FSA Consultation Letter, 30 July 2009

NUTRITION LABELLING - Consultation on front of pack nutrition labelling for pre-packed foods sold through retail outlets in the UK

The Project Management Panel’s independent research on front of pack (FOP) labelling concluded that there should be a single approach to FOP labelling which combines use of the words 'high, medium, and low', traffic light colour coding and percentage of Guideline Daily Amount (%GDA). In this document we have called this an integrated approach. The Agency is now formally consulting on practical issues which need to be resolved for an integrated FOP nutrition labelling approach to work in real life settings and help consumers to make healthier choices.

We are grateful for the input received from stakeholders in identifying the areas of costs and benefits as well as other evidence related to FOP labelling that was received as part of the pre-consultation discussions. Feedback has been used to develop the content of this consultation package.

We welcome your comments on the questions included in the consultation document and Impact Assessment, and these will inform discussions by the Agency’s Board and its advice to Ministers.

The consultation document is available on this site. See: FOP Consultation Document. The following is the initial overview taken from the consultation document:

Overview

1. The independent evaluation study on FOP nutrition labelling found that a single FOP approach would be most helpful for shoppers and that the most effective FOP label combined text (high/medium/low), traffic light colour coding and %GDA information in an ‘integrated label’. The Agency is now formally consulting on practical issues which need to be resolved for an integrated FOP nutrition labelling approach to work in real life settings and help consumers to make healthier choices. The independent study, funded by the FSA (referred to as the independent research throughout) was published in May 2009, and is available at http://www.food.gov.uk/news/newsarchive/2009/may/pmp

2. Stakeholders views are being sought on the following issues:

• Scope: Consumers use FOP labels across a range of products, and are particularly interested in having this information for more complex products where nutrient content is not obvious. While the FSA currently recommend FOP labelling for seven product categories, we know that many retailers and manufacturers provide labelling on a wider of products. We would therefore welcome your views on the range of foods to which an integrated FOP label should be applied, including suggestions for a limited number of exemptions (paragraphs 17 - 21).
• Calories: We know that consumers find calories on the FOP helpful in making healthier purchasing decisions, for example when watching their weight. We would therefore welcome your views on how to include calories in an integrated FOP label (paragraphs 22 - 28).
• Portion size criteria: It is important that FOP labels help consumers to assess the healthiness of foods regardless of whether the portion size is small, medium or large. Current guidance on the use of text and traffic light colour codes establishes criteria which take account of nutrient levels per 100g and for food recommended to be eaten in portions greater than 100g. We would welcome your views on whether there should be criteria for foods recommended to be eaten in small portions which take account of portion size. If so what should these criteria be (paragraphs 29-31)?
• Saturated fat: We know that consumers are confused by the various terminologies used for saturated fat and their understanding of saturated fat in the context of their overall diet is poor. We would like to improve this where possible to allow consumers to be aware of healthier choices. We also know it is of particular use for consumers with particular health concerns. Do you agree with the proposed approach to improving communication and understanding of saturated fat in an integrated label? If not why not? (paragraphs 32 - 34).
• Guideline Daily Amount (GDA) for sugars: We are aware that the levels of sugars added to some foods are of concern to consumers, and it is important that labels help them to identify sugary products so that they can make healthier choices. In light of the European Food Safety Authority’s recent opinion on the sugars Dietary Reference Value for nutrition labelling purposes we would welcome your views on the appropriate sugars GDA figure that should be used on an integrated FOP label (paragraphs 35-38).
• Salt thresholds: Because most salt consumed is already in the foods consumers buy it is important that labels are as helpful as possible in identifying lower salt products, again so that consumers can make healthier choices. We would welcome your views on whether the salt thresholds for an integrated FOP label should be revised and if so which approach should be used (paragraphs 39 -44):

  (a) changes to the per 100g criterion,

  (b) changes to the per portion criterion, or

  (c) both.

• Improving legibility: In the independent study some consumers sometimes found FOP labels too small to read, or simply did not notice the FOP label, which means that they are unable to use the information provided to inform their decisions. We would therefore welcome views on proposed guidance to maximize the visibility and legibility of an integrated FOP label (paragraph 45-46).
• Public awareness: The independent research found that there was a high level of awareness of the various FOP labels in the marketplace, but use of FOP labels remained low. Raising consumer awareness is likely to increase the impact an integrated FOP label has on purchasing decisions; and we are keen to ensure that this information is equally available across all consumer groups. We would therefore welcome your views on how government and stakeholders can work in partnership to raise consumer awareness and understanding of an integrated FOP label. We are particularly interested in targeting those consumers that do not currently use FOP labels to influence their food purchasing choices, and in particular consumers in social grades C2, D and E, those aged over 65 years and families with children) (paragraph 47).

Significant progress has already been made in the UK by many UK retailers and manufacturers in terms of introducing FOP labelling to a wide range of foods on a voluntary basis. A voluntary approach allows industry to change labels (as a part of their normal re-labelling cycle) at minimum cost. The Agency notes that integrated FOP labels (incorporating ‘High/Medium/Low’ text, traffic light colour coding and %GDA) are already available in the marketplace, such as those used by Asda and McCain. The Agency will continue to monitor progress of the voluntary approach.