Should the charitable status of Primary Industries Education Foundation Australia be revoked?

Primezone Australia is a website that “provides teachers with single-point access to a range of primary industries education resources”.

It is managed by Primary Industries Education Foundation Australia (PIEFA), which describes itself as “a collaboration between industry, government and educators to promote primary industries education”. It claims to provide “a credible and authoritative one stop source for primary industries educational information and resources to help build knowledge about this sector”.

PIEFA is a registered charitable institution with the Australian Charities and Not-for-profit Commission (ACNC). It is a tax-exempt body under federal tax laws, and donors who contribute toward a teaching scholarship fund that it operates may be able to claim their contributions as tax deductions.

The Primezone website contains “educational resources” produced by or for (amongst others) Meat & Livestock Australia (MLA), Australian Pork Limited (APL), Australian Eggs Limited (AEL) and Dairy Australia (DA), all of which are or have been members of PIEFA.

Some background on MLA, APL, AEL and DA

MLA provides research, development and marketing services to cattle, sheep and goat meat producers. Its “core purpose” is “fostering the prosperity of the red meat industry”.

MLA’s “educational resources” are also accessed via the “marketing beef and lamb” and “promoting the industry” pages of MLA’s website. They appear to represent a form of marketing or promotion.

APL delivers “integrated services” (including marketing) “that enhance the viability of Australia’s pig producers”.

AEL’s purpose (like that of MLA) is to provide research, development and marketing services. Its stated role includes the need to “increase consumption and ensure industry sustainability”.

AEL’s 2017-21 Strategic Plan commented on current entrenched egg-purchasing patterns in Australia, which are considered to be favourable. However, it then commented on the need to focus on children in order to ensure that existing patterns continue (with the underline added here for emphasis):

However, these habits, culture and patterns cannot be taken for granted and require an ongoing focus and investment to ensure that eggs remain an important staple food into the future. Over the term of the Plan we will give this area a greater focus, particularly in relation to working with children, parents and schools,to ensure that positive habits and perceptions of eggs are passed on to the next generation.”

The Primezone site links to AEL’s “All about eggs” site and also contains material under the heading “Eggscellent Eggs!“.

Consistent with the above strategic plan extract, AEL has stated that the “All about eggs” campaign is “aimed at primary school students” and is “an important aspect of our marketing program”.

DA’s marketing and communications program focuses on protecting the industry’s long-term “right to operate”. It creates “campaigns and programs directed to key consumer target audiences“, which influence “the attitudes of key opinion leaders such as health care professionals, teachers and media”. (Underlines added here for emphasis.)

Its primary schools program, known as “Discover Dairy”,  is one of its three core marketing and communications programs. It provides:

“innovative curriculum-linked programs and resources that enable teachers to educate students about the health benefits of dairy foods benefits [sic], the farm to plate process and career opportunities in the dairy industry”

Negative impacts of members’ products

Reflecting the strength of available evidence, processed meat (which comprises meat that has been transformed through salting, curing, fermentation, smoking, or other processes for reasons of flavour or preservation) has been classified as carcinogenic to humans by the World Health Organization. This classification is identified as “Group 1”.

Unprocessed red meat (comprising all mammalian muscle meat) has been classified as probably carcinogenic to humans. This classification is identified as “Group 2A”.

Animal-based food consumption also has other negative human health and environmental impacts. In 2016, researchers from the Oxford Martin School at the University of Oxford reported on the health and climate change benefits of changing diets, including reduced consumption of animal products.

They estimated that if the global population were to adopt a vegan diet, 8.1 million lives per year would be saved by 2050 due to reduced rates of coronary heart disease, stroke, cancer, and type 2 diabetes.

They also indicated that, in terms of food system change, only the vegan diet would enable us to limit the temperature increase to below 2°C.

Research for a 2018 study involving Oxford, the University of Minnesota and other major research institutions indicated that the average citizen would need to consume 75 per cent less beef, 90 per cent less pork and 50 per cent fewer eggs, while tripling consumption of beans and pulses and quadrupling nuts and seeds, in order to adhere to a 2°C limit.

Egg consumption has been specifically linked to increased risk of heart disease, diabetes and cancer. For example, a review of fourteen studies published in the journal Atherosclerosis indicated that those who consumed the most eggs increased their diabetes risk by 68 per cent.

Dairy products have been found to contribute to adverse health outcomes in respect of heart disease, lactose intolerance, bone health and cancer.

