FDII PRESENTATION TO JOINT OIREACHTAS COMMITTEE ON HEALTH AND CHILDREN
PAUL KELLY, DIRECTOR & SHANE DEMPSEY, HEAD OF CONSUMER FOODS, FDII
THURSDAY OCTOBER 11TH 2012
FDII Presentation to the Joint Oireachtas Committee on Health and Children
11th October 2012
SECTION 1: INTRODUCTION
Food and Drink Industry Ireland (FDII) welcomes the opportunity to present to the Joint
Oireachtas Committee on Health and Children. FDII shares the committee’s concern over
childhood obesity. We seek in this submission to outline industry’s actions and set out a work
programme that will play its part in resolving this societal issue. We look forward to this
committee’s report into childhood obesity and hope that it will represent a clarion call to all
stakeholders across society to work together on this issue.
FDII requests respectfully requests that:
1. this committee recommends that a ‘whole of society’ response to obesity is lead by
this Government. This means that a national obesity strategy is created that involves
all stakeholders in a collaborative process.
2. this committee recommends that industry’s proposed platform, the Livewell Platform
become the basis for collaboration between the food companies and Government.
3. committee members oppose policies that are not evidence-based and simply target
food companies
Most developed world governments are struggling to address increasing obesity levels in their
societies. Obesity is viewed as a by-product of sustained economic growth as food production
becomes more efficient; people’s employment moves from the primary to the service sector
and as consumers demand more convenience and variety in relation to food. Indeed, many
experts appearing before the committee have highlighted the significant reduction in activity
levels as a major contributor to our obesity crisis.
All experts agree that multiple societal factors contribute to the individual becoming obese.
There is a growing recognition amongst experts and Governments alike that the solution to this
issue lies beyond the capability of Government or industry to solve alone.
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FDII Presentation to the Joint Oireachtas Committee on Health and Children
11th October 2012
Any solution will require a co-ordinated societal response where industry, government, state
agencies and the citizen collaborates. Action at the individual, local, national and international
levels is also required. Interventions, policies and actions aimed at reducing obesity should be
objective and science-based. Where policies have not been science-based or collaborative,
policies have failed or resulted unintended consequences. When addressing this complex
societal issue, it is inappropriate to single out a single food group.
In the Irish context, this means using the government-sponsored consumption research carried
out by the Irish Universities Nutritional Alliance (IUNA). This research is considered world class
and should be the foundation of health policy in this country.
Due to our relatively small population size, Ireland’s leading food scientists and health
professionals believe Ireland is uniquely placed to become a live ‘lab’ and become the global
exemplar in creating a ‘whole of society’ response to obesity.
Institutions such as the EU, WHO and the OECD and indeed all of the experts who have
attended this committee all advocate a societal response. These bodies are also in agreement
that policies or responses that ‘target’ any particular stakeholder or product will not solve
obesity in the long-term.
Industry fully supports the ‘whole of society’ response. FDII has a strong track record in
engaging with Government on this issue. For example, our organisation facilitated companies
and the Food Safety Authority of Ireland in significant reductions of salt across many categories.
In addition, food companies are consulting with the Department of Health on issues such as
calorie posting, taxation, advertising restrictions, portion control and other measures.
Genuine multi-stakeholder collaboration involving Government Departments, all sectors of
industry, consumer groups, unions, NGOs and local communities is the way forward. The
pursuit of policies that target the food industry will not be effective or reduce obesity.
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FDII Presentation to the Joint Oireachtas Committee on Health and Children
11th October 2012
For example, the Broadcasting Authority of Ireland (BAI) has devised an advertising code that, if
implemented, will see the advertising of various foods to children being banned. Industry has
repeatedly asked the BAI to utilise Ireland’s world class IUNA data in formulating their code but
instead they are using a UK model which does not take into consideration our Irish
consumption profile. The banning of advertising cheese to children is just one example of the
deficiencies in using the UK model and has been well documented in the media. If the BAI had
used the IUNA data it would have identified that particular cohorts of Irish children are calcium
deficient and a system better suited to our population could have been designed.
This example demonstrates the difficulties and unintended consequences of pursuing punitive
policies against one nutrient, product, or stakeholder. In the current economic environment
and depressed domestic economy any negative impact of health policies should be avoided
that may either damage the food industry’s competitiveness and/or leave Industry with no
other option but to take legal action to protect their competitiveness.
This example demonstrates the difficulties and unintended consequences of pursuing punitive
policies against one product, stakeholder or nutrient. The impact of health policies that may
damage the food industry’s competitiveness should be avoided, particularly in the current
economic environment and depressed domestic economy. FDII believes that Government can
achieve health objectives more effectively through harnessing the influence each stakeholder
has with citizens.
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FDII Presentation to the Joint Oireachtas Committee on Health and Children
11th October 2012
INFORMATION ON THE IRISH FOOD SECTOR
The Irish food industry supports every community across Ireland. It purchases 90% of the
output of Ireland’s farmers maintaining over 120,000 farming families.
Food companies
purchase huge amounts of Irish products and services supporting 60,000 jobs indirectly, whilst
directly employing over 50,000. Due to the geographically dispersed nature of the sector, that
means jobs across the country including economically depressed areas. Finally, the food
industry services every Irish retailer across the country in addition to representing brand Ireland
on the supermarket shelves of many export markets.
Key statistics
• 230,000 jobs linked to the agri-food sector
• €24bn turnover in the sector
• €8.85bn worth of exports in 2011 to 120 countries
• 2/3 of exports by indigenous Irish companies
• Destinations – UK 41%, rest of Europe 34%, third countries 25%
• Total payroll in the sector is €1.74bn – more than any other manufacturing sector
• €8bn worth of materials purchased - 75% are sourced in Ireland
• €3.5bn worth of services purchased – almost half are sourced in Ireland
• Supplies the majority of produce to Ireland’s €14bn domestic grocery sector
• Ireland is the largest net exporter of dairy ingredients, beef and lamb in Europe
• Ireland exports over 80% of its dairy and beef production
• Ireland is the UK’s largest supplier of food and drink
• Irish beef is stocked by more than 70 retail chains across Europe
• Ireland exports over half the pigmeat it produces – to over 60 countries around the world
Ambitiou
s growth strategy
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FDII Presentation to the Joint Oireachtas Committee on Health and Children
11th October 2012
Export growth is the central element of Food Harvest 2020, the Irish Government’s blueprint
for growth for the food industry, because it will impact on the wider economy in a way that is
not possible from any other sector. Every extra euro of food exported has a bigger impact on
the wider economy that other product or service exports because the sector is by far the largest
consumer of Irish goods and services.
Most importantly, this sector supports every local community in Ireland by sourcing agricultural
output of farmers and by servicing every retailer outlet in the country. Food companies
themselves provide employment in manufacturing, marketing, logistics and other professional
services in towns across the country.
As a highly regulated and competitive sector, food companies, including the Irish offices of
global food companies, are highly sensitive to changes in the policy environment that reduce
their competitiveness. The recent recession has resulted in significant job losses in the sector
and the wider grocery sector.
Further costs imposed on the food sector will result in further depressing consumer demand.
It’s essential that any future policy achieves the maximum reduction in obesity with minimal
risk to jobs in the sector.
It’s worth noting that 50% of food produced in Ireland is retained in Ireland contributing
significantly to the economy. This further demonstrates the need to calibrate policy carefully to
ensure Irish produce isn’t disadvantaged. Locally produced foods and imports must be treated
equally to ensure competitiveness is retained. Another complex challenge relates to ensuring
that policies do not favour one channel over the other, and all sources of food to the consumer
are equally treated.
FDII believes that Government can achieve more in relation to health in collaboration with Irish
food companies. These companies take their responsibility to their consumers very seriously.
They are investing in a healthy vibrant Ireland and are constantly adapting to ensure they are
positively contributing to Irish society.
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FDII Presentation to the Joint Oireachtas Committee on Health and Children
11th October 2012
The Irish food industry has a strong track record in this area.
Most recently, FDII members
have:

