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Brussels, 06 March 2003
Euro Coop comments on nutrition labelling
EURO COOP welcomes the opportunity to contribute to the proposed review of the Council Directive 90/496/EEC on Nutrition Labelling. Already in 1997 EURO COOP members, the consumer co-operatives, called for a thorough review of the Nutrition Labelling Directive1 . EURO COOP has never been satisfied with the Nutrition Labelling Directive as a tool for informing consumers. It is clear from surveys that consumers cannot use the information on the label in order to make dietary choices, at best they can use it to compare similar products. We therefore welcome the European Commission's initiative to launch a consultation process on this important issue.
EURO COOP also strongly supports the pragmatic and logical approach taken by the Commission to first identify the gaps of the current EU legislation and then to propose policy options to address these identified deficiencies. Too often EU legislation is proposed without looking first at the actual implementation and usefulness of existing legal requirements. We believe that a realistic approach involving all the actors of the food chain such as the one taken on this important issue is a pre-requisite to ensure the effectiveness of EU legislation.
EURO COOP comments follow the format of the Commission's questionnaire on nutrition labelling, which is organised around three main issues: 1) Report on the current EU legislation on nutrition labelling; 2) Future amendments and; 3) Impact assessment of future regulatory changes.
1. Report on Current EU Legislation
EURO COOP members, the consumer co-operatives believe that the Council Directive 90/496/EEC on Nutrition Labelling fails to achieve its objective to "contribute significantly towards enabling the consumer to make the choice of an appropriate diet to suit individual needs"2 . Moreover, the absence of legal requirements for labelling prevents consumers from efficiently comparing different food products. When a claim is made, nutrition information can be disclosed either as the "Big Four" (energy, protein, carbohydrates and fat) or as the "Full Eight" (the Big Four plus sugars, saturates, fibre and sodium).
EURO COOP believes that these formats are not consumer-friendly. Consumer research shows that consumers do not understand such panels (see Figures 1 and 2 below)3 . Not only are they confused about the relationship between salt and sodium, and the relationship between carbohydrate and sugar, but also about content as a proportion of the Guideline Daily Amount (GDAs). Consumers in the National Opinion Poll study conducted in the UK 4 were shown a typical label giving content per serving information about fat (27.3g per 100g), saturated fat (13.4 g per 100g) and sodium (1g per 100g). They were asked to say for each whether this was 'a lot', 'a fair amount', 'not very much' or 'don't know'. The correct answer for all cases was 'a lot'. Just over half of the consumers (58%) gave the correct answer on fat. Just under half (46%) gave the correct response on saturated fat. 45% of the consumers said that they had no idea about what sodium relates to.
Figure 1 shows a typical Big Four Panel. Among other weaknesses, the format allows companies to avoid giving health critical information about saturated fat, sugar and salt content.
Figure 2 shows a typical Full Eight Panel. This obliges companies to state the amount of saturated fat and sugar, but still falls short of being helpful.
These findings are fairly consistent between studies and mirror what consumer co-operatives have found in their own consumer research5 . EURO COOP believes that the existing EU Directive 90/496/EEC on Nutrition Labelling does not relate particularly well to health messages and advice given to consumers nor does it put the information into any context to allow the average consumer to be able to make use of the information. It is in a style most useful and familiar to the professional nutritionist. This is what is wrong and why its review is imperative.
2. Future Amendments
1. Nature of the Declaration: Voluntary vs. Mandatory
EURO COOP believes that a certain, basic level of nutrition labelling needs to be mandatory if consumers are to be able to use the information consistently to choose a healthy diet. Whilst it remains voluntary there will be gaps in the consumer's access to nutrition information on the products they are eating. Mandatory nutrition labelling is necessary to help consumers select more healthful foods and reduce their risk of disease. It will also encourage food manufacturers to reformulate their products and produce healthier foods.
There is no point including nutrition information on products which contribute little or no nutrients in the diet. Within the consumer co-operatives' policy these are the only foods which are exempt; items like tea and coffee where the addition of milk and/or sugar contributes more nutrients than the beverages themselves.
Some flexibility needs to be allowed for small packs where space restricts the amount of information that can be given. In this specific case, EURO COOP believes information for the key nutrients per serving should be given at the point of purchase (on the outside of the packaging) but the inside of the label can be utilised to give the full nutrition information. Allowing such flexibility is something the Commission could well take account of in this review. The flexibility to use linear rather than a tabular format is helpful in providing more information on small packs but should be discouraged where space is not at a premium.
