Front of pack nutrition labelling for pre-packed foods - Cancer ...

Cancer Research UK submission to the FSA consultation on Front ofpack (FOP) nutrition labelling for pre-packed foods sold through retailoutlets in the UK3 rd November 2009Background informationCancer Research UK is the world’s largest independent organisation dedicated tocancer research; in 2007/2008 our total scientific spend was £333 million. Our visionis that ‘Together we will beat cancer’. We carry out world-class research to improveour understanding of cancer and to find out how to prevent, diagnose and treatdifferent types of the disease. One of our priorities is the reduction of cancerinequalities. We welcome the opportunity to respond to this inquiry.Cancer is a major cause of illness with more than 290,000 people diagnosed eachyear in the UK. It is also the biggest cause of death in the UK, accounting for morethan 1 in 4 deaths or 155,000 deaths in the UK each year. There are significantinequalities in cancer incidence, mortality and survival. The risk of being diagnosedwith certain types of cancer is greater among the most deprived groups. In addition,although cancer survival rates have been improving since the 1970s, the survival gapbetween the most and least affluent has been increasing.In the response below, we have focused our efforts where we feel our expertise isstrongest. We have therefore not answered question 3 as we feel that others arebetter placed to comment.General commentsClear and accurate food labelling can help people to make healthy dietary choicesmore easily and to that effect Cancer Research UK supports the use of front of packfood labelling, based on the Food Standards Agency’s recommended principles.The current FSA work provides a significant opportunity to create a single integratedlabelling scheme which will be helpful for consumers. We hope that the scheme willfulfil an additional role of further educating the public about the nutritional value offood products and how they contribute to a healthy diet.We are, however, particularly concerned about the list of food products it is proposedwould be excluded from the front of pack labelling scheme. Some of the productsincluded in the exemption list can be high in salt content, contain high levels ofsaturated fat or sugar. We would urge the FSA to reconsider the list of exemptionswith a view to including the current list in the FOP scheme to ensure that consumersare assisted with clear and comprehensive information to help inform healthierchoices.Question 1:

We welcome your views on the range of foods to which an integrated FOP labelshould be applied, including suggestions for a limited number of exemptions(paragraph 20).We are concerned about the list of exemptions contained on page 7 and 8 of theconsultation document and would welcome further information about some of thecategories. In particular we would welcome information about the definition of foodssold in packages with small surface areas. We are concerned that this couldpotentially include foods which are energy dense or contain a high salt content.We are also concerned that bacon and ham are included in the list of exemptions asthese foods can be high in salt content. There is a clear link between processed meatand bowel cancer. Some bacon and ham products are high in salt content andCancer Research UK recommends that they should not be included in theexemptions category.We are also concerned that some dairy products are included in the exemptionscategory as some yoghurts can be high in fat. Consumers have also stated that theyare particularly confused about the composition of yoghurt products as they cansometimes contain high levels of saturated fat and calories and also because someproducts are marketed and promoted as being good for digestive health.We would welcome further information about what would be included in the categoryentitled ‘fresh and minimally processed fruits’ and in particular there needs to be aclear definition of ‘minimally processed fruits’. Particular caution needs to beexercised around fruit juice drinks as these can sometimes contain high levels ofsugar. There is clear evidence about the links between sugary drinks and obesity andit is because of this that we would welcome further information about the types offood which would be included in this category.Question 2:We welcome your views on the proposal for including calories in an integratedFOP label (paragraph 27), and that interpretive elements should not beincluded.Obesity is the leading cancer risk factor for non smokers. We therefore believe thatevery effort should be taken to help the population prevent obesity and to managethe condition where necessary and we agree with the proposal for including caloriesin an integrated FOP label.Consumers seek and use calorie information about food products where it isavailable. The provision of information about calories can also help motivate people’sinterest if they are not currently aware of calorie values and this information shouldbe clear, consistent and understandable.We agree that interpretive elements should not be included as guideline dailyamounts as energy cannot apply to the broad range of consumers. For example,including interpretive elements of GDA for energy for adults on the front of breakfastcereals could potentially be confusing and misleading for other consumers of thattype of food such as children and young people.Question 4:Do you agree with the proposed approach to improve communication andunderstanding of saturated fats in an integrated FOP label (paragraph 34)? Ifnot why not?