Introduced the Guideline Daily Amount (GDA) labelling system into the market to give
consumers more practical nutritional information so they can make informed choices.

Participated in a highly effective salt reduction initiative with the Food Safety Authority
of Ireland across a number of categories

Increased the range of alternative, ‘reduced’ products and increased their promotion

Supported multi-stakeholder platforms such as the Nutrition Health Foundation and the
EU’s Platform on Health and Physical Activity to promote healthy lifestyles
A survey carried out by FDII in 2012 into member’s reformulation (changing the nutritional
quality of products) and choice initiatives showed:

82% of respondents had reformulated their products

76% had reduced salt in their products

50% had reduced saturated fat in their products

58% had reduced sugar in their products

60% launched ‘alternative’ products

83% of companies advertise these ‘alternative’ products

68% have portions size information on their products

46% have introduced reduced portion versions of their products
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FDII Presentation to the Joint Oireachtas Committee on Health and Children
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SECTION 2:
FDII INDUSTRY INITIATIVES
FDII members have spent significant resources on a range of health and nutrition initiatives
within their organisations. We believe that these initiatives demonstrate that Government
should collaborate, incentivise and support these companies as part of their national obesity
strategy.
Food company initiatives can be grouped into the following categories:
1. Reformulation and fortification
2. Increasing choice and range for consumers
3. Information to consumers
4. Promotion of Active Lifestyles
1.
REFORMULATION, FORTIFICATION AND CHOICE
The food and drink industry in Ireland has invested significantly over the past number of years
to improve the range and choice of food and drink products available to the Irish consumer. In a
competitive business environment, and driven by the continued upward trend in obesity rates
in Ireland, the industry has focused on innovating to develop an ever increasing range of
healthier options, while working to reformulate and improve the nutritional profile of existing
products. Reformulation is, it should be noted, a very expensive, research intensive and
complex process in most cases. Some of the key reformulations carried out by FDII members
are set out in this section.
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FDII Presentation to the Joint Oireachtas Committee on Health and Children
11th October 2012
Salt Reduction
In 2004, the Food safety Authority of Ireland (FSAI) approached Food and Drink Industry Ireland
(FDII) to enter into a voluntary partnership on the reduction of salt levels in foods. The
recommendation was made in the “Salt and Health Report”, that the industry should reduce
salt on a gradual and sustained basis.
Since agreeing to this partnership approach, FDII has been co-ordinating and ensuring that
members take part in the campaign. FDII has approximately 150 members. These include a
number of companies for whom salt is not a concern e.g. non food grocery, beverages and
various other product categories. The partnership approach has allowed a targeted approach
and, through FDII, FSAI has been able to work with appropriate companies and sectors. FDII
members typically represent significant proportions of the key target markets for a salt
reduction programme. There has been no drop off in commitment, engagement or
participation from FDII members in recent years.
On an annual basis, FSAI engage with FDII to assess recent progress and commitments. Each
year, the FSAI publish an updated list on their website. They have recently completed this work
for 2011. The FSAI monitor the commitments made by the industry through product testing
and results of these surveys are published on a regular basis. This ensures that the reported
reductions are actually been made.
Current Population Salt Intakes
The FSAI estimate that salt consumption has reduced by 1.1g or about 14% since the
programme started. IUNA published their latest Adult Nutrition Survey results in March 2011.
This shows that the mean daily intake of salt from foods is 7.4g/day and a total salt intake of
9.8g/day. This highlights that approximately 25% of our salt intake is discretionary, significantly
higher than previously thought (10%).
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FDII Presentation to the Joint Oireachtas Committee on Health and Children
11th October 2012
FDII is committed to continuing our work with the Food Safety authority of Ireland to further
reduce salt levels. Our achievements are on course to at least match those of the UK and to
surpass those requested by the High Level Group on Nutrition, which is part of the EU Platform
for Action on Diet, Physical Activity and Health.
The recent results show that, while industry continues to reduce salt, consumers must be
responsible on salt use during cooking and at the table. We would support further educations
campaigns in this respect. This partnership approach shows that the Irish industry can work
with the regulator to achieve real improvements in population health.
Summary of FDII Product Categories Commitments to the FSAI Salt Reduction
Programme
BREAD
The Bread Bakers Association has achieved reductions of up to 20%
BREAKFAST
The Irish Breakfast Cereals Association has achieved a 48% reduction on
CEREALS
a sales weighted basis since 1998.
SOUPS
AND The Soups and Sauces Association have achieved reductions of up to
SAUCES
25% depending on product category
The Snack Food Association has achieved reductions of up to 19% in
SNACK FOODS
crisps and significant reductions across a variety of other product
categories.
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FDII Presentation to the Joint Oireachtas Committee on Health and Children
11th October 2012
Trans Fat:
In the 1990s, in line with scientific data, food companies began to reduce and remove Trans
Fatty Acids (TFAs). Over the past number of years, most companies have almost entirely
eliminated TFAs from their products. The success of this voluntary initiative was confirmed in
an FSAI report, published in May 2008, showed that 80% of 100 pre-packaged food products
tested for their fat and TFA content, contained either no or low levels of TFA’s.
Saturated Fat:
FDII acknowledges the over consumption of saturated fat is significantly in excess of
recommended dietary guidelines. The Food Safety Authority of Ireland has highlighted this as
an area for future partnership and is in the process of obtaining up to date data through the
IUNA 2011 research.
Nonetheless members have been reformulating products. For example, cooking crisps in