2. Nutritional Information to be provided: What key nutritional information do consumers require?
EURO COOP believes that it is possible to identify a key list of nutrients; a compromise between the current short and long formats, which should be mandatory. In our list we would have Calories, fat, saturates, salt, protein, carbohydrate, sugars and fibre. This encompasses all those nutrients detailed in current healthy eating advice and uses the terms familiar to consumers both in these messages and in official advice.
The following remarks explain in more detail EURO COOP position on key nutritional information to be provided to consumers:
- Calories and Joules: Consumers use Calories as their measure for energy. To add joules merely adds to consumers' confusion whilst adding unnecessarily to the amount of information which has to be given.
- Sodium: EURO COOP believes that the term "sodium" is misleading for consumers. We would suggest declaring "salt", based on an approximation of sodium content multiplied by the factor 2.5. EURO COOP members' research and that of others shows that consumers are confused by the relationship between salt and sodium. They know that they should eat less salt but do not relate this to the on-pack sodium declarations. We recognise that strictly speaking sodium and salt do not equate. However, for the purposes of cutting consumer confusion and in the interests of getting the consumer message across, we think it acceptable to use this approximation.
- Short v. long format: EURO COOP does not think there should be a choice over long and short format nutrient declarations. If the list is carefully chosen to reflect majority consumer needs and healthy eating messages, we feel there is no need for the shortened form. In any case, the current short list lets consumers down by failing to give information of 3 key nutrients that feature prominently in healthy eating advice; sugar, salt and saturates.
- Beyond the core list of nutrients we fully support additional requirements laying down the format for addition of other nutrients. This helps to regularise the information and allow consumers to find what they need. For example, some of our consumer co-operatives are thinking of the possibility of adding a line to indicate how many portions of fruit and vegetable is contained in a particular product in line with the some Governments' advice to eat 5 portions of fruit and vegetables a day (see Figure 3 below).
3. Presentation of nutrition information: What format should be utilised?
EURO COOP believes that a tabular format provides the clearest information. The addition of a graphical format greatly improves consumer understanding. The Commission should rescind the ban on graphical formats. If it is, at long last, to establish a graphical format we commend to it the HIGH, MEDIUM and LOW banding scheme developed by the Corony Prevention Group 6. Some Euro Coop members use it on all their Co-op Brand labels since 1992. It is easy and practical to apply. Consumers respond well to it (see Figure 3 below).
As we have said above, in rare exceptions where space is a premium, the linear format is useful. The law should only permit its use in exceptional circumstances.
EURO COOP believes that the order of nutrients should be changed to put those of key importance first. They should be highlighted by emboldening which is easy and universally applicable, unlike the use of specific colour combinations. We would put Calories, fat, saturates and salt first and embolden them. They would be followed by protein, carbohydrate and sugars and fibre (see Figure 3 above).
- Best language to express nutritional terms
As we have said above, salt should be the declared nutrient not sodium (see comment under 2 above).
Calories should be the only term used to express Energy. Consumers do not understand or relate to joules, making this information useless and unnecessary.
For consumers folic acid is the familiar term not folacin.
- Possible use of symbols to designate nutrients
EURO COOP recognises the attraction of using symbols for multi-lingual packs in particular, and for easy consumer comprehension. However, it is difficult to design symbols which readily represent the nutrients. Previous attempts to do so have not been successful. Also, for symbols to be recognisable, they often take up considerable space. A British competition to design such symbols came up with a droplet to represent fat, a sugar cube for sugar, and a salt shaker for salt. An ear of wheat may have been proposed for carbohydrate but this conflicts with a symbol used on product suitable for coeliacs. They were interesting ideas but failed to be instantly recognisable.
Consumer research by the UK Institute of Grocery Research Distribution (IGD)7 8 showed 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. EURO COOP agrees and supports these conclusions. Rounding all nutrients to whole numbers makes the panel look less complicated. We think that consumers can handle this information more easily. As the nutrition information is in any case averages it is misleading to imply they can be controlled to one decimal place.
The information should be printed clearly in as large a font size as the packaging reasonably allows. For most purposes we believe that practically this is 8 point, although there will be some small packs where only 6 point can be achieved. Whilst we agree with the UK FSA that 10 point would be ideal, the consumer co-operatives' own experience is that on the majority of packs this is simply not feasible. This really should be considered as a part of the whole labelling information so would be better decided within the context of the labelling review which the Commission is currently establishing.
- Expressing of nutritional content
Several studies 9 have proved that consumers appreciate graphical presentations because they provide interpretation of the numbers. In 1992 the Coronary Prevention Group (CPG) also endorsed such an approach and went further in establishing a scientifically based system to define the nutrient bands for High, Medium and Low 10. EURO COOP members that they would be useful for consumers and invites the Commission to consider this option as a tool to better inform consumers. Another possibility could be to express the nutritional content as a percentage of the Recommended Daily Intake.
