6 Consumers and nutrition labelling L. Insall, Food and Drink Federation, London 6.1 Introduction: the problem of providing nutrition information Developments in nutrition research and improved scientific understanding of the relationship between diet and health have led to increasing interest in the nutri- tional aspects of the food supply. This interest is shared by academics, health professionals, government officials, consumers and the food and supplement industries alike, although not always for the same reasons and generally at dif- ferent levels of knowledge and understanding. Interest in nutrition, in respect of both total diet and individual foods, is second only to concern about food safety and is sometimes confused with the safety aspects of the food supply. Pick up any newspaper or general magazine in the UK and you will almost certainly find several column inches devoted to some aspect of food, either as the latest ‘scare’ or controversial issue, or as a feature about the most recent fashionable food trend or restaurant or celebrity chef. However, despite extensive media coverage and take-up of food issues and master classes in cookery, knowledge and under- standing about food – how to prepare and cook it, and what constitutes a healthy, balanced diet – remain poor, particularly in the younger generations and lower socio-economic groups. The nutritional content of the diet is blamed for a wide range of health problems such as obesity, cardiovascular disease and certain cancers, i.e. long-term chronic diseases as opposed to the type of short-term acute illnesses that are usually associated with food safety problems. Improving the overall diet in the UK with a view to reducing the incidence and severity of certain diet-related chronic diseases has been a major plank in UK government health strategy for several years and now involves several key departments: Education and Employment (DfEE), Health (DH), and the Food Standards Agency (FSA); the last-named has taken over responsibility for this area from the (now defunct) Ministry of Agriculture, Fisheries and Food (MAFF) since April 2000. Nutrition information is, therefore, an aspect of a very broad debate, often highly politicised, about the nutritional quality of the modern food supply, and specifically about the contribution to the modern diet, and therefore to the health of the population, made by pre-packed ‘convenience’ foods which, together with ‘fast food’ restaurants and take-aways, make a substantial contribution to the total dietary intake of a significant proportion of the UK population. In terms of issues, the provision of nutrition information ranks very high in the diet and health debate. The UK has possibly been more absorbed by this subject than have most other European Member States, a reflection, perhaps, of the cultural attitude towards food as fuel and the growing obsession with fitness and body form in a population inclining towards obesity. Where food has traditionally been enjoyed as one of life’s great pleasures, notably France, the most important factor is what the product tastes like, not the ‘vital statistics’ of its content. These cultural dif- ferences across Europe have had a significant bearing on the regulatory controls governing food labelling, including nutrition information, and are in part respon- sible for what is generally regarded as a somewhat ‘user unfriendly’ approach to nutrition labelling. This will be discussed in greater detail later in the chapter, but firstly the current application of nutrition labelling will be considered. The provision of nutrition information, as with the provision of any other form of information, is an enabling mechanism intended to assist the purchaser to make a reasoned choice about the product he or she is considering buying. The degree of interest in this particular segment of the mass of information printed on a food label is a matter which will be discussed in greater detail in section 6.4, but two essential points should be borne in mind: ? The provision of nutrition information on a label is voluntary, unless a claim is made. ? Approximately 80% of pre-packed foods manufactured in the UK carry nutri- tion labelling; this is far higher than in most other EU Member States. The strict and detailed regulatory requirements which govern the presentation of nutrition information are set out below, and it will be clear from a brief glance that the legislation was not drafted with consumer understanding in mind. This is not necessarily a criticism of the lawyers – laws are, after all, drafted and inter- preted by lawyers, not by the general public. So whilst the formulaic nature of the required presentation may appear unnecessarily prescriptive, there is good reason for this. The intention of the current legislation was to encourage the pro- vision of nutrition information in a prescribed format which would allow con- sumers to compare the nutritional content of various products. The effectiveness of this policy is another issue which will be discussed in greater detail in a later section, but it is not arbitrary and reflects the complexity of negotiating legisla- tion on a contentious issue to cover a large trading block made up of a dozen European Member States, risen to 15 at the time of writing. These states have Consumers and nutrition labelling 143 diverse geographic and cultural backgrounds, and there are therefore differences in local food supply and eating patterns. If criticism is due, it should perhaps be aimed at those authorities whose job it is to explain the existence and meaning of legislation in lay terms, but this too can be a complex communication issue and many attempts have been made to bridge the gap between legislator and con- sumer, and in the case of nutrition information are still on-going. This aspect will be developed later. 