Food Law News - UK - 2005
FSA Consultation Letter, 18 March 2005
LABELLING - Further consumer research on signposting labelling
The Agency's Action Plan on Food Promotions and Children's Diets and the recently published Choosing Health White Paper for England contains a commitment to develop a single UK wide signposting scheme to make it easier for consumers to make healthier choices. Responses are requested by: 15 April 2005
This initiative complements work being taken forward as part of the Scottish Action Plan Eating for Health, Meeting the Challenge, the Welsh strategy 'Food and Wellbeing' and the proposed Food and Nutrition Strategy for Northern Ireland .
This work also has an important role in reducing potential confusion caused by the increasing range of different food retailer and manufacturer signposting schemes being applied in the UK at the current time.
In November last year, the Agency published the results of qualitative research to examine what form of signposting consumers would find most helpful. The research revealed strong support for the principle of signposting, and identified two of the five formats tested as being particularly promising. These were:
- simple traffic light: providing a single overall rating for the food presented as one of three colour coded ‘lights' (green, amber or red)
- multiple traffic lights: with separate high, medium or low ratings (and corresponding green, amber or red colour coding) for each of: fat, saturated fat, salt and sugar
In December, the Agency held a stakeholder meeting to discuss the outcomes of this research. At the meeting it was agreed that the Agency should:
- undertake further focus group work to develop an execution of a Guideline Daily Amount (GDA) based format (i.e. to indicate the proportion of fat, saturated fat, salt and sugar an individual food contributed towards the overall GDA for each of these nutrients) which would appeal to consumers for inclusion in the next phase of research
- commission quantitative consumer research to examine consumers' understanding of, and preference for, the single traffic light option, the multiple traffic light option and a GDA-based option which would be informed by the results of the focus group work
- establish a ‘Signposting working group' to help with the planning both the additional qualitative and quantitative research
The findings of the focus group work are set out below, together with an outline of the next phase of the consumer research, on which views on some specific issues are sought.
Focus group research to Improve the GDA execution
The signposting working group (which was set up in January 2005 and comprises representatives from retailing, manufacturing and consumer organisations) was consulted on the study design for this research. The key findings in relation to GDA executions were as follows:
- Percentages / Numerical information: there was no consensus among consumers on whether the GDA information should be presented as a numerical value, or as a percentage of the GDA. Where percentages were used, there was some confusion as to whether it represented the percentage of that nutrient in the food, or the proportion that food contributed to the GDA for individual nutrients.
- Bar charts: there was no consensus. Where bar charts were used to present the percentage information, some consumers found them useful, others found them difficult to interpret and felt they added little value in terms of a visual aid.
- Colour coding and high, medium and low descriptors: These features, and particularly colour coding, were welcomed by all and considered to be helpful in interpreting the numerical information. Most respondents indicated that they would use these features to guide their purchasing decisions, and would only refer to the numerical data to differentiate between similar products, or if they had particular concerns about a specific nutrient. Without the descriptors, respondents found the numerical information difficult to use except where the food contained particularly high or low levels of a particular nutrient and for products eaten in large portions.
The research also reached the following conclusions:
- multiple traffic lights: Consumers felt that the addition of percentage GDA information to this simple system unnecessarily and unhelpfully complex
- simple traffic lights: Consumers preferred information based accompanying text to advisory messages
As was the case in the first phase of research, there was strong support among consumers for the idea of signposting as a tool to help them make healthier choices.
On the basis of the results of the research, and taking account of the views of the Signpost working group, it is proposed that the GDA design featuring colour coding, and using numbers rather than bar charts (i.e. option 7), should be included in the second phase of research.
Design of quantitative consumer research
The next phase of research will test consumers' understanding of the most popular signposting concepts identified from earlier research, and the reasons for this. For the purposes of this research, the effectiveness of each signposting concept will be judged by the ease with which it allows the consumer to make an assessment of the product, in terms of fat, saturated fat, salt and sugar content, and to compare the nutrient content of similar products; and consumers' preferences for each signpost concept.
The proposed methodology, which has been developed with input from the Signposting working group, is as follows:
- a total of 1,300 (if three signposting options are tested) or 1,700 (if four signposting options are tested) hall based interviews of around 25 minutes in length at four locations in England, and one location in each of Scotland, Wales and Northern Ireland
- quantitative analysis will be broken down by gender, age, life-stage, socio-economic group, and interest in diet-related health issues
- questions will be included to assess consumer use and understanding of the signposting options (both looking at a single product in isolation and comparing a pair of similar products) and preferences between the tested formats
- each of the signposting concepts to be tested will be incorporated into visual stimulus material relating to paired products within four categories consisting of: ready meals, breakfast cereals, and two from pizza, breaded chicken products, crisps, and biscuits)
- visual stimuli will consist of life-sized photographed images of real products available in retail outlets which would appear on double sided A4 boards (i.e. with the front of the packet on one side of the board, and the back of packet (with consistent nutrition labelling panel) printed on the other side)
- the order in which interviewees are shown the visual stimuli incorporating the signposting concepts will be rotated
- a small number of follow-up qualitative interviews will be conducted (48 weighted towards C2DE's) to explore the reasons for signposting
To ensure robustness, the study has been designed to ensure that consumers consider each concept in detail, without interviewee fatigue, and as such the research has to be limited to testing a maximum of four signposting options. These will include the following three concepts:
- simple traffic light: providing an overall (green, amber or red colour code) rating for the food as a whole, with descriptive wording relating to the healthiness of the food
- multiple traffic lights: with a separate high, medium or low rating (and corresponding green, amber or red colour coding) for each of fat, saturated fat, salt and sugar
- GDA-based concept with colour coding: indicating the amount of fat, saturated fat, salt and sugar provided per serving, together with the GDA for each nutrient; accompanied by traffic light colours to indicate whether the content of each nutrient in the food is high, medium or low
It would be possible to include a fourth option, which could take the form of one of the following:
- monochrome GDA based concept: indicating the amount of fat, saturated fat, salt and sugar provided per serving, together with the GDA for each nutrient; but without colours or any indication of whether the nutrient content of the food is high, medium or low
- no signposting: rely on the back of pack nutritional information alone as the source of information. It is recognised that this approach would not reflect the current situation in the UK marketplace, given the range of signposting schemes already in use, and would not help identify the signposting approach that is most helpful to consumers, which is the aim of the exercise
It is intended that fieldwork for the quantitative research will start in May, and be published later in the summer.
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