Nutrition profiling: ‘Good’ Food; a ‘Bad’ Concept?
1.
What is a Balanced Diet?
The concept of a balanced diet is based on the premise that an individual’s daily, or
more realistically weekly, food intake should ‘balance’ so as to include all the elements
that the human body needs in terms of macro-nutrients (protein, fat and carbohydrate)
and micro-nutrients (vitamins and minerals). Balance also means eating these
nutrients in the right proportions and not eating too much of any one of them.
No single food can provide all the essential nutrients needed by an individual and
foods differ significantly in the amounts of nutrients they contain. Indeed, individual
foods will vary markedly in their nutrient content. Cheese, for example, is high in fat,
calcium, protein and salt; but low in vitamin C and fibre. In contrast, fruit is low in fat,
calcium, protein and salt; but high in vitamin C and fibre. Taken together, however,
these two foods can provide a good range and balance of nutrients. By extending this
approach, it becomes evident why nutritionists encourage consumers to eat a wide
range of foods.
Many nutrition experts and dietitians believe that categorising foods as ‘good’ or ‘bad’
is contrary to the concept of a balanced diet and would not be helpful to consumers.
Such categorisation has also been suggested as a means of restricting advertising of
certain foods, especially to children and for pre-vetting of foods which can carry health
claims or have nutrients added to them.
Leaving aside the practicalities of implementing such a system, undesirable
consequences of such labelling might include:

Foods which are ‘blacklisted’ being considered undesirable by consumers and so
unwisely discourage the consumption of a wide range of foods and consequential
reduction in micro-nutrient intakes.
o For example, because of its fat and salt content, cheese might be placed in a
‘less healthy’ category. In the overall diet, however, cheese provides much
calcium and protein, as well as other essential nutrients such as vitamin A and
B vitamins.
o Similarly, some children’s breakfast cereals might be deemed too high in sugar
and/or salt; yet they contribute much iron and folic acid to the diet.
Iron, calcium and folic acid are all considered to be vulnerable nutrients, which
recent dietary surveys have shown to be in short supply in many people’s diets,
particularly teenage girls and young women.

Some individuals feeling that consuming any ‘treat’ foods, labelled as ‘less
healthy’, is wrong. This could lead to feelings of guilt, which could trigger
disordered eating behaviour. Indeed, a new and growing eating disorder has been
identified termed orthorexia nervosa, where sufferers become obsessed with only
eating healthily and they feel compelled to eat in only a very controlled way.
Experts have warned that the focus on ‘good’ and ‘bad’ foods is problematic and
fuels an increasingly neurotic relationship with food in modern western society

2.
Perversely, increased demand for ‘blacklisted’ products, as a reaction against
prohibition.
Individuals have differing nutrient needs
(‘One man’s meat is another man’s poison’)
Another problem of defining whether a food is ‘healthier’ or ‘less healthy’ is that people
vary: an ‘ideal’ diet for one person will not suit everyone else.
Dietitians are increasingly aware that many patients, in hospitals and in their
outpatient clinics, are underweight and require building up. For such individuals, a low
fat/sugar diet is not desirable. Similarly, some children and the elderly have small
appetites and therefore cannot achieve sufficient calories with the bulk of a low energy
dense diet.
Athletes and sportsmen also require a high calorie diet which
necessitates eating some calorie dense foods (which would be high in fat/sugar). To
advise such groups to consume foods stigmatised as ‘unhealthy’ would be counter
intuitive.
Trying to classify a food according to a set of general nutrient profiles is not going to
be appropriate for everyone.
3.
Experience with nutrition profiling of foods
‘Profiling’ is the setting of levels for a range of specified nutrients, typically ‘high’,
‘medium’ and ‘low’ for salt, fat and sugar. These criteria are then used to assess an
individual food in terms of its composition. If the food falls outside the profile for any
one of the specified nutrients, because its content exceeds the maximum level set, it
is deemed to have ‘failed’ and therefore to be ‘less healthy’.
In Annex X, examples are given of products which have been labelled according to a
scheme currently used by a UK retailer. These examples serve to show how nutrient
profiling results in a range of value judgements (high, medium and low) for the nutrient
content of a single food. It is, however, unclear how this information is intended to be
interpreted, and more importantly will be interpreted by consumers, in considering the
contribution which the food would make to their diet if consumed.
