VEGA comments on a FSA consultation.
Re: Revision of Council Directive 90/496/EEC on the Nutritional Labelling of Foodstuffs
1. Front of Pack Nutrition Signpost Labelling.
1.1 Signpost labelling should be displayed on the front of packaging or in the equivalent dominant space. This practice is being applied fairly widely already. The signaling may be extended, e.g. to illustrate allowed claims. It should be presented in a similar, but distinct, way.
1.2 Regulation should be devolved on Food Standards Agencies or their equivalents in EU countries and be applied for by manufacturers, dealers, and importers in the EU. Rigid consistency may be allowed for in considerations of regional nutritional priorities and policies. Back-of-pack and country-of-origin information should settle specific doubts. Some inconsistencies in practice or interpretation, e.g. for salt and sodium, may be resolved by continuing to use both.
2. Mandatory Nutrition Labelling
2.1 Exemption at present allowed for, say, in-store bakeries, home-made foods on sale at occasional functions, and farmers’ markets, as well as products sold by SMEs and in the partisanal trade have been in use for some time. Variations and inconsistencies have been allowed on the basis that such products do not apply to major components of the diet. However, such concessions should remain under constant review. Advances in packaging technology, point-of-sale information, and availability of details on websites should supply customers with as much information as possible. Packaging of supplements and medical supplies offers precedents, albeit with balancing the value in costs and in environmental terms. Packaging of small items in boxes, e.g. soup cubes, tubs and sachets of jams and spreads, and multipacks of soups, yogurts, and beverages could be exempted from details required on the outer sleeve or container if individually their use would account for, say, no more than 1% of a GDA.
2.2 SMEs have particular difficulties that could be overcome and could allow for extension into other areas of nutritional education, e.g. in restaurants and publishing. IT software and passwords allow easy development of the common details once access to sources such as “McCance and Widdowson” Composition of Food Tables has been gained, which does not come cheap. By contrast, relevant material is on open access from USDA. The British or (a European) FSA should facilitate extraction of the information that the FSA requires from purveyors of food, great and small. We have direct experience of these difficulties with the “weekly recipes” chosen from the accredited Portfolio of eating plans that we put up on our website. It is pioneering practices that could be translated into the workings of SMEs, including restaurants and journalists and writers of cookery information and books. We are researching into these possibilities and would like urgently to discuss them with an appropriate FSA official.
2.3 Labelling on all drinks and labelling should follow the general rules, whether or not the product is alcoholic. It is high time that exemptions for beers, wines, and spirits be lifted. Alcoholic content of all drinks or beverages must be declared if it exceeds, say, 1.5% or more than one unit per serving (which would need some further definition to accommodate differences in European interpretations). Contents per serving may serve the customers’ enquiries better than per 100gm (or ml), with a little loss of precision but some gain in avoiding unreliable assessments of size or volume; however, major suppliers are offering both measures with little trouble.
2.4 Labelling required for frontal information as well as back-and-sides has certain shortcomings and sources of misunderstandings
2.4.1 Special needs: eg of age, ethical or religious persuasions, or pregnancy, for which the details in the labelling and warning should be appropriately explained.
2.4.2 The practice of likely combinations in common bread-and-butter practices has to be reviewed. Working examples might include breakfast cereals “elevated” in appeal by inclusion in data in mixture with, say, milk and fruit (as in muesli); or tea of no or questionable value unless as a vehicle for water or milk of a taste needing “enhancement”; or of yeast extract sold in tubs with little space for details or in jars containing the means of multi-dosing in portions in the form of spreads on bread or as Marmite soldiers; or, as we have indicated above, as components of full meals.
2.4.3 Nutritional information must avoid confusions or omissions owing to oversights: for instance, iron (and, possibly, other nutrient) content is affected over a wide range by the composition of a meal, among the components of which may be fibre (the measurements of which are still in debate). Therefore, warnings should be given for such variations. Descriptions of fats are likely to require modification, according to their derivation (eg saltwater or freshwater fish); some “good” or not-bad” trans-fats may be found – like the CLAs and other polyunsaturated examples – to be “good” or at least “nor bad”. Data on salt (or sodium or both) may arouse some unease in countries – of which there are now examples in the EU – where iodized salt is regarded as an assured or assumed essential source of the element iodine (and possibly selenium). Education can be made much more interesting and useful if such factors emerge in information dispensed and recorded in FSA publications to the press and schools.
We regret the use of signaling with traffic lights when warnings and encouragements can be offered more cheaply and effectively in a less colorful way. Traffic lights on road and rail denote a ban on movement and a crime to be overridden. Foods designated in this scheme with a red should not be on the market; in railway terms the sequence is green, amber, double amber, and then red. Signals passed at red (SPADs) are serious offences. Similarly, “jumping” reds is dangerous and indictable practice on the road. Foods carrying a red in the present traffic light system may carry a caution in generally healthy eating plans with a lot of redeeming features, but still be a prudent occasional indulgence in a large population of consumers.