sunflower oil, which all FDII members now do, provides a crisp much lower in saturated fat and
has resulted in public health benefits. The massive growth of the “better for you” markets
across all sectors has also resulted in wider consumer choice in this area.
Fortification:
Recent food consumption surveys have shown that there are inadequate intakes of some
vitamins and minerals in the Irish population. Specifically, there is a tendency for women to fall
short of their recommended daily intakes for calcium, iron and folate (folic acid), while children
and teenagers have also been shown to have inadequate intakes of calcium, iron, vitamin A, C,
D and folate.
Certain food categories have become increasingly important in providing our population with
vital micronutrients. These products are either naturally rich in essential micronutrients or
fortified during the manufacturing process. Important sources of key micronutrients are; dairy
products, meats, vegetables, potatoes, fish, eggs, fruit, breads and breakfast cereals.
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FDII Presentation to the Joint Oireachtas Committee on Health and Children
11th October 2012
In 2006, the National Committee on Folic Acid Fortification recommended that most bread
products should be fortified with folic acid during manufacture. Although this recommendation
was subsequently shelved, the industry has continued to fortify foods such as bread and
cereals. IUNA data shows that breakfast cereals continue to be a vital contributor of a range of
micronutrients in the Irish diet.
EU legislation, in the form of the Addition of Vitamins and Minerals to foods, will set maximum
and minimum limits for fortification of foods and supplements. FDII are encouraging the
conclusion to the implementation of this legislation.
Additives:
As consumer needs and perceptions change, the food industry must respond. This has never
been more evident than in the use of artificial additives and flavours.
All additives must be scientifically reviewed and approved for safety before they can be used.
They can only be used where they are functionally important in food and in some cases, where
the additive is essential to make the food available to consumers. The confectionary category
has been particularly successful in removing additives from products in the previous five years.
Over the past number of years, consumers have become less accepting of artificial additives.
FDII members have monitored these trends closely and have responded, where relevant, by
actively removing artificial colours, flavours and preservatives, where it is technically feasible to
do so.
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FDII Presentation to the Joint Oireachtas Committee on Health and Children
11th October 2012
2.
INCREASING CHOICE AND RANGE FOR CONSUMERS
In addition to the extensive work that has been undertaken by the industry on product
reformulation, FDII member companies have invested significantly over the past five years into
the development of new healthier options or ‘better for you’ product ranges, to provide the
consumer with improved choice.
A significant number of new products are now introduced to the market for their ‘better for
you’ qualities. More than 25% of new products are introduced to the market for their ‘better
for you’ qualities.” 1 Consumers now have the option of choosing lower calorie, lower fat, lower
salt and lower sugar varieties of many leading brands, as well as products that have added
beneficial nutrients and micronutrients.
Significant investment has also been made in the marketing and promotion of these products
to help them succeed in the marketplace and drive consumers towards healthier alternatives.
FDII member companies are committed to supporting and enabling consumers to choose a
healthy balanced diet for themselves and their families. The food industry will continue to
develop and expand the range of products that they offer to help make healthier choices easier
for consumers.
While many sectors of the food industry have developed low or no sugar alternatives in recent
years, perhaps the best examples of this activity are in the soft drink category.
Almost every leading soft drink brand is now available in a ‘no sugar’ variant. These brands,
which include products such as Ribena Toothkind, Diet Club Orange, Pepsi Max, 7-Up free,
Diet Coke and Coke Zero, are readily available where the original brand variety is supplied,
giving the consumer the choice to opt for sugar or no sugar.
1
FDII member survey, 2008
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FDII Presentation to the Joint Oireachtas Committee on Health and Children
11th October 2012
Sugar free variants are well-marketed and are positioned as an enjoyable alternative to the
sugar-containing versions. The result has been a massive growth in market share for low and no
sugar varieties over the past number of years, with the no added sugar:added sugar ratio
moving from 28:72 in 1987 to 57:43 in 2007.
These shifting trends have resulted in a significant decline in the contribution to sugar intake by
soft drinks in the diets of Irish consumers. Recent IUNA data shows that carbonated beverages
contribute only 2.5% of energy consumed by Irish children.
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FDII Presentation to the Joint Oireachtas Committee on Health and Children
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Portion size
To support consumers in choosing suitable portion sizes, the food industry must ensure that it
provides an appropriate range of portion sizes to suit individual needs. Consumption of
inappropriately large portion sizes is now considered to be a significant contributor towards the
rising levels of obesity in Ireland (IUNA, Food Consumption Surveys).
The food industry has been cognisant of this fact and has begun to take action across Europe
towards agreeing standard portion sizes. In addition to the agreement of standard portion size,
the industry must inform and educate the consumer about appropriate sizes. To support this,
the vast majority of companies include recommended portion sizes on pack, where
appropriate.
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FDII Presentation to the Joint Oireachtas Committee on Health and Children
11th October 2012
3.
INFORMATION TO CONSUMERS
FDII believe that there is an onus on food manufacturers to supply consumers with clear and
consistent information on labels about the nutritional content of the foods. The vast majority of
companies already provide nutrition information in a tabular format. In addition to this, since
2006, FDII has been promoting the Guideline Daily Allowance scheme with our members.
The GDA Scheme:
Since 2006, FDII has been part of a pan European Food Industry initiative to put Guideline Daily
Amount information on our labels. This voluntary scheme has been extremely successful in
Ireland.