An extension of this approach is the ‘traffic lights’ concept (with red indicating a ‘high’
level of the specified nutrient, amber ‘medium’ and green ‘low’) where each nutrient
chosen to be ‘profiled’ will be apportioned an appropriately coloured ‘spot’). Annex Y
includes examples of this type of labelling. Such a scheme is very misleading as it
2
bases the decision on how the various nutrients fair in that food by assuming that this
one food makes up the whole day’s diet. This is not how people eat, and one food
cannot possibly be deemed as ideal. Indeed a day’s diet which was made up of all
foods carrying only green traffic lights would probably be deficient in calories and
many other nutrients.
Dr Mike Rayner recently presented a profiling model for defining ‘unhealthy food’ as a
means of deciding which foods could or could not be advertised to children: this was
based on the FSA criteria of what constitutes ‘a lot’ (anything over one fifth of the
Guideline Daily Amount (GDA)). This model ruled out most sources of iron-rich food
and a variety of foods supplying several other vulnerable micronutients. It also ruled
out most energy dense foods, leaving only foods with a low energy density. 80% of
children are not overweight or obese, and some have high energy needs which cannot
be met by a bulky diet which has a low energy density.
The DH What counts? group is also trying to establish criteria that would allow
composite foods to carry the ‘5-a-Day’ logo. The proposed profile was tested on a
wide range of composite foods containing fruit and vegetables. Only 10% of these
foods ‘passed’: even fruit juice and canned fruit in natural juice failed and so neither
would have been eligible to carry the logo. Consequently, the profiling was ‘fudged’ to
allow these foods to be included in the scheme, presumably because they were
somehow judged to be ‘good’ and their consumption desirable.
The two schemes above also fail to acknowledge any positive attributes of a food,
such as its micronutrient content; fail to take account of the amount of the food that is
consumed; and the frequency of consumption of that food. For example a high fat
food that is seldom eaten is not going to contribute to the national obesity problem.
At the end of last year, a consultant (Lynn Stockley) was appointed by FSA to
compare several different profiling criteria that had been developed in various
countries. The different methods of profiling resulted in completely different lists of
which foods ‘passed’ or ‘failed’, thus demonstrating the real practical difficulty of
devising a system that is objective and useful. This difficulty arises from the
fundamental flaw in assuming that an individual food, rather than an individual’s diet,
can be categorised as ‘good’ or ‘bad’, ‘healthier’ or ‘less healthy’.
The British Dietetic Association has a mantra: ‘all food fits’ - i.e. all food can be
considered as part of a healthy balanced diet.
4.


Other arguments against classifying foods as ‘good’ or ‘bad’
Different countries also have varying ideas on what constitutes a healthy diet, for
example the percentage of energy that should come from fat or sugar.
Different cultures have differing ideas about which foods are, or are not, important.
It would be quite wrong and insensitive to deem a food that is important in a
particular culture as being ‘bad’.
3






Some foods require a certain level of salt/sugar so that they are microbiologically
safe.
Some foods made to a recipe that is traditional, or prescribed in law, need set
levels of certain nutrients so that they can comply with that recipe.
It is not simply the food’s composition that needs to be considered in determining
its contribution to an individual’s diet, but also the amount consumed – and the
frequency of consumption. Raisins have a sugars content of 70g/100g, but make
a negligible contribution to most people’s dietary intake.
Fat criteria could be misleading if they resulted in the following foods being
deemed to be ‘bad’ and claims for other nutrient were thereby disallowed:
1. whole milk could not claim its calcium content
2. olive oil could not state that it is a good source of vitamin E or that it has
benefits for heart health
3. spreading fats could not make claims of any sort, including those
margarines that help to reduce cholesterol levels
4. marbled beef could not claim its iron content
5. nuts, because of their high fat content, could not indicate that they have
heart health properties
Imposing strict nutrient criteria on foods may reduce the incentive to industry to try
and modify the composition of their products. If the alternate product is still
deemed to be ‘bad’, there would be no opportunity to draw attention to a modest
but nutritionally significant change in, say, the fat content.