Consumers also find Guideline Daily Amounts 11 useful as they provide a numerical framework in which to interpret the data.
4. Nutrition Labelling: Link with recommendations regarding healthy diets and lifestyles
; As mentioned above, EURO COOP supports the use of graphics and guideline daily amounts. Consumer co-operatives' research as well as other studies supports these approaches 12.
5. What is the most appropriate reference quantity for nutritional declaration?
The consumer research we have referred to above 13 and a further British MAFF report 14 indicate a consumer preference for serving sizes as the reference quantity. EURO COOP therefore believes this should be the preferred reference point.
EURO COOP recognises that the standard 100 gram portion allows consumers particularly to compare the same product in different brands. We therefore feel that providing this information in addition to that per serving should be allowed provided that the current order of 100g first followed by per serving were reversed.
EURO COOP does not think it is appropriate nor, indeed, necessary to have standardised serving sizes as in the States. EURO COOP members' research and that of the IGD 15 has shown that consumers relate best to the "descriptive" measures which allow them to relate to the food they eat. For example, it is more meaningful to consumers to relate to the whole pack or a fraction of it than to the weight of that portion. Similarly, where products are composed of a number of pieces, they relate to them, e.g. a biscuit, a cake, a rasher of bacon, a sausage/frankfurter, or slice of ham. The actual weight of the servings should, of course, be stated in addition so consumers can compare with other products using different portion sizes. Standardised portion sizes can be useful for products which are not readily divisible into serving sizes such as butter, jam, milk, cheese. We have found a publication produced by UK Ministry of Agriculture, Fisheries and Food most useful in this regard 16.
6. Are more specific measures required for non-prepackaged foodstuffs?
EURO COOP wants to stress that consumers would clearly like the same information for products they buy non-prepackaged as for those bought pre-packed. Whereas the label is a convenient medium for conveying such information, different systems had to be invoked for non-prepacked information. Point of sale labels are too small to carry such information in a format that consumers will be able to read. Various approaches are being used. The system most favoured by some EURO COOP members is to have a manual containing nutrition and other information such as ingredients, shelf life and allergy information at deli counters and similar places where foods are sold non-prepared. Such information may be directly accessible to consumers or it may be available on request from the store staff.
Again this is a bigger issue than just nutrition labelling and needs to be addressed in the EU labelling review.
7. Energy conversion factors: are modifications required?
EURO COOP believes that the current conversion factors used to declare the energy value are still relevant, ie:
- For carbohydrate: 4 kcal/g - 17 kJ/g
- For protein: 4 kcal/g -17 kJ/g
- For fat: 9 kcal/g - 37 kJ/g
- For alcohol (ethanol): 7 kcal/g - 29 kJ/g
8. Declaration of vitamin and mineral content: how should the Annex be revised?
EURO COOP agrees amendments are needed in light of the two Directives mentioned and to take account of scientific developments. In addition reference needs to be made to parallel Community discussions on food fortification which cross references the nutrition labelling directive, particularly with regard to specifying "significant amounts".
On the issue of what constitutes a "significant amount" EURO COOP is happy with the current 15%.
9. Tolerances for declaration of nutrition values
EURO COOP thinks it is useful to set tolerances for declarations of nutrition values. We do not think these should be specified, legal tolerances, since that is not appropriate. The provision of nutrition information is to guide consumers to make healthy choices and implement healthy eating guidelines. It is not an indication of quality or, except where a specific claim is made, a claim as to the amount of particular nutrients in a food. We would therefore support the concept of best practice guidelines as opposed to prescribed, legal limits.
The appropriateness of tolerances varies considerably, dependent on the type of food and how it is prepared. Levels will vary as a result of the natural variation of particular ingredients; the ratio of fat to lean in meat will depend on the particular animal, the amount of protein can vary in plants and animals, etc. Secondly, many foods are not homogenous, adding to the variation in nutrition profile. Products like mueslis and other breakfast cereal may contain different proportions of ingredients due to the difficulties of mixing. All these elements contribute to variations in nutritional composition of individual products.
In the UK, enforcement authorities have been actively putting together guidelines on such tolerances 17. We think their attempt is a reasonable starting point. We think this is a sensible approach which the Commission could usefully use as a starting point accepting that it needs to be adapted in the light of experience.
10. Definitions: are these still appropriate today?
EURO COOP believes that a definition and method of analysis for dietary fibre is long overdue and makes a nonsense of dietary fibre declarations on-pack. We consider agreeing on a standard definition and method so that on-pack declarations are comparable product to product is extremely important. The scientific details are far less important.
