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STATEMENTS FROM INTERESTED PARTIES

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Regulations Relating to the Labelling and Advertising of Foodstuffs

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Annexures – included in the full document

    1. Categories of food additives that may be identified
      by their principal functional category name in a list
      of ingredients
    2. Prescribed mandatory nutritional information/facts declaration format and conversion factors
      1. Estimated glycaemic carbohydrate content of various polyols
      2. Factors for converting total nitrogen to protein
    3. Nutrient Reference Values (NRVs) for the purpose of foodstuffs labelling and list of energy conversion factors
    4. Evaluation of protein quality for the purpose of when a protein claim is made
    5. Letter sizes: definition of x-height
    6. Major dietary carbohydrates
    7. Culinary Herbs and Spices for ordinary use in food preparations
    8. South African Nutrient Profiling Model: Screening criteria for health and nutrition claims
    9. South African Nutrient Profiling Model: Screening criteria for health and nutrition claims
      Illustrative list of foods that need only a “date of manufacture” or a “date of packaging”, as appropriate
    10. Front of Pack Nutrition Labelling (FOPL) logos

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Freedom of Religion SA (FOR SA)

TEMPLATE PROVIDED BY FOR SA

I strongly oppose the Prevention and Combating of Hate Crimes and Hate Speech Bill [B9B – 2018], which I believe to be unconstitutional and unnecessary, for the following reasons:

  1. The Bill violates our constitutional rights as religious persons to express our religious beliefs without fear of punishment or persecution (section 15, read with section 16). Increasingly, around the world but also in South Africa, various holy scriptures (particularly on contentious issues) are regarded as “politically incorrect” or “offensive”, allegedly causing emotional and/or social harm.
  2. I specifically oppose the Bill’s:
    1. wide definition of “harm” (in Clause 1);
    2. the failure to define “hatred” (in Clause 1); and
    3. definition of, and creation of, the crime of “hate speech” (in Clause 4).
  3. The creation of the crime of “hate speech” for saying / distributing something which could possibly be construed as “harmful”, will have certain unintended consequences, namely the criminalisation of good / well-meaning people who will be prosecuted for saying what they sincerely believe (according to their holy texts) and sent to jail.
  4. There are already sufficient existing laws dealing with “hate speech”.
  5. For all of the reasons given, I ask:
    1. For the scrapping of the “hate speech” sections from the Bill altogether;
    2. Alternatively, should the “hate speech” provisions remain part of the Bill, we ask:
      1. That “harm” be defined as: “gross emotional and psychological detriment that objectively and severely undermines the human dignity of the targeted group”; and
      2. That “hatred” be defined as: “strong and deeply-felt emotions of enmity, ill-will, detestation, malevolence and vilification against members of an identifiable group, that implies that members of that group are to be despised, scorned, denied respect and subjected to ill-treatment based on their group affiliation”.
    3. That Clause 4(2)(d) (the “religious exemption clause”) be strengthened as follows to protect:
      “expression of any religious conviction, tenet, belief, teaching, doctrine or writings, by a religious organisation or an individual, in public or in private, to the extent that such expression does not actively support, instigate, exhort, or call for extreme detestation, vilification, enmity, ill-will and malevolence that constitutes incitement to cause gross emotional and psychological harm that severely undermines the dignity of the targeted group, based on race, ethnicity, gender, religion or sexual orientation”.