Consultation on a voluntary front of pack signpost labelling scheme for the UK

The initiatives are:
England: the Department of Health White Paper 'Choosing Health: Making healthier choices easier (2004) and its Choosing a Better Diet: a food and health action plan' (2005).
Scotland: the Scottish Executive�s 'Eating for Health: Meeting the Challenge' (2004) and its 'Improving Health in Scotland: the Challenge' (2003) and the 'Scottish Diet Action Plan' (1996).
Wales: the Food Standards Agency and Welsh Assembly Government�s 'Food and Well Being: Reducing inequalities through a nutrition strategy for Wales' (2003).
Northern Ireland: work is progressing to develop a Department of Health�s food and nutrition strategy.

Background
According to the Food Standards Agency 'Nutritional Labelling Qualitative Research', final report November 2001, many consumers have difficulty using nutritional information as currently presented on food labels. Businesses have responded to this by introducing front of pack logos that aim to help consumers quickly assess the nutrient composition of a food. A number of different schemes are currently used, but Agency funded research indicates that consumers would prefer a standardised front of pack system, developed and controlled by an independent and authoritative body such as the FSA.

The Agency is therefore proposing a voluntary front of pack signposting scheme to help consumers make healthier choices.

The scheme being proposed by the Agency aims to:

• present dietary advice in a prominent and easily used format that the consumer can use to make dietary choices
• provide a consistent basis for signposting and reduce potential confusion in the marketplace caused by the increasing range of different food retailer and manufacturer signposting schemes which are being applied at the current time. These schemes have different symbols and criteria (for example some allow a healthy eating symbol to be used on products that may contain high levels of fat, salt or sugar)

Development of the proposals
The proposals are based on extensive research carried out since July 2004, and take account of views expressed during discussions with public health bodies, consumer organisations, manufacturers and retailers. The key research findings are that:

• current nutritional information is too complex, and not easily used
• consumers would welcome a single, standardised front of pack scheme providing simplified nutrition information
• front of pack signposting helped consumers make decisions about the nutritional composition of foods
• overall, of the signposting formats tested, the Multiple Traffic Light (MTL) was well liked and performed best, particularly in identifying quickly the key nutritional characteristics of food when compared to the criteria set out at the beginning of the quantitative study carried out in 2005
• a colour coded Guideline Daily Amount (GDA) format (CGDA) also performed well, particularly when comparing two foods, and was the format most liked by consumers
• 96% of consumers felt that a signposting scheme would help then make healtheir choices

The Agency is considering recommending the MTL format because it performed best in respect of the core task of categorising products on the basis of their nutritional characteristics. In doing so it recognises that the CGDA format had merits in other respects and is therefore also recommending that GDA information should be provided on back of pack.

During development of the scheme interested parties have been updated on the progress of this work at regular intervals and consulted on the principal decisions relating to the design of the key performance tests. Copies of these interested party letters and the methodology consultation package can be found at the link below .

The proposed voluntary front of pack signpost labelling scheme
The Agency is considering recommending that:

• the front of pack signposting format should be a Multiple Traffic Light (MTL), which indicates whether the product is high, medium or low in fat, saturated fat, sugar and salt (see Annexe 1 of Appendix 2)
• MTL information on front of pack should be supported by GDA information on back of pack, as recommended by the Institute of Grocery Distribution (IGD)
• criteria for front of pack signpost labelling should take account of proposed European Union (EU) legislation and expert advice from the Committee on Medical Aspects of Food (COMA) and the Scientific Advisory Committee on Nutrition (SACN). The proposed criteria are detailed in Annexe 2 of Appendix 2
• signposting should be introduced in the first instance on foods where consumers have difficulty assessing nutritional quality, and which are eaten frequently or in large quantities, that is ready meals, breakfast cereals, pizzas, sandwiches and meal components such as burgers, sausages, pies, breaded, formed or coated meat, meat alternative, poultry and fish products (see para 6 of Appendix 2)

We are interested in views on the following points

• Do you agree that on the basis of the information provided the Agency should recommend the MTL format as being the most suitable for a UK voluntary front of pack signposting scheme? If not, why not, and which format would you prefer and why?
• (Industry respondents only.) Would you adopt the proposed signposting format. If not, why not?
• (Industry respondents preferring another format only.) Would you adopt your preferred format on front of pack? If not, why not?
• Do you agree with the banding criteria proposed in Annexe 2 of Appendix 2? If not, why not?
• If you disagree with any of the low band criteria please make a case for alternative levels that could be submitted to the European Food Safety Authority (EFSA)
• Do you agree that the sugar criteria should be based on total sugars? If not, why not? If you think non-milk extrinsic sugars (NMES) or added sugar should be used please indicate how analytical and traceability difficulties could be addressed
• Do you agree that the Agency should also recommend provision of back of pack information on GDAs as developed by the IGD? If not, why not?
• Do you agree that signposting should be introduced in the first instance on ready meals, breakfast cereals, pizzas, sandwiches and meal components such as burgers, sausages, pies, breaded, coated or formed meat, meat alternative, poultry and fish products (see para 6 of Appendix 2)? If not, why not? Please make alternative proposals
• Do you have any further comments on the proposed guidance?

Comments on the information provided in the partial Regulatory Impact Assessment
Please provide details of what costs and benefits you anticipate your organisation (or indeed other stakeholders) will incur as a result of the introduction of voluntary signpost labelling. You may wish to bear in mind the following points:

• It would be helpful if you could differentiate between one-off costs (such as those incurred by redesigning labelling) and ongoing or recurring costs
• Think about what indirect costs or benefits you may incur (e.g. will there be any �knock-on� effects not currently considered by the RIA?)
• Are there areas in which costs and benefits may arise that are not currently discussed in the RIA?
• Are there any areas in which the new requirements will impact on small businesses in particular?

This consultation has been prepared in accordance with the HM Government Code of Practice on Consultation, which states that a consultation must follow better regulation best practice, including carrying out an Impact Assessment (Regulatory Impact Assessment in Scotland). The assessment is included in the consultation documents.

We are interested in what you thought of this consultation and would therefore welcome your general feedback on both the consultation package and overall consultation process. If you would like to assist us to improve the quality of future consultations, please feel free to share your thoughts with us by using the consultation feedback questionnaire.

Consultation feedback questionnaire (Word)

Consultation feedback questionnaire (pdf)

In accordance with the FSA principle of openness our Information Centre at Aviation House will hold a copy of the completed consultation. Responses will be open to public access upon request. The FSA will also publish a summary of responses, which may include personal data, such as your full name and contact address details. If you do not want this information to be released, please complete and return the Publication of Personal Data Form. Return of this form does not mean that we will treat your response to the consultation as confidential, just your personal data.

Data protection form (Word)

Data protection form (pdf)

Within three months of a consultation ending we aim to publish a summary of responses received and provide a link to it from this page.

If, after three months, the summary is still not showing, please contact the person who was responsible for the original consultation. Alternatively, you can contact Judith Taylor, the FSA Consultation Co-ordinator, on 020 7276 8633.
Email: judith.taylor@foodstandards.gsi.gov.uk