Any cut off point for a food to be deemed ‘healthier’ or ‘less healthy’ is likely to be
arbitrary. If the fat criterion is set at 20g per 100g, a product with a fat content of
20.1 g would be deemed less healthy than one that has a fat content of 19.5g.
Conclusion
FDF questions the merits, in terms of the benefit to consumers in assessing and
balancing their diets, of a subjective system of nutrition profiling whereby individual
foods might be perceived by consumers as ‘good’ or ‘bad’.
4
Annex X
Example Food Labels
Nutrition
Product 1
(Typical Values per 100g): Energy Value 110kg (25 kcal), Protein 1g MEDIUM,
Carbohydrate 5g MEDIUM (of which Sugars 5g HIGH), Fat 0.3g LOW (of which
Saturates 0.1g LOW), Fibre 7g HIGH, Sodium Trace g LOW
Product 2
(Typical Values per 100g): Energy Value 140kj (35 kcal), Protein 4g HIGH,
Carbohydrate 2g LOW (of which Sugars 2g MEDIUM), Fat 0.9g MEDIUM, (of which
Saturates 0.2g MEDIUM), Fibre 3g HIGH, Sodium Trace g LOW
Product 3
(Typical values 100g): Energy Value 60kj (15kcal), Protein 0.8g MEDIUM,
Carbohydrate 2g MEDIUM (of which Sugars 2g HIGH), Fat 0.5g MEDIUM (of which
Saturates 0.1g LOW) Fibre 1g HIGH, Sodium Trace g LOW
Product 4
(Typical values 100g): Energy Value 70kj (20kcal), Protein 0.7g MEDIUM,
Carbohydrate 3g MEDIUM, (of which Sugars 3g HIGH) Fat 0.3g LOW, (of which
Saturates 0.1g MEDIUM), Fibre 1g HIGH, Sodium 0.1g HIGH, Salt Nil g
Product 5
(Typical values 100g): Energy Value 610kj (150kcal), Protein 13g HIGH, Carbohydrate
Trace g LOW (of which Sugars Trace g LOW), Fat 11g HIGH (of which Saturates 3g
HIGH), Fibre Nil g, Sodium 0.1g MEDIUM
Products:
1 – Raspberries
2 – Broccoli
3 - Lettuce
4 – Plum Tomatoes
5 – Eggs – NB the front of the box labels eggs as having no Salt (the nutritional info
inside says 0.1g/100g)
5
Annex Y
Examples of Traffic Light Labelling
The table below shows the high, medium and low values for specific nutrients
according to the Coronary Prevention Group’s (CPG) Nutrition Banding Scheme.
Nutrient
Total Sugar (%)
Total Fat (%)
Saturated Fat (%)
Total Salt (g/10MJ)
Population Dietary Goal
17
33
10
6
Low
<8.5
<16.5
<5
<3
Medium
8.5 to 25.5
16.5 to 49.5
5 to 15
3 to 9
High
>25.5
>49.5
>15
>9
This table outlines the percentage sugar, total fat and saturated fat content of 4 foods
or food products and their salt content in g per 10MJ.
