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House of Commons
Environment, Food and Rural
Affairs Committee
Food information
Seventh Report of Session 2004–2005
Report, together with formal minutes, oral and
written evidence
Ordered by The House of Commons
to be printed 16 March 2005
HC 469
[Incorporating HC 690, Session 2003–2004]
Published on 30 March 2005
by authority of the House of Commons
London: The Stationery Office Limited
£24.50
Environment, Food and Rural Affairs Committee
The Environment, Food and Rural Affairs Committee is appointed by the House of Commons to
examine the expenditure, administration, and policy of the Department for Environment, Food and
Rural Affairs and its associated bodies.
Current membership
Mr Michael Jack (Conservative, Fylde) (Chairman)*
Ms Candy Atherton (Labour, Falmouth and Camborne)*
Mr Colin Breed (Liberal Democrat, South East Cornwall)
David Burnside (Ulster Unionist, South Antrim)
Mr David Drew (Labour, Stroud)*
Patrick Hall (Labour, Bedford)
Mr Mark Lazarowicz (Labour/Co-op, Edinburgh North and Leith)*
Mr David Lepper (Labour, Brighton Pavilion)
Mr Ian Liddell-Grainger (Conservative, Bridgwater)
Mr Austin Mitchell (Labour, Great Grimsby)*
Diana Organ (Labour, Forest of Dean)
Joan Ruddock (Labour, Lewisham Deptford)*
Mrs Gillian Shephard (Conservative, South West Norfolk)
Alan Simpson (Labour, Nottingham South)
David Taylor (Labour, North West Leicestershire)
Paddy Tipping (Labour, Sherwood)
Mr Bill Wiggin (Conservative, Leominster)*
*These Members were nominated as Members of the Sub-Committee on Food Information. Mr Mark
Lazarowizc was Chairman of the Sub-Committee.
Powers
The Committee is one of the departmental select committees, the powers of which are set out in
House of Commons Standing Orders, principally in SO No. 152. These are available on the Internet
via www.parliament.uk.
Publications
The reports and evidence of the Committee are published by The Stationery Office by Order of the
House. All publications of the Committee (including press notices) are on the Internet at
www.parliament.uk/efracom
A list of reports of the Committee in the present Parliament is at the back of this report.
Committee staff
The current staff of the Committee are Matthew Hamlyn (Clerk), Fiona McLean (Second Clerk), Dr
Antonia James and Jonathan Little (Committee Specialists), Marek Kubala (Inquiry Manager), Andy
Boyd (Committee Assistant) and Anne Woolhouse (Secretary).
Contacts
All correspondence should be addressed to the Clerk of the Environment, Food and Rural Affairs
Committee, House of Commons, 7 Millbank, London SW1P 3JA. The telephone number for general
enquiries is 020 7219 5774; the Committee’s e-mail address is: efracom@parliament.uk.
Food information
3
Contents
Report
Page
Summary
5
1
Introduction
7
2
Responsibility for food information policy within Government
8
Responsible bodies
Food Standards Agency
Department of Health
Department for Environment, Food and Rural Affairs
Department for Education and Skills
Department for Culture, Media and Sport
Department for Trade and Industry
Local government
UK’s representation at EU level
‘Joined-up’ government?
Our conclusions
3
Food safety and hygiene
Legal framework
International standards: Codex Alimentarius
Hazard Analysis Critical Control Points
Government’s role
Pesticides Residues Committee
Evidence received
Role of the FSA
Labelling for food safety purposes: allergen labelling
Our conclusions
4
Food labelling: prepacked foods
Legal framework
What information is currently required?
General information
Nutrition information
EU review of labelling requirements
What nutritional information should be required?
Current voluntary provision of information
Should provision of nutrition information be mandatory?
The need for contextual information
Nutrition signposting: a ‘traffic light’ system?
What other information should be required?
Means of production: ethical issues
Ingredient listing on alcohol
8
8
9
9
10
11
11
11
12
12
14
15
15
15
15
16
17
17
18
18
19
20
20
21
21
22
23
23
23
24
26
28
33
33
35
4
5
Food labelling: non-prepacked foods
What information should be required?
Non-prepacked food in the ‘eating out’ sector
Non-prepacked food in the retail sector
Our conclusions
6
Verifying food information: food assurance schemes
Legal requirements relating to farm assurance schemes
Evidence received
The British Farm Standard—the little red tractor
Our conclusions
7
Other sources of food information
Legal controls on what information is put before consumers
Consumer understanding and education
How well informed are consumers?
Who do consumers trust?
What is currently being done to inform and educate consumers?
What future plans does the Government have to inform and educate
consumers?
Our conclusions
36
37
37
39
39
41
41
42
44
46
47
47
47
47
48
48
50
50
Conclusions and recommendations
52
Table of legal instruments, directives and guidelines mentioned in this report
58
Formal minutes
60
Witnesses
61
List of written evidence
62
List of unprinted written evidence
63
Reports from the Committee since 2001
64
Food information
5
Summary
Food information policy is not simply an issue of regulation; it encompasses public health
initiatives, education within schools and advertising. Currently, responsibility for these
areas is divided between at least six different government departments and agencies. It is
not apparent to us that there is effective co-ordination between these bodies in respect of
government policy and initiatives about food information, both domestically and at EU
level. The Government should explicitly task Defra with lead responsibility for coordinating food information policy across both central and local government, and for
representing the position of the UK Government at EU level.
Government has a vital role to play in providing definitive guidance which assists
consumers to assess food safety risks. We commend the Food Standards Agency on the
work it has done towards providing clear advice to consumers about food safety issues.
However, we recommend that the Government undertake a speedy investigation into the
events which resulted in the illegal dye, Sudan 1, making its way into the UK food chain.
Extensive nutrition information should be mandatory on all prepacked foods, and the
Government should make the necessary legislative change a high priority matter for the
UK’s forthcoming presidency of the EU. Nutrition information should be presented in a
standard, tabular format and in plain English. Guideline daily amounts for energy
consumption should be included on all labels, and the inclusion of guideline daily amounts
for fat, sugars, and salt should be the rule, rather than the exception. Where feasible, the
same level of nutrition information should be given on food sold loose and food sold
prepacked for direct sale in supermarkets and other food shops. Currently, there are few or
no requirements for clear and meaningful labelling of such foods, and the Government
seems to be doing little to address this gaping hole in food labelling requirements.
We are strongly supportive of the introduction of a UK-wide system of front-of-label
nutrition signposting, to assist consumers in making healthier choices ‘at a glance’; speedy
action by the Government is required to introduce such a system. The traffic light system
has much to commend it but, whatever signposting system the Government decides to
adopt, the determining factor should be clarity, rather than comprehensiveness.
In terms of achieving improvement in nutrition labelling on a voluntary basis, we are
disappointed that major supermarket chains seem to be making little effort to influence
their suppliers of non own-brand products. We urge them to enter into a dialogue with
these suppliers to encourage them to introduce improved nutrition labelling, including
nutrition signposting.
Those who sell or otherwise provide food in the eating out sector must take responsibility
for providing healthy choices to their customers, and for highlighting those choices as
healthy. The Government should work with the eating out sector to develop a ‘green light
only’ nutrition signposting system to highlight healthy food choices.
Consumers should receive better information about ethical issues associated with food
production. Although the scope of legislating for compulsory provision of such
6
information is limited by WTO agreements, failure by the food industry to provide
consumers with further information about these matters could well be interpreted as a
failure to engage with the ethical implications of the industry’s activities. The Government
should ensure the central registration of food assurance schemes.
Consumers are often faced with a range of contradictory messages about nutrition and
diet, from a wide range of sources. In order to improve consumers’ knowledge and
understanding of nutrition and diet, a broader education campaign about these matters
is required, driven forward by both the Government and the food industry, working in
partnership with each other. If consumers are ever to trust messages about diet and
food, such messages must be presented in a coherent and authoritative manner. The
Government needs to provide the industry with a single agenda with a clear list of
priorities that both the Government and industry can work towards achieving. At the
same time, the food industry has a key role to play in raising consumer awareness about
nutrition and diet and in making healthier choices both available and attractive.
Food information
7
1 Introduction
1. In November 2003, we agreed to inquire into the ways in which messages about food are
communicated to consumers by food producers and retailers, and by Government and
others. We indicated that we would particularly consider how customers can be better
informed about foods’ nutritional content, safety, means of production (for example, whether
foods are organic or not, battery or free-range) and ethical considerations relevant to food,
such as whether good labour practices were used. In considering these matters, we agreed we
would look at the role of labelling, programmes of education, and other means of
communication, and at food information in the context of trade negotiations in the World
Trade Organisation (WTO).
2. We appointed a Sub-Committee to carry out the inquiry. The Sub-Committee was chaired
by Mr Mark Lazarowicz; its other members were Candy Atherton, Mr David Drew, Mr
Michael Jack, Mr Austin Mitchell, Joan Ruddock and Mr Bill Wiggin.
3. The Sub-Committee received 39 written memoranda and took oral evidence from: the
Institute of Food Research; the Consumers’ Association (now known as Which?); the Medical
Research Council’s Centre for Human Nutrition Research; Sustain; the National Farmers’
Union for England and Wales; Product Authentication Inspectorate; The Co-op; Tesco;
Asda; Whitbread Restaurants; McDonald’s; the Royal Agricultural College, the Food and
Drink Federation; the Trading Standards Institute; the Food Standards Agency and the
Minister for Food, Farming and Sustainable Energy, Lord Whitty of Camberwell, together
with Defra officials. We are grateful to all those who gave evidence or otherwise assisted with
our inquiry.
4. Issues relevant to food information have also been examined by the House of Commons
Health Committee in its report on Obesity, published in May 2004. Several of the
Committee’s conclusions are relevant to our present inquiry, and we refer to them in the
course of our report.1
1
Health Committee, Third Report of Session 2003–04, Obesity, HC 23–I
8
Food information
2 Responsibility for food information
policy within Government
5. Responsibility for food information policy and food regulation within the Government
sector is currently divided between a number of departments and agencies, principally Defra,
the Food Standards Agency (FSA) and the Department of Health. The FSA described the
division of responsibilities to us as follows:
The FSA has lead responsibility in Government for general food labelling rules and for
product-specific legislation on a number of specific foods. The Department of
Environment, Food and Rural Affairs and the relevant devolved Departments lead on
marketing standards, which often contain labelling measures, as well as on rules on
country of origin labelling for beef. The Department for Trade and Industry is the lead
Department for labelling rules on net quantity of prepacked foods.2
6. Some responsibility for food policy and regulation is also devolved to local government,
particularly in the area of enforcement.
Responsible bodies
7. The FSA is a statutory body, independent of Government, and is accountable to Parliament
through the health ministers. The Minister for Food, Farming and Sustainable Energy told us
that the FSA is responsible for “mandatory information provided by regulation in relation to
… food safety or nutritional content”.3 In the 2004 Spending Review, the Government
identified two roles for the FSA:
x
a “traditional” role of fulfilling “public health functions of reducing food-borne illnesses,
enforcing food law, and promoting best practice in the food industry”; and
x
a “newly-emphasised” role in “public dietary health improvement and the promotion of
accurate and informative labelling in order to facilitate consumer choice”.4
In carrying out these roles, the FSA produces guidelines and recommendations, rather than
instruments with legislative effect and, at official level, represents the UK Government on
food and safety standards in the European Union (EU).
8. The Minister for Food commented on the decision to make the FSA responsible to
Parliament via the health ministers, rather than the ministers for the then-Ministry of
Agriculture, Fisheries and Food (MAFF):
… it was felt at the time—and I think I would agree with this—that having the
department which was basically a production department, which was even more a
2
Ev 132, annex, para 1 [Food Standards Agency]
3
Q 625 [Defra]
4
HM Treasury, Spending Review 2004: New Public Spending Plans 2005-2008, 12 July 2004, chapter 8, para 8.9; available at
www.hm-treasury.gov.uk
Food information
9
production-focused department when it was MAFF, also responsible for the regulation
at the consumer end was a conflict of interest … it seems to me quite a consistent line
that the producer department and the main regulator ought probably to be separated.5
Department of Health
9. The Department of Health (DoH) has responsibilities relevant to food information which
are distinct from those discharged by the FSA. In the period 2005–08, the DoH has been set a
Public Service Agreement (PSA) target of “halting the year-on-year rise in obesity among
children under 11 by 2010 in the context of a broader strategy to tackle obesity in the
population as a whole.” This target is to be achieved jointly with the Department for
Education and Skills (DfES) and the Department for Culture, Media and Sport (DCMS).6
10. As part of its role in promoting healthy lifestyles, the DoH recently published a Public
Health White Paper.7 The White Paper discussed what can be done to assist consumers in
making healthy choices in a consumer society. The DoH is also leading a food and health
action plan intended “to help people in England improve their diets”.8 To achieve this plan,
the DoH states that it is “working across Government, with the food industry, and with other
stakeholders”.9 The FSA, Defra and the DfES are all involved with the action plan; Defra told
us that “improving consumer information” will be a key focus of the plan.10
11. The food and health action plan was published only recently by the DoH, on 9 March
2005.11 The plan had been in development since July 2003, when an initial consultation paper
was published.12 The plan is focused on nutrition: it sets out how the Government intends to
deliver the nutrition commitments contained in its recent Public Health White Paper and
other government actions on nutrition. The plan also forms part of the Government’s
farming and food strategy; in its response to Sir Don Curry’s Policy Commission on Farming
and Food, the Government undertook to produce such a plan.13
12. The Department for Environment, Food and Rural Affairs (Defra) describes its role in
food policy as acting as “sponsor department” for the UK food and drink manufacturing and
retailing industries, including the food services sector. The food industry’s trade association,
the Food and Drink Federation (FDF), described the industry as “the largest manufacturing
sector in the UK”.14 Defra’s focus in this role is on fostering and promoting greater
5
Q 656 [Defra]
6
HM Treasury, Public Service Agreements White Paper 2005–2008, 12 July 2004, chapter 3; available at www.hmtreasury.gov.uk
7
Department of Health, Choosing Health: making healthier choices easier, Cm 6374, November 2004, p 25
8
www.dh.gov.uk
9
www.dh.gov.uk
10
Ev 145 [Food Standards Agency] and ev 144 [Defra]
11
Department of Health, Choosing a better diet: a food and health action plan, 9 March 2005; available at www.dh.gov.uk.
12
A consultation document was published in July 2003: Department of Health, Food and health action plan: food and health
problem analysis for comment, 31 July 2003. A summary of consultation responses was published in December 2003. A
further consultation document was published in May 2004: Department of Health, Choosing Health? Choosing a Better
Diet: A consultation on priorities for a food and health action plan, 6 May 2004. All documents are available at
www.dh.gov.uk.
13
Defra, Policy Commission on the Future of Farming and Food, 2002; available at www.archive.cabinetoffice.gov.uk.
14
www.fdf.org.uk
10
Food information
competitiveness and removing obstacles to growth; it offers help to industry with marketing,
exporting and importing.15 In the period 2005–08, Defra has been set a PSA target to
“promote a sustainable, competitive and safe food supply chain which meets consumers’
requirements”.16 Defra is also the co-ordinating department for the public procurement of
food, and therefore influences the DfES, the DoH, the Prison Service and the armed forces,
amongst others, in this matter.17
13. At EU level, Defra leads for the UK Government on EU legislation regulating means of
production and production standards, and is responsible for the UK regulations
implementing the EU legislation. Examples include egg and poultry meat marketing
legislation, rules on origin labelling for fresh, chilled and frozen beef and veal and marketing
standards for fresh fruit and vegetables.18
14. When we asked the Minister for Food to identify who was responsible for food
information within Government, he described Defra’s responsibilities as being distinct from
the FSA’s responsibilities for information about food safety and nutritional content, in that
they relate to:
other methods of information about food including assurance standards, retailers’
information and other forms of information in which we [Defra], as sponsor ministry,
encourage the industry to provide as accurate and as detailed information as they
can…19
15. The Minister also defined Defra’s position as ‘sponsor’ of the food industry as meaning
that, rather than representing the industry’s views, it represented:
[the industry’s] long-term interest, which is a different thing from representing their
views. Their long-term interest is in ensuring they have got informed, healthy, longlived and understanding customers.20
Department for Education and Skills
16. As noted above, the Department for Education and Skills (DfES) shares with the DoH and
the DCMS the PSA target relating to obesity among children, because of its responsibility for
policy on school meals.21 Decisions about who should provide school lunches and what their
nutritional content should be are made by local education authorities; in the case of all
secondary schools and some primary schools, these decisions are delegated to the schools’
governing bodies, together with the necessary funding.22 Since 1 April 2001, all school lunches
15
www.defra.gov.uk
16
HM Treasury, 2004 Spending Review: Public Service Agreements 2005–2008, 12 July 2004, chapter 13; available at
www.hm-treasury.gov.uk
17
Q 631 [Defra]
18
Ev 145–146 [Defra]
19
Q 625 [Defra]
20
Q 637 [Defra]
21
22
Under section 512A of the Education Act 1996, as amended by section 116 of the School Standards and Framework Act
1998.
Food information
11
have been required to comply with minimum nutritional standards set by the Secretary of
State.23
Department for Culture, Media and Sport
17. The DCMS shares with the DoH and the DfES the PSA target relating to obesity among
children.24 The DCMS is responsible for increasing participation in sport by young people. It
also shares, with the Department for Trade and Industry, responsibility for the Office of
Communications (Ofcom), the independent regulator and competition authority for the
UK’s communications industries. On 1 November 2004, Ofcom contracted out responsibility
for television and radio advertising codes to the Advertising Standards Authority (ASA), the
body set up by the advertising industry to police the rules laid down in the advertising
codes.25
Department for Trade and Industry
18. The Department for Trade and Industry (DTI) is responsible for administering trading
standards legislation, which regulates matters including weights and measures, trade
descriptions and consumer protection.26
Local government
19. Much food legislation is enforced by local authorities, through their trading standards
officers and environmental health officers. Trading standards officers are required by law to
enforce 35 or so statutes; local authorities can choose to authorise their officers to enforce
another 30 or so statutes. Central government periodically issues codes of practice advising
local authorities on enforcement.
20. The Trading Standards Institute (TSI), which represents trading standards officers, told us
that, on average, each local authority undertakes four prosecutions per year. It felt that
authorities were probably deterred from bringing prosecutions by the difficult and timeconsuming nature of the legal process, such as the six-month time limit on obtaining
evidence, and by a lack of resources.27
21. The consumer interest group Sustain claimed that “most companies who break food
labelling laws are likely to get away with it” and called for improved enforcement of food
labelling law.28 Sustain described prosecutions for breaking food labelling laws as “extremely
rare” and suggested companies are “getting away with it” because “local authority trading
standards departments often do not have enough staff or money to take food companies
(often major multinational firms) to court.”29 Sustain stated that central government support
for food law enforcement has focused exclusively on food safety issues, such as fraud in the
23
The Education (Nutritional Standards for School Lunches) (England) Regulations 2000 (S.I. 2000/1777)
24
25
www.asa.org.uk
26
Including: the Weights and Measures Act 1985; the Trade Descriptions Act 1968; the Consumer Protection Act 1986; the
Consumer Credit Act 1974.
27
Qq 538, 542–544 [TSI]
28
Ev 41 [Sustain]
29
Ev 41 [Sustain]
12
Food information
meat trade, and called on the FSA to offer support and funding for prosecutions for breaches
of food labelling laws. Even where a court case is brought and won by a local authority,
Sustain considered that “penalties for the company are weak, with low fines and precious little
adverse publicity”.30 Sustain described a recent fine imposed on Nestlé by the courts for an
illegal medicinal claim as “derisory … less than Nestlé’s paperclip budget probably”.31
UK’s representation at EU level
22. Given the number of government departments which share responsibility for food
information policy and food regulation, we sought clarity from the Minister for Food about
how the views of the UK Government on these matters are represented at EU level. The
Minister described for us how the UK Government would respond to a Commission
proposal to change the EU position on food labelling regulation. The FSA would be
responsible for contact with the relevant Commission officials and would lead consultation
across government departments, including Defra, in order to gain a cross-departmental
view.32 Once a consensus position had “hopefully” been reached, the FSA would produce a
detailed brief based on that position.
23. When the Commission proposal came to be debated at ministerial level, however, it
would be Defra ministers who would take the lead in negotiations, despite the fact that the
FSA is responsible to Parliament through the DoH ministers. This is because, at EU level,
food labelling matters are dealt with in the Agriculture Council.33 The views of the UK
Government would therefore be represented at the Council by the Secretary of State for
Environment, Food and Rural Affairs, on the basis of the brief prepared by the FSA.34
‘Joined-up’ government?
24. The FSA told us that it has concordats in place with both the Department of Health and
Defra, setting out the division of responsibilities between each body.35 Despite this, a number
of witnesses commented on the apparent lack of ‘joined-up’ government in the area of food
information policy and enforcement. The FDF claimed “a lack of clarity, a lack of joined-up
government” and commented that “the roles of the FSA and the DoH are sometimes difficult
for manufacturers, and indeed other stakeholders up and down the food chain, to unpick”.36
The FDF said that it had “taken the view that both organisations are arms of government and
that we must do our very best to not pick a path between them but to engage fully and
completely with both operations”.37
25. Food retailers echoed the FDF’s comments. Asda said that the division of responsibilities
within Government sometimes caused it “real problems”, and considered that:
30
Ev 41 [Sustain]
31
Qq 215–216 [Sustain]
32
Qq 659 and 662 [Defra]
33
Q 660 [Defra]
34
Qq 661 and 665 [Defra]
35
Q 589 [Food Standards Agency]
36
Q 523 [Food and Drink Federation]
37
Food information
13
… it would be really helpful if we could have a completely joined-up agenda. I think
there are lots of different parties. It is a very complex issue … a single agenda with a
clear list of priorities that we all work towards would be the most helpful, from one
source.38
Whitbread called on the Government to demonstrate a better understanding of the food
sector, and suggested that it did not properly understand the needs of the food services sector
in particular:
… a more joined-up approach would be helpful but, from our perspective, there is a
more fundamental issue in that there is not sufficiency of understanding of the
difference between the food service sectors and the other parts of the food chain: the
producers and the retailers. So, a better start point for us—and we spend some time
trying to achieve this—is to educate … government departments, [the] FSA and others
about what our industry is. Everybody experiences it but they do not understand it.39
26. McDonald’s suggested that, from an industry perspective at least, food policy in Scotland
appeared more ‘joined up’ than that in England and Wales:
… north of the border … we have found there are fewer players and there is really quite
good co-ordination through the Scottish food tsar which has made the job a lot easier.40
The “food tsar” referred to is the Scottish Food and Health Co-ordinator, employed by the
Scottish Executive’s Health Department. The post is currently filled by a dietician.
27. Witnesses outside the food industry also identified a lack of co-ordination. The TSI
commented that it had “quite a few masters at central government level and I think
sometimes there is confusion and maybe there is not the joined up element which we would
like”.41 The lobby group Sustain described co-ordination of food policy across government as
“a complete dog’s breakfast” and commented: “the Department of Health and Food
Standards Agency fight. Defra does not really get involved most of the time. DfES is too busy
with other stuff.”42
28. The Medical Research Council’s Resource Centre for Human Nutrition Research (HNR)
has been involved in consultations on food information schemes initiated through the DoH,
the FSA and the EU. On the basis of this experience, Dr Susan Jebb of the HNR commented
that:
… there is too much fragmentation in government action in relation to food, that there
is a lack of joined up initiatives across a whole range of different areas, that there are
competing priorities coming from different departments and that makes it difficult for
everybody: for scientists, for the food industry, for consumers, for anybody to know
quite where they are.43
38
Qq 335 and 336 [Asda]
39
Q 429 [Whitbread Restaurants]
40
Q 473 [McDonald’s]
41
Q 560 [Trading Standards Institute]
42
Q 199 [Sustain]
43
Q 169 [Human Nutrition Research]
14
Food information
29. A majority of respondents to the DoH’s recent consultation on developing a food and
health action plan also called for improved co-ordination. The Department’s summary of
consultation responses stated that a majority believed that “better co-ordination between
government departments, agencies, sectors and organisations was necessary, with one agency
taking the lead role, and new resources.”44
Our conclusions
30. We support the existing separation within government of the producer department—
Defra—from the main regulator—the Food Standards Agency. However, food
information policy is not simply an issue of regulation; in particular, it encompasses
public health initiatives, education within schools and advertising. At present, the main
areas of responsibility are divided between the FSA, the Department of Health and Defra,
and other responsibilities fall to the Department for Education and Skills, the
Department for Culture, Media and Sport and the Department for Trade and Industry. It
is not apparent to us that there is effective co-ordination between all these different
players of government policy and initiatives in the field of food information, both
domestically and at EU level.
31. We recommend that the Government explicitly task one government department with
lead responsibility for co-ordinating food information policy across both central and local
government, and for representing the position of the UK Government at EU level. We
consider that Defra would be the most suitable department to assume this role. We also
recommend that Defra assume joint responsibility for achieving the Public Service
Agreement target of “halting the year-on-year rise in obesity among children under 11 by
2010 in the context of a broader strategy to tackle obesity in the population as a whole”,
alongside those departments already responsible for achieving the target (the DoH, the
DfES and the DCMS).
32. We were concerned to hear suggestions that local authorities are being deterred from
taking prosecutions for breaches of food law, in part due to a lack of resources, and that
breaches of food labelling law are not being pursued. We recommend that the Government
investigate whether it is indeed the case that local authorities are being deterred from
taking prosecutions for breaches of food law, particularly food labelling law, and, if so,
that it establish the reasons why. The Government must ensure that local authorities are
sufficiently well-resourced to be able to take prosecutions against food manufacturers and
retailers, whose legal budgets are of a size that does not prevent them from fully using the
law to defend their interests.
44
www.dh.gov.uk
Food information
15
3 Food safety and hygiene
33. The provision of safe and fit food is something which we tend to take for granted in a
modern society. However, as recent events in relation to the discovery of an illegal dye—
Sudan 1—in chilli powder have demonstrated, consumers remain susceptible to large-scale
public health ‘scares’.
Legal framework
34. The key piece of legislation in ensuring safe food is the Food Safety Act 1990, which sets
out the fundamental principles of the law in this area. The Act makes it an offence to sell or
possess for sale food that does not comply with food safety requirements, and to render food
injurious to health.45 Secondary legislation made under the Act provides detail on matters
such as the chemical or microbiological safety of food, food quality, food labelling and
advertising.
35. From 1 January 2006, a ‘package’ of new EU food hygiene legislation will come into effect,
intended to modernise and consolidate existing EU legislation.46 The legislation is intended to
introduce a ‘farm to fork’ approach to food safety by including primary production, such as
farming, in food hygiene legislation for the first time. The FSA states that the UK supported
the introduction of the new legislation and has argued for some time that the current
legislation, some of which is now 40 years old, is inconsistent and often difficult to enforce.47
International standards: Codex Alimentarius
36. The Codex Alimentarius Commission is a joint body of the World Health Organisation
and the Food and Agriculture Organisation, both United Nations bodies.48 It sets
international standards with the purpose of protecting public health in respect of food and
agricultural products, and also of facilitating fair practices in the food trade. Standards are
developed through consensus, which means that decision-making can be very slow. The
Codex Alimentarius is the series of food standards and related texts produced by the
Commission, and provides reference standards for the WTO in the context of settling trade
disputes.
Hazard Analysis Critical Control Points
37. The Hazard Analysis Critical Control Points (HACCP) system of guidelines was devised
30 years ago and has become the universally recognised and accepted method for food safety
assurance. The system aims to reduce food-borne disease through the application of a
45
Sections 7 and 8
46
Regulation 852/2004 on the hygiene of foodstuffs; Regulation 853/2004 laying down specific hygiene rules for food of
animal origin; Regulation 854/2004 laying down specific rules for the organisation of official controls on products of
animal origin intended for human consumption; Directive 2004/41 repealing certain directives concerning food hygiene
and health conditions for the production and placing on the market of certain products of animal origin intended for
human consumption and amending Council Directives 89/662 and 92/118 and amending Decision 95/408
47
www.food.gov.uk/foodindustry
48
www.codexalimentarius.net
16
Food information
systematic approach to hazard and risk analysis and grew out of growing public concerns
about food safety from public health authorities, the food industry and consumers.49
38. In 1993 the guidelines for the application of HACCP were adopted by the Codex
Commission. The Codex Code on General Principles of Food Hygiene was revised to include
recommendations for the application of the Codex HACCP Guidelines. In the EU and in
most developed countries, the HACCP system is widely regarded as being crucial to the
management of food safety and, in turn, consumer protection. The FSA advocates the use of
the HACCP guidelines as the most effective way for businesses to ensure consumer
protection.
