Complaint to ACCC about Helga's wrap labels

On behalf of the Food Intolerance Network, I have lodged an official complaint today 20/08/2014 with the Australian Competition and Consumer Commission (ACCC) as follows:

Goodman Fielder Limited ACN 000 024 546
Helga’s Continental Bakehouse


The Helga's Continental Bakehouse "Mixed Grain Wraps" claim on the packaging "no preservative 282" (which is calcium propionate) but the list of ingredients includes "cultured dextrose", which is a propionate-based preservative. Dextrose has been cultured with propionibacteria to produce a preservative indistinguishable from that which is claimed not to be present in these wraps.

This is clearly intended to mislead consumers into thinking that this product does not contain the bread preservative, which many consumers seek to avoid and which has been shown to affect children and adults in their health, behaviour and learning.

More information and scientific references:

Australia's food regulator FSANZ have in the past declined to act on this misleading advertising. A complaint to ACCC in 2010 on the same topic was referred by ACCC to FSANZ who referred us in turn to the ACCC. This is an inadequate public response from two agencies responsible for protecting consumers.

(The above complaint was also copied to the CEO of Australia's food regulatory agency today, saying "Does FSANZ really believe that it can regulate additives while permitting them to be added as ingredients?")


Howard Dengate BSc PhD 
02 6654 7500
PO Box 718 WOOLGOOLGA NSW 2456 Australia

The Food Intolerance Network is a free service with over 10,000 families mostly in Australia and New Zealand and provides independent information about the effects of food on behaviour, health and learning ability in both children and adults, and support for families using a low-chemical elimination diet free of additives, low in salicylates, amines and flavour enhancers (FAILSAFE) for health, behaviour and learning problems.

If you would like to be counted as a supporter, you can subscribe to our free email newsletter (4 issues per year) by sending an email with "subscribe" in the subject line to address: This email address is being protected from spambots. You need JavaScript enabled to view it.


Response from FSANZ 21/08/2014:

Dear Howard

Thank you for sharing this complaint to ACCC with us. 

ACCC is the appropriate authority for dealing with your complaint and have the regulatory powers to do so.  That said, we will examine the technical aspects of the complaint and will be happy to confer with the ACCC if they seek our input.

Kind regards

Steve McCutcheon

55 Blackall Street, Barton, ACT 2600
PO Box 7186, Canberra BC, ACT 2610
t  +61 2 6271 2200 | f  +61 2 6271 2261 | m  0417 021 255


First response from ACCC 2/09/2014

An ACCC officer discussed the issue with Dr Howard Dengate on 4/09/2014 and in essence the labelling is not false according to FSANZ, but it appears intended to mislead those consumers who seek to avoid this food additive and to secure a competitive advantage for Goodman Fielder Ltd, which may be an issue for ACCC. Further action is expected.


SUCCESS! Complaint to ACCC about Helga's wrap labels accepted 13 November 2014

Heard today from ACCC that Australia’s largest baker Goodman Fielder Ltd have given an undertaking to remove the misleading claim from their packaging on Helga’s wraps.

This will happen early in the New Year (this is the “using up old packaging” routine).

The claim on the front of the package is that the wraps have “No Preservative 282” but in fact they contain an ingredient called cultured dextrose which contains propionic acid and is identical with preservative 280.
Goodman Fielder’s claim is correct in that there is no preservative 282, although the additive 280 used is functionally identical. They could equally claim that it contains no elephants and still be correct.

So a win for consumers. But note that the Helga’s wraps will still contain cultured dextrose and so remain NOT FAILSAFE.

See more information


See earlier complaint and responses from ACCC 2010 and FSANZ 2011 here

See survey of 100,000 Australian consumers in 2008 that showed that 78% of people avoid food additives.