Front of pack food labelling position statement
Obesity Prevention Policy
4. Front-of-pack labelling schemes
4.2 Nutrient information only schemes
5. Policy context in Australia
6. Consumer understanding and use of labels
7. Consumers most likely to benefit from front-of-pack labelling
7.1 People with diet-related disease
7.2 Shoppers under time pressures
8. Use and influence on purchase behaviour
Key messages
- Food labels are a population-wide measure for assisting consumers to make healthier food choices, which in turn can assist people to avoid excess weight gain and reduce their cancer risk.
- Front-of-pack labelling can support consumers to select healthier food products and encourage industry to produce healthier foods.
- Currently, food labels do not present nutrition information in a way that is easily understood or that encourages consumers to make healthy choices.
- Government intervention is required to ensure that an interpretive front-of-pack nutrition labelling system that can be understood by all consumers is available on all food products.
Recommendations
Cancer Council recommends that consistent and interpretive front-of-pack food labelling be introduced into the Australian grocery market to encourage shoppers to make healthier choices. This should be part of a broader obesity prevention strategy and be supported by a social marketing campaign that enables and encourages Australians to use food labels to make healthier choices.
A front-of-pack labelling scheme should:
- support consumers in selecting healthier food products;
- promote food choices consistent with the Australian Dietary Guidelines and the Australian Guide to Healthy Eating;
- be informed by the best available evidence, including independent consumer research, in peer reviewed publications;
- contain an interpretive element;
- contain an informative element;
- supplement rather than replace Nutrition Information Panels;
- comprise one consistent system;
- be based on 100 g/mL of foods;
- be introduced across all retail grocery food and drink products;
- be mandatory;
- encourage healthier food product formulation;
- be evaluated, monitored and enforced; and
- be accompanied by a public education campaign.
Background
Overweight and obesity are risk factors for some cancers, and increase the risk of cardiovascular disease and type 2 diabetes[1]. Having excess body weight can increase the risk of cancers of the bowel, kidney, pancreas, oesophagus and endometrium, as well as breast cancer (after menopause)[2]. In Australia in 2011-12, around 63% of Australians aged 18 years and over were overweight or obese, including 70% of males and 56% of females[3]. Proportionally more women living in areas of most disadvantage were overweight or obese (64%) compared with women living in areas of least disadvantage (48%), however for men the rates are the same (69%) for men living in areas of most and least disadvantage[3].
The nutritional status of Australians is typified by an increasing intake of unhealthy, discretionary food and beverages[4] and is exacerbated by a supermarket environment with high levels of snack food and soft drink displays[5] and advertising for unhealthy foods[6]. Shelf space for energy-dense foods and drinks is greater in stores in socio-economically disadvantaged neighbourhoods[7]. Population-wide strategies are required to address diet-related diseases, with particular emphasis given to the equity of these approaches for the most disadvantaged population groups, who bear a disproportionate burden of diet-related chronic disease in Australia[8].
Shoppers are confronted with a large and potentially confusing range of items and are often too rushed to intentionally search for nutrition information in supermarkets and therefore need easily accessible nutrition information[9]. The provision of nutrition information at the point of sale potentially provides a direct vehicle for assisting consumers to identify healthier food choices[10] and in so doing may improve health outcomes. Front-of-pack labelling has the dual potential for educating consumers to identify healthier food products and encouraging food product reformulation and innovation[11]. It is, however, important to recognise that front-of-pack labelling alone will not address obesity and chronic disease. It is a strategy with population-wide reach that can assist Australians to consume a healthy diet and prevent diet-related diseases[12].
The Australia New Zealand Food Standards Code currently mandates the inclusion of a Nutrition Information Panel on all packaged foods, with some exceptions such as very small packages and foods that are packaged for immediate consumption[13]. The nutrition information panel outlines the amount of key nutrients per 100 g or 100 mL and per serve of a product[13]. Serving size is specified by the manufacturer and varies within and between manufacturers. It is mandatory for nutrition information panels to carry information about energy, protein, total fat and saturated fat, carbohydrates, sugars and sodium. Manufacturers may also list dietary fibre, other fats, and other vitamins and minerals on the Nutrition Information Panel[13].