The vast majority of foods (80% branded; 95% retail) now carry GDA labels.

In 2008, FDII spent €400K on consumer outreach campaign which covered broadcast,
internet and print media educating consumers on how to use GDA. We have been
encouraged to see that consumers in Ireland now recognise and use GDA labels.

The Food Safety Authority of Ireland has clearly showed in their “Consumers Attitudes
to Food Labeling”2 report in 2009 that consumers prefer GDA to any other form of
nutrition labeling.
New EU Food Labeling Regulation
In discussions on the recently agreed Food Information to Consumers regulation, FDII fully
supported that nutrition labeling should be mandatory and that information should be given
front of pack where possible.
As a result of this new legislation, FDII members must adopt to a new environment on labeling.
Under the new rules, a food company must provide nutritional information on the back of pack.
As stated, most Irish products carry such information anyway.
2
GDA 53%, Traffic Light 39%, Hybrid 8%
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FDII Presentation to the Joint Oireachtas Committee on Health and Children
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Manufacturers will be able to repeat information on a voluntary basis either by providing (a)
energy information per 100g, or (b) energy per 100g, and energy, sugar, fat, saturates and salt
on a per portion basis. The legislation also allows the Commission to set standard portion sizes.
Traffic Lights
FDII has always completely opposed the concept of colour-coding foods. This is an overly
simplistic system that does not address the individual needs of consumers. The system also
inhibits ‘positive’ product reformulation as there is no incentive for companies. The scheme is
based on 100g rather than per portion of food actually eaten, which discriminates against the
many foods eaten in less than 100g. Finally, traffic lights take no account of the micronutrient
contribution of products and subsequently these are classified as unhealthy foods.
Harmonisation
FDII strongly support calls for a harmonised nutrition labeling scheme in the EU. As a country
that exports the majority of the products we produce, consistent rules across Europe are of
paramount importance. We do not believe it would be feasible for Irish food exports to thrive in
an environment which allows Member States to introduce their own national rules on labeling.
Marketing and Advertising
Food and Drink companies in Ireland adhere to a range of regulatory and self-regulatory
frameworks that cover food and drink advertising.
Advertising Standards Authority of Ireland (ASAI) Code
The Advertising Standards Authority for Ireland is the independent self-regulatory body set up
and financed by the advertising industry and committed to promoting the highest standards of
marketing communications. All FDII members adhere to the conditions for advertising as set
down by the Advertising Standards Authority of Ireland, a specific section of which relates to
the advertising of food and non-alcoholic beverages. ASAI have undertaken independent
compliance audits with the code and found 99% compliance with the code.
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FDII Presentation to the Joint Oireachtas Committee on Health and Children
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EU Pledge
This is an initiative by a number of major food companies who have made a voluntary
commitment to the EU Platform on Diet, Physical Activity and Health. The participating
Companies committed to implement company specific measures on food and beverage
advertising to children before 2009.
All companies must meet the following minimum standards by not advertising food and
beverage products to children under the age of 12 on TV, Print and Internet except for products
which fulfill specific nutrition criteria based on accepted scientific evidence and (ii) not to
engage in any commercial communications related to food and beverage products in primary
schools, except where specifically requested by or agreed by the school administration for
educational purposes. In 2011, Accenture audited companies signed up to the Pledge and in the
Irish market there was 98% compliance levels in TV advertising and 100% compliance in print
media.
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FDII Presentation to the Joint Oireachtas Committee on Health and Children
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UNESDA / International Council of Beverage Associations Codes
The European Soft Drinks Association’s members have committed to a code, which states that
their members will not place any marketing communication in any paid, third party media
whose audience consists of 50% or more of children under the age of 12. This covers broadcast
(TV and radio), print and digital media (including internet and phone messaging) as well as
cinema (including product placement).
In addition, they recognised the need to review other forms of marketing practices (including
the use of licensed characters, sponsorships and other forms of marketing communications) in
channels which are predominantly related to children under 12. They will undertake this work
by the end of 2009.
Individual Company initiatives:
The vast majority of individual companies have adopted and implemented specific internal
codes of conduct in relation to food and beverage marketing communications.
Results of the voluntary codes on TV Advertising:
In 2010, advertising slots on RTE2 during children’s programming were analysed for the rate of
advertising for foods and drinks that fell into categories, which are usually considered to be
high in fat, sugar and/or salt over the previous eight years. RTE2 was chosen because it is
responsible for 90% of children’s advertising programming on indigenous broadcast media and
children’s programming is defined as the period 9.00am – 5.30pm daily.
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FDII Presentation to the Joint Oireachtas Committee on Health and Children
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Over 8 years, between 2002 and 2010, the advertising of the following products on RTE2 was
measured:

BISCUITS, CEREALS, CHEWING GUM, CHOCOLATE-BARS, CHOCOLATE-BOXED, CORDIALS,
CRISPS POPCORN & SNACKS, DIPS/DIPPERS SNACKS, ICE CREAM & LOLLIES, JAM &
SPREADS, PIZZA, MINERAL WATER, SOFT DRINKS, SUGARS & ARTIFICIAL SWEETENERS
Advertising of Food and Drink Categories during Children’s Programming 2002- 2010
Year
2002 2003 2004 2005 2006 2007 2008 2009 2010
No Spots
8055 8218 5661 4238 4169 2775 1829 2026 1634
Percentage
36.9% 34.2% 25.3% 16.8% 16.9% 9.8% 7.2% 9.9% 7.1%
Source: RTE
FDII position on the Broadcasting Authority of Ireland’s proposed Children’s Advertising Code
The Food and Drinks industry recognises the importance of advertising responsibly to all
consumers and we support all practical measures that protect children.
Given the importance of the food and drink industry to the Irish economy, we believe that all
regulatory measures should be rigorously analysed, based in sound scientific fact and should
not diminish the competitiveness and growth potential of the sector.
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FDII Presentation to the Joint Oireachtas Committee on Health and Children
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Our members operate in, and comply with, a highly complex advertising environment. Through
a combination of self regulatory measures and internal codes, the advertising landscape has
changed significantly in recent years. So dramatic is the change that advertising for products
across a wide range of food and drink categories, now account for as little as 7% of all
advertisements shown during children’s programming on indigenous media.3
Furthermore, the UK model is based on the concept of 100g rather than on portion size. As a
result, foods which are eaten in smaller portions (e.g. dairy, cereals) are unfairly penalised. In
addition, the model has not been accepted in any other country. Neither has it been updated in
the UK to take account of the Scientific Advisory Committee on Nutrition’s 4recommendations
or in light of recent European regulatory developments. 5
We are aggrieved that the BAI ignored the extensive research into Irish dietary habits as funded
over the past 15 years by the Department of Agriculture’s Food Institutional Research Measure
(FIRM) at a cost to the taxpayer of over €7 million. This data should form the scientific evidence
base for policy decisions made relating to food and health.6
To monitor commercial communications to children, FDII supports a co-regulatory framework,
in line with most EU countries. This approach has been recognised as successful through the EU
Platform on Diet, Health and Physical Activity.
FDII strongly rejects the proposed concept of a watershed, which by its nature is a blunt
instrument, likely to have disproportionate and unintended consequences. Children’s
programming should be determined by the proportion of the audience under 18 watching the
show. Therefore, audience profiling is the most succinct and suitable regulatory instrument.
RTE Research, 2010
SACN, Recommendations of the Nutrient Profiling Model Review Panel, 2008
5 EU Regulation 1925/2006/EC on the addition of vitamins and minerals and of certain other substances to foods
6 Department of Agriculture Press Statement
http://www.agriculture.gov.ie/press/pressreleases/2008/january/title,13491,en.html
3
4
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FDII Presentation to the Joint Oireachtas Committee on Health and Children
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FDII believe that the Broadcasting Authority of Ireland (BAI) can achieve their stated goals in a
straightforward and cost effective manner by facilitating dialogue and engagement with all
stakeholders, including experts in the scientific, food, broadcasting and advertising industries,
in a co-regulatory framework.
4.
PROMOTION OF ACTIVE LIFESTYLES
FDII members promote healthy and active lifestyles through a comprehensives series of positive
initiatives. The food and drink industry is unique amongst other commercial sectors in the
commitment it has to supporting healthy, active lifestyles. No other sector does more to
encourage and promote healthy eating and physical activity – from large-scale national
campaigns to smaller initiatives in local communities.
The majority of food companies support healthy/active lifestyles through significant local and
national support. Some major examples of these are:

Cadbury/Kraft’s GAA Under 21 Football Sponsorship

Coca-Cola’s Grassroots Sports

Britvic Energise Sport Sponsorship of the Gaelic Players’ Association

Kellogg’s Field of Dreams initiative

Unilever’s Flora Women’s Mini Marathon

Significant sponsorship of sporting teams throughout Ireland
FDII members make significant contributions to the development of local communities. A large
proportion of this support is funnelled towards promoting sports, health and activity-based
clubs. Nationally, FDII members contribute significantly to support healthy lifestyle initiatives.
This contribution is recognised by a number of public representatives and state agencies at
local and national levels.
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FDII Presentation to the Joint Oireachtas Committee on Health and Children
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The Nutrition Health Foundation
In 2005, the Irish food and drink industry launched the Nutrition & Health Foundation (NHF) –
an innovative multi-stakeholder partnership platform, which brings together industry,
Government, scientists, health professionals, educators and other relevant stakeholders to
provide evidence-based information to consumers, encouraging them to make positive changes
to their dietary and physical activity habits.
The NHF is wholly funded by the food industry and has run a range of enormously successful
initiatives over the past seven years, including:

Workplace Wellbeing Campaign – delivered to over 100,000 employees

Annual ‘Eat Smart Week’ – national campaign to promote nutrition literacy

Move Smart Week which was commenced this year in association with the Camogie
Association

Kids Size Me initiative launched July 2011 in conjunction with the Restaurants
Association of Ireland - one year on line self report restaurant audit just completed and
results being collated

A member of the European Nutrition Foundation Network and involved in the
development of the European Food Framework on nutrition, energy balance and
physical activity for kids aged between 5 and 16
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FDII Presentation to the Joint Oireachtas Committee on Health and Children
11th October 2012
Work in progress

Healthy cinema options with a cinema group - consumer survey should go live in the
coming weeks

Nutrition and physical activity information booklets for teenage Camogie players

Partial funder of Masters by Research in DIT on developing life skills module for new
entry level students

