Faculty of Public Health
Of the Royal Colleges of Physicians of the United Kingdom
Working to improve the public’s health
UK Faculty of Public Health Response to the UK Consultation on Front of Pack
Nutrition Labelling
About the UK Faculty of Public Health
The Faculty of Public Health (FPH) is the standard setting body for specialists in public health in the
UK. FPH is the professional home for more than 3,000 professionals working in public health. Our
members come from a range of professional backgrounds (including clinical, academic and policy)
and are employed in a variety of settings, usually working at a strategic or specialist level.
FPH is a joint faculty of the three Royal Colleges of Public Health Physicians of the United Kingdom
(London, Edinburgh and Glasgow). In addition, FPH advocates on key public health issues and
provides practical information and guidance for public health professionals, aiming to advance the
health of the population through three key areas of work: health promotion, health protection and
healthcare improvement.
Introduction
FPH welcomes the opportunity to respond to the Department of Health consultation on Front of Pack
Nutrition labelling and commends the Government’s decision to seek views on how to maintain and
extend the use of labelling and increase consistency in labelling in line with research on what
consumers find most useful.
As a signatory to the British Heart Foundation led Joint Response to the UK Consultation on Front of
Pack Nutrition Labelling (hereafter referred to as the ‘Joint Response’), FPH firmly supports the robust
and clear answers to the consultation questions contained within that document. FPH urges the UK
Government to recommend that traffic light labelling is used consistently on the front of packs across
all appropriate products. For your attention a copy of the Joint Response is attached with this
submission.
In addition to the Joint Response, FPH is keen to make the following supplementary points, which, for
ease are split into the order of the consultation questions. If you would like further information about
this response please email Mark Weiss, Policy Officer at the UK Faculty of Public Health,
markweiss@fph.org.uk or call 020 7935 3115.
Context
Non-communicable diseases and obesity are increasing in prevalence globally. Almost two-thirds of
UK adults and one-third of children are overweight or obese1: few medical specialties will be
unaffected, whether treating diabetes, cardiovascular disease or cancers, or indirectly through comorbidities associated with increasing adiposity, particularly disability.
In 2007, obesity cost £15.8bn; including £4.2 billion in NHS costs. 2 Reductions in physical activity
have been accompanied by increased intake of energy-dense foods of poor nutritional value, driven
mainly by the global food system, which is ‘producing more processed, affordable, and effectively
marketed food than ever before’. 3 Despite improvements over the past decade, average intake of
1
Craig R, Mindell J (eds). Health Survey for England 2010.Leeds: NHS Information Centre, 2011.
Swanton KA. Healthy Weight, Healthy Lives: A toolkit for developing local strategies. London: National Heart Forum, 2008.
www.dh.gov.uk/prod_consum_dh/groups/dh_digitalassets/documents/digitalasset/dh_088967.pdf (accessed 07/05/2012)
3
Swinburn B A, Sacks G, Hall K D, McPherson K,Finegood D T,Moodie M J,Gortmaker S L. The global obesity pandemic: shaped by global
drivers and local environments. Lancet. 2011;378:804–14.
2
4 St Andrews Place  London  NW1 4LB  Tel: 020 7935 0243  Fax: 020 7224 6973
Email: enquiries@fph.org.uk  Website: www.fph.org.uk  Registered Charity No: 263894
saturated fat, ‘free’ sugars and salt in the UK exceeds recommended levels, while fibre intake is too
low.4
Clear information is important in helping people to choose healthier foods,5, 6 by correcting consumer’s
knowledge deficits. 7
I) To what degree does your organisation believe that greater consistency in UK FoP labelling
would be beneficial to consumers? Is your organisation willing to work with the UK
Governments to achieve this?
FPH supports the BHF led Joint Response answer to this question. In addition, FPH makes the
following observations:
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4
FPH supports its previous assertion that the ‘cross-government strategy to tackle obesity in
England, points to the responsibility of the food industry to provide consumers with clear and
consistent information about the food and drink they consume, and supports the adoption of
“traffic-light” nutritional labelling by retailers and manufacturers’ 8
Clear information is important in helping people to choose healthier foods 9 10 by correcting
consumers’ knowledge deficits, 11 and could be of tremendous benefit to the public
Surveys show repeatedly that consumers want not only a system of nutritional labelling which
they trust but also want a single system used consistently across all brands in all shops 12, 13
However, ‘consistency’ needs clear definition. For example a scheme that is consistent but
which standardises unhelpful or confusing labels would impede public health
FPH supports consistent use of front of pack ‘traffic-light’ food nutrition labelling. ‘Traffic-light’
nutrition labelling uses red, amber and green labels on packaged foods
These colours indicate whether a product is high, medium or low in total fat, saturated fat,
sugars, calories, and salt content
The principles behind ‘traffic-light’ nutritional labelling were developed by the UK’s former Food
Standards Agency (FSA), reflecting criteria derived from dietary recommendations of the UK
Committee on Medical Aspects of Food and Nutrition (COMA) 14 and the Scientific Advisory
Committee on Nutrition (SACN). 15
‘Traffic-light’ nutritional labelling is also recommended by the National Institute of Health and
Clinical Excellence (NICE). 16
Bates B, Lennox A, Bates C, Swan A (eds.). National Diet and Nutrition Survey: Headline results from Years 1 and 2 (combined) of the
rolling programme 2008/9 - 2009/10.London: Department of Health & Food Standards Agency, 2011.
