Response to FSA consultation on a voluntary front of pack signpost labelling scheme for the UK

Transcription

1 Shifra Sheikh Food Standards Agency Room 115c, Aviation House 125 Kingsway London WC2B 6NH Dear Shifra, 7 th February 2006 Response to FSA consultation on a voluntary front of pack signpost labelling scheme for the UK Thank you for the opportunity to comment on the FSA s proposed signposting scheme. We are supportive of practical, user-friendly front of pack signposting linked to GDAs that is cognisant of current public health concerns. But we have yet to be fully convinced that superimposing red/amber/green traffic light banding upon this and applying the scheme to only a limited range of foods is the best way forward, as we feel it weakens a valuable consumer education tool. Do you agree that on the basis of the information provided the Agency should recommend the MTL format as being the most suitable for a UK voluntary front of pack signposting scheme? If not, why not, and which format would you prefer and why? We understand that the FSA is proposing the MTL model for use on front of pack for specific food categories only (namely ready meals, breakfast cereals, pizzas, sandwiches and meal components such as meat products, meat alternatives, poultry and fish products) and that this decision is based on the conclusions drawn from qualitative and quantitative research carried out to explore consumers preferences in relation to the different signposting formats. We also understand that this research tested the ability of consumers to identify products higher or lower in a particular nutrient, but not specifically the ability to interpret this information. On the basis of the research findings presented, the MTL format seems to have been marginally better at helping consumers to identify the nutritional characteristics of a particular product, although the CGDA format performed better when comparing two foods and appeared to be most liked by consumers. 1

2 We note that the FSA supports the inclusion of GDAs on back of pack. BNF believes that GDAs offer consumers a valuable benchmark and support their use whether front or back of pack. Whether manufacturers and retailers will adopt the scheme using the MTL format needs to be established as a priority, given that some have already developed their own front of pack schemes, some of which provide useful information without adopting the red/green interpretation (e.g. Tesco). We note that regardless of whether the FSA signpost labelling scheme is adopted by the food industry, its development has already stimulated the food industry to respond to the need to provide more information for consumers, i.e. some major retailers and manufacturers have developed and are using their own schemes for front of pack. To establish whether the MTL is the most suitable format, compared to others now in use on front of pack, would require additional consumer testing to establish how different formats influence dietary choices and behaviour change. There is also a need for follow-up research following implementation of such a scheme to evaluate how usage affects consumer purchasing and whether, in practice, it helps consumers to make healthier dietary choices. This evaluation needs to be embedded in the process from the outset and the 5 year period suggested by the FSA is too long. Do you agree with the banding criteria proposed in Annex 2 of Appendix 2? If not, why not? On balance, we would have preferred that the use of banding had been avoided. But the process used to identify the proposed banding criteria seems reasonable, provided the bands themselves are realistic and are able to discriminate within food categories, e.g. breakfast cereals, which can be an important source of vitamins & minerals (through fortification) and fibre. It would have been helpful and reassuring if the FSA had published evidence to this effect as part of the consultation. We agree with the need to have different criteria for foods consumed in larger portion sizes (> 100g). However, we are disappointed that a similar approach has not been suggested for small serving sizes, should the scheme be extended or manufacturers/retailers choose to use the scheme on a wider range of products. If you disagree with any of the low band criteria please make a case for alternative levels that could be submitted to the European Food Safety Authority (EFSA) The process adopted for identifying the low criteria would seem to be logical. But it would have been useful and reassuring to have seen the evidence that the low, medium and high 2

3 criteria help consumers to identify which products are lower in e.g. salt compared to standard versions. If genuinely lower salt versions of ready meals, for example, still fall into the same category as standard versions, this will not help consumers to make healthier choices and subsequently develop an acceptance of less salt, which can be the basis for more long-term change. Do you agree that the sugar criteria should be based on total sugars? If not, why not? If you think non-milk extrinsic sugars (NMES) or added sugar should be used please indicate how analytical and traceability difficulties could be addressed We support the proposal to use total sugars at the present time, owing to the difficulties associated with obtaining NMES values and the requirement to declare total sugars if the big 8 labelling format is adopted. We recognise the dilemma faced in identifying an appropriate GDA value. The IGD suggested two values 90g for total sugars and 50g for NMES; we agree that the NMES route is problematic for the reasons mentioned above. The difficulty remains however that some major sources of sugars fruit and milk are foods that are positively promoted as nutritionally important and it would be misleading to consumers if they attracted red or amber signposting. A suggestion was made at the sugars GDA working group meeting to adopt a different approach, namely to take a figure of 50g as a representative value of NMES intake and to add to this a further 10g to cover any intrinsic and milk sugars that might be present in the categories of manufactured foods being targeted by the FSA in its signposting work. Extrapolation from evidence presented at the meeting suggested that this approach would discriminate between manufactured foods in the specific categories being targeted by FSA, in terms of their sugar content, much of which would be NMES. Nevertheless, there remains the problem that whilst this total sugars GDA might be effective within the confines set by the FSA s proposed scheme (i.e. specific food categories), it cannot be extrapolated for use across the whole diet, unlike the GDAs for energy, fat, saturates and salt that are in current use and were mostly developed about 7 years ago by IGD in consultation with nutrition experts. It needs to be determined whether this situation would be unhelpful for those consumers who are seeking access to a comprehensive set of information across the food supply, as seems to be more commonplace according to the major retailers responses in recent months (i.e. considerable enhancement of the amount of information provided on pack). The current GDAs can be used to give a rough idea of the ceiling for fat, saturates or sodium/salt intakes in a typical healthy diet for adults. The introduction of the recently suggested 60g value for total sugars would be a break from this approach in that regular consumers of (low fat) milk and fruit would easily exceed this level even if their NMES 3