Pregnancy/breastfeeding/weaning related phone app
(For more information, visit www.nhfireland.ie)
The NHF was the first of its kind to be established in Europe and the efforts of the Irish food
industry in bringing this initiative to life has been duly acknowledged by the EU Platform on
Diet, Health & Physical Activity.
Since its launch, the NHF has assisted other EU Member States, including Hungary, to establish
their own ‘national platforms’, which have a similar mission to encourage an improved and
healthier society.
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FDII Presentation to the Joint Oireachtas Committee on Health and Children
11th October 2012
SECTION 3: FUTURE COLLABORATION BETWEEN THE FOOD INDUSTRY AND GOVERNMENT
Food and Drink Industry Ireland has been tasked by its members to create a collaborative
platform with Government to address Ireland’s obesity challenge. A significant cohort of these
companies have agreed to fund and participate in a series of initiatives aimed at reducing
obesity in Ireland over the next 2-3 years.
FDII are seeking to collaborate with Government, state agencies and other relevant
stakeholders to increase effectiveness of initiatives across society. These initiatives will be
science-based and objective and they will work more effectively than taxation and other
punitive regulations.
FDII’s role is to encourage the maximum number of its members to join and build this model
out to other business sector such as retail to create an effective societal response to obesity –
Government endorsement makes wider industry uptake more likely.
FDII has engaged a number of respected health professionals to shape initiatives as part of the
Livewell Platform to ensure they have maximum impact on obesity levels.
All participating
members will:

will sign a nutrition and health pledge

Make commitments to reformulate, fortify products and increase choice options for the
consumer

Support health literacy promotion campaign targeted at at-risk segments of the
population and research into increasing activity levels in schools