Government’s role
39. The FSA is primarily responsible for overseeing food safety in the UK, although any
proceedings enforcing food safety legislation must be brought by local authorities, rather than
the FSA. The FSA describes itself as an “independent food safety watchdog”: between 2001
and 2006, one of its key aims is to reduce foodborne illness by 20% by improving food safety
right through the food chain.50 The FSA is now cited by consumers as the top “spontaneous”
source of information about food standards and safety, an increase from 8% in 2000 to 20%
in 2003.51
40. The recent alert caused by the presence of Sudan 1 in a batch of chilli powder provided a
helpful demonstration of the role played by the FSA in such circumstances. On 18 February,
the FSA advised people not to eat foods that had been inadvertently contaminated with an
illegal dye, known as Sudan 1. The dye was found in a batch of chilli powder used by a food
manufacturer, Premier Foods, to make a Worcester sauce; the sauce had then been used as an
ingredient in other food products.52 A very significant number of products from a wide range
of sources was affected—as at 1 March, 474 products from approximately 50 different
manufacturers or suppliers.
41. Premier Foods notified the FSA that Sudan 1 had been detected in a sample of Worcester
sauce on 7 February 2005, and provided the FSA with a list of more than 160 Premier Foods’
customers who had bought the affected products. The FSA then met twice with food industry
representatives in two days, in order to require full disclosure by companies of their affected
products, their removal from sale and appropriate publicity to inform consumers. Following
the receipt of detailed information about the products affected, the FSA issued a press notice
notifying the public of the problem and posted a list of affected products on its website. The
Agency set a deadline of 24 February for the removal from sale of all contaminated products,
and continued to provide updates by way of press notices and additions to the list of affected
products.
42. In the past, the FSA has set up telephone help lines to answer consumer concerns about,
for example, the potential problems of contamination of milk sold at the farm gate during the
49
See www.who.int/foodsafety
50
www.food.gov.uk/aboutus/
51
Ev 129, para 8 [Food Standards Agency]
52
“Action taken to remove illegal dye found in wide range of foods on sale in UK”, FSA press release, 18 February 2005;
available at www.food.gov.uk
Food information
17
foot and mouth crisis and contamination of sealed jars of baby foods by semicarbazide.53
Information and advice about food safety issues is available to consumers at the FSA’s
website; advice about food handling and preparation is available on the FSA’s “eatwell”
website.54
Pesticides Residues Committee
43. Since the 1970s the Government has had a programme of pesticide residues surveillance
in food and drink, as part of statutory controls relating to pesticide approval. As of 2000 this
has been overseen by the Pesticide Residues Committee, an independent non-departmental
government body.55 The committee undertakes a programme of ‘rolling surveys’ which
involves sampling foods, mostly from retail outlets, and testing them for residues.56
Evidence received
44. The British Retail Consortium (BRC), which represents the UK retail industry, suggested
to us that food safety is not a significant problem in the UK: “UK legislation is quite clear—all
marketed food that is properly processed, stored and prepared is safe for general
consumption”.57 The FSA told us that “most food safety risks should be controlled during
food production” and pointed to the risk that arises in the domestic environment, where
“inappropriate preparation and storage practice … can introduce significant risk”.58
45. Which? (formerly the Consumers’ Association) was less convinced of the lack of risk
attached to processed food, arguing that, while ideally foods should not be on sale if they are
unsafe, in practice it is impossible to ensure that foods are completely risk-free.59 Dr Richard
Baines, of the Royal Agricultural College, submitted that there was a lack of regulation of food
hygiene matters in the UK, in that although “imported raw agricultural products will be
subject to regulatory surveillance … home-grown produce is largely unregulated in terms of
food hygiene!” 60
46. Whilst food safety risks are capable of regulation in the public sphere, risks also arise in
respect of food hygiene in the home, an area which is not readily capable of regulation. The
Institute of Food Research (IFR), a research facility sponsored by the Biotechnology and
Biological Sciences Research Council, told us that, because consumers tend to demonstrate
more concern about those risks which they perceive to be beyond their control, they may
ignore microbiological risks in the kitchen, on the basis that they are in control of such risks.61
The IFR commented that a social climate in which, in general, less time is being spent by
consumers in purchasing and preparing raw foods may also encourage an increased
expectation that foods, as bought, should be completely safe. It considered that such
53
Ev 131, para 23 [Food Standards Agency]: the FSA told us that, in each case, fewer than 100 telephone calls were received.
54
www.food.gov.uk and www.eatwell.gov.uk
55
Ev 145 [Defra]
56
www.prc-uk.org
57
Ev 176, para 21 [British Retail Consortium]
58
59
Ev 13, para 11 [Which?] (At the time, of taking evidence, Which? was known as the Consumers’ Association.)
60
Ev 105, paras 2.5 and 2.6 [Dr Richard Baines]
61
Ev 1, para 2 [Institute of Food Research]
18
Food information
consumer attitudes have implications for safety labelling on foods such as, for example,
“chilled, ready-to-eat foods”.62
Role of the FSA
47. Which? welcomed the FSA’s general approach to communicating risk to consumers in
specific cases, such as the risk that baby food could be contaminated by semicarbazide.
Although the European Food Safety Authority had not considered the risk to be significant
enough to advise consumers to change their eating habits, the FSA had nevertheless made
information available to consumers, including advice about how consumers could prepare
baby food at home.63 On the other hand, Which? believed that government advice could be
clearer in some situations. For example, Which? considered that it was still unclear whether
consumers should avoid eating more than one portion of oily fish a week on average, in light
of concerns about high levels of dioxins and PCBs in such fish, on the one hand, and publicity
about the potential health benefits of eating oily fish, on the other.64 The FSA has
subsequently produced more definitive advice about this issue.65
Labelling for food safety purposes: allergen labelling
48. In the context of food safety, the IFR described precautionary food allergen labelling as a
“critical issue” because of the “potentially fatal consequences” for susceptible individuals of
inadequate labelling.66 We received some suggestions that allergen labelling is not as helpful
as it might be. The General Consumer Council of Northern Ireland called for a “consistent
approach to devices that draw attention to allergens”.67 Sustain criticised the “defensive use”
of warnings such as May contain nuts on a wide range of products as being unhelpful to
people with a nut allergy.68
49. Subsequent to our concluding taking evidence on this inquiry, the law regulating allergen
labelling has been strengthened. The relevant requirements are specified in the Food
Labelling (Amendment) (England) (No. 2) Regulations 2004, which implement European
Directive 2003/89/EC and came into force on 26 November 2004.69 From 25 November 2005,
products that do not comply with the new rules will be prohibited from sale.70 The 2004
Regulations insert a new schedule into the Food Labelling Regulations 1996—Schedule
AA1—which lists 12 ingredients known to cause allergies or intolerances. These include
cereals containing gluten, crustaceans, fish, eggs, peanuts, soybeans, milk, nuts, celery,
mustard, sesame seeds and sulphur dioxide or sulphites at specified levels.
50. The Regulations require that the labelling on any pre-packed food which contains any of
the ingredients listed in Schedule AA1 must contain a clear reference to the Schedule AA1
62
63
Ev 13-14, para 12 [Which?]
64
Ev 14, para 13 [Which?]
65
www.food.gov.uk/news/newsarchive/2004/jun/oilyfishwebcast
66
67
Ev 193 [General Consumer Council for Northern Ireland]
68
Ev 40 [Sustain]
69
Directive 2003/89/EC of the European Parliament and the Council of 10 November 2003, which amended Directive
2000/13/EC as regards indication of ingredients present in foodstuffs.
70
Although products that have been labelled before that date may be sold while stocks last.
Food information
19
name—that is, the commonly used name. This requirement does not apply to food sold
loose—non-prepacked—or food sold pre-packed for direct sale: the FSA states that it is
“exploring options” for ensuring that the consumer is still provided with adequate
information in such cases.71 The Regulations do not apply to the use of ‘may contain’
warnings about nuts, because they apply only where the Schedule AA1 ingredients have
deliberately been added to the food. The FSA states that it is considering how best to
encourage provision of clearer and more helpful information for consumers with food
allergies in such cases and will consult on this “in due course”.72
Our conclusions
51. Consumers are often faced with a range of conflicting messages about food safety issues,
from the media and other sources, without being provided with sufficient information and
context to enable them to assess the risk involved. Government has a vital role to play in
providing definitive guidance which assists consumers to assess food safety risks. We
commend the Food Standards Agency on the work it has done, since its establishment in
2000, towards providing clear advice to consumers about food safety issues. We also
congratulate the Agency on its initiative in launching a website providing information
about food hygiene and preparation.
52. Clear and helpful labelling of allergens is a particularly crucial aspect of food safety. The
defensive use of allergen warnings risks restricting consumer choice unnecessarily, and even
undermining valid warnings—the ‘boy who cried wolf’ effect. We welcome recent legislation
improving allergen labelling requirements. However, the new legislation applies only to
allergens which have been deliberately added to food: labelling of foods which may
inadvertently contain allergens remains unregulated. We recommend that the
Government move quickly to consider how this legislation can be supplemented to
regulate the defensive use of allergen warnings, so that consumers with food allergies are
provided with clear and helpful allergen information. The Government should also
ensure that proper channels of communication are in place between the food industry and
medical scientists to allow for the effective flow of information about the latest scientific
findings on allergies.
53. We were unable, in the time available, to take evidence about the recent discovery that an
illegal and potentially carcinogenic dye, Sudan 1, had made its way into the food chain, and
therefore cannot draw any substantive conclusions about the Government’s role in these
events. Nevertheless, we have noted the concern that, although the affected products were
withdrawn from sale, the adulteration of chilli powder may have been going on undetected
for several years. We are also somewhat surprised that it took the Italian authorities to detect
the presence of Sudan 1 in a product manufactured in the UK, although we note that the FSA
had asked the industry to ensure that chilli products imported prior to July 2003 were not
contaminated with Sudan 1.73 The wide-spread nature of the contamination has
demonstrated both the complexity of modern food supply chains and the apparently limited
71
www.food.gov.uk/foodlabelling/; see part 5 of this report.
72
www.food.gov.uk/foodlabelling/
73
The contaminated batch of chilli powder dated from 2002, prior to the FSA’s commencement in May 2003 of a random
sampling programme testing for the presence of Sudan 1 in chilli products:
www.food.gov.uk/news/newsarchive/2005/feb/sudanlist#h_5
20
Food information
sources of ingredients available to food manufacturers, as the same Worcester sauce was used
in hundreds of processed foods. We recommend that the Government undertake a speedy
investigation into the events which resulted in the illegal dye, Sudan 1, making its way
into the UK food chain. We are particularly concerned that the Government should
establish the length of time for which the adulteration of chilli powder is likely to have
gone undetected and why UK authorities did not detect this adulteration in a product
used so extensively in UK food processing. The Government and the FSA should also
carry out work to determine the best way of communicating with the public about
questions relating to the degree of risk actually associated with issues like Sudan 1.
4 Food labelling: prepacked foods
54. One of the most important sources for consumers of information about food is the
information contained on food packaging. In a FSA survey, conducted in 2003, 78% of
consumers said that they read food labels at least occasionally—of this 78%, 31% said they
always read food labels, 26% usually and 21% occasionally.74 A report by IGD, a charity
carrying out research for the food and grocery industry, found that 34% of consumers
identified clearer food labelling as the main way in which the food industry could help them
to make healthier choices.75 Different legal requirements apply to prepacked food and nonprepacked food. We deal with prepacked food in this part and non-prepacked food in the
following part.
Legal framework
55. The 1990 Act again provides the legal framework under which food labelling law is made
in the UK. It also creates an offence of falsely or misleadingly describing or presenting food.76
Detailed requirements about what information must be provided on food labels are set out in
the Food Labelling Regulations 1996 (the 1996 Regulations), which regulate the labelling,
presentation and advertising of food to the final consumer. However, because regulation of
food labelling is an area of EU competence, the 1996 Regulations primarily implement the
relevant EU directives.77
56. The main directive is the Council Directive on the Labelling of Foodstuffs to be delivered
to the Consumer 2000 (the 2000 Directive).78 The 2000 Directive regulates information
provided to the consumer on the composition of the product, the manufacturer, the method
of storage and preparation. Producers and manufacturers may choose to provide additional
information, provided that it is accurate and not misleading. There is no requirement to
apply the Directive to products exported outside the EU.
74
75
IGD, Consumer Watch, June 2003; cited in Department of Health, Choosing a better diet: a food and health action plan, 9
March 2005, p 13
76
Section 15(1)
77
Council Directives 79/112/EEC, 89/398/EEC, 90/496/EEC and 2000/13/EC; Commission Directives 87/250/EEC, 94/54/EC and
2001/101/EC
78
Council Directive 2000/13/EC
Food information
21
57. In July 2003, the European Commission published a proposal for a European regulation
on nutrition and health claims made on foods.79 The proposed regulation would control
nutrition and health claims made in the labelling, presentation and advertising of foods
delivered to the final consumer, including foods supplied to restaurants, hospitals, schools,
canteens and similar mass caterers. In addition to ‘traditional’ nutrients such as calorific
value, protein, carbohydrate, fat, fibre, sodium, vitamins and minerals, the regulation would
cover other substances with a nutritional or physiological effect, such as antioxidants and
probiotic bacteria. The regulation would prevent the making of vague and unverifiable health
claims—for example, claims that a drink “cleanses and refreshes your body, your soul” or that
a fruit and seed bar will “help you stay on top of a busy life”, both found on products
currently sold in the UK.80 We support the European Commission’s draft regulation on
nutrition and health claims made on foods, and trust that the UK Government will do all
it can to facilitate the speedy implementation of the draft regulation.
58. In the international legal context, the World Trade Organisation’s Agreement on
Technical Barriers to Trade (the TBT Agreement) is relevant to food label regulation
established for reasons other than to protect the life or health of people, animals, or plants.
Regulation established to protect the life or health of people, animals, or plants is covered by
the WTO’s Agreement on the Application of Sanitary and Phytosanitary Measures (the SPM
Agreement). Article 2 of the TBT Agreement provides that regulation is illegal if it restricts
international trade more than is “necessary to fulfil a legitimate objective, taking account of
the risks non-fulfilment [of that objective] would create.” Article 2 applies even if the
regulation does not treat imports any differently from domestic products. Article 2 of the
SPM Agreement provides that regulation is illegal if it is maintained “without sufficient
scientific evidence”.
General information
59. The 1996 Regulations define prepacked food as food packaged in such a way that it
cannot be altered without interfering with the packaging and which is ready for delivery to
the ultimate consumer or to a catering establishment.81 All prepacked food must be marked
or labelled with:
x
the name of the food
x
a list of ingredients (although some foods, such as certain fruits, vegetables and dairy
products, are exempt from this requirement)82
x
the appropriate ‘best before’ or ‘use-by’ date
79
COM [2003] 424; the proposal is currently awaiting the opinion of the European Parliament. The draft regulation was
debated in European Standing Committee C in May 2004; the Committee supported the Government’s view that the
measure would promote informed consumer choice and facilitate intra-Community trade.
80
Which? briefing, ‘The Hidden Truth? Health and Nutrition Claims’, January 2005, p 6
81
“Prepacked” food is defined in regulation 2
82
Regulation 18 of the Food Labelling Regulations 1996 (the 1996 Regulations)
22
Food information
x
any special storage conditions or conditions of use (for example, “once opened, keep
refrigerated and consume within 3 days” or “shake well before use”)
x
the name and address of the manufacturer or packer or of a seller
and in certain cases:
x
particulars of the place of origin of the food
x
instructions for use, if it would be difficult to make appropriate use of the food without
them.83
60. The 1996 Regulations also set out other, more detailed, requirements, many of which
apply only to specific foods.84 For example, there are additional labelling requirements for
food sold in vending machines, raw milk and food containing sweeteners, aspartame or
polyols.85 Additional information can be given on food on a voluntary basis, provided that the
information is true and not misleading. Under the Food Safety Act 1990, it is an offence for
anyone to describe food in a way which is false, or likely to mislead as to its nature, substance
or quality.86
61. Particulars of the place (not necessarily the country) of origin or provenance of a food
must be shown if failure to give such information might mislead a purchaser to a material
degree as to the true origin of the food.87 “Place of origin” means the place in which a food last
underwent a substantial change.88 The FSA’s guidelines on the 1996 Regulations give the
example of olive oil pressed in Italy from olives grown in Greece. This could be described as
“produced in Italy” or “made in Italy”, provided that the indication or other information
given on the label did not imply that the olives themselves were Italian.89
62. Following a recent amendment to the 2000 Directive, it is obligatory to show all
ingredients on the label.90 Previously, the so-called ‘25% rule’ had meant that it was not
obligatory to label the components of any compound ingredients that made up less than 25%
of the final product.
Nutrition information
63. Labelling on prepacked foods is not required to carry nutrition information except where
a nutritional or health claim is made or where a food is intended for a particular nutritional
use. What constitutes a nutritional claim is defined in Schedule 6 to the 1996 Regulations;
examples would include claims such as “low fat”, “high fibre” and “low calorie”. Where
nutritional labelling is required, or where it is provided voluntarily, it must be given in one of
83
Regulation 5 of the 1996 Regulations
84
Guidance notes on the 1996 Regulations are available at www.foodstandards.gov.uk/foodindustry
85
Regulations 29, 31 and 34 of the 1996 Regulations
86
Section 15
87
Regulation 5(f) of the 1996 Regulations
88
Section 36 of the Trade Descriptions Act 1968
89
Guidance notes on labelling, available at www.foodstandards.gov.uk
90
Directive 2003/89/EC of the European Parliament and of the Council of 10 November 2003 amending Directive 2000/13/EC
as regards indication of the ingredients present in foodstuffs
Food information
23
two specified formats, known as a ‘group 1’ or a ‘group 2’ declaration. A declaration must be
given for any nutrient about which a claim has been made.
64. A ‘group 1 declaration’ on a label—also known as the ‘big four’— must state values for the
food’s energy, protein, carbohydrate and fat content. A ‘group 2 declaration’—also known as
the ‘4 + 4’ or ‘big eight’—must state the big four plus values for sodium and fibre content plus:
x
what proportion of the carbohydrate is sugars, and
x
what proportion of the fat is saturated fat.
All values must be given in grams provided per 100 grams or 100 millilitres of the food in
question, except for energy which must be expressed in both kilojoules and calories. An
additional ‘per serving’ listing may also be given.
65. The Government recommends that a group 2 declaration is given on all foods, on a
voluntary basis, because a group 2 declaration includes information on the key health-related
nutrients.91
EU review of labelling requirements
66. The European Commission has announced that it intends to review community
legislation on labelling in order to streamline current labelling legislation. The expected
completion date is 2010. The Commission has indicated that it will produce a discussion
document setting out its initial ideas later this year. The FSA has indicated that it intends to
raise with the Commission for inclusion in the discussion paper the need for:
x
improved label clarity
x
a review of the current exemptions from listing certain additives92
x
full ingredient listing on alcoholic drinks, and
x
clearer rules on origin labelling, to prevent misleading labelling where the origin of the
product and its primary ingredients differ, and more mandatory origin information,
especially on meat.93
What nutritional information should be required?
Current voluntary provision of information
67. The FDF estimated that 80% of pre-packaged, processed foodstuffs manufactured in the
UK carry nutrition labelling on the packaging, many of them on a voluntary basis.94 The FDF
described this as “a high level of information provision” and stated that there were sound
reasons why some packs cannot carry nutrition information, such as the small size of the
91
Government guidance notes on nutritional labelling, p 3: available at www.foodstandards.gov.uk/foodindustry
92
That is, additives whose presence in the food is due solely to the fact that they are contained in an ingredient of the food,
if they serve no significant technological function in the finished product, and additives used solely as a processing aid.
93
www.food.gov.uk/foodindustry/Consultations
94
Ev 113, para 7 [Food and Drink Federation]
24
Food information
pack.95 Which? estimated that about 70% of products carried nutrition labelling.96 Both
Which? and the TSI believed that, of the products that do not carry nutrition information,
many tended to be high in fat, sugar and salt.97 Which? agreed with the proposition that a lack
of nutrition labelling may well indicate that a product has “something to hide”.98
Should provision of nutrition information be mandatory?
68. The FSA indicated to us that it supports the mandatory provision of nutrition
information on all foods.99 It told us that its consumer research has indicated that 64% of
consumers look for nutrition information on labels and that “people are becoming
increasingly interested in healthier choices and they are looking for an easier format to use for
nutrition information on labels”.100 In its recent Public Health White Paper, the Government
undertook to “press vigorously” for progress before and during the UK presidency of the EU
(from July to December 2005) to simplify nutrition labelling and make it mandatory on
packaged foods.101
69. Consumer interest groups supported the mandatory provision of nutrition information
on labels. Which? would like to see compulsory nutrition labelling of the ‘big eight’ on all prepackaged foods, put in “a very clear format that is easy to understand, so consumers know
instantly from one product to another and would be able to make comparisons in order to
make an informed choice”.102 Which? referred to its own research, showing that, “on the
whole”, people think nutrition labelling should be provided, in a consistent way.103 Sustain
stated that surveys of consumers had repeatedly shown that “citizens want a great deal of
information about the food they eat, and find current labelling information inadequate,
almost impossible to understand and frequently illegible”.104
70. The FDF preferred to retain a voluntary approach to nutrition labelling, with the use of a
standard format where nutrition information is given, and emphasised that the “primary role
of the food label is to provide key information, not to act as a means of education”.105 It
considered that, if nutrition labelling were to be made compulsory, then some exemptions—
for example, in respect of small packs—would be necessary, and submitted that “the more
additional information you put on a food label, the more you sacrifice clarity”.106 The British
Soft Drinks Association described existing legal requirements as “not necessarily appropriate
for drinks, particularly when these contain only certain nutrients. The result is that nutrition
panels can be cluttered with zeros which confuse rather than inform.”107
95
96
Q 99 [Which?]
97
Ev 12-13, para 7 [Which?]; Q 535 [Trading Standards Institute]
98
Q 100 [Which?]
99
100
Qq 582 and 603 [Food Standards Agency]
101
102
Q 95 [Which?]
103
Q 103 [Which?]
104
Ev 37, para 2 [Sustain]
105
Q 513 and Ev 113 [Food and Drink Federation]
106
Qq 504 and 507 [Food and Drink Federation]
107
Ev 158, para 2.1.1 [British Soft Drinks Association]
Food information
25
Labelling: salt versus sodium
71. Labels which include information on the ‘big eight’ are required to state the amount of
sodium in a food, rather than salt. Confusion arises because salt, by definition, contains
sodium, whereas sodium is also present in other ingredients such as sodium bicarbonate and
MSG. From a health perspective, it is sodium intake, rather than specifically salt, which has
been linked to hypertension, heart disease and stroke.108 There is increasing awareness of the
presence of salt in processed foods, due in large part to a recent Government campaign to
persuade food manufacturers and processors to cut the level of salt in processed food.109 The
FDF told us that, on the majority of occasions, salt is added to food primarily for reasons of
taste.110
72. Research funded by the FSA has shown that many consumers would find information on
salt levels more helpful than sodium declarations.111 The Co-op has carried out research
showing that less than 25% of consumers knew the connection between salt and sodium.112
Dr Sîan Astley of the IFR commented that:
For most individuals sodium is fairly meaningless, whereas salt is easily understood …
Labelling sodium I do not believe would be helpful, and nor do our experts; labelling
salt is, as that will enable people to make the decision to reduce their salt intake.113
73. Consumer interest groups agreed that stating levels of sodium is not very meaningful for
most consumers. Sustain argued that:
While technically correct to label sodium, since this is the element of sodium chloride
(salt) responsible for raising blood pressure, very few citizens are aware of this fact. Nor
do most people know that, to obtain a salt equivalent figure from the sodium that may
be declared on the label, it is necessary to multiply it by roughly 2.5, then compare the
resulting figure to the recommended daily maximum intake.114
74. On the other hand, the Biscuit, Cake, Chocolate and Confectionery Association (BCCCA)
argued that it would be “unscientific and misleading” to label only salt, rather than sodium,
because not all sodium comes from salt—for example, sodium bicarbonate is used as a raising
agent in many baked goods. The BCCCA felt it would be confusing to consumers to give the
salt content of a biscuit that does not contain in fact contain salt but does contain sodium
bicarbonate. It proposed that labels should continue to state sodium content, with salt
content labelled on a voluntary basis.115
108
Food and Drink Federation, Salt and your health, September 2004
109
In June 2004, the Minister for Public Health wrote to a number of major food manufacturers and retailers which, in her
opinion, had failed to draw up adequate plans to cut salt in processed food. In February 2004, manufacturers had
agreed to come up with an action plan to cut salt levels. The Minister wrote to those manufacturers whose plans she
considered inadequate. See “Food chiefs hit back over salt claims”, The Guardian, 18 June 2004.
110
111
Ev 129-130, para 14 [Food Standards Agency]
112
Q 286 [The Co-op]
113
Q 40 [Institute of Food Research]
114
Ev 39, [Sustain]
115
Ev 163, footnote 1 [Biscuit, Cake, Chocolate and Confectionery Association]
26
Food information
The need for contextual information
75. A number of witnesses and submitters emphasised that, if nutrition labelling is to be
meaningful to consumers, it must be given in the context of wider provision of information
about diet and nutrition. For example, Dr Astley of the IFR commented that she was “not
sure” that nutrition labelling was helpful in assisting consumers to follow a well-balanced and
nutritious diet because:
… the information that is conveyed is perhaps sufficient in terms of the information
alone but it has no context and therefore perhaps for consumers it is difficult to
interpret, particularly for their individual circumstances.116
76. Which? also emphasised the importance of contextual information:
For example, on here [indicating a sample product] it says 10 grammes of fat per 100
grammes—what does that mean? How does that relate to my daily diet? Is that a lot? Is
that a little? Should I eat two of them? Should I eat three? We certainly think better
communication of that information is necessary.117
Which? felt that, although the FSA produced useful information about what is rated ‘a lot’
and ‘a little’ in terms of fat, sugars, salt and fibre per 100 grammes of food, the Agency needed
to increase its profile on issues like dietary advice, to make such information more readily
accessible.118 There is currently no requirement for manufacturers to list guideline daily
amounts for nutrients on labels.
77. The HNR described diet composition as a complex subject to communicate because it
required:
… separate messages about calories, the proportion of specific types of fat, protein and
carbohydrates and the additional health effects of food groups such as fruits and
vegetables and alcohol and the importance and health of micronutrients.119
The HNR emphasised that any educational campaigns about food and diet must be
sufficiently flexible to meet the needs of individuals who are at different stages of changing
their lifestyles:
… a pre-contemplation individual needs the motivation to even consider the need to
make lifestyle changes, while an individual who has arrived at the action stage needs
practical implementation strategies … There is a temptation for scientists and
journalists to leap to providing action-oriented messages, yet the majority of the
population have not yet reached this stage of change and hence the information fails to
initiate change.120
78. Opinions varied about the best means of providing contextual information. The FSA
indicated its support for including some contextual nutrition information on labels,
116
117
Q 95 [Which?]
118
Qq 95 and 130 [Which?]; see www.eatwell.gov.uk
119
Ev 29, para 11.1 [Human Nutrition Research]
120
Ev 29, para 11.2 [Human Nutrition Research]
Food information
27
acknowledging that its website “was probably not the best place to be providing that
information”.121 The FDF felt that only “straightforward factual” nutrition information
should be given and that it was the responsibility of Government to ensure that there was
adequate advice to consumers to enable them to understand and use that information.122
Our conclusions
79. We consider that provision of information about the nutrient content of food should
be mandatory on all prepacked foods. For such provision to be mandatory, legislative
change at EU level will be required. We therefore welcome the Government’s recent
undertaking to press vigorously for legislative change within the EU on this matter, and
we urge the Government to make this a high priority matter for the UK’s forthcoming
presidency of the EU. We consider that such mandatory nutrition information should be
extensive and should therefore state values for the following nutrients: energy (expressed
in both calories and kilojoules), protein, carbohydrate, including what proportion of the
carbohydrate is sugars, fat, including what proportion of the fat is saturated fat, fibre, salt
and sodium.