www.dh.gov.uk/en/Publicationsandstatistics/Publications/PublicationsStatistics/DH_128166(accessed 17/02/2012)
5
Thorndike AN, Sonnenberg L, Riis J, Barraclough S, and Levy D E. A 2-Phase Labelling and Choice Architecture Intervention to Improve
Healthy Food and Beverage Choices. Am J Public Health. 2012; 1 02:527-33.
6
Bhargava A. Socio-economic and behavioural factors are predictors of food use in the National Food Stamp Program Survey. Br JNutr.
2004; 92: 497-506.
7
Thorndike AN, Sonnenberg L, Riis J, Barraclough S, and Levy D E. A 2-Phase Labelling and Choice Architecture Intervention to Improve
Healthy Food and Beverage Choices. Am J Public Health. 2012; 1 02:527-33.
8
Faculty of Public Health, Heart of Mersey, National Heart Forum. Traffic-light food labelling. A position statement.London: FPH, 2008.
www.fph.org.uk/uploads/ps_food_labelling.pdf(accessed 15/05/2012)
9
Thorndike AN, Sonnenberg L, Riis J, Barraclough S, and Levy D E. A 2-Phase Labelling and Choice Architecture Intervention to Improve
Healthy Food and Beverage Choices. Am J Public Health. 2012; 1 02:527-33.
10
Bhargava A. Socio-economic and behavioural factors are predictors of food use in the National Food Stamp Program Survey. Br JNutr.
2004; 92: 497-506.
11
Hagan K. Nutritional Information: Traffic Light Labelling Is the Best Way to Reach Consumers. Weekly report Vol 6,No. 19/2010.Berlin:
DIW (German Institute for Economic Research), 2010. www.diw.de/documents/publikationen/73/diw_01.c.357546.de/diw_wr_2010-19.pdf
(accessed 17/02/2012)
12
Malam S. Clegg S, Kirwan S, McGinigal S. Comprehension and use of UK nutrition signpost labelling schemes.London: BMRB Social
Research for the Food Standards Agency, 2009. www.food.gov.uk/multimedia/pdfs/pmpreport.pdf (accessed 18/12/2011)
13
Stockley R, Jordan E, Hunter A. Citizens’ forums on food: Front of Pack (FoP) Nutrition Labelling. London: BMRB Social Research for the
Food Standards Agency, 2010. www.food.gov.uk/multimedia/pdfs/citforumfop.pdf. (accessed 10/02/2012)
14
Committee on Medical Aspects of Food Policy. Dietary Reference Values for food energy and nutrients for the United Kingdom, Report on
Health and Social Subjects 41. London: Department of Health, 1991.
15
Scientific Advisory Committee on Nutrition. Salt and Health.London: The Stationery Office, 2003.
16
National Institute of Health and Clinical Excellence. Prevention of cardiovascular disease at the population level. Public health guidance,
PH25. London: NICE, 2010. www.nice.org.uk/nicemedia/live/13024/49273/49273.pdf (accessed 16/02/2012)
2
4 St Andrews Place  London  NW1 4LB  Tel: 020 7935 0243  Fax: 020 7224 6973
Email: enquiries@fph.org.uk  Website: www.fph.org.uk  Registered Charity No: 263894
II) If you are not a food retailer or manufacturer, please provide your views on the current
provision of FoP labelling in the UK
FPH supports the BHF led Joint Response answer to this question. In addition FPH makes the
following observations:
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FPH is disappointed by the lack of consistency and degree of variation in the UK food labelling
market – consistency over the most useful and evidence based approach is vital to allowing
consumers to make informed choices about the food products they purchase
FPH notes that of those companies not choosing to utilise the food label that clear evidence
demonstrates is most useful to consumers (traffic light labelling), some have sought to
perpetuate false claims about the traffic light scheme, as noted in the BHF Joint Response
Companies have also misled the customers at whom their product is aimed, for example, by
using adult women’s %GDAs for labelling sugary cereals promoted to children. (Children’s
smaller %GDAs for macronutrients would mean that a stated food quantity would represent a
far higher percentage of %GDA than for an adult woman).