The Nutrition Information Panel is typically placed on the side or back of food packages, and is not immediately visible to consumers. Research investigating comprehension of Nutrition Information Panels indicates that some consumers find them confusing and difficult to interpret[14]. People from lower socio-economic groups have more difficulty with existing labels[15][16]. Nutrition Information Panels were made mandatory on food labels to improve the level of information available to consumers and assist them to make informed choices about the foods they buy[11]. However, food labels also have the potential to actively encourage consumers to make healthy choices by presenting nutrition information in a format that is easy to interpret at a glance[10]. A simple, clear method of labelling foods, for use in conjunction with the Nutrition Information Panel has the potential to provide nutrition information equitably for large numbers of shoppers[17].
Front-of-pack labelling schemes
Worldwide, the voluntary introduction of front-of-pack labelling has led to the development of many different labelling systems by food manufacturers and retailers.
Interpretive schemes
These schemes provide a judgement about the nutritional quality of products. The most common interpretive schemes are colour-coded (traffic-light) systems such as that developed in 2006 by the UK Food Standards Agency in which the amount of key negative nutrients (total sugar, total fat, saturated fat and salt) is ranked as high, medium or low (according to nutrient criteria per 100 g/mL of the product) and assigned a colour code of red, amber or green, respectively[18]. Since then many retailers have used variants of that traffic-light labelling scheme on their products. In 2013, the UK government announced the introduction of a consistent traffic light based front-of-pack labelling system which has the support of major UK companies and all the major retailers[19]. The scheme remains voluntary as mandatory labelling laws are enacted across the European Union[19].
In the US, the Institute of Medicine has proposed a system that allocates up to three stars to products meeting acceptable criteria for sodium, added sugars and saturated and trans fat[20]. Other interpretive schemes may provide an overall rating for a product based on its 'healthiness' such as the US Guiding Stars program[21] or the Australian Health Star Rating System[22]. In Australia since 2012, government, industry and community (public health and consumer) groups have been working together on the Health Star Rating System, an overall ‘healthiness’ indicator underpinned by a nutrient profile score. This system is discussed in more detail below.
Some schemes are described as ‘better for you’ schemes as they provide an indication of the best choices within a product category. Examples include the Nordic governments' Keyhole system (Norway, Sweden and Denmark), the Choices program that began in the Netherlands and the Australian non-government Heart Foundation Tick. The Heart Foundation Tick uses food category-based criteria for certain nutrients to limit (e.g. saturated fat, sodium) and positive nutrients (e.g. fibre) to highlight healthier food choices within a category[23].
There are other front-of-pack schemes currently on pack in Australia developed by health organisations and the food industry such as the Grains & Legumes Nutrition CouncilTM certification, an industry standard guiding the use of whole grain ingredient content claims[24]; and the GI Symbol, indicating low GI choices that meet specific nutrient criteria for kilojoules, saturated fat and sodium[25].
While these endorsement symbols may provide some guidance to consumers about healthier food products within a product category, they have been criticised as being overly simplistic, while licensing fees may preclude some companies from applying. Further, as endorsement schemes are binary systems, whereby a product either carries an affirmative label or not, there is no opposing symbol on less healthy products to inform consumers of their less desirable nutrient profile.
Nutrient information only schemes
Percentage Daily Intake (%DI)/Guideline Daily Amount (%GDA) systems display the percentages of the major nutrients that a food provides, based on daily intake reference values for these nutrients. Percentage daily intake schemes are non-interpretive schemes, as only numerical information is provided.
Various iterations of schemes developed by food industry organisations based on percentage daily intake are found overseas including the percentage Guideline Daily Amount (%GDA) scheme in the UK[26] and Facts Up Front labelling system in the US[27]. In 2006, Percentage Daily Intake (%DI) front-of-pack labelling was introduced by the Australian Food and Grocery Council into the Australian market as a voluntary labelling scheme, modelled on the %GDA labelling[28]. This system[28] is based on the recommended dietary intakes of a reference adult (70 kg male) with an energy requirement of 8,700 kJ per day, as stated in the Food Standards Code[13] and relies on manufacturer-specified serving sizes that are not consistent or based on recommended guidelines[29]. This scheme is currently found on over 7200 products across a large range of food categories[30]. The level of compliance with the voluntary code for the use of these labels, the Code of Practice for Food Labelling and Promotion[31], is not known, although, an independent audit of 728 energy-dense nutrient-poor products in nine Australian supermarkets in 2012 found that of the 66% displaying %DI labels, 75% displayed %DI energy only labelling[29]. According to the Code of Practice for Food Labelling and Promotion, as a minimum, companies must use a format that includes energy plus four core nutrients, fat, saturated fat, sugars and sodium[31]. The Code states that the single %DI energy only format may be used only when label space is restricted or the product is very low in all the core nutrients[31], even though the independent audit found it was used more widely than that[29].