6.2 Current EU nutrition information Legislation on nutrition labelling was developed as a means of providing consumers with information about the nutrient content of the foods they were choosing in a standardised format recognisable across the European Community, thereby also promoting the freedom of movement of goods in the Single Market. An essential part of the philosophy behind the Nutrition Labelling Directive, the principal EU legislative instrument in this area, 1 was the growing recognition of the link between diet and health and the need to encourage consumers to make an informed choice about the foods they consume. It was considered that knowl- edge of the basic principles of nutrition and the provision of nutrition labelling would contribute significantly in this and act as a tool in the nutrition education of the public. To this end, it was deemed that the information provided should be simple and easily understood, with a standardised format that would allow comparison of one product with another. This means that the dual principles underlying EU legislation on nutrition labelling are consumer information and education and the removal of technical barriers to trade. As usual in the development of harmonised legislation, one of the driving forces was the divergence in national legislation that risked causing reciprocal barriers to trade after completion of the Single Market on 31 December 1992. In the UK there was no specific legislation on nutrition information, but the Food Advisory Committee (FAC) had issued guidelines on nutrition labelling, which had been widely adopted by the industry. The FAC was abolished in December 2001 because its functions have now been taken over by the Board of the Food Standards Agency, but its advice at the time in question carried considerable weight. The Ministry of Agriculture, Fisheries and Food (MAFF) indicated its intention to introduce national legislation on the compulsory indication of fat content. This spurred the European Commission into pushing its own proposals forward, on the basis that the UK’s freedom to legislate in this area was con- strained by its Community obligations under the Food Labelling Directive, 79/112/EEC (updated and consolidated in 2000 as Directive 2000/13/EC). Work on European harmonisation began in 1988, when the Commission put forward two linked proposals, one on compulsory nutrition labelling and the other 144 The nutrition handbook for food processors 1 Official Journal of the European Communities, No. L 276/40-44, 6.10.90 setting out what that labelling should be. The Directive eventually adopted in 1990, Directive 90/496/EEC on nutrition labelling for foodstuffs, did not require compulsory labelling, except where a claim is made, and focused more on the nature and format of the labelling, about which it goes into great detail. Interestingly, for a piece of legislation for which one of the primary aims is the provision of information regarded as being of benefit to the consumer, it is a highly technical Directive, unlikely to be understood by anyone without some knowledge of food science or food legislation, and ideally both. To understand and use it requires detailed analysis. The following are its main provisions. 6.2.1 Provisions of the current legislation: format The provision of nutrition labelling is voluntary, unless a nutrition claim is made, e.g. ‘reduced fat’, ‘high fibre’, ‘low sodium’. If nutrition information is given, it must be in one of two formats: either ? Group 1 information: energy, protein, carbohydrate and fat (in that order). or ? Group 2 information: energy, protein, carbohydrate, sugars, fat, satu- rates, fibre and sodium (in that order). These formats are commonly referred to as ‘The Big 4’ and ‘The Big 4 plus Little 4’. Quantities must be given per 100 g or 100 ml of the food or drink, or per 100 g/100 ml and per serving. The Directive requires that the information be given in one place, in tabular format, with the numbers aligned if space permits. Declarations may also be made in respect of vitamins and minerals, provided they are listed in the Annex of the Directive and are present in ‘significant amounts’, currently defined as 15% of the Recommended Daily Amount (RDA), supplied per 100 g or 100 ml of the food, or per package if the package contains only a single portion. The vitamins and minerals currently listed and their RDAs are: Vitamin A (mg) 800 Vitamin B 12 (mg) 1 Vitamin D (mg) 5 Biotin (mg) 0.15 Vitamin E (mg) 10 Pantothenic acid (mg) 6 Vitamin C (mg) 60 Calcium (mg) 800 Thiamin (mg) 1.4 Phosphorus (mg) 800 Riboflavin (mg) 1.6 Iron (mg) 14 Niacin (mg) 18 Magnesium (mg) 300 Vitamin B 6 (mg) 2 Zinc (mg) 15 Folacin (mg) 200 Iodine (mg) 150 A declaration may also be given in respect of one or more of the following: ? starch ? polyols ? mono-unsaturates ? polyunsaturates ? cholesterol Consumers and nutrition labelling 145 but if a declaration is made in respect of polyunsaturates, mono-unsaturates or cholesterol, the amount of saturates must also be given. 6.2.2 Calculation of energy value For the purpose of calculating the energy value for these nutrients, the Directive specifies the values on which they are to be calculated by means of the follow- ing conversion factors: ? carbohydrate (except polyols) 4 kcal/g – 17 kJ/g ? polyols 2.4 kcal/g – 10 kJ/g ? protein 4 kcal/g – 17 kJ/g ? fat 9 kcal/g – 37 kJ/g ? alcohol (ethanol) 7 kcal/g – 29 kJ/g ? organic acid 3 kcal/g – 13 kJ/g 6.2.3 Definitions The Directive, like most pieces of legislation, must specify to what it refers so that all the nutrients are defined scientifically. So, for example, the Directive states that: ‘protein’ means the protein content calculated by using the formula: protein = total Kjeldahl nitrogen ￥ 6.25 and ‘saturates’ means fatty acids without a double bond This exemplifies the earlier comment that it is a Directive written for the food scientist rather than for the average consumer. The Directive also defines ‘average value’. This is necessary because the com- position of foods is subject to natural variation due, for example, to variations in cultivar, weather, growing location, conditions and practices (crops) and in breed, seasonality, rearing conditions and practices (animal-derived materials). The Directive therefore states that: ‘average value’ means the value which best represents the amount of the nutrient which a given food contains, and reflects allowances for seasonal variability, patterns of consumption and other factors which may cause the actual value to vary.’ 6.2.4 Declared values These are the average values of the nutrients, as defined above, based on: 1 The manufacturer’s analysis of the food. 2 A calculation from the known or actual average values of the ingredients used. 3 A calculation from generally established and accepted data. 146 The nutrition handbook for food processors The amounts declared must be for the food as sold. However, where appro- priate they may relate to the foodstuff after preparation, provided that sufficiently detailed instructions for preparation are given and the information relates to the food as prepared for consumption. The Directive provides for the use of the Standing Committee procedure in the event of discrepancies being found between the declared values and those estab- lished during the course of official analysis. The Standing Committee is convened from experts from all Member States who will adjudicate on the matter(s) placed before them. In the UK, the term ‘typical’is preferred to ‘average’and is more gen- erally used as a more representative indication of value than the average. 