FPH urges the government to set out a firm recommendation for all food companies to use the
single integrated food label including traffic light colours in order that people are able to make
informed dietary choices, and identify healthier choices at a glance
The food industry has expressed concerns that changes to the current provision of Front of
Pack nutritional labelling will result in reduced profits and therefore job losses 17, 18
These arguments are false. Study participants report that traffic light labels are particularly
useful for comparing products 19 and are therefore more likely to influence specific product
choices rather than quantities purchased, so would impact little on jobs in the food industry
III) in what circumstances do you think it might be appropriate to give an energy declaration
alone FoP, instead of energy, fat, saturates, sugars and salts? Please detail the reasons for
your views
FPH supports the BHF led Joint Response answer to this question.
V) Currently FoP labelling in the UK is based on ‘per portion’ The FIR permits expression of
FoP information per 100g or per portion, but where per portion information only is provided,
energy should be provided per 100g in addition. Views are sought on whether per portion
remains the right basis for consistent FoP declarations.
FPH supports the BHF led Joint Response answer to this question.
VIII) The FLABEL study indicated that consistency in positioning of the FoP label also played a
part in gaining consumer attention. Views are sought on the degree to which position on pack
could be harmonised.
FPH supports the BHF led Joint Response answer to this question.
17
Leatherhead Food International. Evaluating the impact on business of changes to nutrition labelling requirements in the UK. Project
undertaken for the Food Standards Agency.London: FSA, 2006. www.food.gov.uk/multimedia/pdfs/lfinutritionlabellingreport.pdf (accessed
18/12/2011)
18
Civitas. ’Traffic Light’ food labels given the red light. www.civitas.org.uk/wordpress/2010/06/23/traffic-light-food-labels-given-the-redlight/(accessed 15/05/2012); COM/2011/0077 final - COD 2008/0028 */COMMUNICATION FROM THE COMMISSION TO THE EUROPEAN
PARLIAMENT pursuant to Article 294(6) of the Treaty on the Functioning of the European Union concerning the position of the Council at
first reading on the adoption of a Regulation of the European Parliament and of the Council on the provision of food information to
consumers.
19
Campos S, Doxey J, Hammond D. Nutrition labels on pre-packaged foods: a systematic review. Public Health Nutr. 2011;14L:1496-1506.
3
4 St Andrews Place  London  NW1 4LB  Tel: 020 7935 0243  Fax: 020 7224 6973
Email: enquiries@fph.org.uk  Website: www.fph.org.uk  Registered Charity No: 263894
IX) Views are sought on whether % Reference Intakes (%GDAs) should be used on all FoP
labels.
FPH supports the BHF led Joint Response answer to this question. In addition FPH makes the
following observations:
There are several key problems with Guideline Daily Amounts (%GDAs) being used on their own:
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20
%GDAs do not distinguish between recommended maximum (for fats, sugar, salt) and
recommended minimum (for fibre): they appear to represent a target consumers should reach,
rather than a maximum that should not be exceeded regularly.
People differ in their requirements. Not everyone is of average size (which %GDAs are based
on); requirements for those who are over- or underweight, elderly or ill may vary.
Labels using %GDAs can also mislead by using arbitrary portions sizes instead of amount per
100g, preventing easy comparisons between different products as different companies use
different portion sizes.20
Concern that %GDAs have been produced and energetically promoted by the food and drink
industry, rather than by health-based organisations.21
Standard %GDAs signals lack colour coding for quick consumer appraisal and interpretation
and some retailers confusingly use colours to differentiate the type of nutrient rather than the
levels of those nutrients
Research demonstrates that most shoppers spend insufficient time choosing food products in
order to interpret %GDAs 22,23, 24; whereas traffic-light nutritional labelling can be understood at
a glance 25, helping consumers make healthier food choices by choosing products with fewer
red (or amber) symbols and more green (or amber) symbols 26
%GDAs take longer to interpret, even for literate and numerate consumers 27, 28
Research shows that traffic light colours and high, medium and low text are the most important
factors in achieving high levels of comprehension, making it vital for these to be used on all
front of pack labels 29
Research participants often report that arithmetic nutrition labels such as %GDAs are more
difficult to understand that ‘traffic-light’ nutritional labelling 30, 31
By contrast, a recent EU/industry-funded project reported that the use of colour coding can
increase attention and use in certain situations 32
FPH urges the Department of Health to take account of the fact that %GDAs have been
energetically produced and promoted by the food and drink industry, rather than by healthbased organisations
Lobstein T, Landon J, Lincoln P. Misconceptions and misinformation: the problems with GDAs.London: National Heart Forum, 2007.