Policy context in Australia
In October 2006, the Australia New Zealand Food Regulation Ministerial Council began seeking advice on whether a uniform front-of-pack food labelling system would be an effective health strategy and the efficacy of a range of options for such a labelling system. In 2009, the National Preventative Health Taskforce recommended that nutrition labelling on the front of food labels be introduced within three years to support healthier food choices[32]. The recommendation included provision of easy to understand information on energy, sugars, fats, saturated fats, salt and trans fats, and a standard serve/portion size[32]. In 2011, the independent panel commissioned by the Australian Government to review food labelling law and policy recommended that a multiple traffic-light front-of-pack labelling scheme be introduced, initially on a voluntary basis but with mandatory requirements for products carrying health claims or endorsements[11]. The government response to this review supported the development of an interpretive front-of-pack labelling scheme[33].
In June 2013 the Australian and New Zealand Ministers responsible for food regulation, meeting as the Legislative and Governance Forum on Food Regulation, agreed to a voluntary front-of-pack labelling system for all packaged, manufactured or processed foods[34]. The recommended system included an interpretive star rating element underpinned by an algorithm that indicates the overall healthiness of the food, with a half star rating for least healthy and up to five stars for the most healthy food[34]. As well, the system shows nutrition information for energy, saturated fat, sugars and sodium and another optional nutrient e.g. calcium or fibre[34]. In 2014, the algorithm for the nutrient profiling was finalised[35] and a style guide for application of the Health Star Rating System was developed[36]. Communication and educational material is being developed for consumers and industry[22].
Consumer understanding and use of labels
Front-of-pack labelling can help consumers make healthier choices[37][38][39][40]. Systematic reviews have shown that graphics, symbols and text are more effective than numbers in assisting consumers to correctly determine healthiness[37][41] and percentages are not well understood by some consumers[42]. There is also evidence that the existence of multiple front-of-pack label formats in the marketplace may impede consumer comprehension and discourage use[43][44].
The addition of interpretation aids like indicative text (high, medium and low)[44] or dietary advice (eat often, eat sparingly)[45] helps in product comparison and in putting products in a total diet context[10]. A recent review found systems that provide summary information may influence consumers to purchase healthier products[41]. In the US, the Institute of Medicine conducted an extensive review of the evidence and found that a simple, interpretive, ordinal system was most likely to facilitate better product choice amongst consumers with low literacy skills[20]. Studies have shown that front-of-pack label schemes outperform nutrition information panels on measures of consumers' knowledge[40][46][47]. There is evidence that consumers prefer front-of-pack labels over information on the back of the pack[37][42][48].
Much of the research into front-of-pack labels has investigated consumers’ ability to use traffic-light schemes. The UK Food Standards Agency has conducted extensive consumer research on front-of-pack food labelling since 2004. The research found labels using the words ‘high’, ‘medium’ and ‘low’ as well as traffic-light colours achieved the highest level of comprehension with consumers[44].
Qualitative focus group research showed strong consumer support for the introduction of a single consistent front-of-pack food labelling system on packaged food, developed by an independent organisation[49][50]. In quantitative consumer performance testing, the majority of consumers preferred front-of-pack labelling formats with colour coding together with high, medium, and low indicators or information on nutrient levels to assist in the interpretation of colours[51]. Colour-coding was perceived to assist consumers in making food purchasing decisions at-a-glance[44]. Some consumers were unable to use the numerical information provided on %GDA labelling correctly and were confused by the use of percentages[44]. Consumers supported the inclusion of fat, saturated fat, sugars and salt on front-of-pack labels and perceived the strongest need for front-of-pack labelling on processed foods[44].
Further research commissioned by the UK Food Standards Agency into what information people actually look at when shopping showed consumers used specific wording or symbols as ‘beacons’ to help them shop quickly, by negating the need to read the back of the labels[52]. The research found "shoppers generally wanted quick and easy information to make shopping easier, and did not want to have to turn over food labels to find the information they required. Many did not want to look at nutrition information in detail, but wanted to be quickly reassured on specific elements so they could pick up the product quickly"[52].