6.2.5 Nutrition claims As stated earlier, the provision of nutrition information is voluntary unless a claim is made. So, for example, if a claim is made that a product is ‘low in fat’, at least Group 1 information must be given. Very often the full Group 2 information is given, but this would only be compulsory if the claim were for one of the ‘Little 4’ nutrients, i.e. ‘saturated fat’ rather than ‘fat’. The Directive defines as a nutrition claim: ‘any representation and any advertising message which states, suggests or implies that a foodstuff has particular nutrition properties due to the energy (calorific value) it – provides, – provides at a reduced or increased rate or – does not provide and/or due to the nutrients it – contains, – contains in reduced or increased proportions or – does not contain.’ Only generic advertising is excluded from this, so if a producer decided to launch a campaign to persuade people to eat more fresh green vegetables and claimed that green vegetables are low in fat, he would not have to include the nutrition information alongside his images of leafy greens. 6.2.6 Timescale The Directive came into force in September 1990 and required that trade in prod- ucts complying with the Directive be permitted by 1 April 1992 and that prod- ucts not complying with the Directive be prohibited with effect from 1 October 1993. The Directive also required that, eight years from its notification, the Com- mission would submit to the European Parliament and the Council a report on the application of the Directive and any appropriate proposals for amendment. This review, due in autumn 1998, has not yet taken place at the time of writing and will be discussed further in sections 6.5 and 6.6. Consumers and nutrition labelling 147 6.2.7 Implementation Most legislation is only as good as its implementation and enforcement and the application of these procedures has been variable in the case of the Nutrition Labelling Directive. Some Member States were tardy in including it in their national legislation and some, the UK being a prime example, did it so clumsily that it would have been a deterrent to use had the Directive itself not already been familiar to most UK food and drink manufacturers and its provisions already widely used on a voluntary basis. Reports from elsewhere in Europe suggest that national implementing rules, which invariably entail a degree of interpretation, have indeed been a deterring factor and have acted as a disincentive in provid- ing nutrition information voluntarily. The UK’s record of some 80% of manu- factured food and drink products voluntarily carrying nutrition information remains a matter of surprise, admiration and consternation in other Member States. UK implementation of the Nutrition Labelling Directive is via the Food Labelling Regulations 1996 (as amended). These are complex Regulations cov- ering all the essentials of food labelling from batch marking to medicinal claims. Implementation of the Nutrition Labelling Directive, which took place in 1994, carried with it the usual burden of complexity that comes with turning the posi- tive approach of EU legislation (you are not allowed to do it unless the Directive says so) into the negative style of UK Regulations (you can do what you like unless the Regulations state that ‘No person shall . . .’). The transposition of Article 4.1 of Directive 90/496/EEC, which states simply that ‘Where nutrition labelling is provided, the information to be given shall consist of either group 1 or group 2 in the following order: Group 1 (a) energy value; (b) the amounts of protein, carbohydrate and fat. Group 2 (a) energy value; (b) the amounts of protein, carbohydrate, sugars, fat, saturates, fibre and sodium.’ became in Schedule 6A Part I of The Food Labelling (Amendment) Regulations 1994 a half page single table listing both Group 1 and Group 2 nutrients, plus all the additional nutrients allowed to be mentioned, such as polyols under carbo- hydrates and polyunsaturates under fats, with a complex set of cross references to Part II of the Schedule and subsequent paragraphs of Part I to explain the two separate groups and how they should be set out. It is no wonder that MAFF needed to issue explanatory guidance notes to accompany the amendment to the Regulations. 2 148 The nutrition handbook for food processors 2 MAFF Guidance Notes on Nutrition Labelling, issued 18 March 1994 6.2.8 General requirements It is important that nutrition information is correct. Not only is it a legal require- ment that any labelling information must be accurate and not misleading, but peri- odically consumer organisations run checks on the values given for the various nutrients and publicise embarrassing inaccuracies. The manufacturer also has an obligation to ensure that the label is understandable in the market(s) in which the product is sold. However, this requirement has not yet been extended to ensure that the consumer understands the nutrition information per se, only the language in which it is provided. Regrettably, it cannot be assumed that consumers through- out the EU understand the nutrition information if given in the language of the country of manufacture even though it is set out in a recognised format and order of nutrients. On the other hand, consumers may well express interest in the nutri- tional attributes of the product, whether or not nutrition information is provided. Many manufacturers and retailers produce leaflets to help explain nutrition labelling and how it can help them to choose a balanced diet, or refer their cus- tomers to some of the organisations and resources referred to in section 6.7. 