Again the definition and method needs to be linked to a recommended daily amount so that consumers can put the declared values into context.
3. Impact Assessment
As long as there is a significant period, around 3 years, to allow industry to implement any changes, these can be undertaken in the normal relabelling cycle and will not cause additional costs. There could be additional costs for analysis but again this would be taken up in the normal cycle, given sufficient time. Under these circumstances it will not impact on consumer prices. It would, however, make for enforcement difficulties as there would be a significant period where it would not necessarily be clear which regime a product was labelled under.
Clearly it depends on what changes are implemented but we believe there is great potential for revised nutrition labelling to give considerable social benefits.
EURO COOP sees great potential for this to have a significant impact provided it is backed by appropriately funded campaigns to educate consumers.
REFERENCES
- The Consumers' Association, The Ministry of Agriculture, Fisheries and Food, National Consumer Council "Consumer Attitudes to and Understanding of Nutrition Labelling", British Market Research Bureau 1985
- Just Read the Label: Understanding nutrition information in numeric, verbal and graphical formats". The Coronary Prevention Group, Alison Black and Michael Raynor, 1992, London, HMSO
- Voluntary Nutrition Labelling Guidelines to Benefit the Consumer-Voluntary Nutrition Labelling Research Findings, IGD, February, 1998
- IGD "Additional Voluntary Nutrition Labelling Research - Final Report", MMR Product and Concept Research, May 1997
- Ministry of Agriculture, Fisheries and Food "Nutrition Labelling Study Report" Research Services Ltd., 1995
- Ministry of Agriculture, Fisheries and Food "Food Portion Sizes. Second Edition", HMSO, 1993
- Proposed LACORS Guidance on Tolerances to be Applied to Nutritional Declarations, LACORS, July 2002
The Co-operative Group18 Consumer Research Reports
- Nutritional Labelling Qualitative Research, September 1993
- Report on Research into Nutrition Labelling, September 1993
- Putting the Consumer First, October 1993
- Nutrition Labelling Study Report, April 1995
- Salt Research, April 1998
- Labelling Research Report, Sustain, May 2002
- Lie of the Label 2 - Research Findings, July 2002
- Lie of the Label II, August 2002
- Euro Coop's comments on the Commission's Green Paper on the general principles of food law in the European Union COM (97) 176, 5/09/19971.
- Council Directive 90/496/EEC of 24 September 1990 on nutrition labelling for foodstuffs, Official Journal L 276 , 06/10/1990 P. 0040 - 0044, Explanatory Memorandum
- Lie of the Label II, the Co-operative Group (CWS) Limited, August 2002, page 20
- NOP Consumer Research conducted 1,061 face-to-face interviews with a representative sample of the UK population, completed in June 2002
- The latter has not been published but we would be more than willing to share our findings with the Commission
- Just Read the Label: Understanding nutrition information in numeric, verbal and graphical formats". The Coronary Prevention Group, Alison Black and Michael Raynor, 1992, London, HMSO
- Voluntary Nutrition Labelling Guidelines to Benefit the Consumer-Voluntary Nutrition Labelling Research Findings, IGD, February, 1998
- IGD "Additional Voluntary Nutrition Labelling Research - Final Report", MMR Product and Concept Research, May 1997
- The Consumers' Association, The Ministry of Agriculture, Fisheries and Food, National Consumer Council "Consumer Attitudes to and Understanding of Nutrition Labelling", British Market Research Bureau 1985
- Just Read the Label: Understanding nutrition information in numeric, verbal and graphical formats". The Coronary Prevention Group, Alison Black and Michael Raynor, 1992, London, HMSO
- See footnotes 7 and 8
- See The Consumers' Association, The Ministry of Agriculture, Fisheries and Food, National Consumer Council "Consumer Attitudes to and Understanding of Nutrition Labelling", British Market Research Bureau 1985 and references mentioned in footnotes 6, 7, and 8.
- See footnotes 6, 7 and 8
- Ministry of Agriculture, Fisheries and Food "Nutrition Labelling Study Report" Research Services Ltd., 1995
- See footnotes 7 and 8
- Ministry of Agriculture, Fisheries and Food "Food Portion Sizes. Second Edition", HMSO, 1993
- Proposed LACORS Guidance on Tolerances to be Applied to Nutritional Declarations, LACORS, July 2002
- The Co-operative Group is the Euro Coop member in the United Kingdom.
For further information, contact:
Aude L'hirondel, Food Policy Officer
Tel.: +32.(0)2.285.00.74 - Fax: +32.(0)2.231.07.57 - E-mail: alhirondel@eurocoop.org
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