VEGA answers the Food Standards Agency's invitation for consultation on information required for customers
1. The Food Standards Agency must act on a wider front than a Food Safety Agency. Agencies in other countries in Europe are styled in the latter way; therefore their purview is narrower than the range customers expect of the UK’s FSA. This responsibility entails joined-up thinking with full plough-to-plate relevance, as well as to corollaries from farm to fork in the duties of DEFRA, the DOH, DOTI, and local authorities.
2. For example, customers with organic, GM, religious, and social interests and concerns must be prepared for claims, advertising, definitions, and labelling consistently covering pharmaceuticals, pet foods, household goods, toiletries, cosmetics, clothing, and footwear; and farming for biofuels and other sources of power are increasing in importance. In all of these issues the welfare and health of animals (which would comprehend people as consumers and as producers and workers) and the environment must be counted among the FSA’s requirements on labelling and on the education of the customer, who is given his or her final choice and decision on what to buy.
3. It seems likely that these matters will affect production and movement of food, in the raw state or in prepared and convenience forms, from new accessions to the EU or from outside the Union (developments in the poultry industry and its output from sources in the Pacific Rim and South America are already illustrating this point and the cause for concern. Even the little Red Tractor may no longer be a Renault but a model built in India from ship-breakers’ yards steel). Pet foods are increasingly making claims on health grounds, suitability to be sold as kosher, and on provenance that may attract more human customers, and consumers; and customers are taking more interest in the ingredients, additives, and processing aids used for toiletries, cosmetics, clothing, footwear, and household goods, some of which may be by-products (or co-products) of food-manufacturing; the trends will also command more attention to animal husbandry and experimentation and testing on animals and to details of the working conditions on farms and sites of production, adding to the concerns over pesticides and uses of drugs and hormones for purposes of production (metaphylaxis) or restriction for purely therapeutic reasons. Competition within the market (e.g. for organic, non-GM etc) may emphasise these issues variably and on questionable grounds. Compounds common as cosmetic colourings in toiletries and foodstuffs are inexplicably given different descriptions on products intended for different purposes.
4. Just as the packaging of cigarettes carry health warnings, present concerns (particularly connected with obesity and its corollaries) are raising possibilities of similar warnings over contents of fat, sugar, and salt in foodstuffs and beverages. (The warnings on cigarettes would clash with claims and assurances that they were made from a non-GM organic tobacco crop). These will be objectives hard to satisfy; and we and others have argued with some support and success that the public should be equally informed on animal welfare and environmental grounds, even on foodstuffs and other products vaunting free ranging claims for Freedom and other dubious claims for good husbandry.
5. Commercialisation by leasing of logos and sales of symbols is stimulating customers’ confusion over claims and definitions. The seals, marks, and assurances are in many cases awarded by authorities with limited competence and experience and lacking in the means to monitor and police the origins and manufacture of the products they approve. For some customers a declaration of manufacture in a dedicated factory is required. For many people approvals and commendations may be countervailed by an obligatory “may contain” note.
6. We have for a long time been corresponding with MAFF, DEFRA, and the FSA, over the claims, advertising, and labelling of foods of interest to customers avoiding animal-derived content- on grounds of their health, “ethical” persuasions, allergies, and intolerances; and distaste for other reasons may also be cited. This population comprises what the market regards as an important group of “meat reducers and dairy-frees” exercising a better-informed choice than the traditional lacto-ovo-vegetarians, who might be more accurately described as cheesytarians, quichytarians, and even fishytarians; some self-styled vegetarians even eat chicken and eggs, with delusions over a free-range paradise for birds of the tropical jungle. Some of the restrictions are common to Jewish and Muslim practice.
7. We have argued for some time that the word vegetarian should apply in its full zoological significance to abstention from all animal-derived foods (and consistently, vegetarians profess their self-discipline in many other day-to-day commodities on general sale). There seems no need to compound confusion with another word, i.e. vegan (or vegetalian), little understood internationally and attracting another set of connotations, some regrettably extreme and offensive.