6.3 Consumer expectations and understanding of nutrition labelling Of the many factors governing food choice, of which price is likely to be quite high on most people’s lists, nutrition information may not figure strongly for many. But the enormous number and variety of food products available on the market today including imports of exotic foods and ingredients from all over the world, resulting from the increasing interest in ethnic dishes generated by long- haul travel and TV cooks, not to mention new ranges of products inspired by these developments, means that the consumer needs ever greater knowledge and information to allow him or her to choose from this vast range. At point of pur- chase it is the food label that provides the information that will enable the con- sumer to make the choice between products. If diet and health are important to the consumer, the provision of nutrition information on the pack may be a decid- ing factor between purchasing the product and leaving it on the shelf or a more careful study of the nutrition panel later in the home may influence a repeat purchase. A further influence on the provision (or not) of nutrition information may be the intermediate customer, namely the retailer, rather than the end consumer. The major UK supermarket chains exert an enormous influence on the highly com- petitive retail market for food and therefore on food production. All major retail- ers stock a wide range of ‘own label’ products, manufactured to their own specification by a variety of food manufacturers. The specification will cover not only the composition of the product but also the details of the food label. This will almost certainly include ‘full’ nutrition labelling, i.e. the ‘Big 4’ and ‘Little 4’ nutrients (see section 6.2.1) and possibly additional, supplementary voluntary information, which is discussed in detail in sections 6.5 and 6.6. Most retailers Consumers and nutrition labelling 149 and many food brands now carry a range of ‘healthy’ products, in which the com- position is strictly formulated to meet specified nutrition criteria such as reduced fat content, lower sodium content, lower calorie, high fibre or any combination of these. They will invariably carry ‘full’ nutrition information, but consumers interested in a healthier diet may find some of the research work taken out of their shopping expeditions if such ranges of products meet their needs, tastes and pockets. Consumers may also exert their purchasing power by choosing not to buy a product which does not provide nutrition information. In the UK, it has become a general accusation of consumer groups against those manufacturers who choose, for whatever reason, not to provide nutrition information, that they have got something to hide, i.e. it is a ‘bad’ food containing high levels of sugar, fat or salt. It is a long-held view of many nutritionists and dieticians that nutrition labelling alone cannot educate the consumer to select a healthy balanced diet, but that it should provide the cornerstone of any nutrition education policy. Research has shown that relatively few consumers actually read the nutrition information provided, and even fewer of them understand it. Nevertheless, consumer organi- sations have continuously requested greater clarity and use of nutrition infor- mation, at least Group 2 nutrition labelling, and on a mandatory basis. In this context, research conducted by the UK Consumers’Association in 1995 revealed some interesting results. A survey conducted in March/April 1995 questioned consumers on a number of issues about food purchases. The research was both qualitative and quantitative; the qualitative research consisted of four discussion groups held with women responsible for choosing and buying food. The quanti- tative research involved personal interviews with a representative sample of 1454 people in Great Britain aged over 15 years who were responsible for choosing food and doing any of the food shopping. Respondents were asked which of the following were important to them when shopping for food: Most important Important at all (more than 1 answer) Base 1454 Base 1454 Price/value for money 34% 87% Quality 21% 77% Nutrition/how healthy it is 16% 61% Family’s/personal preference 12% 53% How quick/easy to prepare 5% 33% How fattening it is 4% 33% Brand name/label 3% 28% Special diet for medical reasons 3% 10% Ethical/religious considerations 1% 3% The following statements make interesting reading both for nutritionists and marketing departments: 150 The nutrition handbook for food processors Agreement with statements about information given on food labels: Agree Neither Disagree (Base 1454) I believe all of the health messages and claims that appear on products nowadays 33% 17% 48% I never believe the nutrition claims on food packaging and always check the label for more information 47% 24% 27% I find it difficult to work out from the nutrition information panel on food products what is good for me and what is not 49% 18% 32% Nutrition information panels should be laid out in the same way for all food products 90% 7% 3% Claims are a quick and easy way of seeing how healthy a food product is 54% 17% 25% Health messages and nutrition claims should all be regulated 84% 10% 3% It is important that nutrition information is shown on all food products 88% 8% 3% 6.4 The use of nutrition panels The majority of UK food manufacturers and retailers provide nutrition informa- tion on most of their products, at least the ‘Big 4’, and in many cases the ‘Big 4 plus Little 4’ (see ‘format’ under Section 6.2.1 above). However, for as long as a voluntary regime continues, the decision as to whether or not to provide nutri- tion information is largely a commercial one. The arguments for change will be discussed in detail later in this chapter, but taking points 3, 6 and 8 from the Con- sumers’ Association’s research into the factors which are important to consumers when shopping for food as relevant to nutrition, diet and health, 23% of respond- ents consider this the most important aspect when shopping for foods, and a much higher number of some importance, even though nutrition and health ranked third after price/value for money and quality. Of those asked, 86% recognised a nutri- tion information panel, although of these only 42% took notice of it, with 33% stating that it was what they took most notice of. Clearly, nutrition panels are very familiar and the circumstances in which nutri- tion information panels are used are of note: 36% when buying food not bought very often or never bought before; 34% when comparing two different makes or types of the same product; 26% when checking the nutrition claims made on the front of the pack; 15% never use this information; 15% every time food is bought that has this information on it; 14% have never seen this information. Consumers and nutrition labelling 151 If we focus on the preferences expressed by those who participated in the survey for presentation of the nutrition panel and the aspects and terms of the current format they found difficult to understand: the easiest to use were those that were clear and easy to read e.g. large print/good for poor eyesight (50%); good layout (general) e.g. simple, clear, neat, in order (in a column) (22%); easy to understand (9%); (other points were: use of highlighting or bold print; dis- tinction between medium and high; showing value per 100 g; familiar/used to it/seen most often.) The most difficult to use were those with poor layout e.g. crammed together, jumbled, a muddle, words run together, cluttered (41%); dif- ficult to read/indistinct/small print (34%); not tabulated nor itemised, not in columns (9%); hard to pick out a particular piece of information (4%). Terms on a nutrition information panel that were found confusing: % RDA 80% kJ 53% kcals 41% calories (2%) sodium 14% saturates 11% per 100 grams 8% per serving 7% Leaving aside the 88% desire for nutrition information on all food products against the 42% who actually take any notice of it, the provision of nutrition infor- mation is evidently the expectation and the norm. The next hurdle is making it helpful and meaningful to consumers. 