Download National Heart Forum consultation response to: Labelling

National Heart Forum consultation response to: Labelling:
Competitiveness, Consumer Information and Better regulation for the EUA DG SANCO Consultative Document
Introduction
The NHF welcomes the opportunity to comment at this early stage on the review
of the EU labelling directive. We believe that a mandatory universal front of pack
nutritional labelling scheme supported by more detailed back of pack information
can make a very substantial contribution to shaping the market to inform and
provide healthy food choices. We commend the experience of the UK Food
Standard Agency which provides an ideal approach and model that should be
replicated EU wide.
About the National Heart Forum
The National Heart Forum (NHF) is the alliance of 50 organizations working to
reduce the risk of coronary heart disease in the UK. Member organizations
represent the medical and health services, professional bodies, consumer groups
and voluntary organizations. Members also include many individual experts in
cardiovascular research. Government departments have observer status.
The views expressed in this submission do not necessarily reflect the opinions of
individual members of the alliance.
Response to questions
1. Should nutrition labelling be mandatory?
Yes. Consumer friendly front of pack nutrition labelling should be
mandatory for all processed foods for the following reasons:
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Self regulation of the food industry in terms of nutrition labelling has not
worked in the UK or elsewhere and would take too long, if it were at all
possible, to successfully implement. We need whole system change now
to tackle the avoidable chronic disease crisis in Europe.
It is the only way to ensure an independently developed universal and
standard nutrition labelling system that will be adopted by all economic
interests in the processed food industry within the EU.
It will ensure whole industry adoption.
It will prevent competing inferior schemes which will confuse the public.
It will allow a simple, sensible single market standard to ensure no barrier
to trade.
It will support the work of the UK government in moving towards a single
standard scheme.
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It will contribute significantly to shaping a health promoting food economy
and contribute to the Lisbon Agenda.
It will help reduce widening health inequalities.
To assist consumers to make healthy choices the NHF believes that nutrition
labelling should be mandatory on the front-of-pack for all processed food
provided within the EU. The front-of-pack information can be supported by
more detailed information on the back-of-pack. More details are included in our
response to questions below. The NHF believes that it is important that nutrition
labelling should be in a format which is both standard (in order to ensure that
consumers can readily make comparisons between and within food categories)
and comprehensible in order to allow all consumers to judge the potential impact
of food products on their health and the health of their families.
If nutrition labelling were comprehensive, comparable (standardised) and
easier to understand, consumers could use that information to eat more
healthily.
The introduction of front-of-pack nutritional signpost labelling on processed foods
according the early reported results from the retailers - Sainsbury's and Tesco in
the UK - is driving consumer purchasing changes towards a healthier diet and
this in turn will drive reformulation changes by the food producers and retailers.
The success in the UK should be followed elsewhere in Europe as the ideal
solution given the need for a single universal scheme throughout Europe. In the
absence of revised (updated) EU wide labelling regulations the front-of-pack
scheme as it operates presently in the UK is voluntary. This has resulted in two
competing schemes within the UK. An official scheme supported by the FSA (the
multiple traffic light scheme) developed through independent peer reviewed
research and adopted by many retailers in the UK and an industry developed
scheme adopted by the rest of the retail sector and the food producers of high
fat, sugar and salty foods with most to lose - hence the need for a common
mandatory scheme.
The experience in the UK demonstrates that given the heterogeneous and
competitive nature of the food industry, self regulation has proved impossible and
the public interest is best served by a mandatory approach. The UK Food
Standards Agency has undertaken extensive consumer research in developing
and implementing the principles of a common format front-of-pack – the multiple
traffic light system in the UK. The NHF and public interest groups UK-wide have
endorsed the front-of-pack nutrition signposting model announced by the UK
Food Standards Agency in March 20061. The scheme has been adopted by
most retailers the notable exceptions being Tesco and Morrison's. We do not
believe that self regulation is a suitable alternative to legislation as shown by
recent events in the UK, where a number of different labelling schemes have
proliferated. For example the retailer Tesco's is actively publicising its own
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http://www.food.gov.uk/news/newsarchive/2006/mar/signpostnewsmarch
nutrient signposting system; Danone, Kellogg's, Kraft, Nestle and PepsiCo have
announced their own labelling scheme; and the Biscuit, Cake, Chocolate and
Confectionary Association (BCCCA) has launched ‘Be treatwise’ which it
describes as a ‘consumer education initiative’. The ‘Be treatwise’ scheme
encapsulates the problems posed by individual programmes of action. The
model will include a logo which refers consumers to the back of packets for
nutritional guidance as well as nutrition panel colour coding which does not
complement the FSA's Multiple Traffic Light model. None of these schemes
follow the basic principles set out by the FSA model – for example the colour
coding of nutrients as green, amber and red to denote high, medium and low
content levels. Some of these models do not provide crucial front-of-pack
nutritional information, whilst others introduce a variety of colour schemes which
will undermine the impact of the FSA’s scheme. The NHF strongly believes that a
multitude of different models will not be of benefit to consumers across Europe.
Appropriate front-of-pack nutritional labelling is a fundamental human,
consumer and health right. How can consumers obtain information about
what's in their food and make healthy choices without easy-to-comprehend
nutrient information and guidance The simpler the system the better given the
need to reach all groups in society, not widen inequalities and to take account of
the reality of a typical shopping experience. Some in the food industry will argue
against this innovation as they know it will lead to the foods high in fat, sugar and
salt becoming progressively less popular.
How much information is required?
The particular nutrient and energy population goals will vary slightly from country
to country. However there is increasing convergence as the European diet is
being increasingly dominated by highly processed foods high in fat, sugar and
salt.