Hagan K. Nutritional Information: Traffic Light Labelling Is the Best Way to Reach Consumers. Weekly report Vol 6,No. 19/2010.Berlin:
DIW (German Institute for Economic Research), 2010. www.diw.de/documents/publikationen/73/diw_01.c.357546.de/diw_wr_2010-19.pdf
(accessed 17/02/2012)
22
Grunert KG, Wills JM. Pan-European consumer research on in-store behaviour, understanding and use of nutrition information on food
labels, and nutrition knowledge.www.eufic.org/upl/1/default/doc/EUFIC%20pan-European%20results-full%20presentation_FINAL.pdf
(accessed 18/12/2011)
23
FernándezCelemín, Grunert K. Food Labelling to Advance Better Education for Life. Major results and conclusions.
http://flabel.org/en/News/FLABEL-final-webinar/
24
Hagan K. Nutritional Labeling Today: What Consumers Want – And What They Understand. Weekly report Vol 6,No. 20/2010.Berlin: DIW
(German Institute for Economic Research), 2010. www.diw.de/documents/publikationen/73/diw_01.c.357548.de/diw_wr_2010-20.pdf
(accessed 17/02/2012).
25
Campos S, Doxey J, Hammond D. Nutrition labels on pre-packaged foods: a systematic review. Public Health Nutr. 2011;14L:1496-1506.
26
Kelly B, Hughes C, Chapman K, Louie JC, Dixon H, Crawford J, King L, Daube M, Slevin T. Consumer testing of the acceptability and
effectiveness of front-of-pack food labelling systems for the Australian grocery market. Health Promot Int. 2009;24:120-9.
27
Committee on Medical Aspects of Food Policy. Dietary Reference Values for food energy and nutrients for the United Kingdom, Report on
Health and Social Subjects 41. London: Department of Health, 1991.
28
Malam S. Clegg S, Kirwan S, McGinigal S. Comprehension and use of UK nutrition signpost labelling schemes.London: BMRB Social
Research for the Food Standards Agency, 2009. www.food.gov.uk/multimedia/pdfs/pmpreport.pdf (accessed 18/12/2011)
29
BMRB (2009), Comprehension and use of UK nutrition signpost labelling schemes, report prepared for the Food Standards Agency
30
Malam S. Clegg S, Kirwan S, McGinigal S. Comprehension and use of UK nutrition signpost labelling schemes.London: BMRB Social
Research for the Food Standards Agency, 2009. www.food.gov.uk/multimedia/pdfs/pmpreport.pdf (accessed 18/12/2011)
31
Campos S, Doxey J, Hammond D. Nutrition labels on pre-packaged foods: a systematic review. Public Health Nutr. 2011;14L:1496-1506.
32
FernándezCelemín, Grunert K. Food Labelling to Advance Better Education for Life. Major results and conclusions.
http://flabel.org/en/News/FLABEL-final-webinar/
4
4 St Andrews Place  London  NW1 4LB  Tel: 020 7935 0243  Fax: 020 7224 6973
Email: enquiries@fph.org.uk  Website: www.fph.org.uk  Registered Charity No: 263894
21
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Although research for the FSA recommended a combination of traffic-lights, text
(high/medium/low), and %GDAs, the use of traffic lights was the most important factor affecting
usefulness of FoP labelling, with %GDAs alone the worst-performing labels.33, 34
The conclusion from behavioural economics is that traffic-light labelling sends a clear
behavioural signal: colour-coded nutrient information and absolute amounts, not percentages,
are best, particularly for reaching those with less knowledge.35
X) Given current market practice, and the research on consumer preference, a move towards
more consistency would require most interested parties to make some changes alongside the
changes that would be required by the FIR. Views are sought on interested parties’ preference
for the following options for a single approach:
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%GDA only
%GDA + HML text + interpretative CC based on standardised nutrient levels
%GDA + HML text
%GDA + interpretative CC based on standardised nutrient level
Colour coding only
Colour coding + %GDA
Colour coding + HML text
FPH supports the BHF led Joint Response to this question. In addition FPH makes the following
observations:
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FPH supports the BHF led Joint Response view that there is a clear evidence base for a
system that works best for UK consumers – a label that includes traffic light colour coding,
high, medium and low text, with the optional addition of percentage daily amounts. ***
As per the answer to Question IX above, although research for the FSA recommended a
combination of traffic-lights, text (high/medium/low), and %GDAs, it is important to recognise
that the use of traffic lights was the most important factor affecting usefulness of FoP labelling.
