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DHSC Consultation, 30 July 2020
Consultation Document: Building on the success of front-of-pack nutrition labelling in the UK: a public consultation
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We want your views on making sure the 'traffic light' front-of-pack nutrition labels (FOPNL) scheme continues to help people choose what food and drink to buy. This consultation closes at 11:59pm on 21 October 2020
Front-of-pack nutrition labels (FOPNL) are a crucial intervention to support healthy choices and reduce obesity rates by communicating complex nutritional information to shoppers in a way that’s easy to understand.
This can reduce dietary intakes of calories and nutrients, such as salt, saturated fat and sugar which, if overconsumed, have been linked to chronic disease.
In the green paper Advancing our health: prevention in the 2020s, the government committed to consult on the UK’s FOPNL. We previously committed to exploring FOPNL in chapter 1 and chapter 2 of the childhood obesity plan.
This consultation asks for your views and evidence on:
The following are the opening paragraphs from the Consultation Document:
1.1 Obesity is one of the top public health challenges for this generation.
1.2 In England 63% of adults were classified as overweight or obese in 20181, in Scotland the figure was 65%2 and in Wales it was 60%3. In the 2018/2019 Health Survey for Northern Ireland, 62% of people were recorded as overweight or obese4. This challenge is not unique to adults, for example, 28% of children aged 2 – 15 also being classified as either overweight and obese in England5. In 2018, obesity-related conditions contributed to 711,000 hospital admissions in England. It is estimated that the NHS currently spends £6.1 billion a year dealing with ill-health caused by individuals being overweight and obese6. Addressing obesity will therefore reduce the huge financial costs that obesity places on us as a nation.
1.3 The outbreak of COVID-19 has been one of the biggest public health challenges ever faced by the UK and is a catalyst for us to redouble our efforts to reduce obesity levels in the UK. Emerging evidence shows that patients with obesity, and in particular morbid obesity, may be more likely to be admitted to intensive care; require advanced treatment, such as ventilation; and have 37% increased risk of dying from COVID-19 compared to non-obese patients. 7
1.4 This means that the personal costs of obesity are being felt both in short term health impacts including increased risk of adverse outcomes from COVID-198 and in the longer term through increased risk of developing serious diseases such as type 2 diabetes, heart disease and some cancers. Most people know that eating a healthy diet whilst keeping active will help to prevent weight gain and reduce their risk of developing ill health, but this can be hard. We therefore need to support people to make healthier choices and build these into their everyday lives.
1.5 The causes of obesity are complex and multifaceted, and there is no single solution. That is why the UK Government and Devolved Administrations have developed strategies to deliver a wide range of policies to change our food environment for the better, and to make the healthier choice the easier choice.
1.6 For people to make healthy choices about the food and drink they are purchasing, they need to be able to understand what is in that product and what it means for their health. We believe that front of pack nutrition labels (FOPNL), or labels that use interpretational aids such as colours and symbols are a crucial intervention to support healthy choices and reduce obesity rates by communicating complex nutritional information to shoppers in a way that is easy to understand. This in turn can reduce dietary intakes of calories and nutrients, such as salt, saturated fat and sugar which, if overconsumed, have been linked to chronic disease and help consumers to control their calorie intake.
1.7 That is why in 2012, following significant research on labelling schemes, the UK Government and Devolved Administrations consulted on how greater consistency and clarity on FOPNL might be achieved. As a result, in 2013 UK Health Ministers recommended the voluntary multiple traffic light label (MTL), a colour-coded system which shows at a glance whether a product is high (red) medium (amber) or low (green) in fat, saturated fat, salt and sugars, including the total energy (kilocalories and kilojoules) it provides9, as shown in Figure 2.
Figure 2: The UK Government and Devolved Administration’s recommended Multiple Traffic Light Label
1.8 Seven years on, the MTL has proven to be a success with 9 in 10 shoppers agreeing it helps them to make informed decisions when purchasing food10.
1.9 We welcome and value the commitment made by many businesses, including all major retailers across the food and drink industry who have adopted the MTL on a voluntary basis.
1.10 The pioneering label was one of the first in the world and since 2013, many other Governments have followed the UK’s lead and developed their own schemes to provide better information to their own populations. Why are we consulting?
1.11 The aim of this consultation is to gather views and evidence to help to inform any future improvements to the UK Government and Devolved Administration's recommended FOPNL, to ensure that the UK's label remains the most effective at informing healthier choices.
