019. Misleading descriptions for food. Accessed at misleading-descriptions-for-food.pdf
  6. Food Regulation Standing Committee (FRSC). May 2019. Misleading descriptions for food Options Paper.
    Accessed at
  7. NFF RRAT Submission – Definitions of meat