%GDAs alone were the worst-performing labels. 36, 37
The conclusion from behavioural economics is that traffic-light labelling sends a clear
behavioural signal: colour-coded nutrient information and absolute amounts, not percentages,
are best, particularly for reaching those with less knowledge.38
XI) Do you have any alternative suggestions that might fulfil the Government’s ambition to see
a more uniform approach to FoP labelling?
FPH supports the BHF led Joint Response answer to this question.
33
Malam S. Clegg S, Kirwan S, McGinigal S. Comprehension and use of UK nutrition signpost labelling schemes.London: BMRB Social
Research for the Food Standards Agency, 2009. www.food.gov.uk/multimedia/pdfs/pmpreport.pdf (accessed 18/12/2011)
34
Hagan K. Nutritional Labeling Today: What Consumers Want – And What They Understand. Weekly report Vol 6,No. 20/2010.Berlin: DIW
(German Institute for Economic Research), 2010. www.diw.de/documents/publikationen/73/diw_01.c.357548.de/diw_wr_2010-20.pdf
(accessed 17/02/2012).
35
Hagan K. Nutritional Information: Traffic Light Labelling Is the Best Way to Reach Consumers. Weekly report Vol 6,No. 19/2010.Berlin:
DIW (German Institute for Economic Research), 2010. www.diw.de/documents/publikationen/73/diw_01.c.357546.de/diw_wr_2010-19.pdf
(accessed 17/02/2012)
36
Malam S. Clegg S, Kirwan S, McGinigal S. Comprehension and use of UK nutrition signpost labelling schemes.London: BMRB Social
Research for the Food Standards Agency, 2009. www.food.gov.uk/multimedia/pdfs/pmpreport.pdf (accessed 18/12/2011)
37
Hagan K. Nutritional Labeling Today: What Consumers Want – And What They Understand. Weekly report Vol 6,No. 20/2010.Berlin: DIW
(German Institute for Economic Research), 2010. www.diw.de/documents/publikationen/73/diw_01.c.357548.de/diw_wr_2010-20.pdf
(accessed 17/02/2012).
38
Hagan K. Nutritional Information: Traffic Light Labelling Is the Best Way to Reach Consumers. Weekly report Vol 6,No. 19/2010.Berlin:
DIW (German Institute for Economic Research), 2010. www.diw.de/documents/publikationen/73/diw_01.c.357546.de/diw_wr_2010-19.pdf
(accessed 17/02/2012)
4 St Andrews Place  London  NW1 4LB  Tel: 020 7935 0243  Fax: 020 7224 6973
Email: enquiries@fph.org.uk  Website: www.fph.org.uk  Registered Charity No: 263894
5
XII) If your business already provides FoP information, what form of FoP labelling do you use
and why? Do you have any research that supports your choice of FoP scheme that you would
be willing to share? We are particularly interested in research that:
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Addresses consumer preferences, consumer understanding and comprehension
(particularly amongst lower literacy and lower socio-economic groups, those of different
ages, disabilities, long term conditions, gender, race, religion or belief, pregnancy and
maternity
Demonstrates any impact on consumer choice
Demonstrates any effect FoP has had on the reformulation of food products
FPH supports the BHF led Joint Response answer to this question. In addition FPH makes the
following observations:
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Food labelling must not widen dietary inequalities by failing disadvantaged consumers, those
who are less numerate or for whom English is not their first language
Only a fifth of the population have sufficient numeracy skills to achieve a good GCSE in maths
according to the Skills for Life Survey 39
%GDAs s take longer to interpret, 40 even for literate and numerate consumers 41, 42
‘Traffic-light’ labels are more quickly understood by a larger proportion of consumers than
%GDA labels 43, including the less educated 44
Using %GDAs is likely to disadvantage less literate and numerate consumers, 45, 46 thus
increasing inequalities in diet and therefore health
‘Traffic-light’ nutritional labelling performs significantly better than labels without colours across
all socio economic groups 47
Inclusion of ‘traffic-light’ nutritional labelling and the words high, medium and low in a combined
label (with the optional percentage guideline daily amounts) helps to overcome difficulties
some consumers might have with interpreting nutrition labelling 48
A major review published in 2011 concluded that too much information (such as that provided
by %GDAs) may ‘crowd out’ the message, so reducing its effectiveness 49
By contrast, ‘traffic-light’ nutritional labelling is a more effective tool to impact consumer choice
and ‘nudge’ the public 50 towards healthier choices 51
Supermarkets have reported changes in consumers’ purchase behaviour following the
adoption of ‘traffic-light’ labelling
A recent systematic review of 120 studies found that traffic light labelling was preferred by most
participants, being much easier to understand, particularly for making comparisons between
products. Front of Pack labels were particularly beneficial for those with less education. 52
Behavioural economics indicate that while the %GDAs model emphasises freedom of choice,
competition and nutritional education, traffic-light labelling prevents consumers from being
39
Department for Business, Innovation and Skills, The Skills for Life Survey, (2011)
Hagan K. Nutritional Labeling Today: What Consumers Want – And What They Understand. Weekly report Vol 6,No. 20/2010.Berlin: DIW
(German Institute for Economic Research), 2010. www.diw.de/documents/publikationen/73/diw_01.c.357548.de/diw_wr_2010-20.pdf
(accessed 17/02/2012).
