UK Faculty of Public Health Response to the UK Consultation on Front of Pack Nutrition Labelling

About the UK Faculty of Public Health

The Faculty of Public Health (FPH) is the standard setting body for specialists in public health in the UK. FPH is the professional home for more than 3,000 professionals working in public health. Our members come from a range of professional backgrounds (including clinical, academic and policy) and are employed in a variety of settings, usually working at a strategic or specialist level.

FPH is a joint faculty of the three Royal Colleges of Public Health Physicians of the United Kingdom (London, Edinburgh and Glasgow). In addition, FPH advocates on key public health issues and provides practical information and guidance for public health professionals, aiming to advance the health of the population through three key areas of work: health promotion, health protection and healthcare improvement.

Introduction

FPH welcomes the opportunity to respond to the Department of Health consultation on Front of Pack Nutrition labelling and commends the Government’s decision to seek views on how to maintain and extend the use of labelling and increase consistency in labelling in line with research on what consumers find most useful.

As a signatory to the British Heart Foundation led Joint Response to the UK Consultation on Front of Pack Nutrition Labelling (hereafter referred to as the ‘Joint Response’), FPH firmly supports the robust and clear answers to the consultation questions contained within that document. FPH urges the UK Government to recommend that traffic light labelling is used consistently on the front of packs across all appropriate products. For your attention a copy of the Joint Response is attached with this submission.

In addition to the Joint Response, FPH is keen to make the following supplementary points, which, for ease are split into the order of the consultation questions. If you would like further information about this response please email Mark Weiss, Policy Officer at the UK Faculty of Public Health, or call 020 7935 3115.

Context

Non-communicable diseases and obesity are increasing in prevalence globally. Almost two-thirds of UK adults and one-third of children are overweight or obese[1]: few medical specialties will be unaffected, whether treating diabetes, cardiovascular disease or cancers, or indirectly through co-morbidities associated with increasing adiposity, particularly disability.

In 2007, obesity cost £15.8bn; including £4.2 billion in NHS costs. [2] Reductions in physical activity have been accompanied by increased intake of energy-dense foods of poor nutritional value, driven mainly by the global food system, which is ‘producing more processed, affordable, and effectively marketed food than ever before’. [3] Despite improvements over the past decade, average intake of saturated fat, ‘free’ sugars and salt in the UK exceeds recommended levels, while fibre intake is too low.[4]

Clear information is important in helping people to choose healthier foods,[5], [6] by correcting consumer’s knowledge deficits. [7]

I) To what degree does your organisation believe that greater consistency in UK FoP labelling would be beneficial to consumers? Is your organisation willing to work with the UK Governments to achieve this?

FPH supports the BHF led Joint Response answer to this question. In addition, FPH makes the following observations:

· FPH supports its previous assertion that the ‘cross-government strategy to tackle obesity in England, points to the responsibility of the food industry to provide consumers with clear and consistent information about the food and drink they consume, and supports the adoption of “traffic-light” nutritional labelling by retailers and manufacturers’ [8]

· Clear information is important in helping people to choose healthier foods [9] [10] by correcting consumers’ knowledge deficits, [11] and could be of tremendous benefit to the public

· Surveys show repeatedly that consumers want not only a system of nutritional labelling which they trust but also want a single system used consistently across all brands in all shops [12], [13]

· However, ‘consistency’ needs clear definition. For example a scheme that is consistent but which standardises unhelpful or confusing labels would impede public health

· FPH supports consistent use of front of pack ‘traffic-light’ food nutrition labelling. ‘Traffic-light’ nutrition labelling uses red, amber and green labels on packaged foods

· These colours indicate whether a product is high, medium or low in total fat, saturated fat, sugars, calories, and salt content

· The principles behind ‘traffic-light’ nutritional labelling were developed by the UK’s former Food Standards Agency (FSA), reflecting criteria derived from dietary recommendations of the UK Committee on Medical Aspects of Food and Nutrition (COMA) [14] and the Scientific Advisory Committee on Nutrition (SACN). [15]

· ‘Traffic-light’ nutritional labelling is also recommended by the National Institute of Health and Clinical Excellence (NICE). [16]