Initiate a national workplace well-being campaign

Establish product category-specific initiatives to pursue such as the removal of certain
products from vending machines in secondary schools
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FDII Presentation to the Joint Oireachtas Committee on Health and Children
11th October 2012
Livewell Platform
FDII’s Livewell Platform
All members sign-up to overarching platform pledge
Pillar 1: Reformulation &
Pillar
Choice
Well-being
Companies provide info on
NHF carrying out a root and
FDII will engage a market research
FDII will work with product
reformulation activities:
branch of their WWB material
company to establish attitudes and
associations
Salt, Sugar, Sat/Trans Fats,
An enhanced WWB campaign
behavioural
relevant initiatives that can
Additives,
will be rolled out nationally in
fortification,
2:
National
Workplace
choice and portion size
2013/14
Information is collated on a
NHF are engaging with IBEC to
category basis
ensure that WWB is promoted
through its membership.
Information made public to
FSAI
Information reported on a
Pillar 3: Research
Pillar
Commitments
baseline
for
the
population
be
A PR agency will be engaged to
incorporated
into
Livewell
campaigns aimed at target groups
policy on vending machines
in secondary schools
In addition, FDII will engage an
institution to research how to
Once
identified,
increase physical activity levels in
initiatives can have metrics
primary schools
created
for
measurement
Livewell Steering committee will
The metrics committee will establish
basis
create a series of health metrics
health metrics to measure impact
to measure the WWB impact on
amongst
target employees
populations
against
identify
Eg BCI have created a
FSAI measures on a yearly
commitments
to
execute localised communications
yearly basis
progress
4:Category
target
groups
target
26
these
their
FDII Presentation to the Joint Oireachtas Committee on Health and Children
11th October 2012
Food/Nutrient Taxes:
Food taxes or discriminatory taxation are unproven in the context of reducing obesity. Simply
put, they are a simplistic and narrow attempt to address obesity. There are simply too many
factors impacting driving energy imbalance at the individual level for a tax to have any real
impact at a societal level.
In other countries where such taxation measures have been
introduced they have had negative economic impacts and no discernible health benefits.
In
addition, the policy scapegoats one stakeholder and runs counter to the ‘whole of society’
response.
Food taxation will not reduce obesity levels and there is insufficient evidence to introduce such
a potentially ineffective measure. We include a comprehensive list of research in appendix 1.
The Irish food and drink industry is fully committed to playing its role in helping to tackle
obesity and other relevant public health issues. However, the obesity issue will not be resolved
by taxation or other forms of discriminatory legislation aimed at individual food categories. An
evidence based holistic approach is necessary which should include measures such as
reformulation, consumer awareness, the promotion of physical activity, and work-place and
school well-being programmes. FDII believe that by working with the food and drink industry,
the government will be in a better position to achieve its public health objectives and lower
obesity rates in this country.
There is significant evidence to suggest that taxes, in particular discriminatory taxes, are an
ineffective approach to tackling complex diet and lifestyle-related problems. The academic
community has looked extensively at the issue and most studies express serious doubt about
the purported efficacy and appropriateness of discriminatory taxation as a means to affect
dietary change.
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FDII Presentation to the Joint Oireachtas Committee on Health and Children
11th October 2012
Fiscal measures specifically aimed at altering behaviour are complex to design and can be highly
unpredictable. There is no evidence to suggest that the proposed tax will alter the behaviour of
consumers in this country. Policy formulation must apply the principles of better regulation and
be underpinned by a substantive evidence base.
In comparison with our European neighbours, Ireland already has a high tax regime on certain
foods including beverages and confectioneries. While the vast majority of foods in this country
are zero rated, the standard rate of 23% VAT applies to confectionary items like sweets,
chocolate, crisps, ice-cream and soft drinks. The introduction of further taxation would create
unwelcome uncertainty and distress throughout the food chain.
Given the proximity of the border with Northern Ireland, consumers will be encouraged to
avoid the tax by doing their weekly grocery shopping in the border towns. Historically, soft
drinks have been a significant driver of cross-border traffic. The Danish case and our own
problematic history with cross-border shopping should be evidence enough that this form of
taxation is misguided and ineffective in changing consumer behaviour.
By its nature a higher tax on food products is regressive and will hit low-income populations
hardest since lower socio-economic groups spend a larger share of their income on food than
other income categories.
Food taxation measures are at odds with the current drive for recovery and the growth targets
set by the Department of Agriculture, Food and the Marine for the year 2020. A tax of this
nature would give a negative signal internationally, where Ireland’s reputation as the “food
island” would be diminished.
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FDII Presentation to the Joint Oireachtas Committee on Health and Children
11th October 2012
Conclusion
FDII requests that this committee become advocates for a ‘whole of society’ response to the
childhood obesity situation. In addition, this committee can ensure that this approach is based
on positive collaboration between food companies and Government through the Livewell
Platform.
Food companies respectfully request that members of this committee oppose
fragmented policies that scapegoat the food industry as they will not reduce obesity in the
long-term.
All experts agree that multiple societal factors contribute to the individual becoming obese.
There is a growing recognition amongst experts and Governments alike that the solution to this
issue lies beyond the capability of Government alone to solve.
Any solution will require a co-ordinated societal response where industry, government and the
citizen collaborate. Action at the individual, local, national and international levels is also
required. Interventions, policies and actions aimed at reducing obesity should be objective and
science-based. Where policies have not been science-based or collaborative, such as the
Danish government’s sat-fat tax, policies have failed or resulted unintended consequences.
Irish food companies take their responsibility to consumer seriously. They are willing to engage
in a genuine and significant way with the Government’s attempts to tackle obesity. It’s our
belief that this type of collaboration can help achieve health objectives whilst enhancing the
reputation of Ireland’s food sector.
A long-term strategy is required that focuses on changing the behaviors that lead to obesity
through information and education. This strategy should involve all stakeholders and all
policies within this should be based on robust scientific evidence.
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FDII Presentation to the Joint Oireachtas Committee on Health and Children
11th October 2012
FDII commend this committee on its efforts to tackle childhood obesity and wish it well in its
efforts. It is our hope that this report marks a turning point in our country’s response to obesity
and will see the start of a societal response that will secure the health of our nation.
This submission has been made on behalf of all FDII members.
30
FDII Presentation to the Joint Oireachtas Committee on Health and Children
11th October 2012
Appendix 1: Food Taxation
The academic community has looked extensively at the issue of nutrient taxation in recent years. Most
studies express serious doubt about the purported efficacy and appropriate nature of discriminatory
taxation to effect dietary change. This was also confirmed by two recent scientific reviews of existing
literature.
1.
Hughes 2012; Etilé 2012. Alemanno, Alberto & Carreño, Ignacio, 2011. “Fat taxes in the EU between
fiscal austerity and the fight against obesity”, European Journal of Risk Regulation 4, 2011,
http://papers.ssrn.com/sol3/Delivery.cfm/SSRN_ID1945804_code553230.pdf?abstractid=1945804&miri
d=3
“One question is whether these product-specific taxes are really addressing the obesity problem by
penalising certain ‘unhealthy’ products or if they are just new instruments to generate fiscal revenues
(or maybe, even, to protect certain domestic constituencies), in particular in view of the public deficit
problems that many EU Member States are currently facing in the context of the economic crisis.”
“It is not clear whether the imposition of such taxes reduces obesity or whether governments would get
better results from education campaigns, for instance.”
“There is no consensus in the scientific community on which foods to target. Therefore, before
committing to the introduction of a fat tax, policy-makers need to consider their objective, the effect of
the tax in combination with other measures, and the impact on businesses.”