41
Committee on Medical Aspects of Food Policy. Dietary Reference Values for food energy and nutrients for the United Kingdom, Report on
Health and Social Subjects 41. London: Department of Health, 1991.
42
Malam S. Clegg S, Kirwan S, McGinigal S. Comprehension and use of UK nutrition signpost labelling schemes.London: BMRB Social
Research for the Food Standards Agency, 2009. www.food.gov.uk/multimedia/pdfs/pmpreport.pdf (accessed 18/12/2011)
43
Borgmeier I, Westenhoefer J. Impact of different food label formats on healthiness evaluation and food choice of consumers: a
randomized-controlled study. BMC Public Health 2009; 9:184.
44
Campos S, Doxey J, Hammond D. Nutrition labels on pre-packaged foods: a systematic review. Public Health Nutr. 2011;14L:1496-1506.
45
Committee on Medical Aspects of Food Policy. Dietary Reference Values for food energy and nutrients for the United Kingdom, Report on
Health and Social Subjects 41. London: Department of Health, 1991.
46
Malam S. Clegg S, Kirwan S, McGinigal S. Comprehension and use of UK nutrition signpost labelling schemes.London: BMRB Social
Research for the Food Standards Agency, 2009. www.food.gov.uk/multimedia/pdfs/pmpreport.pdf (accessed 18/12/2011)
47
BMRB (2009), Comprehension and use of UK nutrition signpost labelling schemes, report prepared for the Food Standards Agency
48
BMRB (2009), Comprehension and use of UK nutrition signpost labelling schemes, report prepared for the Food Standards Agency
49
Gneezy U, Meier S, Rey-Biel P. When and Why Incentives (Don`t) Work to Modify Behavior. J Econ Perspec. 2011; 25, 4: 191-210.
50
Department of Health. Healthy lives, healthy people White Paper: Our strategy for public health in England. London: DH, 2010.
51
Hagan K. Nutritional Information: Traffic Light Labelling Is the Best Way to Reach Consumers. Weekly report Vol 6,No. 19/2010.Berlin:
DIW (German Institute for Economic Research), 2010. www.diw.de/documents/publikationen/73/diw_01.c.357546.de/diw_wr_2010-19.pdf
(accessed 17/02/2012)
52
Campos S, Doxey J, Hammond D. Nutrition labels on pre-packaged foods: a systematic review. Public Health Nutr. 2011;14L:1496-1506.
40
4 St Andrews Place  London  NW1 4LB  Tel: 020 7935 0243  Fax: 020 7224 6973
Email: enquiries@fph.org.uk  Website: www.fph.org.uk  Registered Charity No: 263894
6
misled and promotes more health-conscious food choices. 53 Positive effects of traffic light
signposting on the behaviour of both consumers and retailers have been reported. 54, 55, 56, 57, 58,
58, 59, 60
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53
Even though traffic lights without additional information may be misunderstood by a minority of
consumers, 61 independent evidence reviews by policy-makers have consistently made
unequivocal recommendations supporting traffic light labelling.62, 63 , 64
A recent present paper reviews the literature on FOP labelling and supermarket shelf-labelling
systems published or under review by February 2011 to inform current investigations and
identify areas of future research. A structured search was undertaken of research studies on
consumer use, understanding of, preference for, perception of and behaviours relating to FOP/
shelf labelling published between January 2004 and February 2011. Twenty-eight studies from
a structured search met inclusion criteria. Reviewed studies examined consumer preferences,
understanding and use of different labelling systems as well as label impact on purchasing
patterns and industry product reformulation. The findings indicate that the Multiple Traffic Light
system has most consistently helped consumers identify healthier products. 65
Sainsbury’s sales of ‘ham and pineapple thin and crispy pizza 335g’ fell by 55% (one red, two
amber and two green segments on Sainsbury’s ‘Wheel of Health’; while sales of ‘ham and
pineapple 356g pizzeria pizza’ (all green on Sainsbury’s Wheel of Health) rose by 42% 66
The Chief Executive of Sainsbury’s reported to a House of Lords Science and Technology
Select Committee that, against a comparable 12 week period in which fresh ready meal sales
increased by 26%, sales of a salmon dish with mostly green labels grew by 46%, while sales of
a moussaka dish with mostly red labels fell by 24% 67
Research by Sainsbury's found that 94% of its customers found the “Wheel of Health” (their
traffic light labelling scheme) easy to understand, with 74% reporting that traffic lights
influenced their buying habits.