4 intake was modest (as demonstrated by NDNS data for sugars intake by fruit/vegetable consumption: men & women eating 5-7 portions of fruit and vegetables a day consumed 61g/d and 59g/d, respectively, of intrinsic plus milk sugars; even those consuming 3-5 servings had 49g/d & 44g/d, respectively). Furthermore, in the women consuming 3-5 servings of fruit and vegetables a day, NMES intake was within recommended limits (i.e. below 10%E at 9.5%E) but total sugar intake was still 86g (19.6%E) and the equivalent figures in men were 117g for total sugars (18.2%E), with NMES close to the upper limit at 10.6%E. Whilst recognising that the FSA is intending to establish a sugars GDA for use with specific food categories identified for the signposting scheme, it has to be acknowledged that the GDAs already in use (energy, fat, saturates, salt) and being adopted by FSA for fat, saturates and salt can be used in a more flexible way than a value that is defined specifically for foods that largely provide only NMES. An alternative approach might be to use the NDNS to identify the true total sugars intake of those adults currently achieving, say, 3-5 servings of fruit and vegetables per day in conjunction with a diet relatively close to the DRV for saturates and the salt target of 6g (perhaps focussing on the value for women as IGD did rather than the mean for men and women which will be higher), and to use this as the basis of the sugars GDA alongside a robust education campaign which stresses the importance of adequate amounts of fruit in the diet and the nutritional attributes of low fat milks. Yet another approach might be to use the total sugars GDA proposed by IGD but to add to this a GDA for fruit and vegetables to help emphasise the importance of this food group. This could be supported by education which highlights the practical implications of the recommendation made by COMA in 1991 that NMES should not exceed 10%E. The 90g GDA suggested by IGD (the GDA for women; the value for men was 120g) would seem a pragmatic approach as it can be derived logically and the only other country that has a total sugars GDA (Australia) has arrived at the same figure using a different approach to that used by IGD. If retailers agree to switch from the schemes they are currently using on a wide range of foods and adopt the FSA scheme, their customers may wish for the scheme to appear on a wider range of foods than is currently being proposed by FSA. If, as a result, the suggested 60g GDA for sugars referred to above were to be adopted for dairy products such as yogurts, they might well attract a red categorisation (>25% of the GDA i.e. 15g/100g or 18g/portion for larger servings) even though much of the sugar is lactose (i.e. not NMES) and such foods may be consumed in place of less nutrient-rich alternatives. The same would apply to high fruit products (e.g. fruit smoothies), where most of the sugar is fructose and lactose. 4

5 Do you agree that the Agency should also recommend provision of back of pack information on GDAs as developed by the IGD? If not, why not? We agree that information on GDAs should be recommended, and there are advantages of this being front of pack as well as back of pack. According to IGD research, GDAs are already widely used and are helpful to some consumers. Furthermore, many food manufacturers and retailers already use GDAs on food labels and consumers expect to find them when making decisions at the point of purchase. Do you agree that signposting should be introduced in the first instance on ready meals, breakfast cereals, pizzas, sandwiches and meal components such as burgers, sausages, pies, breaded, coated or formed meat, meat alternative, poultry and fish products? If not, why not? Please make alternative proposals If the signposting scheme goes ahead, it would seem sensible to test it on a limited range of foods in the first instance, and we agree that foods that are generally consumed frequently or in large quantities should be a priority. We also agree that there is less need for signpost labelling on products that are generally consumed in very small quantities, such as condiments. We understand that the scheme has been devised with only certain categories of foods in mind (namely the above), but we suspect that consumers would expect signposting to be found across a broader range of products. Should the scheme prove successful, roll out to a broader range of products may be hampered by lack of inclusion of criteria derived with smaller servings in mind. Information provision on pack has moved on considerably since the FSA announced its plans to introduce signposting some time ago. A phased introduction, focussing on specific categories, will not necessarily embrace the range of categories for which front of pack signpost labelling schemes are already being provided by some retailers. Indeed, retailers may opt to continue with their own front of pack schemes if these prove to be of help to, and well accepted by, their customers, even when the Agency scheme is introduced. An FSA scheme that is more consistent with schemes in current use would help reduce consumer confusion and increase the likelihood of retailers and manufacturers complying with the voluntary FSA scheme. 5

