Improved nutrition labelling

Since the advent of the European Nutrition Labelling Directive and an agreed regulatory basis for the provision of nutrition information, there has been little scope for divergence from the statutory format, except via additional off-label information to assist consumers to understand and use the information on the pack by providing leaflets, customer helplines and other sources of assistance. However, this does not necessarily help at point of purchase.

Feedback from consumers informs businesses about what their customers want and expect and the results of the UK consumer research outlined in section 6.4 above came as no great surprise to the food industry. Some major UK retailers had already begun to highlight information about specific nutrients below the standard nutrition panel in response to dietary advice in the (then UK Government's) health strategy 'Health of the Nation' White Paper6 recommendations to reduce consumption of fat, and especially saturated fat, and to reduce levels of obesity.

In pursuit of UK Government strategy in respect of nutrition goals, a Nutrition Task Force (NTF) was established to consider a range of aspects which might assist in improving consumers' eating habits including, unsurprisingly, the use of nutrition information. A group of experts commissioned the consumer research project, described above, which concluded that current nutrition information was not helpful to many consumers.

The industry began to look at the possibilities, within the constraints of the existing legislation, for providing additional voluntary nutrition labelling as a tool to help consumers choose a healthy diet. The initiative was formalised in May 1995 under the auspices of the Institute of Grocery Distribution (IGD), a research organisation which draws its membership from every stage of the food supply chain and has links with a number of consumer organisations.

The existing scientific, consumer and company research was reviewed, including that described in section 6.4, and new research commissioned to identify a labelling format for food products which would provide consumers with information to enable them to gain an improved understanding of the amount of fat and energy they consume in their daily diets. The objective was that the labelling format should provide relevant information and the nutrition information be expressed in a format useful to consumers: it should help them to understand and manage the type and balance of nutrients (fat and energy) they were consuming in their diet. The information should be clear and simple to understand, for which reason the study focused on three nutrients in order not to confuse consumers with overly complex or detailed information. The choice of nutrients, fat, saturates and calories resulted from the identification that such a focus would be a significant step forward in providing supplementary nutrition labelling, and that simpler supplementary nutrition labels would assist more consumers in selecting healthy diets.

6 The Health of the Nation — a strategy for health, HMSO, 1992

A two-step research programme was conducted. Step one consisted of qualitative research (five focus groups) which explored consumer attitudes towards nutrition labelling and provided guidance for the design of the larger quantitative research. Step 2, the quantitative research, covered 2300 adult consumers in a nationally representative study to assess the performance of a number of nutrition labelling formats. The research was designed to assess consumers' ability to use the label, i.e. their performance, rather than their preference for different labelling formats.

The main findings of the research were as follows:

  • Current levels of nutrition understanding are low.
  • Current nutrition information is too complicated, frustrating and often illegible.
  • Fat and calories were the most monitored nutrients, followed by protein and sugar with fibre and sodium stimulating little concern.
  • Many people only monitor the nutritional quality of their food if they are dieting or ill.
  • The terms carbohydrate, saturates and sodium were not understood.
  • Kilojoules are perceived as irrelevant to adult consumers.
  • Consumers' ability to assess accurately the calorie content in foods was quite good. However, their ability to assess accurately the fat content in foods was poor. Products were rated as high or low in fat with very few intermediate assessments.
  • Nutrition information is read whilst in the supermarket.
  • There was genuine support for guideline daily amounts. Consumers felt that this was new information which helped them to place nutrition information in context, making the whole label more valuable and useful.
  • Consumers preferred the use of whole numbers to decimal places and could not understand the relevance of having the information expressed to a tenth of a gram.
  • Per serving' information was preferred over 'per 100g', although the 'per 100 g' information was used when comparing the nutrient content of similar products at the point of purchase.

The IGD's guidance on Voluntary Nutrition Labelling was formulated after thorough analysis and discussion of the research results. The concept of Guideline Daily Amounts (GDAs) was central to the labelling formats tested and the underlying purpose of the supplementary voluntary nutrition information, i.e. to assist consumers choice of a healthier diet in line with 'Health of the Nation' recommendations. A number of companies were already promoting daily 'amounts' for fat and calories in company literature, and it clearly made sense to work to a common standard to avoid confusing consumers. The GDAs recommended by the IGD were agreed following discussion with MAFF and the DH. They are based on the predicted daily consumption of an average consumer eating a diet conforming to Committee on Medical Aspects of Food Policy (COMA) recommendations. They are not intended as targets to aim for, but guidance to assist consumers in their understanding of their daily consumption of calories, fat and saturates. The recommended Guideline Daily Amounts are:

Women

Men

Calories

2000

2500

Fat

70g

95g

Saturates

20g

30g

It was recognised that consumer understanding of saturates is low, but the GDA was provided for those companies which choose to offer this information.

There are four other recommendations. The first of these concerns additional on-pack information. In line with the research results which indicated that consumers were most interested in fat and calorie content, and on a per serving basis, the IGD recommends that this information be illustrated independently of the nutrition panel in a separate box, as shown in Tables 6.1 and 6.2. Where this is not possible because of the pack size or layout, it is suggested that this information be highlighted in colour within the nutrition panel. The 'per serving' measures must be stated and be appropriate to consumers, who show a preference for household units, e.g. per teaspoon, per half pack, per biscuit, per slice.

