CFG 42/07
final
Letter dated 21 December 2007 from Foodaware to Janet McKenzie,
Food Labelling and Marketing Terms Branch, Food Standards Agency:
Dear Ms McKenzie
Food Standards Agency Guidance on Clear Labelling
Foodaware Members discussed this revised Guidance at their December
meeting. We note that although FSA is specifically consulting about
the use of the Guidance in England, parallel consultations are occurring
in Scotland, Wales and Northern Ireland. Members feel strongly that
this guidance should apply throughout the UK so that the Agency
is promoting a consistent approach despite the voluntary nature
of the Guidance itself.
Members welcome the clear presentation in the document and particularly
appreciate the way the document recognises the importance of taking
account of the interests of partially sighted people. The inclusion
of pictures and visual material is valued as are the examples of
good practice. Members mentioned that the use of colour to highlight
important aspects on food labels can also be helpful to young children
and those who may have learning difficulties. The traffic lights
for nutritional labelling have been particularly valuable in this
regard, allowing young children to begin to discriminate between
products on the basis of their nutritional composition without needing
to understand percentage declarations.
It is disappointing that FSA research has shown that 89% of products
surveyed did not comply with the recommended minimum font size especially
in view of the ageing population and issues facing those who lack
good eyesight. It seems like a retrograde step for FSA to have to
underline in voluntary guidance the importance of the minimum
font size for mandatory information. In general, members consider
the Guidance should follow key principles such as clarity, legibility,
contrast, and use of colour and pictures rather than details of
fonts which are considered appropriate.
Ultimately, whether labelling is clear depends on the understanding
of the customer. Perhaps FSA should consider doing more customer
surveys in this area and consider ‘naming and shaming’
those whose labelling is unclear.
Yours sincerely
Susan Knox
Chairman
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