II) If you are not a food retailer or manufacturer, please provide your views on the current provision of FoP labelling in the UK

FPH supports the BHF led Joint Response answer to this question. In addition FPH makes the following observations:

· FPH is disappointed by the lack of consistency and degree of variation in the UK food labelling market – consistency over the most useful and evidence based approach is vital to allowing consumers to make informed choices about the food products they purchase

· FPH notes that of those companies not choosing to utilise the food label that clear evidence demonstrates is most useful to consumers (traffic light labelling), some have sought to perpetuate false claims about the traffic light scheme, as noted in the BHF Joint Response

· Companies have also misled the customers at whom their product is aimed, for example, by using adult women’s %GDAs for labelling sugary cereals promoted to children. (Children’s smaller %GDAs for macronutrients would mean that a stated food quantity would represent a far higher percentage of %GDA than for an adult woman).

· FPH urges the government to set out a firm recommendation for all food companies to use the single integrated food label including traffic light colours in order that people are able to make informed dietary choices, and identify healthier choices at a glance

· The food industry has expressed concerns that changes to the current provision of Front of Pack nutritional labelling will result in reduced profits and therefore job losses [17], [18]

· These arguments are false. Study participants report that traffic light labels are particularly useful for comparing products [19] and are therefore more likely to influence specific product choices rather than quantities purchased, so would impact little on jobs in the food industry

III) in what circumstances do you think it might be appropriate to give an energy declaration alone FoP, instead of energy, fat, saturates, sugars and salts? Please detail the reasons for your views

FPH supports the BHF led Joint Response answer to this question.

V) Currently FoP labelling in the UK is based on ‘per portion’ The FIR permits expression of FoP information per 100g or per portion, but where per portion information only is provided, energy should be provided per 100g in addition. Views are sought on whether per portion remains the right basis for consistent FoP declarations.

FPH supports the BHF led Joint Response answer to this question.

VIII) The FLABEL study indicated that consistency in positioning of the FoP label also played a part in gaining consumer attention. Views are sought on the degree to which position on pack could be harmonised.

FPH supports the BHF led Joint Response answer to this question.

IX) Views are sought on whether % Reference Intakes (%GDAs) should be used on all FoP labels.

FPH supports the BHF led Joint Response answer to this question. In addition FPH makes the following observations:

There are several key problems with Guideline Daily Amounts (%GDAs) being used on their own:

· %GDAs do not distinguish between recommended maximum (for fats, sugar, salt) and recommended minimum (for fibre): they appear to represent a target consumers should reach, rather than a maximum that should not be exceeded regularly.

· People differ in their requirements. Not everyone is of average size (which %GDAs are based on); requirements for those who are over- or underweight, elderly or ill may vary.

· Labels using %GDAs can also mislead by using arbitrary portions sizes instead of amount per 100g, preventing easy comparisons between different products as different companies use different portion sizes.[20]

· Concern that %GDAs have been produced and energetically promoted by the food and drink industry, rather than by health-based organisations.[21]

· Standard %GDAs signals lack colour coding for quick consumer appraisal and interpretation and some retailers confusingly use colours to differentiate the type of nutrient rather than the levels of those nutrients

· Research demonstrates that most shoppers spend insufficient time choosing food products in order to interpret %GDAs [22],[23], [24]; whereas traffic-light nutritional labelling can be understood at a glance [25], helping consumers make healthier food choices by choosing products with fewer red (or amber) symbols and more green (or amber) symbols [26]

· %GDAs take longer to interpret, even for literate and numerate consumers [27], [28]

· Research shows that traffic light colours and high, medium and low text are the most important factors in achieving high levels of comprehension, making it vital for these to be used on all front of pack labels [29]

· Research participants often report that arithmetic nutrition labels such as %GDAs are more difficult to understand that ‘traffic-light’ nutritional labelling [30], [31]

· By contrast, a recent EU/industry-funded project reported that the use of colour coding can increase attention and use in certain situations [32]

· FPH urges the Department of Health to take account of the fact that %GDAs have been energetically produced and promoted by the food and drink industry, rather than by health-based organisations