80. We consider that nutrition information should, in so far as practicable, be presented
in a standard, tabular format, to assist consumers in identifying the information easily
and in making comparisons between products. Exemptions from the requirements to use
a standard format may be necessary in the case of small packs, although we would then
expect nutrition information to be given in a linear format where practicable.
Information should be given in plain English, with common names rather than (or in
addition to) scientific names.
81. We have recommended that values for both salt and sodium should be stated. We
consider this is the best means of addressing the current confusion amongst consumers
about the relationship between the two. We commend the Government for the action it
has taken to date to have food manufacturers and processors cut the level of salt in
processed food. As a supplement to this action, we recommend that the Government
carry out a specific, targeted programme of public education to inform consumers of the
health implications associated with sodium intake.
82. Although important, mandatory provision of information about the nutrient content
of food will be of limited use to the consumer without the provision of more general
nutrition information. Such general information needs to enable consumers to establish
the relevance of nutrient values to their own individual circumstances. We consider that it
is primarily the role of the Food Standards Agency to formulate and promulgate this
information, but we also consider that the food manufacturing and retail industry has a
role to play in promulgation. In terms of labelling requirements, we consider that the
inclusion on labels of guideline daily amounts for energy consumption should be
mandatory, and we recommend that the Government push for the requisite legislative
change at EU level. In respect of other key nutrients—fat, sugars, and salt—we consider
121
Qq 601–602 [Food Standards Agency]
122
28
Food information
that the inclusion on labels of guideline daily amounts should be the rule, rather than the
exception.
83. We discuss other means of promulgating general nutrition information below.
Nutrition signposting: a ‘traffic light’ system?
84. There has been much public debate about the idea of devising a system of front-of-label
nutrition signposting in order to assist consumers in making healthier choices ‘at a glance’.
The form of signposting can vary: for example, we were interested to hear from the FSA that
Sweden and Finland currently operate a ‘green light only’ signposting system, whereby a
symbol is used to indicate a healthier choice.123 The Co-op uses a nutrition signposting system
on its own-brand food of ‘high’, ‘medium’ and ‘low’ descriptors for each nutrient, based on a
system developed by the Coronary Prevention Group.124
85. In the UK, much attention has been devoted to proposals for a so-called ‘traffic light’
system, which would use red, amber and green flashes on food labels to indicate a food’s
nutritional value. In its May 2004 report on Obesity, the Health Committee specifically
supported such a system and recommended that the Government legislate to make it
compulsory:
… according to criteria devised by the FSA, which should be based on energy density.
This would apply to all foods, Not only will such a system make it far easier for
consumers to make easy choices, but it will also act as an incentive for the food industry
to re-examine the content of their foods, to see if, for example, they could reduce fat or
sugar to move their product from the ‘high’ category into the ‘medium’ category.125
Government proposals
86. The recent Public Health White Paper indicated that the DoH has started work with the
FSA “to develop criteria that take account of fat, salt and sugar levels to indicate the
contribution a food makes to a healthy balanced diet”.126 The Government aims to have
introduced a system that could be used as a standard basis for signposting foods by mid 2005
and, by early 2006, to have a clear, straightforward signposting system in place. The
Government intends that this system will be in common use and will enable “busy people” to
“understand at a glance which foods can make a positive contribution to a healthy diet, and
which are recommended to be eaten only in moderation or sparingly”.127 The Government
will work with the food industry to develop its signposting approach.
87. In evidence to us, the FSA indicated that it considered that any such system would have to
be implemented in addition to mandatory nutrition labelling, rather than instead of, because
“otherwise … you do run into great difficulties in terms of oversimplification because there
are so many individuals and groups of individuals who have particular needs, so you need
123
124
Ev 62 [The Co-op]
125
Health Committee, Third Report of Session 2003-04, Obesity, HC 23–1, para 216
126
127
Food information
29
quite a decent amount of information on a pack in order to serve those different needs”.128
The Public Health White Paper appears to indicate that the Government intends to pursue
this approach.
Evidence received
88. A move to a nutrition signposting system was supported by consumer interest groups,
who argued that a user-friendly system was needed to indicate to consumers whether a food
is high, moderate or low in key nutrients such as fat, sugar and salt. Which? specifically
advocated a traffic light-based labelling system, which would use red, amber and green flashes
on food labels to indicate the level of fat, sugar and salt in a food, because it considered this
would be the most accessible system for consumers:129
… the challenge now is to try and make the healthy choice the easy choice … [so that]
when [consumers] are actually picking up products to come up with the most simple
system possible, so [consumers] can do that without having to have detailed knowledge
about what all these different nutrients mean …130
Which? called for the introduction of an “across the board” system to avoid the possibility of
having a different system in each supermarket, for instance, because this would cause
confusion.131
89. Proposals for nutrition signposting were not supported by the food manufacturing and
retailing industries. The BRC told us that the majority of food retailers believed the use of
high, medium and low descriptors for fat, sugar and salt on foods was potentially confusing.
It cautioned against “any artificial segregation of foods into ‘good’ or ‘bad’” on the basis that
this “ignores the overall nutrient profile of foods, including important micronutrients such as
calcium, iron and vitamin B12”.132 The BRC also expressed concern that overly prescriptive
approaches to nutrition labelling could discourage product innovation by the food industry,
which would be detrimental to consumers.133
90. The BCCCA considered that a traffic light system would ignore portion size:
For example a 50 gram bar of chocolate confectionery that was 50% sugar would
contain only 25 grams of sugar, whereas another food with perhaps only 20% sugar
could easily have larger absolute amounts if the portion size was greater than 125
grams.134
The National Farmers’ Union (NFU) was also opposed to the adoption of a ‘traffic light’
approach to labelling, describing it as “over-simplistic”.135
128
Qq 587–588 [Food Standards Agency]
129
130
Q 107 [Which?]
131
Q 97 [Which?]
132
Ev 178, paras 37 to 38 [British Retail Consortium]
133
134
Ev 163, para 9 [Biscuit, Cake, Chocolate and Confectionery Association]
135
Ev 60 [National Farmers’ Union]
30
Food information
91. In addition to the concerns raised by industry, independent experts raised serious
concerns about the operation of a nutrition signposting system based on a traffic light
approach. Dr Astley of the IFR acknowledged that a traffic light system would perhaps work,
because consumers are not currently reading food labels, but added:
It is not sufficient to inform; you must put it into context. You must provide the
consumer with something to balance it against, perhaps to say not, “Do not consume
the red label products”, but, “Do not consume more than four or five in a week, or four
or five in a day” … There are limitations to the traffic light system. No system is going
to be perfect. We cannot necessarily provide information for an individual.136
92. Dr Jebb of the HNR pointed out that one difficulty with a traffic light system is whether it
is applied across or within categories of food. In other words, is the basis for deciding whether
a bag of crisps should be labelled red, orange or green to be a comparison with all other bags
of crisps—in which case, a brand with reduced salt and fat may well merit a green rating—or
a comparison with all other foods—in which case, a red rating is probably inevitable,
regardless of whether or not a brand has reduced its levels of salt and fat. Dr Jebb considered
that the latter approach would discourage food companies from producing healthier versions
of certain products, such as crisps, because such versions would still attract a red rating,
regardless. Dr Jebb also pointed to the issue of what nutrient the rating system should be
focused on: “is this just about fat … or is it about fat and salt or salt and sugar, and what about
micro nutrients?”137 A good example of the difficulties on this point is the question of what
rating cheese should attract under a traffic light system. Both Drs Astley and Jebb pointed out
that cheese is high in fat and salt—which would suggest a red rating—but is also an important
source of calcium—which would suggest a green.138
A voluntary scheme?
93. The introduction of any mandatory nutrition signposting scheme would require EU
legislation. Introducing a voluntary scheme would obviously achieve much faster results.
Given that over 90% of consumers now buy their groceries from the major supermarket retail
chains, we explored with Asda and Tesco what influence they, as major retailers, could exert
over the nutrition labelling of their branded suppliers in order to achieve full participation in
any voluntary nutrition signposting scheme.139 The supermarkets’ evidence emphasised the
improvements and changes they are making to their own-brand food ranges. Obviously, this
is the area over which the supermarkets exercise most control, as well as being a significant
area of sales: Asda stated that over half its total sales were of own-brand products.140 However,
as regards the nutrition labelling practices of its suppliers of branded products (that is, non
own-brand products), Asda told us that, whilst it could talk with them:
Obviously we have no power to tell them what to do. We can make suggestions, as
Government and everybody else can, and I think probably the influence of the current
136
Qq 5, 8 and 13 [Institute of Food Research]
137
138
Qq 7 [Institute of Food Research] and 178 [Human Nutrition Research]
139
140
Q 393 [Asda]
Food information
31
focus on obesity in the media, et cetera, will influence the branded manufacturers more
than we would be able to do.141
Tesco agreed with Asda’s assessment and added that, if one individual retailer were to
attempt to influence the nutrition labelling on a large manufacturer’s products, the
manufacturer would reply by saying, “‘Actually, whatever size you think you are, we are in
fact supplying a whole number of other retailers, both large and small, and introducing that
sort of change just for you is very difficult’”.142
Retailer-initiated nutrition signposting schemes
94. In May 2004, Tesco announced its intention to trial a traffic light-based system of
nutrition labelling from September 2004 on “hundreds of products”, with the potential to
apply the initiative across its own-brand range over the next two years. Tesco intended to
apply a red, amber or green marking to each of four nutrients: total fat, saturated fat, sugar
and salt.143 Subsequent research carried out by the Food Commission, a consumer interest
group, suggested that, based on a comparison with the FSA’s nutritional guidelines, some
products in Tesco’s own-brand ‘Healthy Living’ range would have to carry either amber or
red lights.144
95. In the event, Tesco did not proceed with its trial of a traffic-light system in September, as
intended. We understand that research carried out by Tesco revealed an ambivalent response
from consumers to the proposed traffic light system, and a preference for a system based on
guideline daily allowances. Tesco has indicated that the company is still finalising its ideas on
the matter, commenting that “putting all foods into just three categories is an extremely
challenging task.”145 We understand that Tesco intends to launch a nutrition signposting
scheme in the next few months on a range of products, both healthy and less healthy.
96. In the interim, Sainsbury’s has launched its own nutrition signposting scheme. This
features a front-of-pack ‘wheel of health’ which uses separate red, amber and green flashes in
respect of five nutrients: salt, fat, saturated fat, added sugars and number of calories per
serving. In addition, the flashes are used to demonstrate the contribution of these nutrients
towards the guideline daily amount. The scheme was introduced in January 2005 on 30 of
Sainsbury’s own-brand products; Sainsbury’s planned to apply the scheme to all its own label
products at some stage.146
Recent developments
97. The Secretary of State for Health, Dr John Reid, recently announced the Government’s
intention to proceed with a nutrition signposting scheme, during an appearance before the
Health Committee.147 The Secretary of State indicated that, although he preferred to pursue a
141
Q 393 [Asda]
142
Qq 395–396 [Tesco]
143
“Tesco gives healthy eating the green light”, Tesco press release, 26 May 2004
144
The Guardian, “Red alert fear for Tesco over healthy eating range”, 27 July 2004; Food Commission, “Tesco: where red
means ‘proceed’?”, 27 July 2004
145
“Government Public Health White Paper”, Tesco press release, 16 November 2004
146
“Sainsbury’s responds to Government's White Paper on Public Health”, Sainsbury’s press notice, 16 November 2004
147
Health Committee, The Government's Public Health White Paper (Cm6374), uncorrected oral evidence, 23 February 2005,
HC 358-i
32
Food information
voluntary scheme, if that were to prove unachievable the Government would pursue a
mandatory scheme at EU level.148 Earlier media reports had said that the industry had warned
that they would not co-operate with proposals for a traffic light system of nutrition
signposting and had launched a “huge lobbying offensive to derail the plan” by challenging its
“scientific validity”.149 The Secretary of State commented that “the best thing the industry can
do here is engage with us” in introducing a signposting scheme.150
98. The Secretary of State did not go into the specifics of proposed nutrition signposting
schemes, but stated that any scheme should be “a simplified, easy and understandable form of
discovering whether the food [consumers] are buying is nutritious or not”.151 He described
himself as “open about the format” of the nutrition signposting scheme, saying “I do not care
whether it is 1, 2, 3, or A, B, C, or the colours of the rainbow …”.152
Our conclusions
99. We are strongly supportive of the introduction of a UK-wide system of front-of-label
nutrition signposting, to assist consumers in making healthier choices ‘at a glance’. The
traffic light system has much to commend it but, whatever signposting system the
Government decides to adopt, the determining factor should be clarity, rather than
comprehensiveness, although any system should, of course, be as scientifically sound as is
practicable.
100. More broadly, because any signposting system will necessarily oversimplify the very
complex information about what constitutes a healthy diet for each individual, in the
context of his or her lifestyle, it is crucial that any UK-wide system be implemented in the
context of a wider education campaign providing consumers with more detailed
information about nutrition and healthy diets. For such a campaign to be effective, the
Government and the food industry will need to work co-operatively in disseminating
consistent messages.
101. Speedy action by the Government is required on the introduction of a nutrition
signposting system. We would hope that the industry will, in consultation with the FSA
and government, initially introduce such a scheme on a voluntary basis, as a mandatory
system would take some time to be put in place because of the need for legislative change
at EU level to achieve this. However, even if such a voluntary scheme were to be achieved,
we consider that a mandatory scheme, applying at EU level, would still be necessary. We
therefore recommend that the Government pursue legislative change at EU level to ensure
that such a comprehensive and mandatory scheme of nutrition signposting is introduced.
102. We commend the initiatives being used by some of the major supermarkets in
introducing their own nutrition signposting schemes. We trust that the Government will
endeavour to work with these retailers to learn from their experiences in piloting
nutrition signposting schemes, prior to finalising its own signposting scheme.
148
Health Committee, The Government's Public Health White Paper (Cm6374), qq 5 and 65
149
Evening Standard, “Plan for ‘traffic light’ food labels faces axe”, 18 February 2005
150
Health Committee, The Government's Public Health White Paper (Cm6374), q 68
151
152
Food information
33
103. However, in order to be successful, we consider that any nutrition signposting system
needs to be introduced across the board, so that consumers can draw meaningful
comparisons between products. We trust that, once the Government has announced its
preferred system of nutrition signposting, the major retailers will endeavour to comply
with that system as soon as possible, to avoid consumer confusion.
104. In terms of achieving improvement in nutrition labelling on a voluntary basis, we are
disappointed major supermarket chains seem to be making little effort to influence their
suppliers of non own-brand products. It seems to us extremely unlikely that supermarket
chains with as massive a market share as Asda and Tesco enjoy have as little influence over
the practices of their branded suppliers as they claim. We therefore urge them to enter
into a dialogue with these suppliers to encourage them to introduce improved nutrition
labelling, including nutrition signposting, in the products which they supply where they
currently do not do so.
What other information should be required?
Means of production: ethical issues
105. There appears to be increasing awareness amongst consumers of ethical issues associated
with food production, such as employment conditions, animal welfare, food integrity and
environmental impacts. The Co-op told us that its 1994 and 2004 surveys of consumers’
attitudes to the ethics of the food industry had indicated that about 60% of people were more
concerned now than they were ten years ago about ethical issues.153 This increasing awareness
is evident in the recent proliferation in food assurance schemes relating to ethical issues.154
Examples of such schemes include: the Freedom Food scheme, set up in 1994, which
indicates compliance with RSPCA animal welfare standards by farms and farm animal
transport and slaughter;155 the LEAF scheme, set up in 1991, which promotes farm
management which benefits the environment;156 and the Marine Stewardship Council’s
certification scheme, started in 2000, which signifies environmentally responsible fishery
management and practices.157 More recently, figures released by the Fair Trade Foundation
showed that UK sales of products carrying the fair trade mark reached £140m in 2004, an
increase of 51% on £92m in 2003. In 2003, about 150 retail and catering products carried the
fair trade mark; in 2004, 834 did so.158
Evidence received
106. The Product Authentication Inspectorate, an independent food certification body,
commented that, currently, “it is difficult for the consumer to distinguish between marketing
claims and independently verified product information”.159 Which? believed that, as
consumers have become more removed from food production, they want to know more
153
The Co-op, Shopping with attitude, May 2004; available at www.co-op.co.uk
154
We discuss food assurance schemes more generally in part 6, below.
155
www.rspca.org.uk
156
www.leafuk.org
157
www.msc.org
158
Fairtrade Foundation, “Fairtrade shows massive public response to man-made ‘economic tsunamis’”, 28 February 2005
159
Ev 48, para 3.3 [Product Authentification Inspectorate]
34
Food information
about where food has come from and how it has been produced.160 Which? considered that,
in some cases this type of information needs to be provided on the label, whereas in others it
is more appropriate to provide it through other means, such as helplines, leaflets and
websites.
107. The FDF rejected the suggestion that information about means of production might be
required on food labels—such as, for example, labelling of non-free-range eggs or hormoneadded beef.161 In fact, the FDF opposed requirements to include any information other than
that which it considered to be “essential”, and therefore opposed:
… the principle of having to put information on food labels regarding, for example,
production technologies and processes … which makes little or no difference to the
final composition of the food (except where it would be misleading not to give such
information).162
108. The FDF considered that increasing the amount of information given on labels would
restrict the legibility of essential information about food composition and safety.163 It argued
that other means of conveying ethical information about a product will often be more
appropriate, such as “corporate values statements and traditional product information
provision”.164
Country of origin
109. Several submitters raised the question of country of origin labelling with us. Country of
origin labelling is one means of providing consumers with information that may be relevant
to many of the ethical issues associated with food production, although it also serves other
purposes. Currently, particulars of the place of origin of a food must be shown only if failure
to do so might mislead a purchaser to a material degree as to the true origin of the food.
110. The NFU believed that current regulation of country of origin can be “highly
misleading” and called for “a very simple label that just says ‘product of … packed in …’. If it
does not say ‘packed in’ one assumes that the products are packed in the same country [in
which they were produced]”.165 The NFU gave an example of the sort of labelling practices
which it would like regulated:
… we saw [a rib eye steak] last week … where it had ‘product of the EU stamped all
over it but then if you really looked in the small print it said ‘reared and slaughtered in
Brazil’. I do not think that is honest and accurate labelling.166
111. In this respect, Sustain noted that few consumers realise that the presence of an EU flag
on a food may mean only that the food’s ingredients were imported into the EU and then
processed here—not that the ingredients actually originated in the EU.167 Which? called for a
160
161
162
163
164
165
Ev 54 [National Farmers’ Union] and Q 279 [National Farmers’ Union]
166
Q 277 [National Farmers’ Union]
167
Ev 40 [Sustain]
Food information
35
requirement for food labels to give greater information about the country of origin of
products.168
Our conclusions
112. Consumers generally have no means of independently verifying claims made on food
labels, or elsewhere, about food production methods. At the same time, consumers are
becomingly increasingly aware of, and concerned about, many of the ethical issues
associated with food production, such as:
x
the employment conditions of those involved in producing the food
x
the welfare of animals farmed as food animals—for example, battery hens and veal calves
x
the integrity of some food processing methods—for example, adding hormones to beef
and beef or pork protein to chicken
x
impacts on the surrounding environment arising from the way in which food may be
produced—for example, the use of certain pesticides and fertilisers and the destruction or
displacement of important flora and/or fauna.
113. Fundamentally, we consider consumers should receive better information about
these ethical issues, either by way of food labelling or by other means, such as helplines,
leaflets and websites. We appreciate that the scope of legislating for compulsory provision
of such information, on either a UK or EU basis, is limited by the WTO Agreements on
Technical Barriers to Trade and on the Application of Sanitary and Phytosanitary
Measures. Nevertheless, we consider that food producers, manufacturers and processors
should consider ways in which they can provide consumers with further information
about these matters. Failure to do so could well be interpreted by consumers as a failure to
engage with the ethical implications of the industry’s activities.
Ingredient listing on alcohol
114. Currently, the ingredients of any drink with an alcoholic content of over 1.2% need not
be stated on the label, although ingredients may be stated on a voluntary basis.169
Additionally, under the Food Labelling (Amendment) (England) (No. 2) Regulations 2004, if
an alcoholic drink contains a specified allergen—such as sulphur dioxide or sulphites—its
labelling must clearly indicate the presence of that allergen.170 The Co-op has had on-bottle
labelling of ingredients in wine since 1999, and believed that it was the only retailer to have
taken this action.
115. Alcohol seems to be exempt from ingredient listing because the process of its
manufacture is closely regulated. Nevertheless, Sustain described it as “deeply depressing”
that alcohol labelling “has languished behind even food, which is bad enough”.171 In addition
168
Ev 14, para 17 [Which?]; see paragraph 61, above.
169
Council Regulation 1493/1999 on the common organisation of the market in wine and Commission Regulation 753/2002
on the description, designation, presentation and protection of wine products
170
See paragraph 48.
171
Q 224 [Sustain]
36
Food information
to the lack of ingredient labelling, Sustain commented that labelling of alcoholic units is
unclear.172
116. Currently, manufacturers of alcoholic drinks are exempt from listing their
ingredients on the label, although ingredients may be stated on a voluntary basis. We
recommend that the Government report to us on whether any action is currently being
taken at EU level to require compulsory labelling of ingredients on alcoholic drinks and, if
not, whether it has any plans to raise the matter at EU level itself.
5 Food labelling: non-prepacked foods
117. In this part of the report, we discuss food which is not prepacked or which has been
prepacked for direct sale (hereafter referred to as “non-prepacked food”). The definition of
“prepacked” in the 1996 Regulations means that non-prepacked food includes food sold loose
from a supermarket’s delicatessen counter, loose fruit and vegetables and loose baked goods.
Non-prepacked food also includes much of the food sold in the catering or food services
sector. The 1996 Regulations also define food that is “prepacked for direct sale”. This
constitutes food which is prepacked by a retailer for sale on the premises on which the food
was packed, or for sale from a vehicle or stall.173 Examples are bread baked and sold on-site,
sandwiches and salads which a café makes and sells on-site and much produce sold at
farmers’ markets.174
118. Non-prepacked food falls under the same legal framework as that which applies to
prepacked food: for example, the 2000 Directive applies to foods intended for supply to
restaurants, hospitals, canteens and other ‘mass caterers’. However, non-prepacked food is in
practice exempt from most or all of the general labelling requirements. Generally speaking,
non-prepacked food need be labelled only with the name of the food and, where appropriate,
with any additives.175 Where such food is sold from catering establishments, it is exempt from
all such requirements.176
119. Specific regulations requiring additional information apply to greengrocery produce.
Information about the nature of the produce, its country of origin, quality (for example, class
I or class II) and, where applicable, the variety name must be made available at the point of
retail, either as a label on prepacked produce or, in the case of loose produce, as a shelf label
or display card.177
172
Q 224 [Sustain]
173
Regulation 2
174
Although flour confectionery (for example, shortbread, sponges, crumpets and pastry), bread and edible ices are still
defined as being “prepacked for direct sale” if the producer sells them from premises that trade under the same name
as the premises on which the food was produced: regulation 2, (b) of the definition of “prepacked for direct sale.
175
Regulation 23
176
Regulation 27
177
Ev 146 [Defra]
Food information
37
What information should be required?
Non-prepacked food in the ‘eating out’ sector
120. There are about 350,000 catering establishments in the UK.178 Eating out accounts for
around one-third of UK consumers’ spending on food and drink and the figure is continuing
to grow: the ‘eating out’ market as a whole is valued at £28.2 billion and accounts for some 4.4
billion “eating out occasions”.179
121. We received some evidence that, given that eating out accounts for such a significant
proportion of the nation’s diet, improved food information should be available to consumers
in the ‘eating out’ sector too—that is, restaurants, pubs, cafés and canteens—not just those
purchasing prepacked food in the retail sector. The TSI commented on the lack of a
requirement for food provided in this sector to be labelled with nutritional information; it
believed that information about nutritional content “must be displayed for all foods no
matter how they are sold”.180 Dr Astley of the IFR asked:
Why can we not ask McDonalds or Burger King, or whatever, to put labels on it? Not
everything is bad about those foods; it is just the frequency that they are consumed that
is an issue.181
The Meat and Livestock Commission advocated provision of information about means of
production and country of origin, so that interested consumers are able to exercise choice in
respect of these matters.182
122. We discussed what further food information might be provided to consumers in this
sector with two large restaurant chains, Whitbread and McDonald’s. Whitbread describes
itself as the largest operator of full service restaurants in the UK, with over 1,600 restaurants.
Its UK brands include Beefeater (which serves over 18 million meals a year), Brewer’s Fayre
(“the biggest UK pub restaurant brand”), Costa (“the UK's leading coffee shop in terms of
both sales and the number of outlets”), Pizza Hut and TGI Fridays.183 McDonald’s has over
2.5 million customers a day in the UK, at over 1,000 restaurants. Worldwide, it has over
26,500 restaurants in 119 countries serving around 39 million customers a day, making
McDonald’s “by far the largest food service company in the world”.184
123. The labels on all of McDonald’s pre-packaged foods carry nutrition information, and
nutrition information is printed on the back of tray liners. As its food labels cannot, of course,
be read until after purchase, McDonald’s also has a leaflet available in all its restaurants
providing nutrition information, full country of origin information where possible, and full
178
179
Ev 174 [British Retail Consortium] and Ev 86, para 4.1 [Whitbread]
180
Ev 122, para 1.4 [Trading Standards Institute]
181
182
Ev 206, para 12 [Meat and Livestock Commission]
183
www.whitbread.co.uk; Pizza Hut is operated by Whitbread as part of a 50/50 joint venture.
184
www.mcdonalds.co.uk
38
Food information
allergen information.185 This information is also available on McDonald’s UK website and on
its customer services helpline.186
124. Whitbread’s brands do not currently provide nutritional or ethical information “as a
matter of course”.187 Whitbread opposed the imposition of any immediate requirements for
the food services sector to provide further food information, questioning whether restaurants
were the most appropriate environment in which to start the public education process on
healthier eating:188
… restaurant dining is very clearly seen as a treat or social occasion, often a celebration.
By comparison there is a functionality associated with shopping for food. In
restaurants, people are more interested in those emotional aspects that influence their
level of enjoyment, such as atmosphere, service, choice and value for money. Research
to date has indicated that they are less interested in food production issues, nutritional
content and animal welfare and country of origin issues [than] when compared to
shopping for domestic use.189
125. Whitbread also pointed out that practical difficulties would arise for restaurants, in
particular, were they required to provide nutrition information:
… restaurants serve dishes comprising a number of ingredients. Choice is a key
element of restaurant dining which means that a typical table of diners will all choose
different dishes or combinations of dishes from the same menu. Many of our
restaurants will also offer ‘off-menu’ choices or ‘specials’ only available on that
particular day. The menus will change with different regularity depending on the
brand.190
Whitbread suggested that, were restaurants to be required to provide a comprehensive
breakdown of nutritional and other information, “the risk is that the menu would become an
unwieldy and incomprehensible tome”.191 Whitbread has experimented with displaying
Weight Watchers points on one of its menus.192 It commented that “the research back from
the majority of customers was that, when they come out for a treat, they do not want to be
told that they are having their total calories in one particular dessert!”193
Signposting
126. Due to the likely practical difficulties were the eating out sector to be required to provide
comprehensive nutrition information, it has been suggested that a nutrition signposting
system would be particularly suitable for this sector. The FSA believed that nutritional
signposting could, in principle, be used on menus in catering establishments to highlight
185
Ev 86, para 4.2 [Whitbread]
186
Ev 86-87, paras 4.3 to 4.5 [Whitbread]
187
Ev 87-88, para 6.1 [Whitbread]
188
189
190
191
192
Q 419 [Whitbread]
193
Q 420 [Whitbread]
Food information
39
choices high in fat, sugar or salt, and healthier options.194 Which? advocated the
implementation of a traffic light system, in particular, in catering outlets, to make it easier to
convey nutrition information.195
127. Whitbread, however, considered that a traffic light-based approach would create
potential for a wide range of ‘typical values’ on any one food or meal, because:
x
the rating given would need to reflect the dish as served, including accompaniments and
side orders
x
individual ingredients within a dish might change during the life of a menu due to nonavailability or seasonality
x
it would be difficult to accommodate daily ‘specials’ or additions to the menu, and
x
nutrition content may vary according to nature of cooking method/equipment used.196
Non-prepacked food in the retail sector
128. We have discussed the sale of prepacked food in the retail sector in part 4. However,
food is of course sold in other forms in this sector, including in a loose, unpacked form, or
prepacked for direct sale (that is, prepacked by the retailer on the premises on which it is to be
sold). Examples of food sold loose include fruit and vegetables, food sold in delicatessens, or
from a delicatessen counter in a supermarket, fresh bread sold in bakeries and meat in a
butcher’s shop.
