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Appendix to the Australian Dietary Guidelines: Dietary Guidelines through an environmental lens submission

This submission reflects the views of
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Sugar Australia Pty Limited
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Submission by Sugar Australia Pty Limited to the public consultation on the draft appendix to the Australian Dietary Guidelines

 Australian Dietary Guidelines through an environmental lens

2nd November 2012

Sugar Australia Pty Limited (Sugar Australia) welcomes the opportunity to respond to the public consultation on the draft appendix to the Australian dietary guidelines, concerning the guidelines’ environmental impact.

Sugar Australia strongly supports dietary guidelines that are based on the best available scientific evidence and within the context of a whole lifestyle approach, which encourages energy balance through exercise as well as consuming a range of foods to ensure optimal health in the longer term. Sugar Australia is committed to the accurate representation of the scientific evidence on sugars and health, noting that expert scientists agree that sugars are not directly responsible for lifestyle diseases including obesity, diabetes, cardiovascular disease or cancer1-5.

We agree that the issue of sustainable diets is complex and that there may be a need for guidance to the public. However we do not consider an appendix to the Dietary Guidelines is the correct approach, for two critical reasons:

  1. Dietary Guidelines are used by health professionals and health policy makers to advise Australians on a healthy eating, and in the long term to help reduce the risk of diet related diseases and conditions. Communication of dietary advice to populations is a difficult task. However the inclusion of environmental considerations, which in itself is a complex issue, could detract from the key messages that the dietary guidelines have to offer. Guidance on the environmental impacts of diets should not be included within the appendix, to ensure that key messages of the dietary guidelines are not misconstrued, and result in misleading advice or misdirected policy.
  2. The NHMRC places great importance in the strength of the evidence that is required for public health guidance, as is evident in the systematic review of the literature which was carried out to inform the dietary guidelines6. Sugar Australia supports this evidence based view. It is logical to expect public health guidance on the environmental impact of the dietary guidelines to be derived in the same rigorous scientific manner. However, this current consultation document states that much of the evidence on environmental impacts of the guidelines stems from narrative sources. It frequently refers to the limited evidence, different methodologies used which limit comparability of findings, most of the evidence is in relation to primary production, and there is ‘.. less available information for aspects of the food supply chain such as processing, distribution, retail, consumption and disposal of waste’.

It is clear that research in the area is lacking and with such poor quality information available it is not possible to make any meaningful conclusions. By way of illustration:

  • Guideline 3 on the environmental impact on foods containing added sugars, the key references provided confirm that ‘limited studies are available’. While the dietary guideline refers to limiting intake of foods and drinks containing added sugars, the practical considerations and environmental benefits given have not been aligned with this. They state ‘Avoid foods produced with high levels of added sugar...’. The interpretation of the dietary guideline in this way is of great concern and no evidence is presented to justify the use of the term ‘avoid’ when environmental concerns are considered.  In fact the evidence that has been provided is in relation to irrigated maize, vegetables and grain products. No evidence in relation to sugars or sugar containing foods or drinks is given.    
  • Dietary guideline 3 C itself has been based on poor evidence. The NHMRC systematic review of the literature states the evidence on sugars is grade D, is weak and any recommendations must be applied with caution. The strength of this evidence does not support the change the dietary guideline on sugars from ‘moderate’ to limit’ as a means to combat obesity. New research furthermore confirms that sugars consumption in Australia has continued to decrease over the past 40 years while obesity levels continue to rise7.  It was found that sugar consumption per capita has fallen from 57 kg/capita in 1951 to around 42 kg/capita in 20117. This new analysis of the data uses an updated ABS data series (original 1938-1998, updated 1999-2011), using the ABS methodology. It measures sales by domestic refiners to all direct users and manufacturers in Australia, and incorporates sugar imports into Australia. The report also found that claims of widespread use of fructose in place of sucrose in foods in Australia could not be verified7.


  •  The key references provided in the consultation document refer to discretionary choices and state ‘discretionary foods are not necessary for a nutritionally balanced diet’. This is controversial however since the dietary guidelines already make a provision for sugars within the recommendations. Regarding micronutrient density of the diet and sugars intakes, inconsistent outcomes been reported in the scientific literature8. A clear conclusion is further hampered due to use of varying sugars terminology, inconsistent adjusting of the data for energy intake and underreporting of dietary intakes9. Although the US dietary guidelines advisory committee suggested a maximum intake of 25% energy from added sugars, only some micronutrient dilution was seen in the supporting data, and no upper tolerable intake level for carbohydrates was set10. Added sugars intake is reportedly falling in the US, with 2011 estimates at 14.6% energy for children and adults11.  Furthermore a number of recent reviews of the evidence found either no or little impact of sugars intakes on nutrient adequacy in the diet4,8,9. The European Food Safety Authority also failed to set an upper limit for (added) sugar intake and suggested any effect on micronutrient density of the diet was related to the pattern of intakes of foods rather than to sugar itself1

We therefore strongly recommend that this annex is removed from the dietary guidelines. Rather than making recommendations purely as a result of public need for guidance, Sugar Australia considers it wiser to promote the need for further research in the area, particularly if there is any direct environmental effects on actual food and drink consumption and vice versa.

Yours sincerely

Tim Hart

Chief Executive Officer


  1. EFSA. Scientific Opinion on Dietary Reference Values for Carbohydrates and Dietary Fibre. EFSA Journal 2012; 8(3):1462
  2. FAO/WHO. (1997) Carbohydrates in human nutrition (FAO Food and nutrition Paper 66). FAO Rome
  3. Institute of Medicine. (2002) Dietary reference intakes for energy, carbohydrate, fiber, fat, fatty acids, cholesterol, proteins, and amino acids. The national Academies Press. Washington, D.C. 
  4. Ruxton, C. H., Gardner, E. J. & McNulty, H. M. (2010) Is sugar consumption detrimental to health? A review of the evidence 1995-2006. Crit Rev Food Sci Nutr, 50, 1-19
  5. Joint WHO/FAO Expert Consultation on Diet Nutrition and the Prevention of Chronic Diseases, Diet, nutrition and the prevention of chronic diseases: report of a joint WHO/FAO expert consultation, in World Health Organ Tech Rep Sep 2003: Geneva. p. i - viii, 1-149.
  6. NHMRC (2011) A review of the evidence to address targeted questions to inform the revision of the Australian Dietary Guidelines.
  7. Green Pool commodity Specialists (2012) Sugar consumption in Australia. A statistical update. https://greenpoolcommodities.com/files/8113/4932/3223/121004_Sugar_Consumption_in_Australia_-_A_Statistical_Update_-_Public_Release_Document.pdf
  8. Gibson (2007) Dietary sugars and micronutrient adequacy: a systematic review of the evidence. Nut res Rev 20: 121-131
  9. Livingstone & Rennie (2009) Added sugars and micronutrient dilution. Ob rev 10 (suppl 1) 34
  10. USDA/HHS (2010) report of the dietary guidelines advisory committee on the dietary guidelines for Americans 2010
  11. Welsh et al. (2011) Consumption of added sugars is decreasing in the United States. Am J Clin Nutr, 94, 726-34

Page reviewed: 4 February, 2013