Product
Sugar (%)
Total Fat (%)
Sat. Fat (%)
Salt (g/10MJ)
Broccoli
Chinese Chicken and cashew
nuts
Sundried Tomato Risotto with
chargrilled chicken
22.8
MED
23.8
MED
5.3
MED
Trace
LOW
12.4
MED
45.8
MED
10.8
MED
22.12
HIGH
13.4
MED
16.7
MED
3.2
LOW
10.7
HIGH
Organic Falafels
8.7
MED
42.2
MED
4
LOW
16.29
HIGH
Wholemeal Bread Rolls
2.5
LOW
23.08
MED
12.6
MED
10.09
HIGH
Orange Juice
77.8
HIGH
0g
LOW
0g
LOW
0g
LOW
Broccoli
Sugar
Total Fat
Sat’ Fat
Salt
Fat
Nutrition Information
(Typical Values per 100g): Energy Value 140kj (35kcal), Protein 4g HIGH,
Carbohydrate 2g LOW (of which Sugars 2g MEDIUM), Fat 0.9g MEDIUM, (of which
Saturates 0.2g MEDIUM), Fibre 3g HIGH, Sodium Trace g LOW
6
Chinese Chicken and Cashew nuts
Sugar
Total Fat
Sat’ Fat
Salt
Fat
Nutrition Information
Typical Composition
Energy
Protein
Carbohydrate
Of which sugars
Fat
Of which saturates
Mono-unsaturated
Polyunsaturated
Fibre
Sodium
This pack (350g)
provides
1582kj
378kcal
33.3g
17.2g
12.3g
19.6g
4.6g
11.9g
2.5g
2.1g
1.5g
100g (3.50z) provide
452kj
108kcal
9.5g
4.9g
3.5g
5.6g
1.3g
3.4g
0.7g
0.6g
0.4g
A serving (350g) contains the equivalent of approx. 3.9g of salt
7
Sundried Tomato Risotto with Chargrilled Chicken (weight reduction eating range)
Sugar
Total Fat
Sat’ Fat
Salt
Fat
Nutrition information
Typical Values
Energy kj
kcal
Protein g
Carbohydrate g
Of which sugars g
Fat
Of which saturates
Fibre g
Sodium g
Equivalent as salt
Per 100g
Per 330g Pack
465
110
6.3
16.6
3.9
2.1
0.4
0.9
0.18
0.5
1535
365
20.8
54.8
12.9
6.9
1.3
3.0
0.60
1.7
8
Organic Falafel
Sugar
Total Fat
Sat’ Fat
Salt
Fat
Nutrition Information
Energy
Protein
Carbohydrate
Of which sugars
Fat
Of which saturates
Dietary Fibre
Sodium
Salt
Per 100g
921kj
220kcal
8.0g
23.3g
5.0g
10.5g
1.0g
7.6g
0.6g
1.5g
Per falafel (25g)
230kj
55kcal
2.0g
5.8g
1.3g
2.6g
0.3g
1.9g
0.2g
0.5g
9
Wholemeal Bread Rolls
Sugar
Total Fat
Sat’ Fat
Salt
Fat
Nutritional Information
Typical Values
Per 100g
Per Roll
1090
260
11.9
37.4
1.7
6.8
3.7
4.4
0.45
1.1
810
190
8.8
27.7
1.2
5.1
2.7
3.3
0.34
0.8
Energy kj
kcal
Protein g
Carbohydrate g
Of which sugars g
Fat
Of which saturates
Fibre g
Sodium g
Equivalent as salt
Orange Juice
Sugar
Total Fat
Sat’ Fat
Salt
Fat
Nutritional Information
(Typical Values per 100ml): Energy Value 185kj (43kcal), Carbohydrate 9g (of which
Sugars 9g)
NB – it is considered that all sugar in fruit juice products are extrinsic. Therefore
orange juice contains 73% NMES (well above the 10% population dietary goal).
10
Points to Note
 Whole milk (3.9% fat by weight) would be classed as “high fat” as it is 53%
energy from fat. But this is the same as clotted cream (63.5% fat by weight and
97% energy from fat) and butter (81.7% fat by weight and 99% energy from
fat).
 Orange juice would have to be labelled “high NMES” as it is only 8.8% sugars
by weight but 96% energy from NMES. This would be the same “high NMES”
label as full sugar jam (which is 69% NMES by weight and 99% energy from
NMES) and reduced sugar jam (31.9% NMES by weight and 97% energy from
NMES).
 The traffic light labelling for orange juice would also be identical to that of most
sugar sweetened drinks.
Worked Examples
Method of calculating for fat and sugar (based on CPG scheme)
Conversion Factors (g to kJ):
Sugar
Fat
16 kJ/g
37 kJ/g
3.75 kcal/g
9 kcal/g
% energy (kJ/100kJ) = fat/sugar (g/100g) x Conversion factor (kJ/g)
for fat and sugar
Energy (kJ/100g)
x 100
Worked example for sugar in Broccoli:
[(2 x 16) / 140] x 100 = 22.8% (MEDIUM)
Method of calculating for salt (based on CPG scheme)
salt (g/10MJ) =
salt (g/100g)
energy (MJ/100g)
x 10
Worked example for salt in organic falafels:
NB – energy needs to be converted from kJ to MJ, do this by dividing by 1000
(1.5 / 0.921) x 10 = 16.29 g/10MJ
11