129. Again, Which? advocated the adoption of a traffic-light-based approach as an effective
way of conveying nutrition information about food sold loose.197 The TSI’s comments about
the need for information about nutritional content to be provided for all foods, no matter
how they are sold, applied equally to food sold in this way.198
Our conclusions
130. Currently, what requirements there are for clear and meaningful labelling are almost
entirely confined to prepacked foods. Little or no information is offered at point-of-sale
to consumers of non-prepacked foods. The Government seems to be doing little to
address this gaping hole in food labelling requirements.
131. We recognise that it may not be feasible to provide the same range of nutritional
information at point of sale to purchasers of non-prepacked foods as to those of
prepacked food. Nevertheless, we believe that the Government should be working to
ensure that clear and meaningful nutrition information is provided to the extent that it is
feasible to do so on all foods purchased by consumers, including food purchased in the
eating out sector and other food sold loose or prepacked for direct sale. The Government
should work at the EU level to achieve policy change on these matters. In the interim, the
194
Ev 129-130, para 14 [Food Standards Agency]
195
Qq 115–116 [Which?]
196
197
Qq 115–116 [Which?]
198
40
Food information
Government should take action to encourage increased voluntary provision of nutrition
and other information.
132. We set out separately below our specific conclusions on non-prepacked food provided
within the context of the eating out sector, and on non-prepacked food provided outside this
sector.
Non-prepacked food provided within the eating out sector
133. It has to be recognised that this sector does not lend itself to a uniform approach to food
information provision, because the range of operations carried out in the sector is so varied.
For example, it is much easier to envisage how information about nutrient content might be
provided in a lunchtime ‘take out’ café where all the food is prepacked for direct sale, for
instance, than in a restaurant with a wide range of dishes subject to change on a daily basis.
We therefore consider it would be impracticable to require the same provision of extensive
information about nutrient content which we have recommended in respect of prepacked
food.
134. We consider that those who sell or otherwise provide food in the eating out sector
must take responsibility for providing healthy choices to their customers, and for
highlighting those choices as healthy. As noted above, the FSA told us that Sweden and
Finland currently operate a ‘green light only’ signposting system, whereby a symbol is used to
indicate a healthier choice. We recommend that the Government work with the eating out
sector to develop a ‘green light only’ nutrition signposting system to highlight healthy
food choices. The Government should devise appropriate nutritional standards to
underpin this model.
135. The challenge for all those involved in the eating out industry is to lead its customers
towards making healthier choices. We expect that any improvements to the information
provided on prepacked food, in the retail sector, should lead to increased consumer
understanding which will be carried over into the eating out sector. For example, if a
consumer better understands the nutritional make-up of the pork pie he or she buys in a
supermarket, that consumer should be able to carry over that understanding to any pork pies
he or she may consume at the pub.
136. McDonald’s has demonstrated that it is possible to provide detailed nutritional
information to its customers. If other major restaurant and convenience food chains are
confident that their food offers at least as much nutritional value as does McDonald’s food,
they should have no objections to making more detailed nutritional information available to
their customers.
Non-prepacked food sold outside the eating out sector
137. We recommend that where it is feasible to do so, the level of nutrition information
which we have recommended be required in respect of prepacked food should apply
equally to food sold loose and food sold prepacked for direct sale in supermarkets and
other food shops. We consider that it would be desirable for the same information about
nutrient content to be provided, in the same standard, tabular format that we recommend
above, although we do recognise that there may be some situations where it is not
practical or necessary to provide as full a range of information as is provided on pre-
Food information
41
packed products. Again, this should assist consumers in identifying the information
easily and in making comparisons between products. Likewise, any nutrition signposting
system which may be adopted in respect of prepacked foods should also apply to food
prepacked for direct sale.
138. We received virtually no evidence relating to catering services in institutions such as
hospitals and schools. Nevertheless, we do not see any reason why the same principles
should not apply to such institutions, and we recommend that the Government report to
us on what work it is currently undertaking towards achieving such an outcome.
6 Verifying food information: food
assurance schemes
139. Food assurance schemes are intended to provide consumers with a greater degree of
information about the product assured, such as the way in which it has been produced, or an
assurance that certain standards have been met. Some schemes exist with the purpose of
assuring consumers that they are purchasing, for example, an organic product, or fish from a
sustainably managed fishery.
140. There are a great many such schemes. Evidence suggested there might be at least 30 of
them.199 Examples include the RSPCA’s Freedom Food scheme200, LEAF (Linking the
Environment and Farming)201 and the British Farm Standard (the “Little Red Tractor”).202
Legal requirements relating to farm assurance schemes
141. Food (or farm) assurance schemes are a category of product certification schemes. The
internationally recognised rules for operating product certification schemes are set out in the
International Standards Organisation (ISO) Guide 65, which is analogous to European
Standard EN 45011. Product certification schemes are voluntary initiatives, although for
some schemes, compliance with EN 45011/ISO 65 is a statutory requirement. FSA guidance
states that all UK food assurance schemes should be accredited to EN 45011 by the UK
Accreditation Service (UKAS).203 Nevertheless, assurance schemes are privately owned and
operated.204 They are not subject to any regulation other than assurance processes and
certification dependent on those who run the individual scheme or schemes.
199
Ev 40 [Sustain] and Q 230 [Product Authentication Inspectorate]
200
Ev 180 [RSPCA]
201
www.leafuk.org/leaf
202
www.littleredtractor.org.uk/whatis.asp
203
FSA, Food assurance scheme guidance, 2003, p 2
204
Ev 146 [Defra]
42
Food information
Evidence received
142. Clive Dibben, an independent consultant working in the food certification and rural
enterprise sectors, stated that “it is widely recognised, even by the [food assurance] schemes
themselves, that they seek to mirror legal requirements rather than exceed them”.205 Dr
Richard Baines of the Royal Agricultural College concurred with this view:
Most farm assurance schemes claim to encourage or ensure that systems of production
meet consumer (or retailer) aspirations. However, the majority merely underpin legal
farming in terms of environmental protection and animal welfare. This is why there is
no premium for farm assured.206
143. He told us that consumers did not really gain anything from such assurance schemes
and suggested that many schemes do not in fact even properly guarantee food safety.207 As an
example, Dr Baines pointed to the British Farm Standard, or ‘little red tractor’, scheme, which
he claimed was not actively managing safety because it did not require its member schemes to
have HACCP in place. He stated that consumers were nevertheless being told that food
carrying the little red tractor logo was safe.208
144. However, Dr Baines noted that some schemes do in fact exceed minimum legal
requirements in terms of their systems of production. These included the adoption of
integrated crop management in the Assured Produce scheme, additional environmental
auditing under the LEAFMarque scheme and higher than legally mandated animal welfare
under Freedom Foods.209 Dr Baines concluded that, although “other schemes claim to …
promote systems of production that are environmentally and animal welfare sensitive, yet
they merely require members to meet minimum legal requirements in these areas”.210
145. Some evidence noted the confusion caused by the number of schemes. The NFU
thought there were probably too many of them.211 Which? argued that there was a growing
sense of confusion surrounding the many assurance schemes, and the public needed to be
made more aware of what they really meant.212 In 2003, the National Consumer Council
(NCC) carried out a study of consumers’ views on voluntary food labelling, including food
assurance schemes. It concluded that the proliferation of labels and logos has caused
confusion and information-overload among consumers. The NCC’s research showed that
consumers did not understand what the majority of the labels and logos mean, and that food
assurance schemes were most often used as a marketing tool rather than a way of informing
consumers and offering real choice.213 The NCC recommended that, in the absence of
legislation, the FSA should “develop, champion and promote” a code of practice for food
assurance schemes and should encourage maximum take up of the code across the food
205
Ev 169, para 31 (emphasis added) [Clive Dibben]
206
Ev 104 [Dr Richard Baines]
207
Qq 494–96 and ev 105, paras 2.5 and 2.6 [Dr Richard Baines]
208
Ev 106, para 3.2 [Dr Richard Baines]
209
210
211
212
Q 147 [Which?]. The Product Authentication Inspectorate made similar points: q 240.
213
Ev 208 [National Consumer Council]. See also q 234 [Product Authentication Inspectorate]
Food information
43
industry.214 On this point, Mr Dibben commented that “various attempts have already been
made to develop an overarching body to explain the merits of assurance schemes to UK
consumers and to act as an authority on all UK assurance matters. As yet none has succeeded
…”.215
146. The FSA stated that it would like to see some degree of collaboration between assurance
schemes in order to provide the consumer with information with which to compare different
schemes.216 In August 2003, the FSA published advice to scheme operators, which
recommended that the following information should be easily accessible and clearly
communicated to consumers:
x
what the scheme seeks to achieve and what advantages it offers consumers
x
in what ways, if any, the scheme standards exceed the legal minimum
x
how the scheme ensures that its standards are being met by member producers
x
the scheme’s arrangements for monitoring delivery of standards, for example through
analysis of scheme produce
x
how instances of non-compliance are dealt with, and
x
the evidence base for any specific claim—for example, on food safety or quality.
The FSA also planned “to carry out a survey of the consumer information available from
scheme operators and to publish a collation of this information to help inform consumer
choice.”217
147. Dr Baines noted that, where schemes do require producers to meet additional
conditions, there was no evidence of this adding value for those who deliver these enhanced
conditions.218 To deal with this problem, he argued that producers delivering such additional
requirements should be adequately rewarded, and that labelling should differentiate foods
with these extra assurances so those consumers interested in such foods can identify and
preferentially source them.219 He acknowledged that, if such a system were to work,
consumers would have to be prepared to pay for the added value of the product, and that
premium should then flow to the producer. Dr Baines cited one example of a product where
producers had received a premium for committing to a higher level of biodiversity, and this
cost had been passed to the consumer in terms of a higher price.220
214
National Consumer Council, Bamboozled, Baffled and Bombarded: consumers’ views on voluntary food labelling,
February 2003, p 5
215
Ev 170, para 34 [Clive Dibben]
216
Ev 143 [Food Standards Agency]
217
218
Ev 104 [Dr Richard Baines]
219
220
Ev 107, para 6.2 and q 500 [Dr Richard Baines]
44
Food information
Farm assurance schemes and non-own-brand labels
148. Large retailers sell both their own-brand products and also food produced under
recognised assurance schemes. Dr Baines felt that the aim of the main multiple retailers was
to promote their own brands of food. “Any additional ‘assurance label’ has the potential to
dilute their own brand”.221 He suggested that, although the supermarkets claim to sell only
farm assured products, this could not in fact be the case:
… the main retailers claim that the producers who supply ‘their’ integrators
[processors] are farm assured … [yet] there is no formal audit of this in the [British
Retail Consortium Standard] or equivalent standards … there is no audit trail to ensure
only assured produce reaches and is sold by the retailers.222
149. However, the FDF told us that it had “great sympathy” for the general aims of farm
assurance:
To ensure that consumers have reliable information, ethical and associated logos
relating to production methods should be backed by established schemes, information
on which is accessible to consumers and compliance with which is independently
audited.223
The FDF told us in evidence that, although there was no “fundamental requirement” for
retailers to sell farm assured produce, individual companies might well build this into their
specifications, on a company basis.224 “Broadly speaking, the issue is to source materials to
the required standards of safety and quality from wherever they happen to be available.”225
The British Farm Standard—the little red tractor
150. One of the best-known assurance schemes in the UK is the ‘little red tractor’, which,
according to the NFU, has a 47% recognition level among the public.226 The NFU is a partowner of the scheme, which was set up in 2000. The scheme is run by a separate organisation,
Assured Food Standards (AFS), an organisation which is “owned by sections of the agri-food
industry, including several of the farm assurance schemes, the National Farmers’ Union and
the Meat and Livestock Commission”.227 The NFU described the scheme as follows:
Clear labelling of food with the red tractor logo denotes that it is farm assured …
Through consolidation of all the assurance schemes under one logo, the consumer is
better able to recognise farm assured product. Indeed a key driver in the development
of red tractor was to reduce the number of logos associated with farm assurance to
assist consumers in their purchasing decisions.228
221
222
Ev 105, para 2.4 and ev 106, para 4.4 [Dr Richard Baines]
223
Q 516 and ev 116, para 29 [Food and Drink Federation]
224
225
226
227
www.littleredtractor.org.uk/contact.asp
228
Ev 55 [National Farmers’ Union]
Food information
45
One of the aims of the scheme, according to the NFU, was to “put a logo” on “a multitude
of schemes … designed to give consumer reassurance”.229
151. We heard some specific criticisms of the scheme. In 2002, the FSA argued that the AFS
was not independent enough, and recommended that a new independent organisation
should be established to govern the ‘little red tractor’ scheme:
A new, independent governing body for Red Tractor schemes, along with measures to
improve transparency and consistency across the board, are essential to meet the needs
of the consumer.230
Subsequently, AFS was ‘re-constituted’ to form ‘AFS 2003’. However, Clive Dibben told us
that this new body still did not have “a constitutionally independent structure and retains
strong links with the industry … it is believed that the AFS 2003 Board retains a majority in
favour of industry directors”.231 Mr Dibben suggested that AFS favours existing, industrycontrolled schemes:
As such any assurance scheme wishing to use the British Farm Standard mark will be
required to operate in the same way as AFS’s own schemes, rather than ensuring that
any scheme deliver the equivalent outcome (essentially compliance with UK
legislation).232
152. It is sometimes thought that food assured under the scheme is British.233 Which? pointed
out that the red tractor logo does not indicate that a food comes from British farms, as
consumers often believe; it merely denotes that a food has been produced in accordance with
the British Farm Standard. The FSA has also said that “research shows that people wrongly
assume the red tractor logo indicates a British product, but the logo can also be used on
produce sourced outside the UK.”234 The little red tractor scheme website also appears to give
the impression that the scheme applies only to British farmers. Although it avoids stating that
only British farmers are eligible for the scheme, it nowhere states that food carrying the logo
need not necessarily have been grown on a British farm.235
153. Clive Dibben was critical of the NFU’s role in respect of the scheme. He argued that the
NFU had issued a press statement in 2003 which clearly implied country of origin attributes
to the red tractor. He noted that certification schemes must permit access to all who are able
to comply with their standards, and it was also questionable whether the use of a mark as a de
facto country of origin label is consistent with the objectives of the EU single market or ISO
Guide 65 with regard to the facilitation of trade.236
154. The NFU argued that they did not claim the tractor logo was ‘British’, but acknowledged
that all the food assured under the scheme had, in fact, been British:
229
230
FSA, ‘Call for shake-up of Food Assurance Schemes’, 9 July 2002
231
232
233
For example, ev 63 [The Co-Op]
234
Ev 169, para 27; FSA press notice 9 July 2002, 2002/2035
235
www.littleredtractor.org.uk
236
Ev 169, paras 26 and 28 [Clive Dibben]
46
Food information
no product has been licensed to the red tractor other than British product … what we
cannot do because of the Single Market is state equivocally that the red tractor is
British; that is illegal.237
Our conclusions
155. It is not at all clear that food assurance schemes are currently providing useful and
meaningful information to consumers, and the proliferation of such schemes adds to the
confusion. Few consumers are in a position to inquire into the veracity or reliability of the
schemes’ claims. Furthermore, even where schemes are sound, they may certify nothing
more than that required minimum standards have been met—something consumers
should be able to take for granted without the need for assurance by an external, private
body. We believe that most consumers are likely to assume that the fact that a food carries
an assurance scheme mark means that it has exceeded legal requirements in some respect.
156. We recommend that the Government should ensure the central registration of food
assurance schemes. All schemes should have to be registered and approved by an
identified body. The FSA would be an obvious candidate for the task. The purpose of such
schemes should be to certify that the product carrying the mark has either been:
x
produced or manufactured in a way which exceeds minimum legal standards—for
example, in respect of the environment or animal welfare—or
x
has a ‘special characteristic’, such as meeting organic or vegan/vegetarian production
requirements.
The registration body would have to satisfy itself that the operators of the schemes had
appropriate verification systems in place to ensure that producers taking part in a scheme
were fully meeting its requirements. We further recommend that the Government, in
consultation with stakeholders, consider ways in which this kind of registration could
limit the numbers of schemes in operation, and introduce some common elements in
labelling, in order to make it easier for consumers to understand the schemes.
237
Food information
47
7 Other sources of food information
157. In the course of giving oral evidence, the Minister for Food commented on the ways,
other than labelling, in which consumers receive information about food:
… most of the messages that impact on people would not be the minutiae of the EU
labelling standards or even the actual labels themselves, they will be the advertising, the
way things are presented in the shops, the way they are presented on menus and the
way they are presented in other literature which the industry create.
158. In this part, we briefly discuss these wider sources. Although FSA research has found
that 78% of consumers read food labels at least occasionally, it has also shown that consumers
get information about food issues from newspapers and magazines, television, supermarkets,
and friends and family.238 Although the evidence we received tended to focus on the
information consumers receive from food labelling, rather than from other sources, we
nevertheless consider it is important that attention is paid to other sources of food
information.
Legal controls on what information is put before consumers
159. Outside labelling, advertising, marketing and trading of food are regulated to the extent
that misleading statements are illegal.239 The 1990 Act makes it is an offence to publish an
advertisement which falsely describes any food or which is likely to mislead the consumer as
to the nature, substance or quality of any food.240 More broadly, the Trade Descriptions Act
1968 makes it an offence for a person acting in the course of a trade or business to make false
or misleading statements about goods. The 2000 Directive prohibits advertising or presenting
foods in such as a way as to mislead the purchaser or to attribute medicinal properties to
foods.241
Consumer understanding and education
How well informed are consumers?
160. Opinions amongst our witnesses varied as to how well-informed consumers are about
diet and nutrition. Dr Jebb of the HNR considered that consumers are confused because of
the number of messages which they receive about these matters and the fact that “nutrition
science is not straight forward”:
This is not smoking where the one message ‘stop smoking’ meets all circumstances, all
eventualities. With nutrition science you have endless different nutrients, endless
different foods … That makes it phenomenally complicated for people to work their
way through.242
238
Ev 128, para 2 [FSA]; see above paragraph 55.
239
Specific marketing standards apply to organic products, eggs, fresh fruit and vegetables, olive oil, preserved fish products
and spirits: see the FSA’s website, www.food.gov.uk.
240
Section 15(2)
241
Article 2
242
48
Food information
161. Tesco described consumers’ understanding and knowledge of nutritional information as
“quite poor”, and Dr Astley of the IFR suggested that “if you took a large majority of the
public and asked them what the labelling currently means, they do not understand it”.243
Research carried out by Which? “highlighted that many people were unclear about what
constitutes ‘a lot’ and ‘a little’ in terms of fat, sugar and salt”.244 Which? found that consumers
generally had a better understanding of how many portions of fruit and vegetables a day they
should aim to eat, although 21% of men and 13% of women still thought that the
recommended number was fewer than five.245
162. The FSA took a more optimistic view of consumers’ awareness of what kinds of foods
they should be eating—“foods which contain less fat, less salt, … more fruit and vegetables”—
describing it as “fairly high”.246 However, it pointed to the “huge variance between what
people know and what people do” and identified the need to turn this knowledge into
behavioural change as a key issue facing government.247 The FSA also observed that “the
poorer people are, the less use they make of food information and the less access they have to
food information and … conversely, the better off people are, the more food information they
have”.248
Who do consumers trust?
163. Opinions were divided on the extent to which consumers trust food information
provided by the Government. On the basis of its consumer surveys, the FSA considered that
trust and confidence in the Agency had increased.249 The Minister for Food wasn’t certain
that consumers trusted anyone:
It is pretty clear that [consumers] do not trust Government, they do not trust scientists
and they do not trust the agriculture sector, they do not trust the food manufacturers
and they do not even trust the newspapers. They trust slightly more the supermarkets
… [although this] is not a particularly logical position … 250
And McDonald’s believed that consumers probably trust it more than they trust the
Government.251
What is currently being done to inform and educate consumers?
164. From the perspective of the food industry, the BRC described food retailers as “expert
communicators, in touch with millions of consumers every day” by way of point of purchase
information, in-house magazines, leaflets and websites.252 The BRC told us that retailers also
communicate with their customers through “non-traditional channels”, such as road shows,
243
Q 366 [Tesco]; Q 15 [Institute of Food Research]
244
245
246
247
248
249
250
Q 675 [Defra]
251
Q 446 [McDonald’s]
252
Food information
49
customer care helplines and educational packs for schools.253 The FDF operates three websites
providing consumers with information about issues such as healthy lifestyles and food
safety.254 Amongst the supermarkets, by way of example, the Co-op provides information to
consumers about products on labels, at point of sale, in leaflets, on its website and in response
to inquiries to its free customer helpline and Waitrose branches hold a reference book
containing detailed nutrition and special dietary information about its products and provide
a range of fact sheets on nutrition and dietary issues.255
165. From the perspective of government, the FSA described its “consumer information
strategy” as having two principal threads: encouraging improved food labelling; and
providing consumer information and advice, both directly and via the media and other
channels.256 Defra referred to its work with the following bodies and schemes:
x
Farming and Countryside Education, a body set up by the National Farmers’ Union and
the Royal Agricultural Society in 2001 with the aim of increasing the number of school
children who visit farms
x
the National Advisory Group for Growing Schools, a Government initiative set up in 2001
and funded by DfES which aims, amongst other things, to raise awareness of food and
where it comes from
x
the educational access option under Defra’s Countryside Stewardship scheme, which
currently has over 800 sites available for schools or local groups to visit and demonstrates,
amongst other things, how farming links to a range of services, including food production
x
the statutory agriculture and horticulture levy boards, which produce information about
the food produced by the sectors they cover.257
166. At a local level, the TSI told us that trading standards divisions within local authorities
were “becoming more proactive in publicising the nutritional content of foods, particularly
school meals and meals on wheels”.258
167. We were interested to hear from the IFR about an initiative in which it is involved in
schools: a ‘smartcard scheme’, which monitors school students’ meal choices at point of
purchase.259 The IFR considered that the scheme had potential to offer rewards to students if
they could demonstrate they were purchasing a balanced diet, although the scheme can
monitor only what students purchase, not what they actually consume.260
253
254
www.foodfitness.org.uk, www.foodlink.org and www.foodfuture.org.uk
255
Ev 61 [The Co-op] and ev 165 [Waitrose]
256
257
Ev 148 [Defra]
258
259
260
Qq 32–37 [Institute of Food Research]
50
Food information
What future plans does the Government have to inform and educate
consumers?
168. The food and health action plan recently published by the DoH sets out the actions
which the Government plans to take to inform and educate consumers about nutrition.261
The plan prioritises action on diet and nutrition to reduce consumers’ intake of fat, saturated
fat, salt and sugar and to increase their consumption of fruit and vegetables. Specific action is
proposed in respect of education campaigns about obesity, simplified food labelling in the
form of nutrition signposting, and advertising and promoting food to children. The plan also
acknowledges the need for Government to work with the food industry to increase access to
healthier foods.
169. The delivery of the plan across government is to be overseen by the Cabinet Committee
MISC 27, which is chaired by the Secretary of State for Health and supported by a Health
Improvement Board made up of senior government officials. Other boards and steering
groups “involving partners outside government and other stakeholders” will be convened “to
help lead change and to report on progress”.262
Our conclusions
170. Given that FSA research has shown that 78% of consumers read food labels at least
occasionally, clear and informative labels are obviously a key means of promoting informed
consumer choice. However, labels are only one way in which consumers receive information
about food. In order to improve consumers’ knowledge and understanding of nutrition
and diet, a broader education campaign about these matters is required, driven forward
by both the Government and the food industry, working in partnership with each other.
diet, from a wide range of sources. Consequently, if consumers are ever to trust messages
about diet and food, such messages must be presented in a coherent and authoritative
manner. A consistent approach between industry-run consumer awareness programmes
and Government-funded consumer education must be adopted, with a shared aim of
delivering clear and consistent messages to consumers. The success of the Government’s ‘5
a day’ initiative demonstrates that Government and industry can work to promote the same
simple message.
171. We are greatly encouraged by the positive moves made by the Government in this
direction in its recently published food and health action plan. The plan engages with
many of the themes raised in the course of our inquiry, and supports many of the
conclusions we have reached in this report. Importantly, it also specifies target dates by
which particular actions are to be achieved. We will continue to monitor the
implementation of this plan, and the coherence of the messages delivered by it, in so far as
it relates to the way in which consumers receive information about food.
261
Department of Health, Choosing a better diet: a food and health action plan, 9 March 2005
262
Ibid., p 37
Food information
51
Role of the Government
172. We consider that implementation of our earlier recommendation, that the
Government explicitly task one government department with lead responsibility for coordinating food information policy across both central and local government, would
assist enormously in achieving this consistent approach between the Government and the
food industry. The industry should be able to rely on a definitive position on food
information policy, issuing from a single source. The Government needs to provide the
industry with a single agenda with a clear list of priorities that both the Government and
industry can work towards achieving.
Role of the food industry
173. In its report on Obesity, the Health Committee called on the food industry to take
voluntary actions to address the problem of obesity, such as pricing healthy foods in an
affordable way, stopping forms of product placement that emphasise unhealthy foods (such
as placing confectionery and snacks at supermarket checkouts) and phasing out ‘super-size’
portions.263
174. The Government appears to have paid some attention to the Committee’s
recommendations. The FSA highlighted to us the “whole area of promotional activity” as one
which the Government particularly needed to look at, especially in relation to commercial
activity aimed at children.264 The FSA commented:
We want particularly to encourage supermarkets, for instance, when they are making
‘two for the price of one’ type offers, to take into account the nutritional quality of the
food which they are encouraging people to buy more … as part of corporate social
responsibility.265
175. The food industry clearly has a key role to play in raising consumer awareness about
nutrition and diet and in making healthier choices both available and attractive. The
figures which we have heard in the course of taking evidence demonstrate the role to be
carried out by the major players, in particular. More than 90% of consumers now buy their
food from the major supermarket retail chains, McDonald’s has over 2.5 million customers a
day in the UK, Whitbread claims to lead both the UK pub restaurant market and the coffee
shop market.266
176. Little benefit to consumers’ diet will be gained from improving the provision of
nutrition information if such improvements do not go hand in hand with corresponding
changes in industry practice. We reiterate the Health Committee’s call for the food
industry to re-examine its practices with respect to matters such as pricing, product
placement and portion size.
263
HC 23–I, (Session 2003–04), para 241
264
265
266
See above paragraphs 93 and 122.
52
Food information
Conclusions and recommendations
Responsibility for food information policy within Government
1.
We support the existing separation within government of the producer department—
Defra—from the main regulator—the Food Standards Agency. However, food
information policy is not simply an issue of regulation; in particular, it encompasses
public health initiatives, education within schools and advertising. At present, the main
areas of responsibility are divided between the FSA, the Department of Health and
Defra, and other responsibilities fall to the Department for Education and Skills, the
Department for Culture, Media and Sport and the Department for Trade and Industry.
It is not apparent to us that there is effective co-ordination between all these different
players of government policy and initiatives in the field of food information, both
domestically and at EU level. (Paragraph 30
2.
We recommend that the Government explicitly task one government department with
lead responsibility for co-ordinating food information policy across both central and
local government, and for representing the position of the UK Government at EU level.