There was a noticeable increase in understanding of the signposting scheme and in change of
shopping habits in the first two years after this chain introduced the “Wheel of Health”.
According to Sainsbury’s nutrition and health manager ( B Hart): "The colour coding is the most
important part of the Wheel for us…Although we have found that the red label does not stop
our customers buying these products, we are finding shoppers are gradually making healthier
choices.” 68
Hagan K. Nutritional Information: Traffic Light Labelling Is the Best Way to Reach Consumers. Weekly report Vol 6,No. 19/2010.Berlin:
DIW (German Institute for Economic Research), 2010. www.diw.de/documents/publikationen/73/diw_01.c.357546.de/diw_wr_2010-19.pdf
(accessed 17/02/2012)
54
Thorndike A N, Sonnenberg L, Riis J, Barraclough S, and Levy D E. A 2-Phase Labeling and Choice Architecture Intervention to Improve
Healthy Food and Beverage Choices. Am J Public Health. 2012;102:527-33.
55
Bhargava A. Socio-economic and behavioural factors are predictors of food use in the National Food Stamp Program Survey. Br JNutr.
2004; 92: 497-506.
56
Scientific Advisory Committee on Nutrition. Salt and Health.London: The Stationery Office, 2003.
57
National Institute of Health and Clinical Excellence. Prevention of cardiovascular disease at the population level. Public health guidance,
PH25. London: NICE, 2010. www.nice.org.uk/nicemedia/live/13024/49273/49273.pdf (accessed 16/02/2012)
58
Hagan K. Nutritional Labeling Today: What Consumers Want – And What They Understand. Weekly report Vol 6,No. 20/2010.Berlin: DIW
(German Institute for Economic Research), 2010. www.diw.de/documents/publikationen/73/diw_01.c.357548.de/diw_wr_2010-20.pdf
(accessed 17/02/2012).
59
Campos S, Doxey J, Hammond D. Nutrition labels on pre-packaged foods: a systematic review. Public Health Nutr. 2011;14L:1496-1506.
60
Kelly B, Hughes C, Chapman K, Louie JC, Dixon H, Crawford J, King L, Daube M, Slevin T.
61
Malam S. Clegg S, Kirwan S, McGinigal S. Comprehension and use of UK nutrition signpost labelling schemes.London: BMRB Social
Research for the Food Standards Agency, 2009. www.food.gov.uk/multimedia/pdfs/pmpreport.pdf (accessed 18/12/2011)
62
Malam S. Clegg S, Kirwan S, McGinigal S. Comprehension and use of UK nutrition signpost labelling schemes.London: BMRB Social
Research for the Food Standards Agency, 2009. www.food.gov.uk/multimedia/pdfs/pmpreport.pdf (accessed 18/12/2011)
63
Kelly B, Hughes C, Chapman K, Louie J, Dixon H, King L, On behalf of a Collaboration of Public Health and Consumer Research Groups.
Front-of-Pack Food Labelling: Traffic Light Labelling Gets the Green Light. Sydney: Cancer Council, 2008.
www.cancercouncil.com.au/nutrition/foodlabellingreport (accessed 17/02/2012)
64
Blewett N, Goddard N, Pettigrew S, Reynolds C, Yeatman H. Labelling Logic. Review of Food Labelling Law and Policy. Victoria: Obesity
Policy Coalition, 2011.www.opc.org.au/downloads/positionpapers/Traffic_light_labelling_policy_brief.pdf (accessed 15/05/2012)
65
Kristy L Hawley,*, Christina A Roberto, Marie A Bragg, Peggy J Liu, Marlene B Schwartz and Kelly D Brownell, Public Health Nutrition:
(doi:10.1017/S1368980012000754) The science on front-of-package food labels, Yale University, Rudd Center for Food Policy and Obesity,
New Haven, USA
66
Lincoln P. Good fats, bad fats. Eur J Cardiac Prev Rehab. 2010;17:S1-S115.
67
House of Lords Science and Technology Select Committee (Neuberger J, Chair). Behaviour Change.London: The Stationery Office, 2011.