3 Alongside the results of the UK Consumers’ Association’s research, it is also pertinent to consider the Nutrition Labelling Study Report prepared for the UK Ministry of Agriculture, Fisheries and Foods (MAFF) by Research Services Ltd and published in April 1995. 4 The purpose of this study was to conduct a quan- titative survey on consumers’ awareness of nutrition labelling on food products, with the main objective of the research being to find out the extent to which con- sumers use and understand this type of information. This was particularly timely in terms of baseline information as the new Regulations on nutrition labelling i.e. implementation of the Nutrition Labelling Directive, came into force in March 1995. The study looked at the level of use of nutrition labelling; any problems in its presentation; and dietary habits, including changes in dietary patterns and what consumers thought they should be eating more or less of. The areas examined were: ? The level of usage of nutrition labelling, including level of awareness; who uses nutrition labelling; the nutrients respondents were aware of/looked for 152 The nutrition handbook for food processors 3 Reference: Consumers’ Association Nutrition Labelling Research, Brief Summary of Quantitative Survey, 1995 (Tables reproduced by kind permission of the Consumers’ Association) 4 Study Report, Research Services Limited (RSL), MAFF J1366, April 1995 on the label; use of 100 g or per serving information and which was most useful; and how the labelling was used, i.e. to compare different foods or to assess the nutritional profile of individual foods and whether this was in the context of an individual meal or the whole diet. ? Any problems with the way in which the nutrition information was presented, including whether or not the nutrients shown were understood, e.g. energy, sodium, protein and the relationship between carbohydrate and sugar, fat and saturates; whether the units and other terms were understood, i.e. kilojoules, kilocalories, calories, grams, percent RDA; could consumers understand the relationship between per 100 g and per portion information? Were consumers able to compare nutrient levels in different products on a 100 g and per portion basis? And were consumers able to make judgements about products across the range of nutrients, i.e. products that may be high in fat but differ in their content of saturates? ? The type of diet followed at the moment, including special dietary require- ments; changes in diet over the last few years; what people think they should be eating more or less of. A nationally representative sample of 1000 interviews was used, following an initial qualitative phase for which actual knowledge was tested in a hall test situation. Those interviewed had to be personally responsible for shopping for food for the household or play a significant part in choosing what food was to be bought for themselves or their household. Further tests were incorporated to distinguish between those who were ‘nutritionally aware’ and those who were less well informed. Most respondents were aware of nutrition labelling when asked about the information which could be found on foods, 62% mentioning nutrients whilst only 45% mentioned ingredients. The sample was more likely to look for nutri- tion labelling than look for the ingredients. Nutrition labelling was found to be the primary source of information about the content of foods. Around half the sample claimed to take this information into account when buying or using foods. People who were health conscious were more likely to take nutrition labelling into account than any other subgroup. Within the nutrition panel, the information of most interest was fat levels (68%). About half those who looked at labels looked for energy levels, whilst sugar, protein and fibre were of less interest. Overall, ‘per serving’ information was preferred to ‘per 100 g’ information. (65% of those who looked at labels preferred per serving information against 21% who preferred per 100 g information). However, the perceived usefulness of the ‘per 100 g’ information increased among respondents who could understand labels and had a high knowledge of nutrition. Respondents were most likely to use nutrition information to compare two brands of the same product (49% of those who looked at labels claimed this). They were less likely to use it to compare two different products (only 15% claimed this). They were slightly more likely to use the information to assess Consumers and nutrition labelling 153 products in terms of their whole diet rather than see how products fitted in with the rest of the meal. The sample was equally divided between those who considered nutrition infor- mation useful and those who did not. However, certain subgroups believed it to be more helpful than others did. A large majority (68%) of those who were health conscious considered the information useful. The researchers stated ‘if it is the aim of nutrition labelling to be helpful to those who want to use it, it would make sense to see this group as the ‘target group’, therefore a result of over two-thirds finding nutrition information useful seems encouraging’. Some 53% of females compared to 44% of males claimed nutrition information to be quite useful or very useful. Younger age groups were more likely to find the information useful (62% of those aged 16 to 34, 51% of those aged 35 to 44, 48% of those aged 45 to 64 and 33% of those aged over 65), as were those from higher social grades (60% of ABs, 53% of C1s, 48% of C2s, 43% of DEs). Other subgroups which found the information