6 Do you have any further comments on the proposed guidance? Choice of nutrients The rationale for choice of the nutrients in the scheme is unclear. Consumer research has repeatedly identified energy content as something consumers are interested in and better awareness of the energy content of individual foods is clearly of importance in terms of obesity trends. Having both total fat and saturates may be open to misinterpretation and could be misleading does the FSA have evidence about how consumers interpret, for example, high fat plus low saturates? Research has regularly demonstrated that positive messages are more likely to result in appropriate behaviour change than negatives ones (see the review conducted by BNF for the FSA on factors affecting food choice), yet all of the nutrients selected are ones targeted for reduction. Inclusion of fibre would have provided a surrogate for fruit and vegetable and whole grain cereal content, and was consideration given to a specific criterion for fruit/vegetables? Fibre and micronutrients A feature of the proposed labelling scheme is that it does not take into account contribution to positive nutrients, such as fibre, iron, calcium and folate. Furthermore, there appears to have been no evaluation of whether consumers understand that some foods, while attracting amber or red for fat, salt or sugar, may also be good sources of other nutrients, e.g. fortified breakfast cereals, which can make a useful contribution to nutrients such as fibre, iron and folate in the UK diet. Was understanding of this assessed in the research conducted? For example, was there evidence that consumers used both the back of pack information and also the front of pack signposting when making a judgement? Fruit and vegetables Some foods that have been proposed for inclusion in the initial roll out contribute to fruit and vegetable intake (and some may be eligible to carry the 5 A DAY logo), for example some ready meals such as vegetable curry or vegetarian pizza. Yet some of these foods may be labelled as red for fat, saturates or salt, and may attract amber for sugars if they contain plenty of tomatobased ingredients, for example. Moreover, if there are plans to extend the scheme to desserts and snacks containing fruit (including dried fruit), consideration needs to be given to the fact that these foods may carry a red for sugar but may also contribute to consumers 5 A DAY and may carry the 5 A DAY logo. This could obviously be confusing for consumers and highlights the need for consumer education on these sorts of issues (see above). 6

7 Consumer interpretation One of our main reservations about the proposed scheme is how it will be used and interpreted by consumers. It appears that there has not, as yet, been any evaluation of whether the scheme will actually encourage consumers to follow a healthy, balanced diet. What do consumers understand by foods with a majority of red values or foods that have a mixture of colours on the label? Do they think that to be healthy one should avoid red completely or do they understand the concept that foods with red values can still be eaten as part of a healthy, balanced diet, just not too frequently? Also, how will consumers use the signposting information in relation to the nutrition panel on the back of pack which includes calories, fibre and sometimes micronutrients, and information about GDAs? Dietary variety is the foundation of good nutrition and achieving this often means consuming small amounts of a diverse range of foods, some of which are high in total fat or total sugars (on a per 100g basis) such as nuts, dried fruit and cheese. It would therefore be counterproductive if this diversity was compromised. We therefore suggest that further evaluation of these aspects is needed as a matter of urgency. It is therefore important that use of the scheme is evaluated in order to ascertain answers to questions such as the following: What effects will signpost labelling have on the choices consumers make at point-ofpurchase? Will this type of labelling scheme be effective in actually improving the choices that consumers make? Will signpost labelling be effective in improving people s diets? Consumer education It is essential that there is an appropriately targeted education campaign alongside the launch of the signposting scheme to help ensure its success. This could include education about GDAs and how they can be used to assess how a particular product might contribute to a balanced diet and to compare different products. Summary In summary, we agree that appropriate front of pack information about key nutrients has the potential to help consumers choose a healthy diet, and we are supportive of practical, userfriendly front of pack signposting linked to GDAs that is aligned with tackling public health concerns. But we have reservations about the use of traffic lights, particularly in light of the current lack of consumer research about how this information is interpreted by consumers, as 7

8 opposed to what their preferences are. Schemes recently introduced by some manufacturers that provide information on nutrient content and provide GDAs as a reference point (some of which also include energy, which can be done more easily if traffic lighting is not used) seem to offer a rational alternative and allow consumers to compare nutrient provision across food categories and with GDA values, and so gain a better understanding of the pros and cons of a particular food in the context of a balanced diet. Yours sincerely Professor Judith Buttriss Science Director Claire Williamson Nutrition Scientist 8