8. However, you do not have to be Indian to eat in an Indian restaurant nor Greek to enjoy a meal in a taverna (some Indian restaurants claim to be “pure vegetarian” which seems to mean that, unlike many others that include in their menus certain meats and eggs, they- probably as Bangladeshis-anglicise practices acceptable to the Hindu and Muslim customs). We recommend the food-industry and legislators to avoid a plethora of dodgy claims and assurances by adopting a “Free From” list that anticipates well-informed customer choice in the practice of aversions for many reasons. This procedure obliges greater care by manufacturers and retailers and is being increasingly adopted in the market place.
9. To suit the customers needs objectively in other ways we recommend that, say, half the space on wrappings and containers of foods should comprise nutritional and production information and that IT methods in-store and or on websites should give details of SOPs (standard operating procedures) and the farming husbandry. (For some years Body Shops have dossiers of such extended information suitable for their customers). Complaints that people don’t read information on labels are understandable when it is presented in an unattractive and uneducative fashion. The well-versed customer needs also to understand the limits of definition for words such as dairy-free, cruelty-free etc; that fish and poultry count as meat, that animal milks must rate as liquid meat; etc… There is much the FSA could do in joining and augmenting the definitions and education NGO’s are involved with.
10. Recent developments sharpen the need for revisiting definitions of dairy-products. Some years ago we overcame the MAFF’s opposition to use of the word milk, even with qualifying words, to any other but the mammary secretions of non-human animals. The MAFF relented before our complaints that in food technologists’ terms words such as milk, cream, butter etc described emulsions of various consistencies and that soya milk, peanut butter (and other nut creams and butters) were understood in common parlance (and that oddities such as milk stout and cream crackers needed more alteration). Having accepted this view the MAFF pleaded it to EU authorities and was rebuffed. Therefore, manufacturers and retailers have to resort to various means of overcoming an unnecessary impediment to developments edging significantly into the market. The time has come to recognize soya milk and soya yoghurt as alternative dairy-products worthy of such description; correspondingly, cow milk, goat cheese etc should be applied appropriately to definitions of animal-derived versions. The history of margarine illustrates similar attempts at obfuscation by the “cowboys”.
11. Our concern over the last decade that vegetarians derive enough iodine from their diet for their nutritional needs may be cited as an example of defects in labelling and information that the FSA should overcome in its negotiations. Our interest developed into a concern of national importance with resonances in the rest of Europe and in North America, where-unlike in Britain-most of the salt used in cooking, food manufacture, and at the table is iodised. Strict vegetarians have hardly any reliable dietary source. Supplements have proven to be unreliable (in the content not conforming to the amounts on the labels) and some of the main brands are unacceptable because, like many pharmaceuticals, they are formulated with lactose or whey. Lacto-ovos would derive some available iodine from dairy produce, eggs, or fish, but these supplies are haphazard, some being the result of supplements fed to the livestock and of disinfectants used to clean the animals’ udders and teats and the milking machinery.
12. Working with MAFF and independently since we have supplied results of analyses for the Composition of Food Tables and we have pursued the matter in a manner described and about to be described on the VEGA website. The alternative dairy-products coming increasingly on the market prompted us to try to persuade the manufacturers to fortify their products to the (diminishing) levels in ordinary cow-milk. After much delay additions of iodide are now being noted in lists of ingredients, but the manufacturers are refusing to disclose the amounts in the lists of nutrients; they also refuse to reveal possible sources of seaweed-based thickening agents and artificial colourings for which we can provide results of analyses. This confidential commercial information may be important because excessive iodine intakes are dangerous. The latest results (Volume 4) of the NDNS confirm our misgivings that women of child-bearing age may inadvertently go into pregnancy deficient in iodine status, which compromises the development of their baby. We adduce this example to illustrate a need we descry for greater participation by the FSA and the labelling authorities with an NGO denied information of general importance and lacking the funds to clinch means of remediation. The FSA condemns the excessive use of salt in food preparation and calls for reduction and clear labelling. Such advice for consumers should be accompanied in the nutritional information on the content, if any, in the salt declared among the nutrients.
13. We have had several rebuffs in our requests for meetings with the FSA and to an invitation to accompany one of us as consumer representative requiring information and actually reading labels in store and at home. The offer still stands.