more useful were those with children in the household (57%); those whose education finished at the age of 19 or over (65%); those who were working (55%); those who were in the household with someone who had a special diet (60%) and those with high nutritional knowledge (61%). Suggestions for improvement, apart from ‘make it easier to understand’ were generally in terms of making the print larger and giving more explanation of what the names and numbers meant. With regard to understanding of the nutrients, fat was the most widely recog- nised nutrient and the one that respondents considered they knew most about (89% claimed to know something about it). The vast majority stated that indi- viduals should cut down on fat. When comparing two products, over half the respondents cited a lower level of fat as a healthier difference. By comparison, saturates, polyunsaturates and monounsaturates were less well recognised or understood. A proportion of the sample was aware of the need to cut down on saturates and increase polyunsaturates intake. However, compared with the number of respondents looking at fat levels on labels, very few claimed to look for saturate levels. When comparing two products, a very small number cited a lower level of saturates being a healthier difference. The researchers concluded ‘it appears that there is a need for people to be made more aware of the impli- cations of high saturate intake’. Carbohydrate was very widely recognised, but around 25% of the sample claimed not to be sure what it was. Some 27% of respondents claimed carbohy- drate intake should be increased whilst 17% believed intake should be reduced. When comparing two products, opinion was divided as to whether carbohydrate should be looked for in higher or lower levels. Fat, sugars, protein, fibre and energy were all more likely to be looked for on a nutrition label than carbohydrate. Sugar and starch were at least as well recognised as carbohydrate, sugar being under- stood and looked for more than carbohydrate. The vast majority of the sample believed sugar levels should be reduced. However, respondents were also far more likely to believe that starch intake should be reduced. The researchers concluded ‘there is a need to educate people on the healthiness of this nutrient’. Protein was widely recognised, but as with carbohydrate, about a quarter of 154 The nutrition handbook for food processors the sample were not sure what it was. The majority of respondents agreed that intake of protein was beneficial and, when comparing two products, about half of them cited a higher level of protein as a healthier difference. Fibre was better recognised and understood than either protein or carbohy- drate were. Some 84% of the sample claimed to know something about fibre. Over two-thirds of the sample believed fibre intake should be increased, and around half of the sample cited a higher level of fibre to be a healthier difference when comparing two products. Energy was perceived by respondents as ‘calories’. Most respondents (67%) claimed to know something about energy although, again, about a quarter of the sample were not sure what it was. After fat, it was the item of most interest on the nutrition label. The term ‘sodium’ was much less well understood than ‘salt’. Some 62% of respondents felt salt intake should be reduced, compared with 22% believing that sodium should be reduced. Sodium levels were rarely inspected by those who looked at nutrition labels. A majority of the sample mentioned that a lower level of sodium was beneficial when there was a substantial difference in sodium levels between two products. Only 15% of the sample gave the same answers when com- paring salt and sodium levels between two products, suggesting that relatively few respondents were able to equate sodium levels with salt levels. ‘Calories’ was a term recognised by almost all the sample, and most respond- ents correctly defined it as a measure of energy. By comparison, the terms ‘kilo- calories’ and ‘kilojoules’ were less well recognised and understood. Grams were recognised and correctly defined as a measure of weight by the vast majority of respondents. Few claimed to be aware of the term ‘percentage RDA’, only about one in ten being able to correctly define this term. As far as visualising what amount of food constitutes 100 g, the sample’s per- formance was generally quite poor, though this was dependent upon the food- stuff in question. Where respondents were given three different amounts of the food to choose from, 28% of the sample gave the correct answer for fish fingers, 30% gave the correct answer for digestive biscuits and 16% gave the correct answer for raisins. When asked to read figures from a nutrition label, or to make comparisons of nutrient levels between two labels, almost a third of respondents were unable to answer each time. When no calculation was required, the majority of the sample could read ‘per 100 g’ or ‘per packet’ information from a label. The declaration ‘of which saturates’ or ‘of which sugars’ was understood as well as any other part of the label. Calorific information confused some respondents, bringing the pro- portion of those who could read this particular statement of information down to around 50%. If a simple calculation was required, less than half of the sample was able to obtain the correct answer. This also applied when comparing nutri- ent levels between two labels. Most people did not have the ability to make the necessary calculations in their head to convert ‘per 100 g’ information into infor- mation for the whole packet, either when comparing two products or when assess- ing one product. The researchers wanted to test how well respondents could assess the product’s Consumers and nutrition labelling 155 healthiness taking into account all as opposed to individual nutrients. In comparisons between two products, respondents were good at recognising the healthier product when the healthier differences between the products were to do with the most well known nutrients, for example lower in fat, higher in fibre, higher in protein. Respondents were less likely to recognise the healthier product when the healthier differences between the products involved nutrients which were less well known, for example, lower in saturates, lower in sodium. Few respondents claimed to be in a household with someone who had special dietary requirements, the most common being a slimming diet which was men- tioned by one in ten respondents. However, most individuals claimed to have changed their diet over the last few years, and the most commonly given reason was to ‘be healthier’. The foods people were most likely to believe they should be eating less of were fatty foods and sweet things. In terms of what the sample felt they should be eating more of, the most likely responses were fruit and veg- etables. The researchers concluded ‘most respondents claimed to be concerned about the healthiness of foods although less than half claimed to always choose a healthier food. A strong feeling for enjoying the foods they were eating emerged.’ Geographically, respondents in Wales and southern England performed better than those in the Midlands and the north of England. Respondents from Scotland and Northern Ireland were relatively less well informed. The results of this research galvanised the food industry, both retail and manufacturing, into seeking ways of providing nutrition information in a manner which would be more helpful to consumers. Further research commissioned and conducted in the UK by the Institute of Grocery Distribution (IGD) in 1996 showed that of those consumers who use the nutrition information on the label, most focus on energy, and to a lesser extent fat, and this finding is slightly at odds with the RSL Report. The research also indicated that many consumers have little knowledge of how much energy, in terms of kilocalories or kilojoules, they need per day and little idea of what guide- line targets are with respect to fat. As indicated in the previously listed research results, few understood the meaning of the term ‘saturates’, especially in the given format where it is indicated under fats as ‘of which . . .’, and the concept of kilo- joules was not understood at all. Most respondents said that ‘per serving’ infor- mation was generally found to be more helpful than ‘per 100 g/100 ml’, although the latter was useful when making comparisons between products at point of sale. As a result of this research, proposals were drawn up for highlighting calories and fat on the nutrition label, and the UK Ministry of Agriculture, Fisheries and Foods (MAFF) and Department of Health (DH) were consulted about Guideline Daily Amounts of calories and fat and values were agreed for both men and women. Various formats were tested on consumers and, as a result, a scheme for supplementary voluntary nutrition labelling was launched in February 1998. 5 The details of this scheme are set out in the next section. 156 The nutrition handbook for food processors 5 Voluntary Nutrition Labelling Guidelines to Benefit the Consumer – Supplementary to legislative nutrition labelling requirements, Institute of Grocery Distribution, 1998 6.5 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 Paper 6 recommen- dations 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 infor- mation 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, includ- ing that described in section 6.4, and new research commissioned to identify a labelling format for food products which would provide consumers with infor- mation 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, satu- rates 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. Consumers and nutrition labelling 157 6 The Health of the Nation – a strategy for health, HMSO, 1992 A two-step research programme was conducted. Step one consisted of quali- tative 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 nutri- tion 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 100 g’, 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 recom- mended 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 158 The nutrition handbook for food processors 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 70 g 95 g Saturates 20 g 30 g 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 con- sumers 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 informa- tion be highlighted in colour within the nutrition panel. The ‘per serving’ meas- ures 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 informa- tion panel should be changed so that ‘per serving’ information comes before the ‘per 100 g’ 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 ensur- ing that saturates appear on the label. Consumers and nutrition labelling 159 Table 6.1 Nutrition information: typical values Nutrition information Typical values per 100 ml 280 kj Energy 67 kcal Protein 3.2 g Carbohydrates 4.8 g of which sugars 4.8 g Fat 3.9 g of which saturates 2.6 g fibre 0.0 g sodium 0.1 g Table 6.2 Nutrition information: per serving Per serving (a cup) 67 calories 3.9 g fat The final issue is that of legibility. The IGD referred to its June 1994 publi- cation 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 sup- plementary 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 require- ments 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 ‘pro- gressive 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. 160 The nutrition handbook for food processors 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 sup- plementary 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 100 g’, 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, partic- ularly 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 coro- nary 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 infor- mation 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. 6.6 Future trends The application of the Nutrition Labelling Directive and its usefulness to con- sumers has remained under constant review since it entered into force. The an- ticipated arrival of the formal deadline of October 1998 for the European Commission to provide its report and any proposals for amendment provided an Consumers and nutrition labelling 161 additional focus, as did the Commission’s 1997 Green Paper on The General Principles of Food Law in the European Union. The review of the Directive is at the time of writing more than three years overdue and it is high time to consider proposals for change. In May 2001 the European Commission published a discussion paper on Nutrition Claims and Functional Claims (SANCO/1341/2001). Whilst this was not a review of the nutrition labelling Directive as such, clearly any such dis- cussion cannot ignore the issue of general nutrition labelling and it would seem sensible to consider the entire package. The FSA response to the discussion paper, following extensive consultation with stakeholders, was that the scope of any pro- posal should embrace all nutrition and health claims, but also that harmonised rules on nutrient claims would help to improve the quality of information available to help consumers choose a healthy diet. It