Front of pack versus back of pack. guideline daily amounts (GDAs) versus traffic lights. Portion sizes, font sizes and health claims. Just a flavour of the minefield of issues surrounding food and drink labelling. If you're developing a headache over these subjects, you're in good company.
The debate over nutrition labelling is enough to induce a migraine. For years, the nutrient profiling debate has raged over three ways to convey information about fat, saturated fat, sugar and salt content on food and drink packaging. They are: GDAs, traffic lights or a combination of the two.
More UK firms back GDAs than traffic lights and the Food and Drink Federation (FDF) and the CIAA, the Confederation of Food and Drink Industries of the EU, support GDAs.
Speaking at Food Manufacture's 'Food labelling in the dock' event in Warwick last month, FDF director general Melanie Leech said: "There are some categories where a simple traffic light approach conveys the wrong advice."
She gave the examples of hot cross buns and wine gums. Traffic light labels for both displayed mostly green colours, despite them being high in sugar. Comparing hot cross buns with crisps sent out similar mixed signals, with the buns looking healthier, especially on salt, but sugar content remaining the sticking point.
She saw no problem with the use of traffic lights or GDAs if shoppers indicated no preference. But she said combining the two schemes wouldn't work. "I don't think at the moment it's the right thing to do. They are conceived from different starting points."
The Food Standards Agency (FSA) champions the traffic light approach, arguing that it is easier for consumers to understand. Countering claims the food industry had acted too soon in developing front of pack nutrition labelling solutions, Rosemary Hignett, head of the FSA's nutrition division, said: "We aren't in a position of sitting back and waiting for five years to see what the answer might be."
To settle the argument, the FSA launched in-depth consumer research on front of pack labelling at the end of last year. Hignett anticipates a report on the results in late spring, followed by a public consultation and the issuing of advice to ministers.
"The aims of the study are to determine how consumers use front of pack labelling and test comprehension of it," said Hignett at the Food Manufacture conference.
Whatever the outcome, she reassured processors that the FSA was mindful of the cost of labelling developments, supporting Leech, who said: "We want to see a real, demonstrable cost benefit analysis."
Whichever system prevailed, Sue Davies, chief policy advisor at consumer organisation Which? argued at the conference that the evolving EU Nutrition and Health Claims Regulation should account for it. Products with high levels of particular nutrients should not be able to trumpet health claims, she said. "It's ridiculous that you could have a product with a health claim that's high in sugar or salt and that people are choosing it because they are looking for a healthy option."
In the wake of a debate on the impact of regulations on innovation, Hignett said: "I recognise there are areas where a manufacturer can make a justified claim, so long as there is evidence for it and it is not undermining the key priorities of dietary health."
Nutrition labelling should not only connect with wider thinking surrounding health claims, but also address alcoholic drinks, said Davies. In particular, there was a case for including energy content on labels, she said. "Whisky manufacturers used to say they didn't have a problem with that. It's something we'd like to see, but unfortunately there doesn't seem to be the support for it. Often people don't realise how many calories they are consuming."
Whatever direction the UK takes on nutrition labelling could be overshadowed by what happens at an EU level. The European Commission (EC) has proposed a new Food Information Regulation (FIR) combining general and nutrition labelling issues. Key elements of the proposal include the introduction of mandatory front of pack nutrition labelling embracing energy, fat, saturates and carbohydrates with specific reference to sugar and salt. Further proposals include a mandatory declaration of a percentage reference intake value (similar to GDAs) for mandatory nutrients and voluntary provision of information on other nutrients.
Renate Sommer, European Parliament rapporteur for the FIR, and the CIAA are against the introduction of voluntary nationwide front of pack labelling schemes, with Sommer fearing they will become mandatory by default. However, such schemes may well be permitted as the FIR develops and few object to the continuation of different industry labelling methods, within final regulatory guidelines.
Hignett said FIR negotiations at EC level were at an early stage. "All the signs are that there won't be an early agreement. Discussions will go on beyond the summer and into the next [Swedish] presidency."
About 1,200 amendments to the draft FIR have been introduced and were discussed by the European Parliament Committee on Environment, Public Health and Food Safety at the end of February. They include proposals for a minimum font size of 1.2mm on front of pack, versus the original suggestion of 3mm, and mandatory country of origin information where omitting it would be misleading.
Davies argued for country of origin labelling for more foods. "We think you should extend country of origin labelling. We don't see this primarily as a traceability issue, but our research suggests people are interested in where their food comes from." FM
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The reasons behind a rash of rejections
Processors have been shocked by how many claims for products under Article 13 of the EU Nutrition and Health Claims Regulation have been rejected so far.
Professor Nino Binns, consultant in nutrition and regulatory affairs, attempted to advise delegates on how to approach the issue at Food Manufacture's 'Labelling in the dock' conference.
Three European Food Safety Authority groups are handling claims applications under the legislation. Two have deadlines for opinions of July and November this year. The other has no deadline yet.
Progress is slow. Either the compilation of the final list of allowed claims, following EU Member States' votes on the issue, would be delayed, or there would only be a partial list, said Binns.
Claims that had been rejected or returned pending more information may have appealed to the wrong section of legislation or have been made in a language other than English, she said. They may also have insufficiently detailed the effects of an ingredient, have not been measurable or simply have been too vague.
"Many dairy products got thrown out over their character," added Binns. "Manufacturers were not specific enough. For example, it's not good enough to say it's milk. You have got to say what type of milk."
In addition, some submitted claims may have suggested that particular ingredients were essential, for example, for bone health, when in fact they were only beneficial.
Regarding the number of human studies required to support claims, Binns said: "My gut feeling is that you need at least two because this introduces a degree of reproducibility."
Evidence had to be provided for the precise function, dose and target group cited, she said.
Given the progress of claims so far, those referring to well-established functions for vitamins, minerals and macronutrients or established epidemiology had a good chance of being approved, said Binns. Less certain were those referring to cognitive function or antioxidant properties.
Fibre and probiotic claims related to digestive function appeared to have a good chance of success, whereas those referring to microflora and immune function seemed less likely to succeed.