1.12 We want to play our part in helping people in the UK eat a balanced diet. FOPNL is an important tool to support consumers to better understand the nutrient content of their food and drinks and make healthier choices for themselves and their families.
1.13 We believe now is the right time to consult for several reasons. Firstly, it is seven years since the UK Government and Devolved Administrations recommended the MTL. During that time, the evidence on the effectiveness of FOPNL systems has continued to develop, and several new forms of FOPNL schemes have been implemented in other countries.
1.14 Additionally, in this time the way we purchase groceries and food has changed. In 2018, the UK spent £12.3 billion on online grocery shopping - one of the fastest growing sectors in the UK grocery market11. As such, the way we interact with labels is changing, and it is right that we test with the public that our FOPNL remains effective however and wherever we shop.
1.15 Lastly, while the UK was an EU member state, the European Food Information to Consumers Regulation 2011/1169 (EU FIC) established the criteria for the use and form of FOPNL the UK can use and how we can enforce it. Whilst we have now left the EU, we have entered a transition period until 31 December 2020 during which time we have to remain regulatorily aligned with the EU FIC.
1.16 However, on 31 December 2020 the transition period will end. After this, the UK Government and Devolved Administrations will seek to build on the success of FOPNL in the UK to improve the current scheme. This consultation will therefore ensure that we are in the best position to act quickly to continue to support shoppers to understand what is in the food they are buying.
1.17 This consultation is just one part of the UK Government and Devolved Administration's wider evidence-gathering exercise to ensure the FOPNL recommended is one that works the best for the UK market. As a first step, this consultation will collect views from the public on our current label, whether it could be improved, and invite views and evidence on different, international examples of FOPNL - all of which are based on new evidence that has emerged since we recommended the MTL in 2013.
1.18 Separately, the UK Government is currently in the process of commissioning an independent research body to empirically test whether specific FOPNLs help UK consumers identify the healthier choice when purchasing food and drink. Taken together, this consultation and our empirical research will provide robust evidence to support any changes to our current FOPNL to ensure that it has maximum impact to inform healthier choices.
1.19 In addition to this consultation, the UK Department of Health and Social Care work closely with the Department for Environment and Rural Affairs (Defra) on food labelling and nutrition. At the end of the transition period, Defra will have an opportunity to review food labelling in England and work with the Devolved Administrations to establish shared food policy goals across the UK. Government objectives 1.20 We want to continue to do all we can to help consumers make better informed food choices and to help them improve their health, supporting them to prevent obesity and related conditions such as cancer, heart disease and type 2 diabetes as well as reduce their risk of adverse outcomes if they contract COVID-19.
1.21 To achieve this ambition, the joint objectives of all four administrations for FOPNL are:
1.22 This consultation contributes to these objectives by inviting views and evidence to ensure that the FOPNL that the UK Government and Devolved Administrations recommend for use in the UK remains the most effective system for UK shoppers. Consultation design 1.23 This consultation is split into three core sections and we are seeking views on each area:
1.24 The consultation will run for 12 weeks. Our preferred method of response is via SurveyOptic, the Government’s consultation hub. To help with your response, you will find the questions outlined in each section, and provided as a summary in Annex D. We have specified the questions that should be answered by businesses and those that should be answered by the general public.
If you do wish to send an email response, please send those to firstname.lastname@example.org
1.25 Currently, European Union (EU) Regulation 1169/2011, which came fully into effect on 13th December 2016, sets out the requirements on presenting Food Information to Consumers (EU FIC), including voluntary FOPNL. For example, the EU FIC sets out the criteria for the type and quantity of nutrients to be displayed. In May 2020, as part of the ‘Farm to Fork Strategy’ the EU Commission announced intention to mandate a form of FOPNL that is yet to be confirmed.
1.26 The EU FIC will continue to apply in the UK until the end of the transition period. The nature of our future relationship with the EU will be subject to the negotiations.
1.27 After the end of the transition period, the UK Government and Devolved Administrations will seek to build on the success of FOPNL in the UK. This consultation, and the wider research piece we will commission, seeks to ensure that upon the end of the transition period, the UK Government and Devolved Administrations are appropriately informed by the public, food and drink industry, academia, Non-Governmental Organisations and consumer associations to adapt future regulation in a way that best works for our population and is in line with future trade ambitions.