We, the undersigned members of the Australian Jewish community, oppose the following proposal made in their submission to the Food Labelling Review by the Executive Council of Australian Jewry (ECAJ) and the Organisation of Rabbis Australasia (ORA).
The ECAJ/ORA submission proposes that ORA be responsible for deciding which foods can be labelled ‘kosher.’ We are strongly opposed to this proposal for the following reasons:

The proposal is anti-competitive
The three primary office bearers of ORA have financial interests in the kosher food business, and therefore ORA cannot act independently in this realm. The President of ORA is the rabbi in charge of KAWA, the primary organisation providing kosher certification in Western Australia. The Immediate Past President of ORA is the rabbi in charge of Kosher Australia, the primary organisation providing kosher certification in Victoria. The Senior Vice President is the rabbi in charge of the NSW KA, the primary organisation providing kosher certification in New South Wales. Kosher certification is a business, so proposing that ORA oversee kosher labelling is equivalent to putting the three largest companies in a sector in charge of licensing for that sector.

There is no reason to regulate kosher food labelling
Primarily, food labelling law supports policy objectives of public health and safety, and enabling consumers to make informed choices. Kosher labelling is not related to public health or safety and as detailed in the ECAJ/ORA submission (see points 12-14), the current system of self-regulation suffices to enable consumers to make informed choices about kosher food. Therefore, we cannot see any reason for introducing standards around kosher labelling in Australia.

The regulation of kosher labelling is outside the scope of Australian law
Defining private religious practice is outside of the scope of Australian law.

The proposal limits Jewish religious freedom in Australia
ORA does not represent the plurality of Jewish religious groups in Australia. It consists exclusively of Orthodox rabbis, and even within Orthodoxy, the majority of committee members are from one Orthodox sub-denomination. To put it simply, different denominations within Judaism maintain different interpretations of ‘kosher’. We are concerned that ORA could use their position to limit the ability of Jewish denominations not represented by ORA to maintain their own kosher labelling.

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