· Although research for the FSA recommended a combination of traffic-lights, text (high/medium/low), and %GDAs, the use of traffic lights was the most important factor affecting usefulness of FoP labelling, with %GDAs alone the worst-performing labels.[33], [34]

· The conclusion from behavioural economics is that traffic-light labelling sends a clear behavioural signal: colour-coded nutrient information and absolute amounts, not percentages, are best, particularly for reaching those with less knowledge.[35]

X) Given current market practice, and the research on consumer preference, a move towards more consistency would require most interested parties to make some changes alongside the changes that would be required by the FIR. Views are sought on interested parties’ preference for the following options for a single approach:

· %GDA only

· %GDA + HML text + interpretative CC based on standardised nutrient levels

· %GDA + HML text

· %GDA + interpretative CC based on standardised nutrient level

· Colour coding only

· Colour coding + %GDA

· Colour coding + HML text

FPH supports the BHF led Joint Response to this question. In addition FPH makes the following observations:

· FPH supports the BHF led Joint Response view that there is a clear evidence base for a system that works best for UK consumers – a label that includes traffic light colour coding, high, medium and low text, with the optional addition of percentage daily amounts. ***

· As per the answer to Question IX above, although research for the FSA recommended a combination of traffic-lights, text (high/medium/low), and %GDAs, it is important to recognise that the use of traffic lights was the most important factor affecting usefulness of FoP labelling. %GDAs alone were the worst-performing labels. [36], [37]

XI) Do you have any alternative suggestions that might fulfil the Government’s ambition to see a more uniform approach to FoP labelling?

FPH supports the BHF led Joint Response answer to this question.

XII) If your business already provides FoP information, what form of FoP labelling do you use and why? Do you have any research that supports your choice of FoP scheme that you would be willing to share? We are particularly interested in research that:

· Addresses consumer preferences, consumer understanding and comprehension (particularly amongst lower literacy and lower socio-economic groups, those of different ages, disabilities, long term conditions, gender, race, religion or belief, pregnancy and maternity

· Demonstrates any impact on consumer choice

· Demonstrates any effect FoP has had on the reformulation of food products

FPH supports the BHF led Joint Response answer to this question. In addition FPH makes the following observations:

· Food labelling must not widen dietary inequalities by failing disadvantaged consumers, those who are less numerate or for whom English is not their first language

· Only a fifth of the population have sufficient numeracy skills to achieve a good GCSE in maths according to the Skills for Life Survey [39]

· %GDAs s take longer to interpret, [40] even for literate and numerate consumers [41], [42]

· ‘Traffic-light’ labels are more quickly understood by a larger proportion of consumers than %GDA labels [43], including the less educated [44]

· Using %GDAs is likely to disadvantage less literate and numerate consumers, [45], [46] thus increasing inequalities in diet and therefore health

· ‘Traffic-light’ nutritional labelling performs significantly better than labels without colours across all socio economic groups [47]

· Inclusion of ‘traffic-light’ nutritional labelling and the words high, medium and low in a combined label (with the optional percentage guideline daily amounts) helps to overcome difficulties some consumers might have with interpreting nutrition labelling [48]

· A major review published in 2011 concluded that too much information (such as that provided by %GDAs) may ‘crowd out’ the message, so reducing its effectiveness [49]

· By contrast, ‘traffic-light’ nutritional labelling is a more effective tool to impact consumer choice and ‘nudge’ the public [50] towards healthier choices [51]

· Supermarkets have reported changes in consumers’ purchase behaviour following the adoption of ‘traffic-light’ labelling

· A recent systematic review of 120 studies found that traffic light labelling was preferred by most participants, being much easier to understand, particularly for making comparisons between products. Front of Pack labels were particularly beneficial for those with less education. [52]

· Behavioural economics indicate that while the %GDAs model emphasises freedom of choice, competition and nutritional education, traffic-light labelling prevents consumers from being misled and promotes more health-conscious food choices. [53] Positive effects of traffic light signposting on the behaviour of both consumers and retailers have been reported. [54], [55], [56], [57], 58, [58], [59], [60]