# summary

- Link: https://dearsouthafrica.co.za/food-labelling-and-advertising/summary/
- Published: 2023-06-01T11:39:39+02:00
- Author: dearSA

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[ Have your say on the regulations](https://dearsouthafrica.co.za/food-labelling-and-advertising/)

### STATEMENTS FROM INTERESTED PARTIES

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Want to display your company or organisation’s statement? [Click here. ](https://dearsouthafrica.co.za/food-labelling-and-advertising/summary/ foodregs@dearsouthafrica.co.za?subject=org info for food regs page)

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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:
 3.  a. wide definition of “harm” (in Clause 1);
     b. the failure to define “hatred” (in Clause 1); and
     c. definition of, and creation of, the crime of “hate speech” (in Clause 4).
 4. 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.
 5. There are already sufficient existing laws dealing with “hate speech”.
 6. For all of the reasons given, I ask:
 7.  a. For the scrapping of the “hate speech” sections from the Bill altogether;
     b. Alternatively, should the “hate speech” provisions remain part of the Bill, we
        ask:
     c.  a. That “harm” be defined as: “gross emotional and psychological detriment that 
            objectively and severely undermines the human dignity of the targeted group”;
            and
         b. 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”.
     d. 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”._

In the media

 * BusinessTech — [Big changes for food labels in South Africa – including sugar warnings and an end to ‘super-food’](https://businesstech.co.za/news/lifestyle/662355/big-changes-for-food-labels-in-south-africa-including-sugar-warnings-and-an-end-to-super-food/)
 * BusinessTech — [New laws to tackle claims of ‘organic’ and ‘free range’ foods in South Africa](https://businesstech.co.za/news/lifestyle/679575/new-laws-to-tackle-claims-of-organic-and-free-range-foods-in-south-africa/)
 * BusinessTech — [Big changes for chips, cereals, sodas and other popular snack foods in South Africa](https://businesstech.co.za/news/lifestyle/680871/big-changes-for-chips-cereals-sodas-and-other-popular-snack-foods-in-south-africa/)

Regulations Relating to the Labelling and Advertising of Foodstuffs

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Annexures – included in the full document

 1.  a.  Categories of food additives that may be identified
          by their principal functional
         category name in a list of ingredients
     b.  Prescribed mandatory nutritional information/facts declaration format and conversion
         factors
     c.   a. Estimated glycaemic carbohydrate content of various polyols
          b. Factors for converting total nitrogen to protein
     d.  Nutrient Reference Values (NRVs) for the purpose of foodstuffs labelling and 
         list of energy conversion factors
     e.  Evaluation of protein quality for the purpose of when a protein claim is made
     f.  Letter sizes: definition of x-height
     g.  Major dietary carbohydrates
     h.  Culinary Herbs and Spices for ordinary use in food preparations
     i.  South African Nutrient Profiling Model: Screening criteria for health and nutrition
         claims
     j.  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
     k.  Front of Pack Nutrition Labelling (FOPL) logos

Encourage participation with this poster/flyer – distribute or place at the office

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