The NHF believes that the key macronutrients that need to be signposted at
European level are Salt, Fat, Saturated Fat/Trans fat and Added or Non Milk
Extrinsic Sugars. These are the nutrients which are consumed in excess
and as a result are a significant contributory factor behind the epidemic of
avoidable chronic diseases in Europe. The number of servings of fruit and
vegetables and the energy value of the food should also be included.
The NHF believes that labelling of sugar should be of ‘added’ or non-milk
extrinsic sugar (NMES) content of foods. This is to make sure that foods which
contain natural sugars do not end up being represented as being ‘high’ in sugar
whilst still being healthier than added-sugar options which are labeled as
containing less total sugars. We accept that work will need to be undertaken to
develop a reliable method for calculating NMES and recommend that DG Sanco
undertake this.
It is important that people should avoid foods high in saturated fat, trans fats and
sodium (salt) in order to reduce their risk of CVD. In addition they need to
regulate their intake and expenditure of energy (and their intake of fat and added
sugars) in order to avoid overweight and obesity – fast becoming one of the most
important public health problems in Europe.
The NHF supports the position of the European Heart Network (EHN) which
produced a policy document published in 2002 Food, nutrition and cardiovascular
disease prevention in the European region2. EHN proposes five priority
population goals in relation to diet and physical activity: a reduction in saturated
fat and trans fats, a reduction in salt intake, a reduction in average body mass
index, an increase in physical activity and an increase in fruit and vegetable
intake. Better information about the energy, saturated fat, trans fats and sodium
content of foods would help in attaining three of those goals.
Nutrition labelling – in its current format –does not give information about trans
fat and added sugars, and frequently does not give information about saturated
fat and sodium. Information about these nutrients on food packets would be more
useful from a public health perspective than information about the content of
other nutrients, e.g. protein which is currently a minimum requirement for nutrition
labelling.
EHN and NHF suggest that the nutrition label should not give too much
information – otherwise consumers will not realise which nutrients information
they should concentrate on when choosing foods on nutritional grounds. EHN
does not think it should be mandatory to provide information about macronutrients other than the six listed above. Other information can be provided on a
voluntarily basis.
By recommending that information about key nutrients should be provided on a
mandatory basis and that information about other nutrients can be provided
voluntarily EHN and NHF are not suggesting that nutrition labelling should be 2tier, as at present. EHN and NHF recommend that the mandatory information
about key nutrients should be clearly separated from voluntary information about
nutrient content so that consumers are directed towards the most important
information in relation to public health.
Where should the nutrition label be put?
NHF considers that it is necessary to distinguish between back-of-pack nutrition
labeling and front–of-pack nutrition schemes. NHF considers that both should be
mandatory and have standardized formats. The back-of-pack nutrition labeling
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EHN (2002) Food, nutrition and cardiovascular disease prevention in the European region:
challenges for the new millennium. EHN: Brussels
should be able to give more and more detailed information whilst the front-ofpack information should be simpler and easier to use.
How important is presentation of the information?
A. Front-of-pack
The NHF believes that nutrition front-of-pack labeling should be visually
consistent across all food products so that consumers become familiar with the
concept. The format should ideally be universal, simple, usable and
attractive to all consumers but especially to low income consumers and
accommodate all ethnic groups. The format should take full account of the
reality of the modern shopping experience i.e. consumers take an average
of around 4 seconds to decide on a food purchase. We also believe it is
important that the model should be established and promulgated by a
trusted, independent and authorative source as this was what consumers
said they felt to be important during research conducted for the UK FSA3.
We commend the UK FSA's model and principles and believe this provides
the ideal starting point for a pan European scheme.
For the reasons outlined above, we do not think it would be appropriate for the
food industry to develop best practice on the presentation of nutritional
information.
B. Back-of-pack
We support the work of the European Heart Network (EHN) on recommendations
on back-of-pack nutrition labeling as set out below:
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Format to be utilized (e.g. linear, tabular, graphical presentation…)
EHN notes that all of the available research on consumer understanding of
nutrition labelling points to a need to a revision of the current format currently
prescribed by the Directive. EHN’s review has examined the literature
investigating alternative formats. This literature demonstrates clearly that various
formats are more comprehensible than the one prescribed by the Nutrition
Labelling Directive.
When testing different formats for nutrition labelling all researchers have
assumed that a tabular format is more comprehensible than a free text format.
Nonetheless, EHN notes the increasing use of free text formats, which EHN
considers should be prohibited in a revised Directive.
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order of nutrients and/or highlighting of certain nutrients
Food Standards Agency, Qualitative Signpost Labelling Refinement Research, November 2005
EHN considers that the nutrients which are most relevant to public health should
be listed first on the label. This means that EHN’s preferred order would be
energy, fat, saturated fat/ trans fats, sugar, fibre and salt (sodium).
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legibility, font size etc…
There are a considerable number of studies to show that both font size and
legibility of current nutrition labelling is serious problem for many consumers –
particularly the elderly with failing eye sight. EHN recommends that any revised
Directive should specify minimum font sizes and that all labelling should be
presented in black on white.
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expression of nutritional content
EHN considers that nutrient content levels should preferably be given as a
percentage of a recommend daily value. Doing so would also help consumers to
see how much of a nutrient they were getting from consuming the product
relative to a recommended amount and this could be useful to them. We
recommend that EFSA, not the food industry, as a matter of urgency, should
develop recommended daily values for food labelling purposes.
References
1. www.fsa.org.uk - food labelling
2. Food standards Agency, Qualitative Signpost Labelling refinement
research, November 2005
3. European Heart network (2002) Food, nutrition and cardiovascular
disease prevention in the European region: challenges for the new
millennium. EHN Brussels. www.ehn.org