We consider that Defra would be the most suitable department to assume this role. We
also recommend that Defra assume joint responsibility for achieving the Public Service
Agreement target of “halting the year-on-year rise in obesity among children under 11
by 2010 in the context of a broader strategy to tackle obesity in the population as a
whole”, alongside those departments already responsible for achieving the target (the
DoH, the DfES and the DCMS). (Paragraph 31
3.
We recommend that the Government investigate whether it is indeed the case that local
authorities are being deterred from taking prosecutions for breaches of food law,
particularly food labelling law, and, if so, that it establish the reasons why. The
Government must ensure that local authorities are sufficiently well-resourced to be able
to take prosecutions against food manufacturers and retailers, whose legal budgets are
of a size that does not prevent them from fully using the law to defend their interests.
(Paragraph 32
Food safety and hygiene
4.
Government has a vital role to play in providing definitive guidance which assists
consumers to assess food safety risks. We commend the Food Standards Agency on the
work it has done, since its establishment in 2000, towards providing clear advice to
consumers about food safety issues. We also congratulate the Agency on its initiative in
launching a website providing information about food hygiene and preparation.
(Paragraph 51)
5.
We welcome recent legislation improving allergen labelling requirements. However,
the new legislation applies only to allergens which have been deliberately added to food:
labelling of foods which may inadvertently contain allergens remains unregulated. We
recommend that the Government move quickly to consider how this legislation can be
supplemented to regulate the defensive use of allergen warnings, so that consumers
with food allergies are provided with clear and helpful allergen information. The
Food information
53
Government should also ensure that proper channels of communication are in place
between the food industry and medical scientists to allow for the effective flow of
information about the latest scientific findings on allergies. (Paragraph 52)
6.
We recommend that the Government undertake a speedy investigation into the events
which resulted in the illegal dye, Sudan 1, making its way into the UK food chain. We
are particularly concerned that the Government should establish the length of time for
which the adulteration of chilli powder is likely to have gone undetected and why UK
authorities did not detect this adulteration in a product used so extensively in UK food
processing. The Government and the FSA should also carry out work to determine the
best way of communicating with the public about questions relating to the degree of
risk actually associated with issues like Sudan 1. (Paragraph 53)
Food labelling: prepacked foods
7.
We support the European Commission’s draft regulation on nutrition and health
claims made on foods, and trust that the UK Government will do all it can to facilitate
the speedy implementation of the draft regulation. (Paragraph 57)
8.
We consider that provision of information about the nutrient content of food should be
mandatory on all prepacked foods. For such provision to be mandatory, legislative
change at EU level will be required. We therefore welcome the Government’s recent
undertaking to press vigorously for legislative change within the EU on this matter, and
we urge the Government to make this a high priority matter for the UK’s forthcoming
presidency of the EU. We consider that such mandatory nutrition information should
be extensive and should therefore state values for the following nutrients: energy
(expressed in both calories and kilojoules), protein, carbohydrate, including what
proportion of the carbohydrate is sugars, fat, including what proportion of the fat is
saturated fat, fibre, salt and sodium. (Paragraph 79)
9.
We consider that nutrition information should, in so far as practicable, be presented in
a standard, tabular format, to assist consumers in identifying the information easily and
in making comparisons between products. Exemptions from the requirements to use a
standard format may be necessary in the case of small packs, although we would then
expect nutrition information to be given in a linear format where practicable.
Information should be given in plain English, with common names rather than (or in
addition to) scientific names. (Paragraph 80)
10.
We have recommended that values for both salt and sodium should be stated. We
consider this is the best means of addressing the current confusion amongst consumers
about the relationship between the two. We commend the Government for the action it
has taken to date to have food manufacturers and processors cut the level of salt in
processed food. As a supplement to this action, we recommend that the Government
carry out a specific, targeted programme of public education to inform consumers of
the health implications associated with sodium intake. (Paragraph 81)
11.
Although important, mandatory provision of information about the nutrient content of
food will be of limited use to the consumer without the provision of more general
nutrition information. Such general information needs to enable consumers to
54
Food information
establish the relevance of nutrient values to their own individual circumstances. We
consider that it is primarily the role of the Food Standards Agency to formulate and
promulgate this information, but we also consider that the food manufacturing and
retail industry has a role to play in promulgation. In terms of labelling requirements, we
consider that the inclusion on labels of guideline daily amounts for energy
consumption should be mandatory, and we recommend that the Government push for
the requisite legislative change at EU level. In respect of other key nutrients—fat,
sugars, and salt—we consider that the inclusion on labels of guideline daily amounts
should be the rule, rather than the exception. (Paragraph 82)
12.
We are strongly supportive of the introduction of a UK-wide system of front-of-label
nutrition signposting, to assist consumers in making healthier choices ‘at a glance’. The
traffic light system has much to commend it but, whatever signposting system the
Government decides to adopt, the determining factor should be clarity, rather than
comprehensiveness, although any system should, of course, be as scientifically sound as
is practicable. (Paragraph 99)
13.
More broadly, because any signposting system will necessarily oversimplify the very
complex information about what constitutes a healthy diet for each individual, in the
context of his or her lifestyle, it is crucial that any UK-wide system be implemented in
the context of a wider education campaign providing consumers with more detailed
information about nutrition and healthy diets. For such a campaign to be effective, the
Government and the food industry will need to work co-operatively in disseminating
consistent messages. (Paragraph 101)
14.
Speedy action by the Government is required on the introduction of a nutrition
signposting system. We would hope that the industry will, in consultation with the FSA
and government, initially introduce such a scheme on a voluntary basis, as a mandatory
system would take some time to be put in place because of the need for legislative
change at EU level to achieve this. However, even if such a voluntary scheme were to be
achieved, we consider that a mandatory scheme, applying at EU level, would still be
necessary. We therefore recommend that the Government pursue legislative change at
EU level to ensure that such a comprehensive and mandatory scheme of nutrition
signposting is introduced. (Paragraph 101)
15.
We commend the initiatives being used by some of the major supermarkets in
introducing their own nutrition signposting schemes. We trust that the Government
will endeavour to work with these retailers to learn from their experiences in piloting
nutrition signposting schemes, prior to finalising its own signposting scheme.
(Paragraph 102)
16.
However, in order to be successful, we consider that any nutrition signposting system
needs to be introduced across the board, so that consumers can draw meaningful
comparisons between products. We trust that, once the Government has announced its
preferred system of nutrition signposting, the major retailers will endeavour to comply
with that system as soon as possible, to avoid consumer confusion. (Paragraph 104)
Food information
55
17.
In terms of achieving improvement in nutrition labelling on a voluntary basis, we are
disappointed major supermarket chains seem to be making little effort to influence
their suppliers of non own-brand products. It seems to us extremely unlikely that
supermarket chains with as massive a market share as Asda and Tesco enjoy have as
little influence over the practices of their branded suppliers as they claim. We therefore
urge them to enter into a dialogue with their suppliers of branded products to
encourage them to introduce improved nutrition labelling, including nutrition
signposting, in the products which they supply where they currently do not do so.
(Paragraph 104)
18.
Consumers generally have no means of independently verifying claims made on food
labels, or elsewhere, about food production methods. At the same time, consumers are
becomingly increasingly aware of, and concerned about, many of the ethical issues
associated with food production (Paragraph 112)
19.
Fundamentally, we consider consumers should receive better information about these
ethical issues, either by way of food labelling or by other means, such as helplines,
leaflets and websites. We appreciate that the scope of legislating for compulsory
provision of such information, on either a UK or EU basis, is limited by the WTO
Agreements on Technical Barriers to Trade and on the Application of Sanitary and
Phytosanitary Measures. Nevertheless, we consider that food producers, manufacturers
and processors should consider ways in which they can provide consumers with further
information about these matters. Failure to do so could well be interpreted by
consumers as a failure to engage with the ethical implications of the industry’s
activities. (Paragraph 113)
20.
Currently, manufacturers of alcoholic drinks are exempt from listing their ingredients
on the label, although ingredients may be stated on a voluntary basis. We recommend
that the Government report to us on whether any action is currently being taken at EU
level to require compulsory labelling of ingredients on alcoholic drinks and, if not,
whether it has any plans to raise the matter at EU level itself. (Paragraph 116)
Food labelling: non-prepacked foods
21.
Currently, what requirements there are for clear and meaningful labelling are almost
entirely confined to prepacked foods. Little or no information is offered at point-of-sale
to consumers of non-prepacked foods. The Government seems to be doing little to
address this gaping hole in food labelling requirements. (Paragraph 130)
22.
We recognise that it may not be feasible to provide the same range of nutritional
information at point of sale to purchasers of non-prepacked foods as to those of
prepacked food. Nevertheless, we believe that the Government should be working to
ensure that clear and meaningful nutrition information is provided to the extent that it
is feasible to do so on all foods purchased by consumers, including food purchased in
the eating out sector and other food sold loose or prepacked for direct sale. The
Government should work at the EU level to achieve policy change on these matters. In
the interim, the Government should take action to encourage increased voluntary
provision of nutrition and other information. (Parqagraph 131)
56
Food information
23.
We consider that those who sell or otherwise provide food in the eating out sector must
take responsibility for providing healthy choices to their customers, and for
highlighting those choices as healthy. We recommend that the Government work with
the eating out sector to develop a ‘green light only’ nutrition signposting system to
highlight healthy food choices. The Government should devise appropriate nutritional
standards to underpin this model. (Paragraph 134)
24.
The challenge for all those involved in the eating out industry is to lead its customers
towards making healthier choices. (Paragraph 135)
25.
We recommend that where it is feasible to do so, the level of nutrition information
which we have recommended be required in respect of prepacked food should apply
equally to food sold loose and food sold prepacked for direct sale in supermarkets and
other food shops. We consider that it would be desirable for the same information
about nutrient content to be provided, in the same standard, tabular format that we
recommend above, although we do recognise that there may be some situations where
it is not practical or necessary to provide as full a range of information as is provided on
pre-packed products. Again, this should assist consumers in identifying the
information easily and in making comparisons between products. Likewise, any
nutrition signposting system which may be adopted in respect of prepacked foods
should also apply to food prepacked for direct sale. (Paragraph 137)
26.
We received virtually no evidence relating to catering services in institutions such as
hospitals and schools. Nevertheless, we do not see any reason why the same principles
should not apply to such institutions, and we recommend that the Government report
to us on what work it is currently undertaking towards achieving such an outcome.
(Paragraph 138)
Verifying food information: food assurance schemes
27.
It is not at all clear that food assurance schemes are currently providing useful and
meaningful information to consumers, and the proliferation of such schemes adds to
the confusion. Few consumers are in a position to inquire into the veracity or reliability
of the schemes’ claims. Furthermore, even where schemes are sound, they may certify
nothing more than that required minimum standards have been met—something
consumers should be able to take for granted without the need for assurance by an
external, private body. We believe that most consumers are likely to assume that the
fact that a food carries an assurance scheme mark means that it has exceeded legal
requirements in some respect. (Paragraph 155)
28.
We recommend that the Government should ensure the central registration of food
assurance schemes. All schemes should have to be registered and approved by an
identified body. The FSA would be an obvious candidate for the task. The purpose of
such schemes should be to certify that the product carrying the mark has either been:
x
produced or manufactured in a way which exceeds minimum legal standards—
for example, in respect of the environment or animal welfare—or
x
has a ‘special characteristic’, such as meeting organic or vegan/vegetarian
production requirements.
Food information
57
The registration body would have to satisfy itself that the operators of the schemes had
appropriate verification systems in place to ensure that producers taking part in a
scheme were fully meeting its requirements. We further recommend that the
Government, in consultation with stakeholders, consider ways in which this kind of
registration could limit the numbers of schemes in operation, and introduce some
common elements in labelling, in order to make it easier for consumers to understand
the schemes. (Paragraph 156)
Other sources of food information
29.
In order to improve consumers’ knowledge and understanding of nutrition and diet, a
broader education campaign about these matters is required, driven forward by both
the Government and the food industry, working in partnership with each other.
diet, from a wide range of sources. Consequently, if consumers are ever to trust
messages about diet and food, such messages must be presented in a coherent and
authoritative manner. A consistent approach between industry-run consumer
awareness programmes and Government-funded consumer education must be
adopted, with a shared aim of delivering clear and consistent messages to consumers.
(Paragraph 170)
30.
We are greatly encouraged by the positive moves made by the Government in this
direction in its recently published food and health action plan. The plan engages with
many of the themes raised in the course of our inquiry, and supports many of the
conclusions we have reached in this report. Importantly, it also specifies target dates by
which particular actions are to be achieved. We will continue to monitor the
implementation of this plan, and the coherence of the messages delivered by it, in so far
as it relates to the way in which consumers receive information about food. (Paragraph
171)
31.
We consider that implementation of our earlier recommendation, that the Government
explicitly task one government department with lead responsibility for co-ordinating
food information policy across both central and local government, would assist
enormously in achieving this consistent approach between the Government and the
food industry. The industry should be able to rely on a definitive position on food
information policy, issuing from a single source. The Government needs to provide the
industry with a single agenda with a clear list of priorities that both the Government
and industry can work towards achieving. (Paragraph 172)
32.
The food industry clearly has a key role to play in raising consumer awareness about
nutrition and diet and in making healthier choices both available and attractive.
(Paragraph 175)
33.
Little benefit to consumers’ diet will be gained from improving the provision of
nutrition information if such improvements do not go hand in hand with
corresponding changes in industry practice. We reiterate the Health Committee’s call
for the food industry to re-examine its practices with respect to matters such as pricing,
product placement and portion size. (Paragraph 176)
58
Food information
Table of legal instruments, directives and
guidelines mentioned in this report
Legal instrument/directive/guidelines
Effect
In force?
United Kingdom
Food Safety Act 1990
Sets out the fundamental principles
of food safety and labelling law;
creates an offence of falsely or
misleadingly describing or
presenting food; and provides the
legal framework under which EU
legislation is implemented in the
UK
Yes
Food Labelling Regulations 1996
Set out detailed requirements
about the labelling, presentation
and advertising of food to the final
consumer
Yes
Insert new Schedule AA1 into the
Food Labelling Regulations 1996;
Schedule AA1 lists 12 ingredients
known to cause allergies or
intolerances
Yes; from 25
November
2005, products
that do not
comply with
the new rules
will be
prohibited
from sale
FSA guidelines and recommendations
Provide non-legislative guidance
about application of food law
Not applicable
Consumer Credit Act 1974; Trade
Descriptions Act 1968; Weights and
Measures Act 1985; Consumer Protection
Act 1986
Set down trading standards
Yes
Implementing Council Directives
79/112/EEC, 89/398/EEC, 90/496/EEC and
2000/13/EC; Commission Directives
87/250/EEC, 94/54/EC and 2001/101/EC;
Directive 2003/89/EC
Food Labelling (Amendment) (England)
(No. 2) Regulations 2004
Implementing Directive 2003/89/EC
European Union
Council Directive on the Labelling of
Foodstuffs to be delivered to the
Consumer (2000/13/EC) (as amended by
Commission Directive 2001/101/EC and
Directive 2003/89/EC)
Regulates information provided to
the consumer on the composition
of the product, the manufacturer,
the method of storage and
preparation
Implemented
in the UK by
the Food
Labelling
Regulations
1996
Food information
Legal instrument/directive/guidelines
Effect
In force?
European Union
Regulation 852/2004 on the hygiene of
foodstuffs; Regulation 853/2004 laying
down specific hygiene rules for food of
animal origin; Regulation 854/2004 laying
down specific rules for the organisation of
official controls on products of animal
origin intended for human consumption;
Directive 2004/41 repealing certain
directives concerning food hygiene and
health conditions for the production and
placing on the market of certain products
of animal origin intended for human
consumption and amending Council
Directives 89/662 and 92/118 and
amending Decision 95/408
A ‘package’ of food hygiene
legislation, intended to modernise
and consolidate existing EU
legislation by introducing a ‘farm
to fork’ approach to food safety.
From 1
January 2006
Council Regulation 1493/1999 on the
common organisation of the market in
wine and Commission Regulation
753/2002 on the description, designation,
presentation and protection of wine
products
Provide that the ingredients of any
drink with an alcoholic content of
over 1.2% need not be stated on
the label, amongst other things
Yes
Commission proposal for a European
regulation on nutrition and health claims
made on foods (COM [2003] 424)
Would control nutrition and health
claims made in the labelling,
presentation and advertising of
foods delivered to the final
consumer, including foods supplied
to restaurants, hospitals, schools,
canteens and similar mass caterers
No
International
WTO’s Agreement on Technical Barriers to
Trade
Applies to regulation established
for reasons other than to protect
the life or health of people,
animals, or plants. Article 2
provides that regulation is illegal if
it restricts international trade more
than is “necessary to fulfil a
legitimate objective, taking account
of the risks non-fulfilment [of that
objective] would create”
Yes
WTO’s Agreement on the Application of
Sanitary and Phytosanitary Measures
Applies to regulation established to
protect the life or health of people,
animals, or plants. Article 2
provides that regulation is illegal if
it is maintained “without sufficient
scientific evidence”
Yes
Codex Alimentarius
The series of food standards and
related texts produced by the
Codex Alimentarius Commission,
which provides reference standards
for the WTO in the context of
settling trade disputes
In use in the
UK
59
60
Food information
Formal minutes
Wednesday 16 March 2005
Members present:
Mr Michael Jack, in the Chair
Mr Colin Breed
David Drew
Mr Ian Liddell-Grainger
Mr Mark Lazarowicz
Mr Austin Mitchell
Paddy Tipping
Mr Bill Wiggin
The Committee deliberated.
Draft Report [Food Information], proposed by the Chairman, brought up and read.
Ordered, That the draft Report be read a second time, paragraph by paragraph.
Paragraphs 1 to 176 read and agreed to.
Annex agreed to.
Resolved, That the Report be the Seventh Report of the Committee to the House.
Ordered, That the Chairman do make the Report to the House.
Ordered, That the provisions of Standing Order No. 134 (Select Committees (reports)) be
applied to the Report.
Several papers were ordered to be appended to the Minutes of Evidence.
Ordered, That the Appendices to the Minutes of Evidence taken before the Committee be
reported to the House.–(The Chairman).
Several memoranda were ordered to be reported to the House.
The Committee further deliberated.
[Adjourned till Tuesday 22 March at Four o’clock.
Food information
Witnesses
Tuesday 15 June 2004
Page
Dr Sián Astley and Dr Nick Walton, Institute of Food Research
Ev 2
Sue Davies and Michelle Smyth, Consumers’ Association (now known as
Which?)
Ev 16
Dr Susan Jebb and Adrian Penrose, Medical Research Council’s Centre for
Human Nutrition Research
Ev 30
Jeanette Longfield, Sustain
Ev 43
Linda Campbell and Paul Wright, Product Authentication Inspectorate
Ev 48
Tim Bennett and Robin Tapper, National Farmers’ Union
Ev 55
David Croft and Adrian Hill, The Co-operative Group
Ev 65
David North and Liz Kynoch, Tesco, and Penny Coates, Asda Stores
Ev 75
Neil Riding, Paula Vennells, Paul Farrow and Mark Kerr, Whitbread Restaurants
Ev 90
Julian Hilton-Johnson and Keith Kenny, McDonald’s Restaurants Ltd
Ev 98
Dr Richard Baines, Royal Agricultural College
Ev 108
61
62
Food information
Witnesses (continued)
Monday 12 July 2004
Martin Paterson, Valerie Saint and Michael Hunt, Food and Drink Federation
Ev 117
David Pickering and Phil Thomas, Trading Standards Institute
Ev 123
Neil Martinson and Rosemary Hignett, Food Standards Agency
Ev 133
Tuesday 20 July 2004
Neil Martinson and Rosemary Hignett, Food Standards Agency
Ev 137
Lord Whitty, Bill Scriven and Ian Newton, Department for Environment, Food
and Rural Affairs
Ev 149
List of written evidence
Institute of Food Research
Ev 1
Consumers’ Association (now known as Which?)
Ev 12
Medical Research Council’s Centre for Human Nutrition Research
Ev 27
Sustain
Ev 37
Product Authentication Inspectorate Ltd
Ev 47
National Farmers’ Union
Ev 54,60
The Co-operative Group
Ev 61,70
Asda Stores Ltd
Ev 72
Whitbread Restaurants
Ev 85
McDonald’s Restaurants Limited
Ev 94
Dr Richard Baines
Food and Drink Federation
Trading Standards Service
Ev 104
Ev 113,122
Ev 122
Ev 128,143
Ev 144
Food information
63
List of written evidence (continued)
British Soft Drinks Association Ltd
Ev 158
British Medical Association
Ev 160
The National Youth Agency
Ev 160
Biscuit, Cake, Chocolate and Confectionary Association
Ev 161
Waitrose
Ev 165
The Agricultural Biotechnology Council
Ev 166
Clive Dibben
Ev 166,172
The British Retail Consortium
Ev 174
Weight Watchers (UK) Ltd
Ev 178
Royal Society for the Prevention of Cruelty to Animals
Ev 180
Genesis Quality Assurance Limited
Ev 182,185
Freedom Food Limited
Ev 187
The Federation of Bakers and the National Association of British and Irish Millers
Ev 190
The Farm Animal Welfare Council
Ev 191
General Consumer Council for Northern Ireland
Ev 192
Countryside Agency
Ev 194
Advertising Association & Food Advertising Unit
Ev 199
Biosciences Federation
Ev 201
Meat and Livestock Commission
Ev 205
English Farming & Food Partnerships
Ev 207
The National Consumer Council
Ev 208
The Family Farmers’ Association
Ev 210
Assured Food Standards
Ev 211
List of unprinted written evidence
An additional paper has been received from the following and has been reported to the
House but to save printing costs it has not been printed and a copy has been placed in the
House of Commons library where it may be inspected by members. Other copies are in the
Record Office, House of Lords and are available to the public for inspection. Requests for
inspection should be addressed to the Record Office, House of Lords, London SW1 (tel: 020
7219 3074). Hours of inspection are from 9:30am to 5:00pm on Mondays to Fridays.
Department for Environment, Food and Rural Affairs (Supplementary memorandum)
64
Food information
Reports from the Committee since 2001
Session 2004–05
Sixth Report
Fifth Report
Fourth Report
Third Report
Second Report
First Report
The future of UK fishing
The Government’s Rural Strategy and the draft Natural
Environment and Rural Communities Bill
Waste policy and the Landfill Directive
The Work of the Committee in 2004
Dismantling Defunct Ships in the UK: Government Reply
The draft Animal Welfare Bill (Reply, HC 385)
HC 122
HC 408–I
HC 102
HC 281
HC 257
HC 52–I
Session 2003–04
Nineteenth Report
Eighteenth Report
Seventeenth Report
Sixteenth Report
Fifteenth Report
Fourteenth Report
Thirteenth Report
Twelfth Report
Eleventh Report
Tenth Report
Ninth Report
Eighth Report
Seventh Report
Sixth Report
Fifth Report
Fourth Report
Third Report
Second Report
First Report
Water Pricing: follow–up
HC 1186
Dismantling Defunct Ships in the UK (Reply, HC 257 Session
2004–05)
HC 834
Agriculture and EU Enlargement (Reply, HC 221 Session 2004–05)
HC 421
Climate Change, Water Security and Flooding (Reply, HC 101
Session 2004–05)
HC 558
The Departmental Annual Report 2004 (Reply, HC 100 Session
2004–05)
HC 707
Sites of Special Scientific Interest: conserving the Jewels of
England’s Natural Heritage (Reply, HC 1255)
HC 475
Bovine TB (Reply, HC 1130)
HC 638
Reform of the Sugar Regime (Reply, HC 1129)
HC 550-I
GM Planting Regime (Reply, HC 1128)
HC 607
Marine Environment: Government reply
HC 706
Milk Pricing in the United Kingdom (Reply, HC 1036)
HC 335
Gangmasters (follow up) (Reply, HC 1035)
HC 455
Implementation of CAP Reform in the UK (Reply, HC 916)
HC 226-I
Marine Environment (Reply, HC 706)
HC 76
The Food Standards Agency and Shellfish (Reply, HC 601)
HC 248
End of Life Vehicles Directive and Waste Electrical and Electronic
Equipment Directive (Reply, HC 557)
HC 103
Caught in the net: by-catch of dolphins and
HC 88
porpoises off the UK coast (Reply, HC 540)
Annual Report of the Committee 2003
HC 225
Water Pricing (Reply, HC 420)
HC 121
Session 2002–03
Eighteenth Report
Seventeenth Report
Sixteenth Report
Fifteenth Report
Fourteenth Report
Thirteenth Report
Twelfth Report
Eleventh Report
Tenth Report
Ninth Report
Eighth Report
Seventh Report
Sixth Report
Fifth Report
Fourth Report
Third Report
Second Report
First Report
Conduct of the GM Public Debate (Reply, HC 443 Session
2003-04)
Biofuels (Reply, HC 270 Session 2003-04))
Vets and Veterinary Services (Reply, HC 974 Session 2003–04)
New Covent Garden Market: a follow-up (Reply, HC 123
Session 2003-04)
Gangmasters (Reply, HC 122 Session 2003-04)
Poultry Farming in the United Kingdom (Reply, HC 1219)
The Departmental Annual Report 2003 (Reply, HC 1175)
Rural Broadband (Reply, HC 1174)
Horticulture Research International (Reply, HC 1086)
The Delivery of Education in Rural Areas (Reply, HC 1085)
The Future of Waste Management (Reply, HC 1084)
Badgers and Bovine TB (Reply, HC 831)
Rural Payments Agency (Reply, HC 830)
The Countryside and Rights of Way Act 2000
(Reply, HC 748)
Water Framework Directive (Reply, HC 749)
The Mid-term Review of the Common Agricultural Policy
(Reply, HC 615)
Annual Report of the Committee 2002
Reform of the Common Fisheries Policy (Reply, HC 478)
HC 220
HC 929-I
HC 703
HC 901
HC 691
HC 79-I
HC 832
HC 587
HC 873
HC 467
HC 385
HC 432
HC 382
HC 394
HC 130
HC 151
HC 269
HC 110
Food information
65
Session 2001–02
Tenth Report
Ninth Report
Eighth Report
Seventh Report
Sixth Report
Fifth Report
Fourth Report
Third Report
Second Report
First Report
The Role of Defra (Reply, HC 340, Session 2002-03)
The Future of UK Agriculture in a Changing World
(Reply, HC 384, Session 2002-03)
Hazardous Waste (Reply, HC 1225)
Illegal Meat Imports (Reply, HC 1224)
Departmental Annual Report 2002 (Reply, HC 1223)
Genetically Modified Organisms (Reply, HC 1222)
Disposal of Refrigerators (Reply, HC 1226)
Radioactive Waste: The Government’s Consultation
Process (Reply, HC 1221)
The Countryside Agency (Reply, HC 829)
The Impact of Food and Mouth Disease (Reply, HC 856)
HC 991
HC 550
HC 919
HC 968
HC 969
HC 767
HC 673
HC 407
HC 386
HC 323
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Environment, Food and Rural Affairs Committee: Evidence Ev 1
Oral evidence
Taken before the Environment, Food and Rural Affairs Committee
Food Information Sub-Committee
on Tuesday 15 June 2004
Members present
Mr Mark Lazarowicz, in the Chair
Mr David Drew
Mr Michael Jack
Joan Ruddock
Mr Bill Wiggin
Memorandum submitted by the Institute of Food Research
1. The Nutritional Content of Foods
IFR believes that it is important that nutritional information is presented to consumers in a balanced way.
From a nutritional viewpoint, the vast majority of individual foods do not have an ideal composition and
it is the frequency of consumption and the composition of the diet as a whole that are significant. Cheese,
for example, whilst usually a high-fat food, can be an important component of a balanced diet and can
contribute appreciably to overall calcium intake.
Encouraging consumers—particularly children—to be aware of the long-term health implications of what
they eat is critical. Such awareness requires balanced nutritional information to be presented on the one
hand and recognition by consumers on the other that they must make “active” choices. One important
initiative in this field, involving IFR researchers, is the SMARTCARD scheme, which enables dietary choice
through school meals to be monitored at point of purchase. Regulators, health educators and the food
industry all have a part to play in ensuring that consumers are presented with balanced, accurate nutritional
and compositional information. This should include unambiguous information on the eVects that food
processing may have on composition.