68
The Grocer, Sainsbury’s Traffic Lights are Rewriting its NPD Strategies http://www.thegrocer.co.uk/companies/sainsburys-traffic-lights-arerewriting-its-npd-strategies/116452.article (accessed 18/12/2-11)
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4 St Andrews Place  London  NW1 4LB  Tel: 020 7935 0243  Fax: 020 7224 6973
Email: enquiries@fph.org.uk  Website: www.fph.org.uk  Registered Charity No: 263894
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MySupermarket.co.uk, an online supermarket shopping and comparison website had a ‘Health
Checker’ icon in 2011 that, if clicked suggested similar products with more green/amber and
fewer amber/red labels. 69
The ‘Health Checker’ created simple to understand traffic light information for products, using
information gathered from each of the four main supermarkets, including the harder to
understand %GDA information. 70
The ‘Health Checker’ was opened by 13% of customers, half of whom used it to reduce the fat,
sugar, salt of calorie content of products they purchase
Among users, customers saved on average 651 kCal (35% of the 1,865kCal suggested); 54g
fat (37% of 147g suggested); 24g saturated fat (40% of 61g suggested); 36g sugar (36% of
100g suggested); and 33g salt (39% of 84g suggested)
Overall, each of these customers had 7.6 healthier products suggested to them, of which they
swapped on average 2.1 (28%) (J Foord, personal communication).
A number of supermarkets have reformulated the recipes of their ready meals, to provide
healthier options and to display ‘healthier’ labels 71
The Waitrose ‘Deliciously Different’ range was formulated using colour coding criteria to
deliberately ensure this was predominantly amber and green.
Because Sainsbury’s had found that ‘traffic-light’ nutritional labelling modified shoppers’
purchases, it announced in 2007 that all future own-label product development would be
influenced by its colour-coded ‘Wheel of Health’ labelling, with recipes adjusted to avoid red
labels where possible.
Thus Sainsbury’s reformulated its ‘Chicken and Bacon Pasta Bake’ by reducing the salt and fat
content, and increasing the amount of chicken. 72
Of particular significance, Sainsbury’s Basics range appears the be healthier, with few red
labels 73
XIII) If your business uses interpretive additional forms of expression, such as HML text and/or
colour coding, how do you determine the cut-off points between each category? Does this
differ between types of food, or are the same criteria applied to all your FoP labelled products,
and, if so, why?
FPH supports the BHF led Joint Response answer to this question.
XIV) The FLABEL research recommends the use of health logos accompanied by repeat
nutrition information as a form of labelling that might provide a way forward in delivering a
consistent form of FoP labelling across the EU for the future. Interested parties’ views and
experience of using health logos are sought
FPH supports the BHF led Joint Response answer to this question.
XV) What are your views on further emphasising the energy content per portion of the FoP in
order to help those looking to reduce their calorific intakes?
FPH supports the BHF led Joint Response answer to this question.
69
Previously at www.nhs.uk/Livewell/Goodfood/Pages/mysupermarketuserguide.aspx but now at
http://webarchive.nationalarchives.gov.uk/+/www.nhs.uk/Livewell/Goodfood/Pages/mysupermarketuserguide.aspx (accessed 15/05/2012).
70
Previously at www.mysupermarket.co.uk/healthy-shopping/traffic-light-labelling.aspx. The website was redesigned in November 2011; the
Health checker is temporarily unavailable but an improved version is due to go live in spring/summer 2012 (not available 15/05/2012).
71
Lobstein T, Landon J, Lincoln P. Misconceptions and misinformation: the problems with GDAs.London: National Heart Forum, 2007.
72
Faculty of Public Health, Heart of Mersey, National Heart Forum. Traffic-light food labelling. A position statement.London: FPH, 2008.
www.fph.org.uk/uploads/ps_food_labelling.pdf(accessed 15/05/2012)
73
The Grocer, Sainsbury’s Traffic Lights are Rewriting its NPD Strategies http://www.thegrocer.co.uk/companies/sainsburys-traffic-lights-arerewriting-its-npd-strategies/116452.article (accessed 18/12/2-11)
8
4 St Andrews Place  London  NW1 4LB  Tel: 020 7935 0243  Fax: 020 7224 6973
Email: enquiries@fph.org.uk  Website: www.fph.org.uk  Registered Charity No: 263894
XIV) Are there any costs or benefits other than those set out in the costs and benefits section
above that might accrue from the further voluntary harmonisation of the provision of front of
pack nutrition information as set out in this consultation document?
FPH supports the BHF led Joint Response answer to this question.
4 St Andrews Place  London  NW1 4LB  Tel: 020 7935 0243  Fax: 020 7224 6973
Email: enquiries@fph.org.uk  Website: www.fph.org.uk  Registered Charity No: 263894
9