also urged the Commission to initiate the Community-wide debate on the mandatory use of ‘full’ nutrition labelling (Group 2) as the Agency view is that consumers will not be able to make fully informed choices between the foods available to them until all foods carry it. In the light of experience and research into consumer use and understanding of nutrition information, the UK response to the need for change can be summed up in a single word: simplification. Most pre-packed food and drink products sold in the UK already carry at least Group 1 information, and many provide Group 2. Nutrition labelling could, if appropriate supporting education programmes were put in place, help consumers to construct a healthy balanced diet from the wide variety of products available to them. A concept enshrined in the Directive is that nutrition information should be simple and easily understood. Highlighting specific information believed to be of most use to consumers, as recommended by the IGD, and removing any unnec- essary clutter would therefore appear to be a step in the right direction. The debate on whether nutrition labelling should be on a voluntary or manda- tory basis has been going on since before the Directive was adopted. Many con- sumer groups call for nutrition information to be mandatory on all pre-packed foods and drinks. However, it should be remembered that no information comes without a price or a trade-off. Consider the amount of compulsory labelling on any food product: the name of the food; the supplier; a full list of ingredients; a use-by or ‘best before’ date; storage instructions; cooking or usage instructions to name but a few. Information overload can be off-putting. Possibly more focus should be placed on the general change in eating patterns and the tendency to consume more of our food outside the home, in restaurants and other catering establishments? At present the Directive concerns nutrition labelling of ‘food- stuffs to be delivered as such to the ultimate consumer’. It also applies to food- stuffs supplied to restaurants, hospitals, canteens and other similar mass caterers, but how often do we see nutrition declarations on a menu or on any food sold loose over the counter? In any future trends, perhaps there is a need to reconsider the primary purpose of nutrition information and whether or not current practice is actually achieving 162 The nutrition handbook for food processors it. Consumer information and consumer education are not necessarily the same thing. The primary purpose of the food label is to inform the consumer, not to educate, but the information, as indicated in section 6.4, is of little or no use without some pre-existing knowledge. Responsibility for providing this back- ground knowledge has always been shared between Government, consumer and health organisations, the media and the trade, but the goal appears not to have been reached. It would appear that the lead needs to come from Government, in the UK specifically from the Food Standards Agency, that has responsibility for food labelling and consumer information, and that, unlike its predecessors, seems to be gaining the trust of consumers. If the provision of nutrition information is to assist consumers to choose a more healthy, balanced diet, they must first know what that diet should consist of, then how to use nutrition information to help achieve it. Consistency and simplicity in the messages would be a good start, fol- lowed by consistency and simplicity on the label. The growing use of electronic information, including in store, offers opportunities not previously dreamt of. If such a medium can provide each individual consumer with every iota of infor- mation he or she wishes to know about any product, why try to cram more and more on the label? Perhaps future policy should gravitate towards providing only the more essential information on the label, and giving interested consumers quick and easy access to any other nutrition information they may wish to know via another medium. The debate on diet and health will continue indefinitely. Arguments over the provision of nutrition information will probably do likewise. 6.7 Sources of further information and advice British Dietetic Association, 7th Floor, Elizabeth House, 22 Suffolk Street, Queensway, Birmingham B1 1LS Telephone +44 (0)121 616 4900 British Nutrition Foundation, High Holborn House, 52–54 High Holborn, London SW1V 6RQ Telephone +44 (0)171 404 6504 Camden and Chorleywood Food RA, Chipping Campden, GL55 6LD Telephone 0386 840319 Food and Drink Federation, 6 Catherine Street, London WC2B 5JJ Telephone +44 (0)171 836 2460 Food Standards Agency, Aviation House, 125 Kingsway, London WC2B 6NH Telephone +44 (0)20 7276 8000 Institute of Grocery Distribution, Grange Lane, Letchmore Heath, Watford, Herts WD2 8DQ Telephone +44 (0)1923 857141 Leatherhead Food RA, Randalls Road, Leatherhead, KT22 7RY Telephone +44 (0)0372 376761 6.8 References Consumers’ Association Nutrition Labelling Research, Brief Summary of Quantitative Survey, London 1995 Consumers and nutrition labelling 163 Council Directive of 24 September 1990 on nutrition labelling for foodstuffs (90/496/EEC), Official Journal of the European Communities No. L276/40-44, 6 October 1990 Department of Health, Guidelines on Educational Materials concerned with Nutrition, London, HMSO, 1996 Department of Health, The Health of the Nation: a strategy for health, London, HMSO, 1992 Dietary Reference Values for Food Energy and Nutrients for the United Kingdom, Report of the Panel on Dietary Reference Values of the Committee on Medical Aspects of Food Policy, London, HMSO, 1991 The Food Labelling Regulations 1996, Statutory Instrument 1996 No. 1499, London, HMSO Food Standards Agency (FSA), Nutritional Labelling Qualitative Research, Final Report, November, 2001 Hunt, M.A., Nutrition Labelling: European Perspectives, The Encyclopaedia of Human Nutrition, ed Michèle J Sadler et al, London, Academic Press, 1998 MAFF Foodsense Leaflet Use Your Label: Making Sense of Nutrition Information, London, MAFF, 1991 MAFF Guidance Notes on Nutrition Labelling, London, MAFF, 1994 McCance and Widdowson’s The Composition of Foods, 5 ed, Cambridge, The Royal Society of Chemistry and London, MAFF, 1991 Nutrition Labelling Study Report, Research Services Limited (RSL), MAFF J1366, April 1995 Voluntary Nutrition Labelling Guidelines to Benefit the Consumer: Supplementary to leg- islative nutrition labelling requirements, Institute of Grocery Distribution, Watford, Herts, 1GD, 1998 164 The nutrition handbook for food processors