The next recommendation is that the column order in the nutrition information panel should be changed so that 'per serving' information comes before the 'per 100g' information.

The IGD also recommended that a consumer education programme is required to improve consumer understanding about saturates and their role in the diet. Companies are recommended to use Group 2 nutrition information thereby ensuring that saturates appear on the label.

Table 6.1 Nutrition information: typical values

Nutrition information

Typical values

per 100 ml

280 kj

Energy

67 kcal

Protein

3.2g

Carbohydrates

4.8g

of which sugars

4.8g

Fat

3.9g

of which saturates

2.6g

fibre

0.0g

sodium

0.1g

Table 6.2 Nutrition information: per serving

Table 6.2 Nutrition information: per serving

Per serving (a cup)

67 calories

3.9g fat

The final issue is that of legibility. The IGD referred to its June 1994 publication Packaging Legibility - Recommendations for Improvements as guidance to assist consumers to read the information provided. The scheme has been widely adopted on UK supermarket 'own label' products. Uptake on branded foods has been less enthusiastic, for two reasons. Firstly, the recommended supplementary format is, strictly speaking, illegal. This was recognised by the IGD, and was stated in the published Guidelines:

MAFF point out that, in the strictest interpretation of the current legislation, this information would likely fall within the definition of 'nutrition information' in Article 1(4)(a). Under Article 4, which sets out the order in which information should be given and the eighth Whereas clause, which prohibits any other form of nutrition labelling than that specified in the Directive, the presentation of fat and Calories as recommended by the IGD Nutrition Group would be prohibited. However, LACOTS [Local Authorities Co-ordinating body on Food and Trading Standards] supports nutrition labelling which assists consumers to make informed dietary choices and takes the view that the IGD recommendations go some way to achieving this aim and therefore welcomes the IGD recommendations. Whilst noting the current legal constraints local authorities will carefully consider pragmatic approaches which will benefit consumers. In the longer term LACOTS strongly supports changes to existing legislation to enable alternative forms of information to be given.

Secondly, most major food producers operate in a European environment and package and market accordingly. The supplementary information, especially the Guideline Daily Amounts, would not necessarily be appropriate to consumers elsewhere in Europe, and would almost certainly fall foul of local enforcement authorities. Many UK manufacturers have therefore opted not to display the supplementary information on the pack, but to include it in their company leaflets and promotional literature.

The IGD is committed to reviewing the effectiveness of the supplementary voluntary labelling, and to considering other nutrients. Sodium/salt has been uppermost in recent discussions.

The establishment of the Food Standards Agency (FSA) with its statutory responsibilities to the consumer sparked a major review of food-labelling requirements from the perspective of consumer needs. An eighteen point Action Plan was agreed by the FSA's Board in September 2000. Its broad themes are the 'progressive development of a more transparent labelling regime based on consumers' priorities and a common set of EU rules, promotion of good labelling practice and the improvement of consumer education and advice'. Points 4 and 7 of the Action Plan are:

  • To press for EU rules requiring nutrition labelling on all foods.
  • To commission consumer research to define the ideal content and format for nutrition labelling.

Results of the qualitative research into possible new formats were published in March 2002. The formats used in the research took into account the existing statutory formats described in section 6.2 and the IGD voluntary labelling supplementary format. The study, based on group and individual in-depth interviews, compared eight different specimen labels to see which layouts were easiest to read and understand.

It is interesting to compare the results of this research with the 1995 survey. The main findings were that consumers check the calorie and fat content first, are more likely to check nutritional values 'per serving' than 'per 100g', and cannot do sums.

In summary, the research found:

  • People generally check calories first.
  • Fat content was widely checked and the most commonly avoided nutrient.
  • Salt was preferred to sodium as a clearer labelling term.
  • People understood that 'trace' meant a small amount, and felt that replacing it with '0' would be inaccurate and misleading.
  • Putting nutritional values as a percentage of Guideline Daily Amounts (GDAs) confuses people.

The research found that consumers would value some reordering of important nutrients such as salt in food labels, and putting some in bold or in a separate text box, but this could risk downgrading the perceived value of others, particularly sugars. The FSA also pointed out that, although salt is regularly listed on labels and is useful for people with conditions such as high blood pressure who need to reduce their salt intake, sodium occurs in ingredients other than salt, e.g. sodium bicarbonate that is added to bakery products.

Again the research found that consumers do not always check labels, particularly for items they buy regularly. Also, of the eight specimen labels shown to consumers, the one which grouped together fat, saturates and salt (linked to coronary heart disease) was considered sensible. So, little has changed since 1995.

The FSA states that the report will help inform its submission to any future discussions about nutrition labelling in Brussels. It will be interesting to see how our European neighbours respond from a regulatory viewpoint. Most importantly, will the proposed changes actually help consumers make healthier choices within a total diet context and encourage those who do not currently use nutrition information to do so, or help those who would like to use it but do not understand it? One thing for certain is that change is unlikely to be rapid.

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