2. The Safety of Foods
This has been a major topic of public concern from the 1980s onwards as a result of successive, high-profile
episodes in the UK and elsewhere (Salmonella in eggs, BSE, GM crops, acrylamide). IFR is active in a
number of research programmes aimed at exploring consumer attitudes to food-safety risks. An important
principle is that consumers tend to demonstrate a greater level of concern in relation to risks that they
perceive as being beyond their control; thus, microbiological risks in the kitchen may be ignored because
the consumer believes (s)he is in control of them. This has implications for the safety labelling of (for
example) chilled, ready-to-eat foods. Further, a social climate in which, in general, less time is being spent
by consumers in the purchase and preparation of raw foods may tend to encourage an increased expectation
that foods, as bought, should be completely safe.
Against this background, it is very important that robust standards of (particularly) microbiological
safety and shelf-life recommendation are maintained. This is particularly so in the light of global sourcing
practices. Precautionary food-allergen labelling is a critical issue in view of the potentially fatal
consequences for susceptible individuals.
3. The Means of Production of Foods
There is considerable scope for confusion and misunderstanding in this area. Terms such as “pure” and
“natural” may convey messages to the consumer that diVer from the precise definitions understood by
regulators and by food manufacturers. The status of the term “natural” in relation to GM products, for
example, needs to be resolved. Terms such as “home-made” may have an imprecise meaning. In some cases,
consumers may not be clear what information is conveyed by a logo, for example the “Red Tractor” symbol.
In recent years, there have been substantial advances in chemical profiling and spectroscopic techniques
(notably SNIF-NMRC, isotope-ratio mass spectrometry and multi-element mass spectrometry) for the
diVerentiation of food products according to their geographical origin and/or means of production. IFR is
one of the lead organisations undertaking research in this field, funded under contracts from FSA and from
the EC. DiVerentiation between organic and conventional production is in principle possible using isotoperatio approaches. It may be possible to detect clear evidence in meat of animal movements prior to slaughter,
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Ev 2 Environment, Food and Rural Affairs Committee: Evidence
and thereby to confirm whether animals have been reared for the required period in a claimed region of
origin. Such developments are increasingly important in underpinning labelling practices and in providing
analytical evidence acceptable in courts of law.
The EC has recently announced over 25 million Euro of funding under the Sixth Framework Programme
(FP6) to two new Integrated Projects—SAFE FOOD and WELFARE QUALITY—under Priority 5—
“Food Quality and Safety”, which are the first to take a “fork to farm” approach, addressing both consumer
concerns and market demands. These new projects bring together researchers from Europe and beyond on
an unprecedented scale and with ambitious goals. The research activities will underpin the development of
European standards of best practice in food quality and safety, through dialogue and knowledge exchange
and the implementation of the European Research Area (ERA). The remit of WELFARE QUALITY is
“Integration of animal welfare in the food quality chain: from public concern to improved welfare and
transparent quality”. Animal welfare practices aVect “quality of life” for livestock, thereby influencing
disease incidence and product quality, and are of substantial concern to both consumers and producers.
Both Integrated Projects aim to restore consumer confidence whilst improving the quality of food, by
stimulating the development of sustainable production systems.
4. Ethical Considerations
Many consumers take account of ethical considerations when buying foods, for example those sold under
the “Fairtrade” logo. Consumers may not always be clear precisely what benefits are associated with such
designations. There are further concerns of energy eYciency, agrochemical inputs and “food miles”. Some
of these issues might in principle be addressed by the analytical approaches outlined in (3) above. Labour
practices are problematic since they are not traceable though the food products themselves. Enforcement is
therefore ultimately dependent upon inspection and certification. This is a field where further research may
be required to clarify current practices.
20 April 2004
Witnesses: Dr Siân Astley, NuGO Communications Manager and Dr Nick Walton, Senior Research
Scientist, Institute of Food Research, examined
Q1 Chairman: Good afternoon. Can I welcome you
to this first meeting in this series of evidence sessions
looking at the question of food information. Can I
say, first of all, if anyone wishes to remove their
jacket please feel free to do so, if they have not done
so already, given the heat of the day. Can I welcome
you, Dr Astley. I understand you are now joined by
Dr Walton from the Institute. Perhaps you could,
for the record, Doctor, tell us what your
responsibilities are within the Institute and then we
will go on to the questions?
Dr Walton: I am sorry?
Q2 Chairman: Perhaps we can ask you, for the
record, to tell us what your post is in the Institute
and then we will move on to the questions?
Dr Walton: I am a senior scientist in the Institute of
Food Safety, Science Division, with a responsibility
for developing platform technologies within the
Institute, and I am also a member of the Institute
Science Communication Team; so my scientific
background is as a bio-chemist.
Q3 Chairman: Thank you very much indeed, Dr
Walton. Dr Astley, can I welcome you too to the
Committee and thank you for both your written
evidence and also coming to give evidence to us this
afternoon. Dr Astley, do you want to introduce
yourself as well?
Dr Astley: I am currently the communications
manager for a European project, the European
Nutrigenomics Organisation, which has an interest
specifically in the relationship between diet and
genes. However, I have been a research scientist for
the last 14 years, 12 of which have been at the
Institute, with a specific interest in the eVect of
dietary compounds on DNA damage and repair.
Q4 Chairman: Could I begin by asking you to tell us
how helpful you think the current food labelling
requirements which are in existence are in assisting
consumers to follow a well-balanced and nutritious
diet. For example, is it satisfactory that provisional
nutritional
information
is
generally
not
compulsory?
Dr Astley: To take the first part of your question, I
am not sure that the labels are helpful, but there are
two problems in that. Firstly, the information that is
conveyed is perhaps suYcient in terms of the
information alone but it has no context and
therefore perhaps for consumers it is diYcult to
interpret, particularly for their individual
circumstances. It depends what you are trying to
achieve with the labelling whether you can
determine it is useful. As for the second part,
compulsory labelling, I do not pretend to be an
expert on that and I do not know that I have a
comment on it. My only remark is that, if you are
going to do it, it should be useful for the consumer
to make choices.
Q5 Chairman: Have you carried out any research in
ways of indicating to consumers whether levels of
nutrients in food are high, moderate or low?
Obviously, fat, sugar and salt. Have you done any
research on this and what is your view of that kind
of practice?
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15 June 2004 Dr Siân Astley and Dr Nick Walton
Dr Astley: We have not done any specific research in
terms of the labelling. It is an area of interest to us
because we are trying to achieve choice for
consumers in their food selection and their lifestyle
and dietary behaviour. The concept of a traYc light
system would perhaps work: because one of the
problems with consumers at the moment is that they
are not reading the labels. Most people when they
walk around their supermarkets selecting items
select because they want to eat that, or they think
they should be eating that product; they do not
actually read the labels. If you are going to try to
convey information to encourage consumers to
make choices that are positive for their own health,
you have to try to convey that in as simple a method
as possible, and that is where the traYc light system
has stemmed from, the idea that perhaps it could be
used to convey information more eVectively whilst
still allowing more detailed information to be
available, such as the current labelling.
Q6 Chairman: It has been suggested, as you know,
that a traYc light system could have the eVect of
demonising particular—
Dr Astley: Absolutely.
Q7 Chairman:—foods in a way which might be
inappropriate for that particular consumer’s needs?
Dr Astley: I think it is very important that
consumers understand that there are no bad or good
foods as such, there are only poor choices in dietary
behaviour. It would be inappropriate for them to
always assume that something that was labelled red
should be excluded from the diet. If you were to take,
for example, full-fat milk, because of the percentage
of fat that is in it, it might be labelled red, but it
would not be appropriate, for example, for underfives to stop consuming full-fat milk. Another food
that might be labelled red would be cheeses, both in
terms of fat content and also salt content, but again
it would be inappropriate if those items were entirely
excluded from the diet, since they provide a good
source of calcium.
Q8 Chairman: How would you try to ensure that
balanced information was provided?
Dr Astley: I think that is the biggest diYculty you
have with the labelling. It is not suYcient to inform;
you must put it into context. You must provide the
consumer with something to balance it against,
perhaps to say not, “Do not consume the red label
products”, but, “Do not consume more than four or
five in a week, or four or five in a day”, so that it is
balanced across the entire diet and not as a single
item.
Q9 Chairman: What about guideline daily amounts?
Should that be included as a compulsory
requirement?
Dr Astley: I think it would be very helpful to have
daily guideline amounts, but we have diYculty
oVering guidelines for elements of the population in
terms of foods and nutrients as it is. We have the
information from COMA, we have the publication
of nutritional requirements, but those are based on
a best guess system for a whole population, they are
not designed to provide information for the
individual, and it is diYcult to provide information
for the individual, but, if a successful consensus
could be achieved amongst those interested parties
that that is an appropriate level for the population to
aim at, allowing for the fact that individuals may
have to modify it in one direction or another
according to their circumstances, according to their
life style, then, yes, we should provide some sort of
context.
Q10 Mr Wiggin: I am going to ask you a question
about diVerent types of labelling in a minute, but one
of the things you are suggesting, particularly with
the traYc lights, is that we have to tell people what
is good for them and what is not when they are
shopping. Once we have assumed that food is safe to
eat and therefore it can be sold in shops, is it not fair
to say that people will read the labels later?
Dr Astley: No, they do not.
Q11 Mr Wiggin: When they are eating it, when they
are curious? There are diVerent types of people:
people who may have a nut allergy, who need to read
the label, people who may be mildly curious and
people who think that the nanny state should tell
them what they should and should not eat. The truth
is that people who need information might find it
easier to have a bar code reader that they take
around the shop with them to check that there are no
nuts in what they are buying, and the rest of us, who
may be less at risk, can take a totally diVerent
approach, because more and more what we are
seeing is that we are being told what is good and
what is not; and you put your finger on it when you
said you simply cannot simplify it that easily?
Dr Astley: No, you cannot.
Q12 Mr Wiggin: So there must be a better way to
do this?
Dr Astley: A better way to what: to provide the
information?
Q13 Mr Wiggin: To inform the people that need to
know and to stop telling us that we are all—
Dr Astley: I am not sure that you can categorise
people any more easily than you can categorise food.
Who is to say at any one stage whether you need to
know that information or not?
Q14 Mr Wiggin: So the traYc light thing is not that
useful, because you were just saying it was?
Dr Astley: No, I am saying it may have a use. There
are limitations to the traYc light system. No system
is going to be perfect. We cannot necessarily provide
information for an individual. We can perhaps take
sub-groups of the population. A reasonably fit man
between the ages of 20 and 50 might like to have X
number of red products, X number of amber and X
number of green during the day or during the week,
but there runs the potential that that individual may
have a genetic pre-disposition to cardiovascular
disease that he is unaware of.
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Q15 Joan Ruddock: I think what you have begun to
describe is extremely important to us, particularly in
the context of what the Health Select Committee has
said about obesity. So I would not agree with my
colleague. It seems to me that there is a major
concern that government has to have, which is that
two-thirds of the population are deemed to be overweight or obese, and, given that is the case, perhaps
most of us do need telling about what potentially
could be good and bad for us, so they are proposing
that there should be a compulsory labelling
classification system that would enable people to eat
healthily. Would I be right in thinking that you
would say that that is not an easy thing, which I
think you have said, but is it potentially possible
with a type of traYc light system, with the kind of
guidance that you suggest, given that it is only
appropriate as an average recommendation, but
might not it take us much further than we are today
where, unfortunately, so many people are making
what seem to be the wrong choices for their
particular physique?
Dr Astley: I certainly take your point. I think it has
to be understood, of course, that obesity is not
simply about food choice, it is about a whole lifestyle
choice, and I think sometimes there is a false
separation of lifestyle and food choices which needs
to be overcome. Anything that facilitates consumers
to make choices in their food selection and their
dietary behaviour within the context of their lifestyle
can only be a good thing, but it is not helpful if we
label the foods without putting it into context,
without providing individuals with the additional
information. Not everybody is going to read it, not
everybody reads the information that is currently
available, but I suspect that if you took a large
majority of the public and asked them what the
labelling currently means, they do not understand it.
There is a minority that does, there is a minority that
has to for the sake of their own health, but they do
not apparently understand the information that is
being conveyed. To give you one example, on a fizzy
drink can you will find carbohydrate, X number of
grams. The choice not to split that down into
starches and sugars means that for most individuals
they are aware they should eat a high carbohydrate
diet; it looks like a sensible choice.
Q16 Mr Wiggin: There is a diVerence between not
reading something and not understanding it.
Q17 Mr Wiggin: I will just give you a chance to
clarify that a bit, because I think that you were right
when you said they do not understand what they
read?
Dr Astley: I think there is a large percentage that
does not read it and there are those that do read it,
perhaps, as you suggest, out of curiosity, but still do
not necessarily obtain the information that they
seeking from it.
Q18 Mr Wiggin: That takes me into the next phase,
which is people who may buy something to take
away which may have information on it and then go
to a cafe, a restaurant, a fast-food outlet and buy
food from the catering sector over which they have
no information and are unlikely to get any. How do
we deal with that?
Dr Astley: Again—
Q19 Mr Wiggin: It would blow your red spot count,
would it not?
Dr Astley: Absolutely, but perhaps if we are able to
facilitate a greater level of understanding in
purchasing products that are labelled, that can be
carried over by the individual in their choices outside
those foods that are labelled. So if someone has the
opportunity to buy, for example, a meat in a
supermarket that does have the label, they are going
to understand that that transfers to meat outside the
supermarket; they are going to understand, if they
are looking at a dressing, for example, that is
purchased in a supermarket which has the labelling,
that it will equally apply to dressing outside the
supermarket context. I do appreciate that it is
diYcult to carry it across, but maybe we just have to
be creative in our ways. Why can we not ask
McDonalds or Burger King, or whatever, to put
labels on it? Not everything is bad about those foods;
it is just the frequency that they are consumed that is
an issue.
Q20 Mr Jack: You have illustrated already in what
you have said, Dr Astley, that this is a complex series
of interactions. During the war the message was that
if you ate carrots it would improve your night vision?
Dr Astley: I believe they were hiding radar at the
time!
Q21 Mr Jack: It was some time later that I first of all
discovered that you had to eat 22 tons of carrots—
Dr Astley: Exactly.
Q22 Mr Jack:—before you had enough carotene to
have any measurable eVect, and that basically
carrots were available and other foods were not. So
if you wanted to divert the public you put out this
clear dietary message with a real gain at the end—
“seeing in the dark”—but the reason for it was
totally diVerent. Ever since I heard that it intrigued
me. First of all, is there any body of research which
tells us what messages about food and lifestyle (the
interaction which you mentioned a moment ago) are
actually picked up on and believed by the public?
Has anybody done any research?
Dr Astley: There are groups. There is certainly a
group at Waganingen University in the Netherlands
that looks at this, and TNO, which is the equivalent
of the Institute of Food Research, if you like, but not
identical, which is also in the Netherlands, and also
our own institute, who all have consumer science
departments which examine how the public respond
to scientific messages, the understanding, how much
they believe, whether they trust the sources, etcetera.
Q23 Mr Jack: Given that there are various attempts
to satisfy society: A, B, C, D and all these various
descriptions, does any of this research touch on the
diVerent ways that diVerent people from diVerent
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backgrounds with diVerent educational potentials
and opportunities also react to this myriad of
messages and information?
Dr Astley: Yes, I believe that the National Centre for
Social Research, based in London, has actually done
some research at diVerent levels as well. We certainly
have looked at the responses, yes.
Q24 Mr Jack: It would be very helpful, if I could ask
you on behalf of the Committee, perhaps to distil
out, if there is some indication of that, because it
strikes me that there is no shortage in total terms of
information about food and diet, but in specific
areas, as my colleagues have touched on already,
there are areas of concern. Why does not the public
react? None of this is new. We have had messages
about food and diet for as long as I can remember.
Dr Astley: There are a number of primary reasons
they do not react. The first is lack of trust: lack of
trust of government, lack of trust of science,
particularly in the UK, because of the issues related
to BSE and Salmonella in eggs. There is also a
certain degree of cynicism because the science
message is seen as being confused and contradictory.
In fact that is not true, that is an issue with perhaps
a failing on the science and also a bias in the media
for looking for the threat or the sensational story
rather than the commonsense one.
Q25 Mr Jack: So what do people trust?
Dr Walton: People trust openness. They are not
afraid for people to say that they do not know or that
people have to wait for the answers.
Dr Astley: They are happy for us to say, “We believe
that this diet generally is okay within limitations”,
much more than us saying, “You should eat that”.
Q26 Mr Jack: Let me pin you down on that, because
in recent times the Atkins diet has suddenly acquired
millions worldwide of adherence, and it would
appear that the recommendations have been trusted,
to use your phrase, by a lot of people very quickly.
Why is it that things like that can suddenly take oV
whereas some of the messages about health, activity,
lifestyle that you referred to earlier seem to be
diYcult to get the same kind of response as
something like the Atkins diet?
Dr Astley: I would suggest that perhaps the Atkins
diet has worked for two reasons: that people’s own
experience demonstrates that it works. Regardless of
some of the questionable medical risks related to it,
it does actually stem from dietary advice for
individuals who have a particular problem
processing carbohydrates, but it is just that it has
been taken to an extreme. So we know that it works.
The other issue is those it is being supported by, such
as celebrity in the press.
Q27 Mr Jack: Are you saying that it is as important
to get the right messenger as the message?
Q28 Mr Jack: Why then has the world of
oYcialdom, according to a lot of findings, and the
Health Select Committee report might be a
reflection, seemingly failed in its task to get across all
of the good messages, whereas it is required to get
celebrities associated with something like Atkins to
instantly break through to a public who, until they
try it, have no experience, so they have nothing to
say, “Shall I or shan’t I? Okay, I will have a go
because X says it is good.” Does the Government in
dealing with this Department of Health need some
of the X factor?
Dr Astley: Perhaps you need to be honest about
what you are trying to achieve. It is more than
informing; it is educating; to some extent it is even
manipulating, but manipulating with the view to the
benefit. Do you need part of the X factor? Yes, you
probably do. You certainly need, if you are trying to
get these messages across, the cooperation of the
media and those that are able to convey the message
to the public en mass.
Q29 Joan Ruddock: Is it not possible that some of
the very good messages and some of the science is
being drowned out by advertising and by the
celebrity promotion of foods that are extremely bad
for people because of their high content of salt and
high content of sugar?
Dr Astley: There is a problem with advertising which
implies health. They are not allowed to advertise on
the basis of health claims unless they can be
supported by scientific evidence, but we are all aware
that there is advertising which implies, and that
certainly drowns out a degree of the science. It is not
as sexy; it does not come across in the same way in a
media that is seeking sexy stories.
Q30 Mr Jack: I want to pick up on one thing you
said earlier about food labelling. You said, “It
depends what you are trying to achieve.” What do
you think food labelling should try to achieve?
Dr Astley: I think it should actually try to achieve to
educate and in educating it then allows individuals
to make choices for themselves, because you cannot
give them information that they cannot use.
Q31 Mr Jack: Does that imply, for example, on a
packet of biscuits, where you can have four or five
lines of complex ingredients including many E
numbers and chemical terms, that that is not
labelling which is helpful to the consumer in
choosing food?
Dr Astley: I do not want to get dragged into the E
number argument, but, no, I do not believe it is
desperately helpful for the consumer: because they
have to go and look up what those E numbers are,
and in some cases they are quite often food products
themselves; they are things like vitamin C. Why not
write vitamin C? It means something more to the
consumer than perhaps E whatever it is. Complex
lines of ingredients—they are currently obliged to be
there, but if you are going to provide that extent of
information in terms of ingredients, why not also
provide the context for the nutritional labelling that
will enable people to make use of it?
Chairman: We are going to go into this point in a bit
more detail in a minute, but can I ask Joan to take
up some points on education.
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Q32 Joan Ruddock: Yes; indeed. Part of your written
evidence said that you were involved in a project
involving a Smartcard scheme in relation to schools
and the purchasing of food by children. I wonder if
you could describe that briefly to us and then we
would like to ask some questions about it?
Dr Astley: The Smartcard scheme stems from a
problem that we all have with nutritional
assessment, that is to say that they are paper based.
So, for example, an individual who you are trying to
assess what they are eating would be given a food
diary and you may be asked to keep a note of what
you consume during a day, a week, a month,
whatever. There are a number of other methods
for looking at these issues; food frequency
questionnaires, for example, so that you tell the
questioner how much you eat those, how frequently
you eat them. There are a number of problems with
all of these methods, such as the fact I can guarantee
if I gave you all a bag of peas and asked you to put
a portion out not one of you would give me the same
amount. Frankly, I do not remember what I ate
yesterday; I doubt you do either. So there are
fundamental problems in accurately recording this
information. There is also the problem that
consumers generally can be biased in their responses
to these questionnaires by the person asking the
questions. They [the questionnaires or the person
putting the question] can imply that there are good
and bad foods and so they [respondents] will tend to
give more information about the good foods and
hold back the information of what they perceive as
bad foods. If you are to assess nutrition, assess
choice, then you have to find as unbiased a way of
determining food consumption as possible. The
Smartcard technology has existed for a number of
other uses—it is literally the credit card swipe
technology—and it was given to a thousand pupils
in local schools, and all it did was record what they
purchased, not what they ate. So there is still the
problem that if they did not eat the salad, it is still
sitting on their tray, okay. That information that
was collected on these cards was then tied up with a
food choice data set in a full nutritional break down
which enabled the children to look at what they had
eaten, in terms of both the foods themselves and also
the nutrients, and to be able to discuss that within
their needs in terms of their diet. With 21st century
technology, this kind of technology is very cheap but
a highly eVective way of determining what is eaten at
the point of purchase.
Q33 Joan Ruddock: What did you do with the data?
You have supplied it to the school children, they
have had discussion about it presumably, but has it
gone further?
Dr Astley: Not that I am aware of currently?
Dr Walton: I think it is being—
Dr Astley: Discussed?
Dr Walton: Yes, and we are looking for it be taken
up rather more widely. We are looking for
opportunities to get it taken up basically. It would be
rather nice if it was taken up in a more widespread
sort of culture.
Q34 Joan Ruddock: What were your findings about
what the children were doing terms of choices?
Dr Astley: The project is not completed; so I am not
able to discuss that.
Q35 Joan Ruddock: Can you tell us when it might be
completed?
Dr Astley: It will be completed in September 2004.
Q36 Joan Ruddock: A little too late for our inquiry,
but, nonetheless, very pertinent to it. When you say
it is cheap, is it feasible that this sort of project could
be made available in every school?
Dr Astley: Absolutely, yes. I think those that have
been on the project would say that it was; and it has
a number of other, if you like, spins on it. The
children can be rewarded if they have eaten a
number of foods that can be regarded as good,
although, as I say, I do not like the label of “good”.
Q37 Joan Ruddock: It is about balance?
Dr Astley: It is about balance for that individual,
and, if they are seen to be eating a balanced diet, they
can be rewarded through that points scheme as well.
The credit card can work both ways: as well as
recording the information it can reward them with,
for example, a free purchase.
Q38 Mr Wiggin: What diVerence is it going to make?
There are people who are obese, there are people
who have allergies, but if you are sort of normal in
terms of your physique, how much does it matter
and what are we really talking about here?
Dr Astley: Thirty per cent of diseases that we
associate with ageing, such as cardiovascular
disease, cancer, cataract, arthritis, etc, are directly
preventable through diet; so that diseases that
currently cause a huge impact in terms of both
mortality and morbidity in our ageing population
we know can be prevented through dietary choice.
Q39 Mr Wiggin: And that will be specific. Could I
ask you about things like sodium and salt? What is
your view on how that should be labelled?
Dr Astley: I am not an expert on sodium or salt, but
I have consulted with the individual in the Institute
that is.
Q40 Mr Wiggin: I am going to ask you about protein
as well, if you are checking it out?
Dr Astley: The issue with sodium and salt is an issue
of understanding. For most individuals sodium is
fairly meaningless, whereas salt is easily understood.
We should not be eating as much salt as we are. Most
of our salt, however, stems from processed foods
and not what we add at the table or what we add
during cooking, although there is a strong argument
for reducing both of those. Labelling sodium I do
not believe would be helpful, and nor do our experts;
labelling salt is, as that will enable people to make
the decision to reduce their salt intake. Why does it
matter if you reduce your salt intake? Because for
some individuals there is the link between salt intake
and high blood pressure: high blood pressure,
cardiovascular disease, etcetera.
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Q41 Mr Wiggin: What about protein?
Dr Astley: Protein. The clerk commented that
nobody suVers from protein deficiency in this
country. That is quite correct. There are very few, if
any, individuals who suVer from protein deficiency
in this country. However, there are individuals for
whom a high protein intake is not appropriate—
those with kidney disease in particular, diabetics
who have nephrology, changes in their kidneys as a
result of diabetes, who do need to monitor their
intake of protein—and therefore, for those
individuals, it is very helpful that that is there. I take
your point that you could argue that those
individuals are given a way of assessing it through a
bar code system. However, we label all our products
containing phenylalanine for a very small
percentage of individuals who suVer from PKU, and
those individuals who suVer from kidney disease,
which means they have to watch their protein intake,
are by far a greater number.
Q42 Mr Wiggin: What about the requirement for
food labels to give energy measurements in calories
or kilojoules? What is a kilojoule in terms we can
understand?
Dr Astley: I do not think you need to worry about it.
I am not being—. I cannot give you the precise
definition. Can you give a precise definition of
kilojoule?
Q43 Mr Wiggin: Do not give a precise definition. My
question is quite the opposite. I do not want a precise
definition; I want to know roughly how a man in the
street, such as myself, might understand what a
kilojoule is. How far do I have to walk, how far do
I have to jump, what do I have to do to use a
kilojoule’s worth of energy?
Dr Astley: I did for the sake of the Committee look
up the definition. Technically, it says that one calorie
is raising one gram of water one degree C. As you
say, you do not need to worry about it.
Q44 Mr Wiggin: You said that. I did not actually!
Dr Astley: As an adult male, you need to consume
around 2,500 calories a day.
Q45 Mr Wiggin: So that is a Mars bar and a half or
something?
Dr Astley: Something about that, yes.
Q46 Mr Wiggin: How far do I have to go, or what
do I have to do to burn oV a kilojoule’s worth of
energy? We are putting this on the food labels. Do
we need to bother?
Dr Astley: You do need to bother because the most
successful way in which people are able to monitor
and to reduce their weight is by a caloriecontrolled diet.
Q47 Mr Wiggin: Do we therefore need to do
kilojoules though?
Dr Astley: Kilojoules are the SI unit, the standard
scientific unit, metric unit, and therefore you do need
that information. However, in the same way that we
give temperatures on weather charts in degrees C
and then give them in Fahrenheit for the sake of the
British population, I see no harm in also having
calories on there.
Q48 Mr Wiggin: I totally understand why you are
saying what you are saying, but I do not think, when
you look at your evidence earlier when you said most
people read the label but do not either understand it
or do not even both to read it, when we have
something like this, which you say is useful, under
pressure you still cannot tell me anything about my
kilojoule or my calorie that I need to know?
Dr Astley: I can tell you that you need two and a half
thousand of them in a day?
Q49 Mr Wiggin: That is an awful lot of reading to
work out what my shopping trolley is worth, is it
not?
Dr Astley: Yes, and that is why I say it is not a
successful way of communicating much of this
information.
Q50 Mr Wiggin: But you just told me it was the best
thing we did?
Dr Astley: It is the best we have.
Dr Walton: This can be done quite simply. If you can
imagine a sliding scale of colours, for example
where, if you are consuming a food which is a red
colour, as opposed to pale pink, then you are getting
close to your recommended daily intake of calories
for individuals. It could be as simple as that if you
wanted it to be. I think it is a bit of a red herring to
get into talking about the numbers too much.
Q51 Chairman: Is not one of the points that putting
information into kilojoules as well is basically filling
up a label with mixed information which hardly
anybody understands simply takes up more space.
Just sticking to the calorie total would be suYcient
surely?