“ In view of the discrimination among specific food categories, the hope is that, in Europe, the adage
that ‘there are no bad foods, only bad diets’ will not become ‘there are no bad health policies, only bad
trade-related measures’.”
2.
Allais, Olivier & Bertail, P. & Nichele, Veronique, 2008. “The Effects of a "Fat Tax" on the Nutrient Intake
of French Households”, European Association of Agricultural Economists,2008 International Congress
Ghent, 2008, http://www.inra.fr/internet/Departements/ESR/publications/iss/pdf/iss10-03.pdf
"A "fat tax" would have ambiguous and extremely small effects.”
"A fat tax policy is unsuitable for substantially affecting the nutrient intake of French households.”
“Food policymakers need to keep in mind that a fat tax policy may have perverse effects by exacerbating
nutritional disparities among consumers".
3.
Amarasinghe, Anura & D’Souza, Gerard, 2010. Obesity Prevention: A Review of the Interactions and
Interventions, and some Policy Implications, West Virginia University, Regional Research Institute,
Research Paper 2010-2, 2010, http://www.rri.wvu.edu/pdffiles/wp2010-2.pdf 10
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FDII Presentation to the Joint Oireachtas Committee on Health and Children
11th October 2012
“Since fat taxes are regressive, tax incidence would be felt hardest by low income families.”
“Justification for a discriminatory excise tax on soft drinks is weak.”
4.
Bahl, Roy, 1998. Why Levy Discriminatory Excises on Soft Drinks?, International Studies Program, School
of Policy Studies, Georgia State University, Working Paper 98.3, 1998,
http://aysps.gsu.edu/isp/files/ispwp9803.pdf
"The economic case for taxing soft drinks is weak. [...] A middle or higher income country that resorts to
a tax list of discriminatory excises on consumption of specified products is taking a step back in the
development of their fiscal system and is postponing a more proper reform that would be in the better
interest of the country."
“The case for a discriminatory tax on soft drinks is very weak. At best the discriminatory taxation of soft
drinks is part of a "stopgap" program, usually designed to solve a short-term revenue problem.”
5.
Barclay, Alan W. & Brand-Miller, Jennie, 2011. "The Australian Paradox: A Substantial Decline in Sugars
Intake over the Same Timeframe that Overweight and Obesity Have Increased", Nutrients 3, 2011,
http://www.mdpi.com/2072-6643/3/4/491/pdf
“Our findings do not support the widely held belief that reducing the consumption of refined sugars, and
increasing the availability and preference for low-joule beverages, will help to reverse societal trends in
obesity.”
“The findings challenge the implicit assumption that taxes and other measures to reduce intake of soft
drinks will be an effective strategy in global efforts to reduce obesity.”
6.
Crowle, Jacqueline & Turner, Erin, 2010. Childhood Obesity: An Economic Perspective, Australian
Government, Productivity Commission Working Paper, Melbourne 2010,
http://www.pc.gov.au/__data/assets/pdf_file/0015/103308/childhood-obesity.pdf
“Bans or taxes on particular energy-dense nutrient-poor foods, for example, face design difficulties,
affect all consumers regardless of their weight status, and in the case of taxes, can have perverse
budgetary and health effects particularly for the neediest groups.”
“The considerable uncertainty about the causes of obesity suggests that hard interventions, such as
taxes or subsidies on specific goods and services, would be difficult to justify. Further, the practical
challenges of designing taxes on specific goods and services limit the likelihood of them being effective
in addressing obesity (and may lead to perverse outcomes).”
7.
Etilé, Fabrice, 2012. “La taxation nutritionnelle comme outil de santé publique : justifications et effets
attendus” (with English summary “Nutritional taxes as a policy instrument for public health: Rationales
and expected impact”, Cahiers de nutrition et de diététique 47.1, 2012,
http://www.sciencedirect.com/science/article/pii/S0007996011001982 11
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FDII Presentation to the Joint Oireachtas Committee on Health and Children
11th October 2012
“Consumers are able to substitute between many food products, and producers are free to change the
price and the quality of the supply; Hence, any taxation scheme may be defeated by market reactions.
The behavioural and health impact of a nutritional tax should thus be low, at least at conventional levels
of taxation (between 5 and 20%).”
8.
Fletcher, Jason M. & Frisvold, David E. & Tefft, Nathan, 2010. "The effects of soft drink taxes on child and
adolescent consumption and weight outcomes", Journal of Public Economics 94, 2010,
http://medicine.yale.edu/labs/fletcher/soda.pdf
"Soft drink taxes do not appear to have countered the rise in obesity prevalence because any reduction
in soft drink consumption has been offset by the consumption of other calories. Cast in this light, the
revenue generation and health benefits of soft drink taxes appear to be weaker than expected."
9.
Gelbach, Jonah B. & Klick, Jonathan & Stratmann, Thomas, 2007. Cheap Donuts and Expensive Broccoli:
The Effect of Relative Prices on Obesity, Social Science Research Network, Working Paper Series, 2007,
http://tigger.uic.edu/~nba/donuts.pdf
"The sensitivity of individuals to changes in relative food prices may not be sufficient to make fat taxes,
within plausible ranges, a viable tool to lower obesity".
10.
Hawkes, Corinna, 2012. "Food taxes: what type of evidence is available to inform policy development?",
Nutrition Bulletin 37, 2012, http://onlinelibrary.wiley.com/doi/10.1111/j.1467-3010.2011.01949.x/pdf
“In high-income countries consumption is not highly dependent on price and consumers are likely to be
more influenced by the prices of close substitutes.
“*…+ if we are talking about shifting consumer behaviour away from whole categories of foods or
nutrients, price changes would appear to have to be very large to have an effect and even then, the
results would be very much dependent on policy design.”
“What does this leave us with for evidence for policy? Well, it tells us that we do not really know how a
population would respond to a tax on foods.”
11.
Hespel, Véronique & Berthod-Wurmser, Marianne, 2008. Rapport sur la pertinence et la faisabilité d'une
taxation nutritionelle (Report on the pertinence and feasibility of a nutritional tax), République
Française, Inspection générale des Finances, Inspection générale des Affaires sociales, Paris 2008,
http://www.igf.finances.gouv.fr/gcp/webdav/site/igfinternet/shared/Nos_Rapports/documents/2008/T
axe_nutritionnelle.pdf
"The establishment of a tax for exclusively nutritional purposes would face a number of difficulties: Very
heavy administrative costs for companies and authorities, as well as legal, technical, economic 12
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FDII Presentation to the Joint Oireachtas Committee on Health and Children
11th October 2012
and social obstacles, especially in terms of justification. The mission repels this option and rather
recommends to go back to available fiscal measures" (translation from the French).
12.
Lacanilao, Ryan D. & Cash, Sean B. & Adamowicz, Wiktor L., 2011. "Heterogeneous Consumer Responses
to Snack Food Taxes and Warning Labels", Journal of Consumer Affairs 45.1, 2011,
http://onlinelibrary.wiley.com/doi/10.1111/j.1745-6606.2010.01194.x/pdf
"The low own-price elasticities found here provide support to the existing literature that suggests that a
tax on less healthy food products would not be an effective way to decrease consumption of these
products."
13.
Mattes, R.D. & Shikany, J.M & Kaiser, K.A. & Allison, D.B., 2011. "Nutritively sweetened beverage
consumption and body weight: a systematic review and meta-analysis of randomized experiments",
Obesity Reviews 12.5, 2011, http://www.coca-cola.com.sg/media/pdf/research-paper_obesity.pdf
"The current evidence does not demonstrate conclusively that NSB consumption has uniquely
contributed to obesity or that reducing NSB consumption will reduce BMI levels in general."
14.
OECD, 2010. Healthy Choices, OECD Health Ministerial Meeting, Paris, 7-8 October 2010, Session 2, Paris
2010, http://www.oecd.org/dataoecd/14/13/46098333.pdf
"[...] fiscal measures aimed specifically to change behavior are complex to design and enforce; their
impact may be unpredictable as the price elasticity of demand varies across individuals and population
groups; they can bear more heavily on low-income groups than on those with higher incomes, and
substitution effects are not always obvious".
OECD, 2010. Sassi, Franco. Obesity and the Economics of Prevention: Fit not Fat, OECD Publications,
Paris 2010,
http://www.oecd.org/document/31/0,3746,en_21571361_44701414_45999775_1_1_1_1,00.html
“The impact of the tax on government and supplier (e.g. food manufacturer) revenues will depend on
the elasticity of consumers’ demand for the taxed product”.
“Taxes on lifestyle commodities, or sin taxes, tend to be controversial. Critics perceive them as undue
interference with individual choice. Governments levying such taxes are sometimes seen as “profiting”
from unhealthy behaviours”.
“In addition, taxes on consumption are typically regressive, unless consumption is concentrated among
the wealthiest, which is certainly not the case for most potentially unhealthy lifestyle commodities, as
the consumption of these tends to be concentrated among the less well off. Therefore, tax payments
will weigh more heavily on the incomes of the most disadvantaged
34