Overview of nutrient profiling consultation responses

Wednesday 1 June 2005

In November 2004, the Agency launched a public consultation on the nutrient profiling model it had developed. Stakeholders were asked to comment on the following specific issues.

Assessment of the scientific basis of the preferred model, and the way in which it has been developed:

• Have the appropriate nutrients been included?
• Is the choice of base (i.e. per 100g) appropriate?
• Is the balance between the scoring thresholds for the respective nutrients appropriate?

Effectiveness of the preferred model:

• Does the model succeed in appropriately classifying foods?
• Does the classification of any categories or groups of foods cause particular concern?

Further development or testing of the model:

• Are there areas of improvement to the model that you consider necessary?
• In what ways might the model be tested to further assess its effectiveness?

Some stakeholders also provided comments on the policy background to the development of the nutrient profiling model, and made suggestions for a number of amendments to the model.

Policy objective
There was support across many sectors for the policy objectives for which the profiling model has been developed, and the Agency's aim of using nutrient profiling to inform policy decisions. Health promotion and consumer groups were supportive of nutrient profiling as a tool to differentiate between 'healthier' and 'less healthy foods', with many commending the objective and step-wise approach taken by the Agency in developing the model.

In general, responses from the food industry indicate that many remain opposed to the principle of nutrient profiling, and its use to categorise foods, considering that certain foods would be categorised as 'less healthy' due to their inherent or traditional composition. There is also some concern that the scoring system used by the model would not reflect minor but beneficial reformulation of products; and that voluntarily added micronutrients have been excluded from the scoring criteria.

Some food industry and public health bodies suggested that, were the model to be used to underpin labelling information, there may be some inconsistency with current advice that all foods, in moderation, can be accommodated in the diet. Many, however, recognised that nutrient profiles are already used by some retailers and manufacturers to define criteria underpinning 'healthier option' ranges.

Scientific basis of the model
Nutrients included
There was general support for the inclusion of the macronutrients most associated with public health concerns, although some stakeholders felt that they might be represented in different forms (e.g. that the inclusion of total sugars would be preferable to NME sugars; and that a chemical or micronutrient marker for fruit and vegetable content would be preferable to a simple measure of percentage content in the food). Many stakeholders welcomed the inclusion of calcium and iron in the model, while suggestions were received for the inclusion for a range of further nutrients, including protein, fibre, and some vitamins and minerals.

Base
There was general support for the choice of a 'per 100g' base which many stakeholders felt was easy to use, familiar to consumers and industry, and facilitates the comparison of products across categories. Many retailers and manufacturers however, favour the use of a 'per serving' base, and some assessment of the contribution a food makes to the diet (eg the frequency of consumption of foods and whether a food is consumed as part of a meal or as a snack) although, many acknowledge the difficulties associated with these issues (ie standard portion sizes are not available for many products). They also suggested that foods should be assessed on an 'as consumed' basis.

Effectiveness of the model
There was support for the way in which the model classifies the majority of foods. Some food manufacturers expressed concern about the proposed classification of some specific foods, such as cheese, nuts, and some cereal based foods.

Regulatory advertising bodies, the majority of manufacturers and some public health bodies were concerned that if the model were to be extended to support signpost labelling, it would not help consumers identify healthier food choices within certain categories, such as olive oil within the fats and oils category. There was some concern that the proposed banding system was over simplified and that too many foods could be classified as Intermediate.

Further development and testing of the model
A number of specific suggestions were received for amendments that might be made to the model. The Agency's expert working group on nutrient profiling has advised on prioritisation of these suggestions (together with further suggestions arising from the scientific workshop on 25 February). Further work is now underway to examine and test five possible refinements.

Other issues
Some manufacturers and enforcement groups voiced concerns about the additional analytical requirements that might arise from the implementation of the model, and the associated increase in costs. These potential costs relate to requirements to analyse nutrients, such as calcium and iron, that may not be routinely analysed at present. Food analysts have indicated that the additional analysis would not pose any technical difficulties.