All the industries mentioned involve inherent cruelty to animals that is exempted by state-based “prevention of cruelty to animals” laws. That is to say that severe and relentless cruelty to production animals is permitted by law.

The Primezone site appears to say nothing about the negative aspects of PIEFA’s members’ products, thereby showing a lack of respect for children and their teachers, who have a moral right to know.

PIEFA’s aim of demonstrating value to members

In PIEFA’s 2017/18 annual report, its CEO stated:

“Like many not-for-profit organisations, our biggest threat remains the security of sustainable levels [of] funding. Tied in with this is the need to demonstrate continued value to our members’ investment.”

PIEFA’s apparent desire to demonstrate to members a return on their “investment”, seemingly in an effort to secure its own funding streams, appears to be inconsistent with the requirements of a registered not-for-profit charity.

According to ACNC:

“Generally, a not-for-profit is an organisation that does not operate for the profit, personal gain or other benefit of particular people (for example, its members, the people who run it or their friends or relatives).”

A company is considered a legal person and would appear to fall within the description used by the ACNC.


PIEFA appears to be providing marketing material to school children, supplied by member organisations. The products in question may be harmful to the children and the environment on which they will depend throughout their lives. Activities of other member organisations may also have adverse impacts.

PIEFA’s practice of providing the material may be an attempt “to demonstrate continued value to” members’ investments. That practice appears to be inconsistent with ACNC’s requirements regarding not-for-profit charitable institutions and would therefore seem to create a case for revoking the organisation’s charitable institution status.


Paul Mahony


Some of this material has been included in the following articles from the same author:

Red meat and sustainability: A modern fairy tale?

Red meat in the classroom


Primezone Australia,

Primary Industries Education Foundation Australia, Information brochure,

Primary Industries Education Foundation Australia,

PIEFA 2017/18 Annual Report, p. 8,


Australian Charities and Not-for-profit Commission, Primary Industries Education Foundation Australia,

Primezone Australia, Cattle and sheep farming,

Primezone Australia, Discover Dairy – From farm to plate,

Dairy Australia, Students,

Primezone Australia, Dairy Australia, Foods that do good,

Primezone Australia, All about eggs,

Primezone Australia, Australian Egg’s YouTube channel,

Primezone Australia, Eggscellent Eggs!,

PIEFA, Eggscellent Eggs!,

Primezone Australia, Changing conditions in the pig industry,

Primezone Australia, Enterprising pig farmers,

Meat & Livestock Australia,

Australian Pork Limited, About,

Australian Pork Limited, Strategic Plan – Amended Version, 2015-20, Amended July 2018,

Australian Eggs Limited,

MLA, What we do,

MLA, Who we serve,

MLA, Marketing beef and lamb,

MLA, Promoting the industry,

MLA, Australian Good Meat, About Us,

MLA, Australian Good Meat, Educational Resources,

MLA, Australian Good Meat, Curriculum link tables,

Australian Eggs Limited, Who we are,

Australian Eggs Limited, 2017-21 Strategic Plan, p. 10, accessible via

Dairy Australia, Industry promotions and marketing,

World Health Organization, Q&A on the carcinogenicity of the consumption of red meat and processed meat, Oct 2015,

Springmann, M., Godfray, H.C.J., Rayner, M., Scarborough, P., “Analysis and valuation of the health and climate change cobenefits of dietary change”, PNAS 2016 113 (15) 4146-4151; published ahead of print March 21, 2016, doi:10.1073/pnas.1523119113, (print edition 12 Apr 2016), and

Springmann, M., et al., “Options for keeping the food system within environmental limits” cited in Carrington, D., “Huge reduction in meat-eating ‘essential’ to avoid climate breakdown”, The Guardian, 11th October 2018,

Physicians Committee for Responsible Medicine (PCRM), “Health concerns with eggs” (undated),

Li Y, Zhou C, Zhou X, Li L. “Egg consumption and risk of cardiovascular diseases and diabetes: a meta-analysis”. Atherosclerosis. 2013;229:524-530, cited in PCRM, ibid.

Physicians Committee for Responsible Medicine (PCRM),”Health concerns about dairy” (undated),

Planetary Vegan, Animal Rights,

ACNC, Not-for-profit,

Australian Government, Australian Taxation Office, Miscellaneous Tax Ruling MT 2006/1,


Monkey Business Images, Shutterstock ID 735971812


No information in this article is intended to represent taxation, financial, health, medical, nutritional or similar advice and should not be relied upon as such. Please consult a professional service provider where relevant.

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