Dr Walton: I think there is a general principle of two
styles of labelling, that you have easily readable
bullet point labelling, preferably pictorial, for
maximum transfer of information to the wider
population and for people who want more precise
information who are taking the trouble to look at the
labels and reading what is said.
Q52 Joan Ruddock: I was checking the bottle of juice
I drank at lunchtime to see how many kilojoules it
had. It said 1600; so I am slightly worried already! I
wanted to ask you about energy dense foods. Again
the Select Committee on Health had something to
say about this. They said they were highly calorific
without being correspondingly filling, and they are
becoming increasingly available. What are they?
Dr Walton: An energy dense food is a food that
provides a lot of energy in relation to its overall
mass, and very often not a lot else.
Q53 Joan Ruddock: Presumably they are mostly
processed foods, are they? They are becoming
increasingly available. What is going on that we are
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producing things that are so energy dense that they
are representing a problem, whereas most people
would think that getting energy is a good thing?
Dr Walton: We are rather good at getting energy;
that is part of the obesity problem. You cannot
identify totally with processing. For example, raw
nuts are energy dense food by anybody’s definition.
Dr Astley: The energy is being sourced from fat and
from sugar, which is why there can be a problem.
Q54 Chairman: Why is there an apparent growth in
this type of product on the market?
Dr Astley: Why is it a problem?
Q55 Chairman: What are the factors leading to this
growth in consumption?
Dr Walton: Consumers buy them easily and they are
attractive to eat, attractively packaged.
Q56 Joan Ruddock: For example, are they the drinks
that we see—I never drink any of these things, so I
have no idea—these energy promoting drinks, fizzy
stuV, coloured stuV? Are these products in this
category?
Dr Walton: I suspect that many people would define
them as energy dense foods.
Q57 Mr Jack: Can I follow on from that? Earlier on
you said that a so-called “normal” man needed two
and a half thousand calories a day, but in your
earlier answers you quite rightly related the
consumption of this energy to what people do, to
activity?
Q58 Mr Jack: Have you done any work about how
people put the two together in a meaningful way?
Because most people are out at work. They can
control what they have at breakfast. They are the
recipients, by and large, of a range which has been
determined by others for lunch, if they are eating in
their workplace or they go out to eat, and they might
or might not have some choice about what happens
in the evening, depending on their ability to shop.
Against that background, people have all kinds of
varying uses of the energy that they put in, and, if
you start to analyse all the variables, it becomes a
complex subject. Against that background you have
got somebody saying, “You have got to eat
healthier, you have got to take exercise, you have got
to do this”. How do you think people ought to
answer that question about what is right for them?
Dr Astley: I do not think at the moment that they are
able to do that with the information that is supplied.
There are charts that give suggestions of what you
should consume if you have a sedentary job versus
an active job. I do not think suYcient information is
available for individuals to make those decisions.
Q59 Mr Jack: Let’s hold you at that point. Who
would you think should make that information
available?
Dr Astley: I think initially you have to source that
from a scientific source and move it outwards—
Q60 Mr Jack: But who is the “you”.
Dr Astley:—using media.
Q61 Mr Jack: But who is the “you”? Should it be the
Government? Should be it be employers? Should it
be supermarkets? Who is the “you”?
Dr Walton: I think there is government
responsibility to do this and I think that the public
would expect that the Government would take and
have a leading role in doing that.
Dr Astley: And the medical and associated
professions.
Q62 Mr Jack: How do you respond to the fact that
when the Government starts putting information
like that out it starts getting hit by the “nanny
state” label?
Dr Astley: Because there is a diVerence between
putting that information out in a way that is
providing information, as Nick described, and
oVering that information for use as opposed to
dictating what the individual should be doing.
Q63 Mr Jack: Do you think that the Government
should make positive eVorts, in other words not just
simply put information out in printed form? I mean
there is a myriad of ways the Government
communicates with the public, but do you think they
should be more proactive? Should there be more
interaction between individuals and representatives
of the Government? Should there be individual
counselling on these matters?
Dr Astley: I think the Government should take every
opportunity and route that it can to put that
information out into the general public. Schools are
one source. You can take that information out into
schools. You can take the information out through
consumer groups. You can encourage the food
industry to put that information out. There are a
number of ways in which the information can be
taken out into the public sector.
Q64 Mr Jack: But, if I read you correctly, within
that mix of opportunities and information you
currently do not believe that what is available now is
satisfactory for the job that has to be done?
Dr Astley: No, I do not.
Q65 Mr Jack: Right. That is very helpful. Let’s
move on to the question of food safety. One of the
things that strikes me is that you still have an awful
lot of problems arising particularly from when
people have eaten out of the home because they have
all kinds of unspecified illness as a result of that, and
we have seen large increases of that in terms of
micro-biological safety. But if we have a look at the
question of what people can influence themselves, do
you think that risks with food are properly
communicated in the context of the labelling
discussions we had earlier?
Dr Walton: Not always. There are specific examples,
for example, where labels are actually hidden or are
not easy to read. One that comes to mind is vacuum
packaging where the label telling you that the
product is protectively wrapped is only legible once
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you have removed the wrapping. This occasionally
happens. More information—simpler information,
not more information, but simpler information
could probably be given on foods with regard to how
to store them, how long keep them, the portions you
should be using.
Q66 Mr Jack: Coming down to the work, has any
work been done to identify or to analyse risks in the
context of home preparation of food?
Dr Walton: A great deal.
Q67 Mr Jack: So where is the area of maximum risk
that this poor labelling which you have mentioned a
moment ago is a contributor? In other words, where
is the area of maximum risk?
Dr Walton: I would not like to say definitely, but
there is a lot of concern about preparation in the
home.
Q68 Mr Jack: Preparation?
Dr Walton: About preparation of foods in the home.
Q69 Mr Jack: Would you like to develop that,
because clearly it is all right telling people what they
ought to eat, but, if they cannot cook it or prepare it
safely, we are into some diYculty. A bad experience
with good food can put people oV the good food?
Dr Walton: Yes; several points. People tend to
assume that what they do is safe, on the whole.
“Food safety, food poisoning is someone else’s risk.
It does not happen in my family. I prepare the food
in the way I have always done and I do it as well as
anybody and better than most.” That is what people
do not recognise, that they are as likely as other
people to have a food poisoning risk in the home.
They automatically assume that they are
conforming to good practice.
Q70 Mr Jack: But in terms of communicating those
messages, you have described to me some of the risk
factors. What I am still not quite clear about is what
are the main causes of risk at home?
Dr Walton: Dirty dish cloths is one.
Q71 Mr Jack: Dirty dish clothes?
Dr Walton: Yes.
Q72 Mr Jack: So labelling food products is not
going to deal with dirty dish cloths?
Dr Walton: The two are closely related. If you are
preparing raw meat, for example, you need to ensure
that you look after the knife and the chopping board
properly and you do not spread the dish cloth
around afterwards.
Q73 Mr Jack: But, coming back to the
promulgation of good practice in that respect, who
should do it and how should it be done?
Dr Walton: Again, I think the Department of Health
and the Food Standards Agency, for example, one
would expect to take something of a lead in
promulgating the right sort of practices.
Q74 Mr Jack: You have fingered two organisations.
Has any work been done to identify where they are
currently deficient in those areas?
Dr Walton: There has been quite a lot of work, as I
said before, on practices in the home from the
assessment of risks and the assessment of people’s
behaviour. The Food Standards Agency, for
example, is very active in thinking about work in
that area.
Q75 Mr Jack: Can you give me any examples of
good practice?
Dr Walton: Good practice, for example, would be
that you do not actually use a dish cloth, but you can
avoid it.
Q76 Mr Jack: I meant whether you had seen any
programmes of communication using the myriad of
ways we can communicate by any oYcial agency,
body or other?
Dr Walton: I see what you mean. You mean good
practice in communication with groups?
Mr Jack: Absolutely.
Q77 Joan Ruddock: There is current advertising by
the FSA, which I have seen, which is extremely
eVective. Dr Astley has seen it, has she?
Dr Astley: Yes.
Q78 Joan Ruddock: It is a good scheme?
Dr Astley: Yes, the FSA currently have an advert
which describes the risk in the home using mimicked
fluorescent technology to suggest how the transfer
occurs and how it can be prevented.
Q79 Mr Jack: Let’s move on to the question of
language as far as food is concerned. There are terms
like “pure” and “natural” which have all kinds of
connotations. Is there any kind of regulation or
description to assist in the use of that kind of
language where, I suspect, if you asked somebody,
or asked individuals, they would have some idea of
what they meant by “pure” and “natural”, but, on
the other hand, those terms can sometimes be
abused by people. I think “home made” is probably
the favourite one, because “home made” is often
used by commercial purveyors of food and I have the
image of a sort of cottage industry, but that is not
quite the way it is.
Dr Walton: This is quite a mine field. There is a lot of
variation between diVerent terms. So as far as I am
aware, there is no statutory definition, for example,
of “farmhouse”. “Natural” is a particularly diYcult
one, because that is the subject of quite complex
regulation.
Q80 Mr Jack: In your evidence you draw the
Committee’s attention in numbered paragraph
three, where you say, “The status of the term
‘natural’ in relation to GM products, for example,
needs to be resolved.” Then you say, “Terms such as
‘home made’ may have an imprecise meaning.” I
think we would agree with you on that. “In some
cases consumers may not be clear what information
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is conveyed by a logo: for example, the red tractor
symbol.” Again, you have stated the problem very
clearly. What is the solution?
Dr Walton: I think the solution probably is one of
trying to make people—. First of all, standardising
definitions if possible, or at least having a code of
practice at the very least, which makes it fairly plain
what you are talking about. “Natural” is very
diYcult because under the term “natural” you can
actually have the production of food ingredients
which are a considerable way from what a consumer
considers to be natural. For example, a lot of
examples of biotransformations are permitted in the
formation of natural flavours provided that no
harsh chemistry is involved. In other words, a
biological production process can be described as
natural, but I think that the average consumer would
probably be unaware of that. I specify that one
because I think that is probably the most important
of them1.
Q81 Mr Jack: But given that we have not time now
to have the debate, if you are trying to have accuracy
in communication, is it important that somebody
tries to rigorously address these issues? In terms of
the pecking order of priorities—
Dr Walton: I quite agree with you.
Q82 Mr Jack:—is this one of the top areas to try and
sort out?
Dr Walton: I think this is important. This is being
handled at two levels. It is being handled at a
national level and, of course, there is the European
Commission level, and, of course, the Foods
Standards Agency has been involved—it actually
ran a consultation on food labelling not so long ago,
where on behalf of IFR we made some of these
points.
Q83 Chairman: The crux of the issue is, bluntly, what
is the point, to some extent, having lots of
information about the calorific content or other
material on the labels described in quasi scientific
terms when the entire packaging, the entire visual
impression is designed to give people an impression
something is healthy when, under any reasonable
analysis, it is not, it certainly would not be healthy in
diVerent circumstances, and does this not have to be
tackled much more seriously?
Dr Walton: Yes, I think that is a slightly diVerent
issue. I think the important thing is that consumers
should not be misled and I think there is a serious
danger with the use of some of these terms. I think
“natural” is a case in point. Consumers are not being
honestly told what they are getting2.
Dr Astley: There is also a potential for
misunderstanding, the red tractor being the
example. Most people assume that the red tractor
1
2
“Important” in the sense of potential for lay
misunderstanding of the term.
A specific issue arises where the everyday usage of a labelling
term diVers from a precise meaning defined in labelling
regulations, with which consumers are unlikely to be
familiar; or conversely, where an everyday term has no
defined meaning at all.
implies that it is British produce, when in fact what
it labels is British standards have been achieved in
that produce.
Q84 Mr Jack: But in terms of addressing the big
issues, for example, if you synthesised all the
chemicals which would add up to “the perfect two
and a half thousand calorie a day diet for
somebody”, and assume you could turn it into a
cube, a pill, or whatever, that would not by any
stretch of the imagination of the word “natural” be
what I understand personally by that, but you would
have produced a totally wholesome, safe, perfectly
balanced, absolutely spot on chunk of food for that
person to eat?
Dr Walton: That is another issue, because there is a
perception in the public mind that chemicals are
bad; so that is a confounding argument actually.
Q85 Mr Jack: Does this not bring us to the heart of
the problem: because people do not like consuming
their food in the way that I have described, as a
perfectly balanced chunk of chemical synthesis; they
prefer to acquire it in many and varied ways? Is that
not part of the diYculty, that as soon as you go into
the huge area of choice you are then into a much
more diYcult descriptive area as opposed to getting
the thing that ticks all the boxes?
Dr Astley: Yes, but food is not just about providing
our bodies with the nutrition that they need to grow
and move and live successfully; food is a far more
complex social interaction, choice, culture, religion.
They are all related in our choices in food.
Q86 Mr Jack: Given that sometimes our choice of
religion can be rather a dangerous thing, is it not
right to allow a bit of danger to creep into the
consumption of food? Should we not be a little
voyeuristic and say, “Yes, I will take a risk; I will try
some of that”?
Dr Walton: Yes, I think you raise another point,
which is that people do have an expectation that
food should be absolutely safe, and that in some
ways is an unrealistic expectation.
Q87 Mr Jack: Is there any research to relate people’s
perceptions with reality to the type of issue that you
have just put before the Committee?
Dr Astley: Yes.
Q88 Mr Jack: What does that tell us, or have you
already told us?
Dr Astley: Well, as Nick says, there is this
expectation that food is 100% safe, but then why
should food be 100% safe when air travel, car travel,
walking down the street is not 100% safe? The public
are capable of making risk assessment; they just have
to be provided with the information to make those
assessments and take those choices.
Q89 Mr Jack: But perhaps the answer is that the
public do not always have the right information to
make the risk assessment: because a lot of people are
quite happy to have a lifestyle on the dangerous side,
that is that they do eat the wrong things, they eat too
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Environment, Food and Rural Affairs Committee: Evidence
Ev 11
many of them and they do not do any exercise, and
expect that the Health Service, the ultimate repair
service, will pick up the tab when the wheel falls oV?
Dr Astley: Yes, and there is also the point that Nick
made that the expectation is that it will happen to
someone else. Smoking, and I do not wish to be
drawn into the argument on smoking, but smoking
is the classic example in that smokers always assume
it will happen to someone else.
Q90 Mr Jack: Let’s conclude this line of questioning
about catering in this context about descriptions,
because in many cases the menu is designed to be an
attractive shop window for the purveyor of food,
whether it be of the mass variety, the branded
variety, or whether it be of the bespoke, a la carte,
best quality menu. People do not want to be
confronted by a lot of the detailed discussion we
have been having now because they are going out for
a good time; they are going out for a meal; they are
going out for social interaction. What responsibility
do you think that caterers and restaurateurs have in
terms of the descriptions that they use: because they
do have a profound influence on the consumption
habits of people in that over 40% of food spend is
outside the home?
Dr Walton: I think they do have a responsibility. I
suppose you can think to some extent of breaking
down the sector, the catering sector, into sections. I
think we would all agree that hospital caterers have
some responsibility to ensure that they provide a diet
which is balanced and nutritious and which provides
an appropriate level of information. Quite the same
considerations would not apply to the fast food
outlet on the street corner. Nevertheless, I would
expect that the Government has a role in
encouraging such outlets to provide appropriate
nutrition.
Q91 Mr Jack: But given the mass purveyors of food,
do they have a responsibility to do more than is the
case now in communicating information about, for
example, what is in the burger or the fish product,
the chicken product, so that you do at least have
some idea of what it is that is being presented to you?
Dr Walton: At the moment I do not think we have a
culture where there is that responsibility in a very
well developed way, but I suspect in years to come
that our culture may well be evolving.
Q92 Joan Ruddock: Some of us try to avoid food
risks by choosing organic. However, I think we also
know, certainly on this Committee, that there may
be some real questions about whether many of the
products labelled “organic” are truly organic. In
your evidence you suggest that there are testing
procedures that could tell us whether we have got
truly organic, whether we have got conventional,
whether the animals, as we are told are coming from
a certain place, or whatever. I wonder if you could
very briefly, because we are running very much out
of time, indicate what those techniques are and how
successful they are?
Dr Walton: These techniques are a variety of
profiling techniques. The best example in this area is
probably the technology that depends upon nuclear
magnetic resonance spectroscopy and isotope-ratio
mass spectrometry to determine the adulteration of
wines, by finding sugars derived from non-grape
sources. That sort of technology, coupled with mass
spectrometry to look at the contents and
distribution of other isotopes, can be used to build
up a picture of the origin and processing of foods
and also the nutrition of animals. It requires quite
sophisticated data treatment and a good database
with which to compare the data of any individual
sample; but the technique with regard to wine, and
also I think olive oil now, is adopted as a European
standard and progress is being made very rapidly in
relation to these technologies for diVerentiation of
geographical origin and for origin with regard to
animal nutrition (for example, whether the animals
have been fed on diets containing animal protein or
vegetable protein) and in relation to crops (for
example, whether crops have been fed with nitrogen
of organic origin or nitrogen of inorganic origin)
which actually bears on the organic nutrition debate.
So, yes, a lot of progress is being made, and quite
fast. Progress has been made quite rapidly in the last
four to five years in this subject. There are certain
problems with it. One particular issue, for example,
is in relation to the legume crops, like peas and
beans, which diVer from other crops in that they fix
nitrogen, atmospheric nitrogen, so this creates a
problem of the isotope discrimination of nitrogen;
but those sorts of problems can probably be
overcome or at least more can be recognised. So, yes,
this is a promising area.
Q93 Joan Ruddock: For most foods is this still very
much laboratory experimentation or is there
suYcient investment to make this something which
could be used for routinely testing and even in a
sense policing the whole food chain?
Dr Walton: The answer to both those questions is,
“Yes”.
Q94 Joan Ruddock: Is the FSA the appropriate body
to be doing this sampling?
Dr Walton: The FSA is already funding a substantial
amount of the research in collaboration with the
European Commission. Whether they would be the
rightly appropriate organisation actually to do the
case law, if you like, is another matter.
Chairman: Thank you very much for answering our
questions so fully this afternoon. If there is any
additional written information which you feel would
be helpful for us to have in the light of our questions,
please feel free to send it to us. Thank you for coming
along to help us with our inquiry.
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Memorandum submitted by the Consumers’ Association
Summary
1. Consumers’ Association welcomes this inquiry looking at food information. As food processing and
supply has become more complex in recent years, consumers have generally become more removed from
food production and less familiar with the ingredients and methods used to produce it. As a result, we are
much more reliant on the information that is provided by the food industry in order to make informed
decisions about the food we eat based on the ingredients and nutrients it contains and the methods used to
produce it. While there is a large body of food labelling legislation in place we are concerned that there are
still gaps. These include the need for clearer and more user-friendly nutrition information, better controls
over the claims made on food and more information on country of origin labelling. Ethical considerations
are an important issue for many consumers and so labelling and information about particular processing
and production methods that may raise concerns are important. Traceability of foods and information
about their origin is particularly important in this context. However in order to secure consumers’ ability
to make informed decisions on these grounds, it is also important to ensure that ethical and consumer
information considerations are given greater emphasis within international food standards.
2. Food labelling information also needs to be backed up by clear communication and advice from
government. In the case of nutrition labelling this includes more prominent and accessible information to
help consumers put healthy eating advice into practice. While we have been pleased with the way that the
Food Standards Agency has worked to be more open about food safety concerns—particularly when
dealing issues where there remains scientific uncertainty, more still needs to be done to provide clearer
information about how individual risks relate to each other and what this means for our eating habits. It is
also essential that consumers are fully involved in decisions about the future direction of food and farming
and that lessons are learnt from the poor handling of genetic modification. Consumers need to be consulted
at the earliest opportunity in order to determine the likely acceptability of new technologies and processes
and any subsequent information and labelling requirements.
Introduction
3. Consumers’ Association (CA) is an independent, not-for-profit consumer organisation with around
700,000 members. Entirely independent of government and industry, we are funded through the sale of our
Which? range of consumer magazines and books. We campaign on a wide range of issues of importance to
consumers, including food and health. The aim of CA’s food campaigns is to ensure that all consumers have
access to food that is safe, nutritious, of good quality and good value, and be able to make healthy
lifestyle choices.
4. Food issues are one of our main campaigning areas and much of our work has focused on issues
relating to information about food, including food labelling and the way that risks and other information
about food are communicated more generally. We therefore very much welcome this inquiry considering
how consumers can be better informed.
5. Consumers have become increasingly reliant on information about the food that they eat in recent
years. A number of factors have contributed to this including a greater reliance on processed, readyprepared foods; increasingly complex methods of production and processing including a lengthened and
increasingly globalised supply chain; and a decline in food skills so that we are more dependent on the
information provided by producers about the ingredients used in a food, its nutritional content and how it
has been produced. At the same time there has been an increased interest in food and the way that it is
produced as reflected by increased demand for organic and free-range foods and the growth in farmers’
markets. For some consumers, ethical aspects are important—for example through choice of fair trade
products, foods produced to high animal welfare standards or concerns about particular production
methods, such as the use of genetic modification. For a whole variety of reasons it is therefore essential that
consumers are in a position to make informed choices about the foods that they eat.
Nutritional Content of Food
6. Poor diet is a major risk factor for diseases such as heart disease, cancer, stroke and diabetes. We face
an obesity crisis with almost a quarter of the population now obese and a high incidence in children. It is
therefore vital that consumers are in a position to make healthy food choices and are aware of government
advice about what they should try to eat and the nutritional content of the foods they choose. We consider
that there are four main areas where consumers are currently let down and where information provision
needs to improve.
7. Firstly, nutrition information needs to be provided in a user-friendly format on all pre-packaged foods.
At the moment this is voluntary although many manufacturers and retailers do provide this information.
Some, however, still do not or only provide it on some products. Many products that do not carry this
information tend to be high in fat, sugar and salt. The European Commission plans to publish a proposal
for review of the nutrition labelling directive this Summer which provides an opportunity to address this. It
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is important that this legislation also requires that the information is provided in a standard and userfriendly format. Food Standards Agency (FSA) research for example indicates that consumers would find
high, medium and low banding included in the nutrition information panel useful. It is also essential that
all relevant nutrients are specified. At the moment for example some manufacturers just provide the ‘basic
four’ nutrients (energy, protein, fat and carbohydrate) without providing information about saturated fat,
sugar and salt levels when these are nutrients we should be trying to eat less of. We should also try to avoid
trans fats, but these are not included in any form on the panel and can only be identified by looking for
hydrogenated vegetable fat or oil in the list of ingredients. Again, information about these fats should be
provided in a format that is most useful to consumers.
8. Secondly, even when information is provided it can be diYcult to make sense of it. It is important that
nutrition information is put into context. We have therefore supported the voluntary provision of guideline
daily amounts (GDAs) for some nutrients by many manufacturers and retailers, as well as the use of high,
medium and low banding as described above. However, we also believe that it is necessary to have a more
user-friendly way of identifying whether products are high, medium or low in fat on the front of the pack.
A “traYc light” type system would be a simple indication for consumers as to whether or not they were
eating to many foods high in fat, sugar and salt and we are pleased that the FSA plans to look at such a
scheme. However at the moment the FSA is only looking at this for foods promoted to children when we
consider it should be used for all pre-packaged foods. With an increasing number of meals now eaten outside
the home, such a system could also be used in catering outlets.
9. A recent survey that we carried out in January1 highlighted that many people were unclear about what
constitutes “a lot” and “a little” in terms of fat, sugar and salt. People generally had a better understanding
of how many portions of fruit and vegetables a day they should aim to eat, although 21% of men and 13%
of women still thought that the recommended number was less than five. This level of awareness reflects the
fact that this has been an area where the government has put greater eVort with its “five a day” campaign.
The FSA however clearly still needs to do more to promote what we should be eating for a healthy diet. It
is for example very diYcult to find information about its “Balance of Good Health”, guideline daily amounts
or advice on “a lot” and “a little” on the FSA web-site. The Agency also needs to launch a hard-hitting
campaign that ‘markets’ healthy eating advice to consumers, motivates people to choose a healthy diet and
explains how this can be put into practice. Supermarkets also have an important role providing practical
information and guidance on how to eat healthily in their stores. Our research has shown that supermarkets
are the most popular place to access information about healthy eating.
10. The final issue is that the information consumers receive about the nutritional content of foods is all
too often confused by claims that are made on foods. These can suggest that the product is a healthy choice
at first glance when in fact the opposite may be true. It is essential that legislation is adopted at European
level that defines nutrition claims such as “light” and “low fat” so that they are used consistently, requires
claims about the health benefits of foods to be vetted prior to marketing and sets down nutrition profiles
for foods that make nutrition or health claims. This will ensure that a product cannot claim to have health
benefits when it is high in fat, sugar and/or salt contradicting well-established advice that we should cut down
on these nutrients. Unfortunately progress of this proposed legislation has now been delayed within the
European Parliament and will not now be considered until the Autumn. We have similar concerns about
the way that foods are often fortified when they are high in fat, sugar or salt and misleadingly suggesting
that they have a healthy image.
The Safety of Foods
11. While ideally foods should not be on sale if they are unsafe, in practice it is impossible to ensure that
foods are completely risk free. The challenge is to achieve a level of risk that is acceptable to the majority
of the population. Some foods, for example, may present particular risks to certain groups of the population.
Dependent on the size and vulnerability of these groups, the risk presented can be dealt with by clear
labelling. This is for example the case with certain allergens or with raw milk. We have welcomed the
introduction of new legislation which will now require much fuller ingredients listing and in addition require
that the most common allergens have to be indicated.
12. Recent food scares have however also highlighted the dilemmas involved in managing food safety
hazards when faced with scientific uncertainty. In such situations a precautionary approach is needed, but
determining just how precautionary to be may not be straightforward. Provision of information to
consumers in such circumstances is therefore important so that they are in a position to make decisions
about the level of risk that they consider acceptable for themselves and for their children. We have for
example welcomed the approach that the FSA has taken in general to the way that it reaches decisions about
managing risks, including opening up the expert scientific committees and appointing consumer
representatives to them. We have also supported the open approach that it has adopted to risk
communication in specific cases—for example in relation to semicarbazide and the possibility that this
chemical found in the seal of glass jars and considered to be a genotoxic carcinogen may be present in baby
food. While the European Food Safety Authority (EFSA) considered that the risk was not significant
1
We interviewed 1,995 people aged 16! face to face in January 2004.
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enough to change eating habits, the FSA provided information including advice about how to prepare your
own baby should you feel that the risk was one that should be avoided altogether. Similarly, we have
welcomed the FSA’s openness over the possibility that BSE may have passed to sheep. It is known that BSE
can be orally transmitted to sheep in experiments, but still unclear whether this could have happened in
practice. Unlike cattle, Specified Risk Material (SRM) controls would provide suYcient protection from the
infectivity as the disease would behave as with scrapie and go throughout the carcass. It is therefore essential
that consumers continue to be made aware of what is and isn’t known so that they can decide whether or
not they wish to change their own—or their children’s eating habits.
13. We have concerns that food safety issues or scares tend to receive a great deal of publicity when they
first emerge and then appear to go away. While government advice may still stand, it may be diYcult to find
and not reiterated regularly enough. For example, advice about consumption of raw eggs. It is important
that this type of advice is regularly reviewed and communicated to the public. In some situations we feel that
government advice could be clearer as in the case of the FSA’s advice about eating oily fish in light of high
levels of dioxins and PCBs, but also the potential health benefits. It remains unclear whether consumers
should avoid eating more than one portion of oily fish a week on average. Retailers also have an important
role in providing easily accessible information at point of sale on food safety issues.
14. We also consider that more needs to be done at national and European level through the FSA and
the EFSA to try to put risks into context and explain how they relate to other concerns. For example, there
have been a number of scares concerning contaminants which are potentially carcinogenic in recent years
including acrylamide, dioxins and semicarbazide for example. These are generally reported and
communicated as individual risks relating to specific foodstuVs. The challenge for regulators is to improve
communication of the relative risk they present.