Early studies in Australia, included a 2009 Cancer Council NSW study that found consumers were better able to correctly identify healthier food products using a traffic-light system compared to consumers who used the monochrome %DI system[53]. Consumers indicated strong support for nutrition information to be included on the front of food packages, particularly saturated fat, sugars, total fat and sodium, and for a single, consistent front-of-pack food labelling system across all food packages[53]. Use of the %DI system was associated with socio-economic status, with those in the most socio-economically disadvantaged groups least likely to be able to use the %DI system[53]. However, an online survey by the National Heart Foundation of front-of-pack systems, including %DI, Traffic-light labelling and the Heart Foundation Tick found that these systems were equally effective in assisting consumers to identify healthier food products[54]. As well, the different labelling systems were equally effective across all socio-economic groups[54]. Qualitative research by Food Standards Australia New Zealand (FSANZ) using in-depth interviews with consumers found they had difficulty comprehending %DI labelling upon initial exposure, and required assistance and practice to use the information[55]. The inclusion of %DI information for energy further hindered consumers' ability to interpret the information[55]. While consumers had difficulty understanding %DI labelling, this research demonstrated the positive effects that education may have on understanding[55].
Research by Cancer Council NSW and Sydney University of a large sample of shoppers using an online survey found shoppers were able to identify the healthier product over 80% of the time using front-of-pack schemes that provided information on multiple nutrients[47]. However, other recent studies have also shown consumers are more able to determine healthier products on packaging with multiple traffic lights[15][38][56][57]. Consumers prefer schemes that include information on individual nutrients, particularly information on fat and sugars[47][58][59][60].
Simple front-of-pack formats may be most appropriate for increasing awareness of healthy eating among targeted groups with poor nutritional knowledge. A review in New Zealand suggested traffic-light labelling increased accuracy and speed of decision making when choosing the healthier option and was able to be used by Maori and Pacific shoppers to determine if a food is healthy[61]. Studies in New Zealand since then have found Pacific and low income consumers relied more on the traffic-light element of a label than %DI[62] and traffic-light labels performed best in classifying if a food is healthy across all income levels and ethnic groups[15]. In Australia, traffic-light labels outperformed other label formats across levels of socio-economic disadvantage[53]. Other studies have found education and income did not affect consumers' ability to choose healthier products[47][63][64]. The variation in results highlights the limitations of experimental studies and the variations in experimental design. Different schemes may be more effective than others for particular shoppers depending on whether shoppers want a directive on the overall health quality of a product versus detailed information to process[65]. Studies have tended to focus on different dependent variables (e.g. understanding vs. preferences vs. intention to use) and therefore it is difficult to compare study results.
Consumers most likely to benefit from front-of-pack labelling
People with diet-related disease
A New Zealand study into the influence of front-of-pack labelling systems on consumers' choice behaviour found front-of-pack labels, particularly those with simple visual cues, enhance consumers’ ability to discriminate between high- and low-sodium products, even when those products feature nutrition claims[66]. Consumers are more attentive to nutrition labels when they have health goals, especially when these health goals concern specific nutrients[67].
Shoppers under time pressures
Front-of-pack information is most useful to those already seeking at-a-glance information[68]. Front-of-pack labels and especially logos enhance healthy product choice, even when consumers are put under time pressure[61][67].
Use and influence on purchase behaviour
There is limited evidence of the impact of front-of-pack labels on purchasing behaviour[41][69]. Studies on the use of interpretive shelf tags in the US, the Guiding Star program, found that sales of products with stars (i.e. healthier choices) increased[41][21]. An investigation of the use of the Choices logo in Dutch supermarkets found those concerned about their weight and those who reported looking at nutrition information purchased products carrying the Choices logo[70].
The effectiveness of a front-of-pack scheme in the marketplace will rely on consumer education as shoppers are motivated by price, brand loyalty, taste, and habitual purchasing as well as healthiness[71]. Consumers are most likely to use front-of-pack labels when they are buying a product for the first time, when comparing between products, when shopping for children and when trying to reduce their intake of certain nutrients or their weight[44].
Impact on reformulation
A study on changes to products since the introduction of the Choices logo in the Netherlands found dairy products decreased in sodium, saturated fat and added sugar, sodium decreased across other food groups, and fibre was significantly higher in most new foods[72]. An examination of changes to Kellogg’s breakfast cereals following the introduction of the Heart Foundation Tick program in Australia found twelve products were reformulated, with reductions ranging from 85-479 mg sodium per 100 g and an average sodium reduction of 40%[73]. Another study on the Heart Foundation Tick program in New Zealand found reductions of sodium in margarine (average of 11%), bread (26%) and breakfast cereals (61%) in reformulated foods and 13 new products (four breads and nine margarines) specifically formulated to carry the logo[74].
