CFG
04/06
Letter dated 7 February
2006 from Foodaware to Shifra Sheikh, Food Standards Agency:
Dear Shifra Sheikh
Foodaware comments on the Food Standards Agency consultation
on a voluntary front of pack signpost labelling scheme for the UK
Foodaware is pleased to support the FSA’s proposal for a front
of pack signpost labelling scheme designed to help consumers to quickly
identify the nutritional content of foods.
We feel a standardised approach to nutritional labelling
of all types is very important and welcome the suggestion of a single
unified system instead of each retailer and large food manufacturer
using their own schemes. Consumers would only have to learn one system
and, if it is backed by the FSA, the public will have more confidence
in it. It is also very helpful that the proposals made are the result
of substantial consumer research which should provide a more workable
system than some suggested in the past. However, while this remains
a voluntary UK scheme, we fear not all manufacturers will be willing
to use it. Monitoring of its uptake will be important. We also hope
efforts will be made to encourage its future adoption at the EU level.
From the results of the research presented, it appears that the
Multiple Traffic Light (MTL) system is the most suitable
available at present for front of pack use and we hope that the food
industry generally will adopt it.
The banding criteria used for low medium and high
values of nutrients seem appropriate. The rationale for the setting
of the high level seems to be rather ill defined. Table 1, Annex 2
of Appendix 2 gives these values and they are discussed in Annex 1,
paragraph 23. For the ‘High’ criteria use is made of the
existing Agency advice on ‘what contributes ‘a lot’
of a nutrient and are linked to GDA values for women’. An explanation
of this ‘link’ would seem appropriate here and the use
of the GDA for women. The figures used seem generally acceptable but
the rationale for choosing 25% of each nutrient needs to be discussed
and why 28% has been chosen for total fat. Perhaps the FSA has provided
this information elsewhere but, if this is the case, a reference to
this information is required here. (The figures for total sugars in
the high column is given one * should this in fact be ** as it relates
to the provisional nature of the GDA for total sugars?).
We agree at present that the sugar criteria should
be based on total sugars, as there does not seem to be a workable
alternative. We look forward to the report from the expert group who
will consider the GDA for total sugars more fully.
We hope that a knock-on effect of the banding criteria will be to
give manufacturers an incentive to lower fat/sugar/salt levels by
adjusting recipes.
Back of pack information on Guideline Daily Amounts
(GDA), as developed by the Institute of Grocery Distribution (IGD),
is a useful adjunct to the front of pack signposting and gives greater
detail for those consumers who choose to use it. We agree that it
should be recommended.
The introduction of signposting on a limited range
of foods initially is a useful way forward so that any problems with
the scheme can be sorted out before it is used more widely. The foods
chosen seem appropriate. There are some other groups of foods where
we hope signposting will follow quickly, particularly those foods
identified as ‘treats’ e.g. cakes, desserts, crisps and
confectionary. Additionally, condiments and food accompaniments are
important particularly because of their potential contribution to
the salt content of meals. We feel there is less need for signpost
labelling of ingredients purchased for home cooking purposes; although
perhaps it would be potentially misleading if some foods were excluded
from the scheme.
Appendix 2 discusses the clarity of the signposting information
and suggests a minimum font size of 4 point. While we acknowledge
that print size is always an issue on small items, we believe 4 point
will be virtually illegible for most people. At present nutritional
information is often given in such small print that it is inaccessible
to many people – particularly a large number of older people.
This issue is often raised by our grassroots membership at meetings/talks.
We recommend that further consideration should be given to increasing
this minimum font size, for example, how does it compare with the
recommendations of the IGD guideline on font size? Clarity of information
should also include the choice of colours used to ensure the writing
shows up clearly. The final guidelines concerning presentation should
be backed up with consumer research using suitable vulnerable groups;
there is no value in having information which is so small it cannot
be read.
We hope the signposting scheme is successful and widely adopted.
Yours sincerely
Susan Knox
Chairman
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