Yes. It is important that awareness and education on saturated fat is clearlycommunicated and understood by the general public.Question 5:In light of EFSA’s recent opinion on the sugars GDA for nutrition labellingpurposes, we would welcome your views on the appropriate sugars GDA figurethat should be used on an integrated FOP label.High intake of sugar remains a major issue for the health of low income consumersand particularly young people of all ages as demonstrated in the Low Income Dietand Nutrition Survey. Guidance on the reduction of sugar consumption should beencouraged and it is important that the current sugar value used by the FSA is notliberalised as demonstrating any uncertainty could undermine FSA credibility. Theguidance should be for 50g in line with guidance for advice on “added sugar”.Question 6:We would welcome your views on the whether the salt thresholds for anintegrated FOP label should be revised and if so which of the approachesdiscussed above should be used:(a) changes to the per 100g criterion,(b) changes to the per portion criterion, or(c) both.We recommend that the salt thresholds should be revised moving the per 100gmedium/high boundary from >1.5g to >1g for salt. We would also recommend thatthe FOP label should maintain the 100g criterion to avoid confusing consumers andin line with promoting lowest salt content of foods.Question 7:The proposed advice on prominence and legibility based on the Agency’scurrent technical guidance can be found at Annex D. We welcome your viewson how this might be revised to maximise the visibility and legibility of anintegrated FOP label.If not included on the integrated label, energy should be displayed on the front ofpack. The guidelines on legibility and visibility should also apply to energy.Question 8:We welcome your views on how government and stakeholders could work inpartnership to raise consumer awareness and understanding of a singleintegrated FOP label (targeting those consumers that are not currently usingFOP labelling, and in particular C2DE’s, those aged over 65 years and familieswith children). We would welcome any information regarding initiatives oractivities that have been undertaken in this area.Cancer Research UK and Weight Concern have developed Ten Top Tips for ahealthy weight.Ten Top Tips is a programme that encourages people to make lifestyle changes totake in fewer calories through food and burn more calories through activity. FollowingTen Top Tips will help people to lose weight safely and avoid putting on more weight.The tips have been designed to fit into daily life and are based on the best scientificevidence.

The tips are designed to:• be simple and easy to follow• help people form healthier habits• cover physical activity and eating habits• make the most of the best available scientific evidenceThe tips are simple habits that everyone can permanently fit into their daily routines.Keeping up all ten tips in the long term will help people lose weight and keep it off.Some of the top ten tips include:1. Go reduced fat. Choose reduced fat versions of foods such as dairyproducts, spreads and salad dressings where you can. Use them sparingly assome can still be high in fat.2. Look at the labels. Be careful about food claims. Check the fat and sugarcontent on food labels when shopping and preparing food.3. Caution with your portions. Don’t heap food on your plate (exceptvegetables). Think twice before having second helpings.4. Think about your drinks. Choose water or sugar-free squashes.Unsweetened fruit juice contains natural sugar so limit it to 1 glass per day(200ml / 1/3 pint). Alcohol is high in calories; try to limit the amount you drink.5. Don’t forget your 5 a day. Eat at least five portions of fruit and vegetables aday (400g in total).The full list can be found here:http://info.cancerresearchuk.org/healthyliving/tentoptips/Cancer Research UK has also developed information on our website to assist peopleto understand labels and nutritional information on food packaging. Informationincludes nutritional information, misleading claims and the ingredients list and moreinformation can be found here:http://info.cancerresearchuk.org/healthyliving/dietandhealthyeating/lookatthelabels/We would be happy to provide any further information or detail as required. Pleasecontact Emily Arkell in the Policy Team at the Cancer Research UK Policy and PublicAffairs department at emily.arkell@cancer.org.uk.