Cost effectiveness
Cost effectiveness modelling of traffic-light nutrition labelling has shown it to be both effective and cost-saving, even when the only benefits included were with respect to expected changes in purchases (other changes such as reformulation, improved consumer understanding and changes to social norms were not included in the modelling)[75]. Modelling showed if 10% of adults shifted their consumption towards healthier options in four food categories (breakfast cereal, pastries, sausages and pre-prepared meals), there would be a cost saving[75]. Furthermore, the intervention would remain cost-effective even if the shift in consumption occurred only in 2.5% of adults[75]. This limited traffic-light labelling intervention, modelled on 10% adults in four categories was calculated to result in reduced mean population body weight of 1.3 kg and 45,100 DALYs averted[75].
In 2014, the Australian Department of Health commissioned a business case analysis to identify the potential costs and benefits associated with the introduction of the front-of-pack labelling Health Star Rating system. The report concluded that "the aggregate benefits of the Health Star Rating system, in the context of multiple public health initiatives, will likely pay back (i.e. meet or exceed) aggregate costs over an indicative five year implementation period"[76].
Recommendations
Cancer Council recommends that consistent and interpretive front-of-pack food labelling be introduced into the Australian grocery market to encourage shoppers to make healthier choices. This should be part of a broader obesity prevention strategy and be supported by a social marketing campaign that enables and encourages Australians to use food labels to make healthier choices.
A front-of-pack labelling scheme should:
- Support consumers in selecting healthier food products. Front-of-pack food labelling should educate consumers and assist them to compare foods to identify healthier food products.
- Promote food choices consistent with the Australian Dietary Guidelines and the Australian Guide to Healthy Eating. A front-of-pack food labelling system should rate foods based on the recommendations of the current Australian dietary guidelines.
- Be informed by the best available evidence, including independent consumer research, in peer reviewed publications. There is a growing body of literature assessing front-of-pack labelling systems and consumers’ ability to use different aspects of food labelling to make healthy choices. Research must be transparent and stand up to peer review.
- Contain an interpretive element. A system based on traffic-light colour coding which is in use in the UK is preferred because the current evidence shows consumers are better able to use this interpretive system to make healthier choices. If a traffic-light coloured schema is not adopted, then an alternative interpretive element must be used to provide at-a-glance interpretation of nutrition content. The Health Star Rating scheme proposed for use in Australia provides that interpretive element.
- Contain an informative element. The system should include information on the kilojoule content and key nutrients which have been shown to adversely impact on health, namely saturated fat, sugars and sodium.
- Supplement rather than replace Nutrition Information Panels. Front-of-pack labelling must complement, not replace, existing nutrition information currently on the back or sides of food packages.
- Comprise one consistent system. To avoid consumer confusion, one consistent, government-endorsed front-of-pack labelling system should be introduced rather than a range of systems permitted.
- Be based on 100 g/mL of foods. Factual information about the levels of key nutrients should be based on 100 g or 100 mL of the food or beverage product, to avoid any manipulation of serving size information and allow comparisons across and within food categories.
- Be introduced across all retail grocery food and drink products. Front-of-pack should be introduced across all packaged retail grocery food products that are eligible to carry Nutrition Information Panels.
- Be mandatory. Only mandatory, legally enforced front-of-pack food labelling regulations will ensure that the system is equitably applied across all food products, giving maximum benefit for consumers. Should a mandatory system not be adopted, a government endorsed co-regulatory system is preferred.
- Encourage healthier food product formulation. Front-of-pack food labelling should aim to spur healthier product development by the food industry.
- Be evaluated, monitored and enforced. The regulations need to be evaluated to ensure the expected effects are achieved and independently monitored to ensure compliance.
- Be accompanied by a public education campaign. An extensive public education campaign must accompany the implementation of front-of-pack food labelling to assist consumers to interpret the labelling system in the context of other government healthy eating guidelines.
Position statement details
This position statement was reviewed and approved by the Public Health Committee in August 2014.
Development
This position statement has been reviewed by:
- Ruth Friedman, Executive Officer, Australian Chronic Disease Prevention Alliance
- Dr Bridget Kelly
- Dr Simone Pettigrew
Contacts
- Clare Hughes, Nutrition Program Manager, Cancer Council NSW
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