The Means of Production of Foods
15. As consumers have become more removed from food production we want to know more about where
our food has come from and how it has been produced. In some cases this information needs to be provided
on the label, in others it is more appropriate to provide this through additional means, such as helplines,
leaflets and web-sites for example. Some processes give rise to particular concerns and these need to be
clearly labelled—for example, the use of genetic modification (GM) or food irradiation. It is important that
consumers are fully involved in the development of novel foods and processes in order to determine whether
or not they are likely to be acceptable and what information requirements are likely to be. Lessons need
to be learnt from the poor handling of GM and consumer attitudes and concerns to new technologies and
production methods debated at the earliest opportunity and prior to marketing. Government and industry
also needs to keep consumers informed about the methods that are used and how food production changes.
In the case of genetic modification, we have welcomed the recently agreed legislation that will require GM
derivatives to be labelled based on traceability. However it is also important that consumers are kept
informed of other uses of the technology, for example the widespread use of GM processing aids, and are
fully involved in determining whether or not further uses of the technology are appropriate.
16. Traceability is in general becoming more important as consumers require greater information about
the origin and the authenticity of the food that they buy. It is also necessary in order to verify claims that
are made about particular production methods. DiVerent approaches to enforcement are also required to
police such claims, including for example country of origin labelling and assurance schemes rather than
merely end-product testing.
17. We would like to see greater information required about the country of origin of food products.
Consumers are interested in this information for a range of reasons. For some it may be that particular
quality characteristics are associated with a particular country. For others it may be that they wish to avoid
products from a particular area because they have safety concerns for example. Our research has also
highlighted that having the option to buy locally or at least domestically is an important aspect for a
significant number of consumers and many consumers are interested in where their food comes from.2
18. Certain groups of consumers are interested in information about the way that animals have been
reared and how particular food stuVs have been produced. Our research suggests that the main issues of
concern include drugs used in animals, food safety problems as a result of modern methods of production,
pollution related to modern farming methods, animal welfare standards and use of pesticides. A significant
number of consumers are now choosing organic foods as reflected by the ranges now available in
supermarkets although reflecting concern about intensive farming practices. Assurance schemes are also an
option. However, we have expressed concerns that these schemes may not go as far as consumers expect.
Provision of greater information in general about the way that food is produced should be encouraged,
including for example details of the feed that has been used, or the extent to which pesticides have been used.
This is the type of information that we consider could usefully be provided through use of helplines, in-store
leaflets or on company web-sites.
2
Setting aside the CAP—the future for food production, Consumers’ Association policy report 2001: 1,002 adults aged 15 plus
were interviewed in-home between 10–16 August 2001.
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Ethical Considerations
19. Several of the examples we have discussed above demonstrate how consumers are increasingly
concerned about the ethics of food production. For some, particular food production methods may be
considered unethical and wish to be avoided. For others, animal welfare standards may be most important.
As raised in the terms of reference, some consumers may want to know about labour practices. These are
all issues that companies should also be considering as part of corporate social responsibility.
20. It is however important that sharing of information is not just seen as a one-way flow of information.
Consumers need to be involved in decisions about the types of food production systems that are
appropriate.
21. We have concerns however that ethical aspects of food production are all too often side-lined or given
insuYcient prominence in discussions about food policy. The Committee’s terms of reference refer to
matters of food information in the context of trade negotiations in the World Trade Organisation (WTO).
While ethical aspects can be an important factor for many consumers in determining which products or
brands they purchase the move towards globalisation of food standards could undermine consumers’ ability
to make decisions on these grounds.
International Standards
22. The body that provides reference standards for the WTO when settling trade disputes is the joint
Food and Agriculture Organisation/World Health Organisation Codex Alimentarius Commission—and in
particular the Codex Committee on Food Labelling. We are concerned that since the establishment of the
WTO and the enhanced status of Codex standards, trade considerations have largely dominated decisions.
With the WTO agreements—particularly the Sanitary and Phytosanitary (SPS) and Technical Barriers to
Trade (TBT) agreements in this context predominantly emphasising the pre-eminence of science, consumer
information requirements based on ethical considerations could come under threat. Codex itself has
recognised the importance of taking into account “other legitimate factors relevant for the health protection
of consumers and for the promotion of fair practices in the food trade”, but these remain poorly defined
and are to be determined on a case by case basis. The Codex Committee on Food Labelling is currently
considering the approach that it should take to the labelling of genetically modified (GM) foods—an issue
that has been on its agenda for many years but where consensus has yet to be achieved—and country of
origin labelling although little progress has been made on this issue. More generally Codex is considering
the approach that should be taken to traceability of foods. However, it is concerning that some countries
view this primarily as an issue of food safety, rather than one of consumer information. The issues on
Codex’s agenda reinforce the importance of negotiations on international standards in order to ensure that
consumer information requirements can be met and sustained at national level.
Conclusion
23. The nature of food production and supply mean that consumers’ demands for information are
increasing and the means of providing this information have become more complex. While there is a large
body of legislation in place to deal with many aspects of food labelling, there are still gaps where consumers
are not in a position to make an informed choice.
24. Nutrition information is a particular issue that needs to be addressed—including the development of
a simpler approach and reinforcement of key nutrition messages by government and by the food industry.
As we have highlighted, while the FSA has improved the way that information is communicated to the
public, there is still a need for greater consistency in some areas and individual food risks need to be put into
a broader context. Ethical considerations, particularly those relating to novel foods and processes are an
important issue for many consumers. There is a need to improve the way that consumer information
requirement are anticipated and handled in such circumstances. It is in this area that the WTO context
presents particular challenges. While it is important to ensure that food labelling requirements are not used
as a pre-text for protectionism, we have concerns that the agreements and related standards currently give
insuYcient consideration and emphasis to consumer information requirement, particularly those that are
based on ethical and consumer “right to know” principles.
April 2004
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Witnesses: Ms Sue Davies, Principal Policy Adviser and Ms Michelle Smyth, Senior Public AVairs OYcer,
Consumers’ Association, examined.
Q95 Chairman: Good afternoon, and thank you
very much for coming along to the Committee
today, and for your written evidence which you have
submitted previously. Our apologies for the fact that
we are a little behind schedule. I see you have
brought some visual aids to assist in the presentation
today. I am looking forward to seeing how they
relate to your evidence. Could I begin by asking you
what the Association thinks is the type of
information that should be on food labels about the
nutritional content of food and how that diVers from
what is currently required by law?
Ms Smyth: The main problem we find at the moment
in terms of nutritional information on products is
that it is voluntary. Yes, there is some legislation, a
European Directive, setting out a format for
information about four of the main nutrients. But
putting that information on the product is only
compulsory if you were to make a claim about your
particular product. So we do find that there are some
manufacturers and some retailers that take this very
seriously, and do provide a lot of very useful, very
clear information to their customers. I have an
example here from the Co-Op, with some clear
information in terms of ingredients but, particularly
on this question, in terms of the nutrition panel.
There are other products that do not give you that
information at all. If I take another example here—
and, by the way, these are just some examples
illustrating the points that we may wish to make; we
are not picking these out specifically—you will see
that it only gives very limited information; it only
refers to carbohydrate and does not give a
breakdown of sugars, for instance. There are many
variations out there on the market at the moment, so
there is a bit of a mix in terms of the information that
consumers get. We would like to see compulsory
nutrition labelling on all pre-packaged foods for the
full eight nutrients. Also, we would like to see that
put in a very clear format that is easy to understand,
so consumers can compare one product to another
and would be able to make comparisons in order to
make an informed choice. Most importantly, it is
about setting that information in context. There is
some nutritional information there. We also have
information about guideline daily amounts, for
instance, but we would like to see consumers made
more aware of exactly what that means. For
example, the Food Standards Agency has some very
useful information in terms of what is rated “a lot”
and “a little” in terms of fat, sugar and salt. For
example, on here it says 10 grammes of fat per 100
grammes—what does that mean? How does that
relate to my daily diet? Is that a lot? Is that a little?
Should I eat two of them? Should I eat three? We
certainly think better communication of that
information is necessary. Thirdly, you talked earlier
about a traYc light labelling system, and we
certainly think that would be an important and
useful way of sign-posting to consumers the
relationship in terms of fat, sugar and salt values of
a particular food.
Q96 Chairman: How common is the provision of
some form of traYc light system or equivalent on
food products at the moment, in your experience?
Ms Smyth: We know that the Food Standards
Agency is working on criteria for a traYc light
system. This is in relation to foods specifically
targeted at children. Obviously, we would like to see
it across the board. Detailed work is going on at the
moment as to how that would look in practice. We
have also seen the announcement a few weeks ago by
Tesco that they are going to introduce later on this
year, on a number of their own-brand products, a
traYc light labelling system. It is certainly clear that
people are taking this seriously, they are looking at
the criteria, and we will just have to wait and see
really how that will look in practice.
Q97 Chairman: Should that type of system be
compulsory or should it be voluntary or flow from
some form of code of practice?
Ms Smyth: Obviously, there is the issue of giving the
industry the opportunity to respond, but we think
such a system is needed now, and whilst we welcome
what Tesco have done, we would like to see a system
across the board so you do not have diVerent
systems in each supermarket for instance, because
that would take us back to square one, where the
consumer would have to ask what it means in
Tesco’s and what it means in Sainsbury’s for
instance. We would like to see that introduced as
quickly as possible.
Q98 Chairman: How would you ensure that there
was some common understanding across products
from diVerent shops, diVerent supermarkets? Would
that be the duty of government, or the FSA, to
regulate that system in some way?
Ms Smyth: We would see the FSA playing a clear
role here in driving this forward and bringing all the
stakeholders together. It is important that there is
buy-in from the industry, consumer groups and
retailers right across the board. That is very
important if the scheme is going to work. Also, we
will see in the coming months proposals from the
European Commission in terms of a review of the
Nutrition Labelling Directive, so perhaps there
could be some scope there for looking at such an
issue. As I say, we will have to wait and see what
those proposals are.
Q99 Joan Ruddock: I just wondered if you knew
what sort of proportion of food and drink is actually
labelled? This is part of something that I got in the
House of Commons today at lunchtime, when I
could not find my organic yoghurt. I was oVered a
lemon mousse with a very nice House of Commons
label on it. It has no sell-by date. It has no labelling
whatsoever. When I look inside it, I see it is bright
yellow—goodness knows what may have
contributed to that! This is a second one, which I do
not intend to eat. When I tried it, it was incredibly
sweet, and I suspect it is full of all sorts of things that
I wish I had not consumed. How common is this?
Ms Davies: We often hear a figure of 70% quoted;
about 70% of products carry nutrition labelling. In
the UK certainly we have more labelling than they
do in other EU countries. As Michelle pointed out,
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15 June 2004 Ms Sue Davies and Ms Michelle Smyth
in a lot of cases you just get the basic four nutrients,
and when we have concerns about salt as well as
sugar, it is not very helpful if you want information
about them. While a lot do provide it, some do not,
and it tends to be the products that are higher in
sugar or salt that do not have the information on
them.
Q100 Joan Ruddock: So it is the case that if there is
no labelling, we may suspect correctly that they have
something to hide?
Ms Davies: Yes, that may be the case.
Q101 Chairman: How do you balance the need to
provide information on the one hand, and the
argument that providing so much information can
confuse the consumer? Specifically, in the case of
products which are quite small, it has been suggested
by some of the producers that, for example, on a
small chocolate bar they cannot provide all the
information anyway. How do you deal with this
kind of issue?
Ms Davies: It is an issue, but I think it is often
exaggerated the extent to which it is a problem. A lot
of products do provide information. Where retailers
have decided to do it voluntarily, they put a lot of
information on, and it is still perfectly legible. If you
look to the US, for example, they have had the
nutrition facts panel since the mid-Nineties on
products. You need flexibility in certain
circumstances where you might not be able to have
the full panel in the same position, but generally you
can get it on most packaging. I think we have been
concerned as well that often you cannot get essential
information for consumers on the product, when a
lot of the products manage to make room for various
promotions or various claims about the product. So
any system does need to be flexible, but we think
there is a need to have a consistent approach and
presentation that is as consistent as possible across
diVerent products.
Ms Smyth: Just on that point, we have an example
here of some products that have about 12 diVerent
languages on one package. Yes, it is putting
information across, but it is extremely diYcult to
understand it with all the diVerent languages on the
packet. Perhaps there is a case for manufacturers
simplifying the labelling in the sense of one language
for each country to which they are selling their
product, and not packaging that will go to ten
diVerent countries. Just having one kind of
packaging per country may be a way forward.
Chairman: You have been referring to examples. If
you would like to pass them round, I am sure the
Committee will be interested. We promise not to eat
them as they go by!
Q102 Joan Ruddock: I wanted to ask you about
children and whether there are some products which
you think are ultra “dangerous”. I heard an item on
the Today programme this morning in which they
were talking about the proportion of young
children, which is very high in some parts of the
country, who are having their milk teeth removed
because they have been rotted. The most
extraordinary case was one where the family had
seemingly put into the baby’s bottles the fizzy drinks
that are now so prevalent. Are there some products
that really are becoming a danger to our children?
Ms Davies: It is diYcult to speak in terms of specific
products, but in terms of the argument about
whether there are any such things as “good” and
“bad” food, we think the boundaries have become
blurred now. Obviously, you need to look at things
in terms of overall diet but there are certainly foods,
as you mention, that are incredibly high in sugar or
incredibly high in salt, and you really would not
want to be giving them to children on a regular basis.
Which products those are is not always very clear,
and that is why we think that some kind of simplified
labelling system would help people to identify which
these products are. There is another issue which we
have identified from some of our research, where we
have looked at product ranges that are specifically
targeted at children. In some cases the retailers have
diVerent ranges and they give them various brand
names which they claim to be ideal for children, but
there are also products which have cartoon
characters on, for example, which will be specifically
promoted to children. When we have looked at some
of those, things like some of the pasta shapes that
have cartoon characters on, they can be very high in
salt and therefore you would be better oV giving
your child the adult version. So we are pleased that
the Food Standards Agency has now put together an
action plan on the way that foods are promoted to
children, and one of the things that they are doing is
looking at developing a traYc light system, and also
looking at what criteria should be applied to foods
that are specifically promoted to children. That is an
area where we think action is desperately needed,
because it is a problem at the moment.
Q103 Mr Jack: What research have you done with
consumers of all types to find out what information
they do want on labels?
Ms Davies: We have been doing work on food
labelling going back probably over the last 15-20
years, and we have done research on a regular basis,
asking consumers what kind of information they
find useful, sometimes in relation to specific issues
like GM labelling, nutrition labelling; in other cases
asking about understandability of labelling. There
are certain things that come out as very clear that
people want information on. Our research shows
that on the whole people think nutrition labelling
should be provided, and it should be provided in a
consistent way. They also expect that if they have
concerns about particular processes, for example,
that information should be provided on the label.
Q104 Mr Jack: Let me stop you at this juncture. I
had a session with Marks & Spencer some time ago,
and they told me that 10% of their customers were
what they called their “enquirers”. They were the
people who would demand the type of information
that you have just put before the Committee. The
rest take it as read that it is OK because it is M&S.
That is why I prefaced my question by asking how
much research have you done of consumers of all
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types, because what you have described to me are the
enquirers, the people who really want to know
everything that there is. I just wonder, when people
pick up this particular item, a Mars bar, do they
make the kind of choice decision that you have just
done based on the analysis of all that you have said,
or do they say, “I want a quick energy fix—Mars
bar”?
Ms Davies: We have not broken it down to that
degree. As you say, even within individuals,
depending on what you are buying a product for, in
a particular situation you may want information at
one point and the next day you might decide . . .
Q105 Mr Jack: Let me just break that down. You
say “you may want”. When it comes to looking at
this very clear panel, for example, on these Co-Op
lemon tarts, it is clear; there is a lot of useful
information on this, but it is diYcult to put it into
context. I do not criticise the Co-Op for that because
they have occupied every square inch of one back
panel of this with a dazzling array of information of
all kinds, shapes, sizes, descriptions: it is low protein,
medium carbohydrate, high in sugar—hang on a
minute! It says here carbohydrate, medium, and
then “of which sugars”, and then it has the word
“high.” If I am one of your people looking at the
detail of this, whilst it is commendably clear, I am
now beginning to wonder whether it is good in
carbohydrate, it is high in sugar. In other words,
what do people want to make some sense of all of
this when it comes to the first time they buy this, in
the context of trying to have week in, week out,
month in, month out, year in, year out, some variety
of diet?
Ms Davies: I think labelling cannot be looked at in
isolation. When you are looking at information like
that, it is a means for people to actually put any
concerns they have or any issues that they are
particularly worried about into practice. In the case
of nutrition labelling, we think it needs to be
simplified. We think it needs to be put in context as
much as possible on the label. The Co-Op goes a lot
further than some people in that they do have the
high, medium and low banding. You also need to
have more general information from the Food
Standards Agency for example, explaining what you
should be aiming to eat on a daily basis. When we
have tried to find that advice, for example, on the
Food Standards Agency’s website, it can be quite
diYcult to find the information that Michelle was
talking about: the guideline daily amounts or the “a
lot” and “a little”, and even the Food Standards
Agency’s plate which tells you about the diVerent
food groups you should be aiming to eat overall.
You need to have that information and that needs to
be disseminated more eVectively, and people then
need to understand when they are buying specific
products how they put that into practice.
Q106 Mr Jack: Just a minute. You use words like
“people”; it could be all of us. The people on this
Committee are passionately interested in food; that
is why we are here asking all these questions. But
there are many whose lifestyle, educational ability,
opportunity, who for a whole myriad of reasons are
just happy to have something to eat. They do not
have time to go into this detailed, dazzling analysis
relating their lifestyle to what they are eating and all
the rest of it. I just wonder whether in fact we are
looking at this through a very narrow window when
in fact the spectrum of people versus knowledge,
opportunity, is much more complex and diverse.
Who is it we are trying to get at?
Ms Smyth: We have also heard earlier though that,
certainly in relation to obesity and diet-related
disease, we are facing a public health time bomb, as
it has been described, and we are really going to have
to face up to the fact that we do need to pay more
attention to what we are eating, and we do need to
be more aware of what we do throughout our day in
relation to physical activity.
Q107 Mr Jack: Have you ever asked people who are
obese how it is they got there?
Ms Davies: A lot of people are doing research into
that, but I think the issue as well is to prevent people
getting obese, to prevent people developing heart
disease, to prevent cancers, and clearly diet has an
important role. As you explain, a lot of people may
not be motivated to look at the information on the
back of the label, and that is why the challenge now
is to try and make the healthy choice the easy choice
and to try and motivate people to make healthy
choices, and when they are actually picking up
products to come up with the most simple system
possible, so you can do that without having to have
detailed knowledge about what all these diVerent
nutrients mean and whether that is a lot or whether
it is something you need to worry about or not.
Q108 Mr Jack: Give us a quick view of how you
apply that philosophy to the restaurant and mass
catering trade.
Ms Davies: That is more diYcult, but I think it is
clear that people are eating out a lot more than ever
before, and we eat out for a lot of diVerent reasons
now. Traditionally, it tended to be the case that you
would think, “I am going out for a celebration, a nice
meal, and why should I be bothered about what I am
eating?” People increasingly buy sandwiches at
lunchtime, they go to fast food outlets, as well as
going to restaurants for special occasions, and you
need to look at what kind of information people
need in those circumstances. That is where we think
the traYc light system would work well, in that if you
could develop that for pre-packaged food,
ultimately we want to see it extended to diVerent
catering outlets as well, so that people have a much
easier way of identifying which of the products are
particularly high in fat, sugar or salt, for example.
Q109 Mr Jack: Would you make that mandatory in
all types of outlet?
Ms Davies: Ideally, we would like to think that the
industry would want to do it voluntarily, but the
important thing is that you need to have a consistent
approach. Unless you do make it mandatory, it is
diYcult to ensure that everybody does apply it and
that they do it in the same way.
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Q110 Mr Jack: Have you come across any examples
of good practice that exist in this area already?
Ms Davies: Not explicitly. Some outlets are starting
to look at providing nutrition information, but it is
very rarely provided. If you are buying pre-packaged
sandwiches from some places, you might have
nutrition information on those, but again, it is how
you put that into context, because when you are
eating out, even less than when you are buying prepackaged food, you are not going to want to try and
start analysing information; you want to have
something that is instantly recognisable.
Q111 Mr Drew: One of the growing trends—and
you can see it on the Vienetta box and the Pringles
tube—we always seem to deal with Pringles on this
Committee. Pringles is our pet hate on the waste
disposal front, and why they have that shape. Both
those products are globally marketed, and there are
on both of them seven or eight languages. I challenge
anyone who does not have very good eyesight to be
able to find the information they are looking for. It is
fair enough that we should be making these products
accessible for people speaking languages other than
English, but there is a real problem in trying to label
properly, because there is only so much information
you can put on one of those tubes, and it is
completely inaccessible. What are your views on
language issues as well as just the information?
Ms Smyth: As you say, the label does have to be
accessible, and there are some countries, in the
European Union for example, that have a number of
oYcial languages and it is important that those
languages are covered on the labels. But on the two
products there, there is such a variety of diVerent
languages, we would simply ask the question is it
really necessary to have 12 diVerent languages on
one pack? Surely that could be broken down into
regions. For example, if that was going to Belgium,
it would need to have information in French,
Flemish and German because those are the three
oYcial languages.
Q112 Mr Drew: The problem with that is that
nobody is going to actually look for the information
on that wrapping, because you would have to
eVectively take five minutes per product. Nowadays,
most people shop in supermarkets for convenience,
and by giving people so much information, it is
completely meaningless.
Ms Smyth: It is giving them nothing, yes.
Q113 Chairman: You would imagine the producer
might say that to provide packaging which contains
less languages means you could have less
standardisation of the packaging across the
countries in which it is sold across the world, and
therefore that would lead to a price consequence for
the consumer. This might be a case where the
consequence of clearer information would be that
the consumer would pay more. Is that the kind of
equation that we have to recognise and if necessary
make that choice?
Ms Davies: It is diYcult to see how that would be the
case. There are examples on the market, but there
are also a lot of products that can quite easily
provide the information in a clear and simple way.
On the one hand, food is becoming more globalised
and we are getting products from all around the
world, but in many ways, as a result, consumers
want to have more information about the products
that they are eating because they might not
necessarily know how it is produced or what has
gone into it. We need to have clarity.
Q114 Mr Jack: I presume the reason why you put so
much emphasis on the labelling aspect is because the
majority of food is consumed from a packaged,
manufactured source as opposed to loose.
Ms Davies: That is right. We are increasingly eating
more processed foods and we have become much
more removed from the way that food is produced.
One issue is about basic food skills: people are less
aware now of exactly how foods are produced, but
even if you do know a lot about cooking, it is very
diYcult to know when you are buying a processed
food how much fat, sugar or salt is in there, or what
kind of processes have been used.
Q115 Mr Jack: You used the term “processed” but,
for example, if you go into a bakery and you buy a
loaf of bread, a process has been involved to produce
that loaf of bread. If you happen to go to a baker
who has some Italian focaccia, for example, in which
there is salt and olive oil, so it has a high fat content
and a high salt content, you might for your own
particular circumstances be having something that
could be potentially wrong, but there is no label, no
information.
Ms Davies: That is where the traYc light system
would be useful again, is it not? One of the diYculties
when you are selling food loose is where you actually
put the information. It would be much more
straightforward if you had a simple system like that
to be able to give people an indication of the
nutritional content.
Q116 Mr Jack: You are suggesting that even for
products which are unpackaged, you would still
want some form of information system?
Ms Davies: Ideally, we need to develop the traYc
light system and come up with a workable approach.
We are pleased that the Food Standards Agency has
started to do that now, but it is looking specifically
at food promoted to children, and ideally, we want
a system that applies to adults as well, then we can
look at how that is rolled out to diVerent types of
foods. Certainly there has always been a challenge
about how to provide information on food in
catering outlets and also food sold loose, but if you
have a much simpler system, that would be a way of
providing the information.
Q117 Joan Ruddock: We have been talking about
languages. Interestingly enough, none of these
languages oVered here are ones that are appropriate
to the ethnic minorities of this country. I wonder if
you have done any research into this. There are
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substantial ethnic minority communities where
reading of English skills are very low, especially
amongst the women, and the older women, who may
be purchasers of food. Is a traYc light system
applicable there?
Ms Davies: Yes, I think that would work really well.
You would obviously need to have communication
behind it to explain exactly what the traYc light
system means. It is not a case of if you see a red, you
do not eat this food, but if you see red, and your
shopping trolley is full of reds on a regular basis,
then you are probably not getting a balanced diet. If
you explain that, people would at least have a very
simple way of choosing foods.
Q118 Mr Jack: Do you think the French would
accept your traYc light system on certain products,
for example, such as foie gras?
Ms Davies: It is something we work very closely on
with the consumer organisations across Europe, and
it is something that they are all very interested in and
that they are pushing in their own countries as well.
Q119 Mr Jack: Are they getting universal acclaim
from the French and Italian governments, the
serious “foody” people? They are all queuing up to
adopt this, are they?
Ms Davies: It does not mean that you could not eat
the food or you could not enjoy it; it just puts it in the
context that yes, it is a treat and you eat it on special
occasions; you do not eat it every day and it is not a
main part of your diet if it is high in fat, sugar or salt.
Q120 Chairman: Just to be clear, are you suggesting
this traYc light system would apply on a Europewide basis?
Ms Davies: I think ideally, to get round the issue
about how you would make it compulsory, because
all food labelling legislation is decided at European
level, it would have to be an EU initiative. As
Michelle was saying, we have the review of the
Nutrition Labelling Directive going on at the
moment and proposals are due this summer.
Hopefully, that will be an opportunity to look at
how nutrition labelling can be simplified. There is
also legislation looking at claims that is being
developed at the moment as well. Both of those
provide opportunities for addressing the issue.
Q121 Joan Ruddock: Are you suggesting that we
could not have a traYc light food labelling system in
this country unless it were to be done as an EU
Directive? Then you are talking about years and
years, and possibly never getting it.
Ms Davies: The way that the Food Standards
Agency tends to work now, because most of the
legislation has to come from Europe, is that you can
do things working with industry and coming up with
a standard and encouraging the industry to adopt it
across the board. That is what we would like to do it
in the short term, but ultimately, if you want to have
legislation, that would be a European initiative.
Q122 Joan Ruddock: The Health Select Committee
called on this Government to legislate. You disagree
with that, do you?
Ms Smyth: It is not a question of disagreeing with it.
It is a question of being aware that the overall
initiative has to be EU-wide, but certainly, what we
are calling for is for the British Government to make
that message loud and clear in Brussels, with other
EU member state governments, but also to carry on
with its development of a scheme and to present the
Commission with a formula of how this could be
applied, and also to see it rolled out at least on a
voluntary basis here in the UK. Ultimately,
however, on food labelling legislation, overall
responsibility does lie with Brussels.
Q123 Chairman: You told us about the possibility of
legislation on claims that are made. How widely
should such legislation apply? Is it going to be able to
deal with claims that produce is pure, natural, homemade, farmhouse, all these terms which we see, or
are we talking about more specialised claims?
Ms Smyth: The regulation is to harmonise health
and nutrition claims, and we are certainly very
supportive of the legislation, because we see on more
and more foods—we have brought some examples
here—various claims, be they health-related or
nutrition-related. You see things like “fat-free”,
“reduced fat”, “light”, etc. There are some
guidelines from the Food Standards Agency in
relation to nutrition claims, but they do not cover all
the phrases that we see on products. For example,
there is not a definition for “light” and we have
found with some products as well that “light” can
mean anything from, say, 10g of fat per 100g to
about 16g of fat per 100g. Again, there is confusion
there for the consumer. What does “light” mean?
You have to turn over the product and really
examine the label in detail. We certainly welcome the
setting of clear definitions. Also, we welcome in the
European Commission’s proposals the prior
approval system for health claims. At the moment
food products should not mislead the consumer, but
the onus is very much on trading standards oYcers
to prove that the food manufacturer got it wrong.
What the EU legislation would bring into place, if it
is approved, is a prior approval system, so the
industry would have to submit its claims to be vetted
first, before that claim could be put on the product.
So at least when that claim is on the product—and I
should just say that we certainly support claims; we
think claims are useful and in our research
consumers have told us that they like claims too, but
they just do not trust them at the moment—if you
have a prior approval system, you have that
certainty; you know that what you see claimed on
that product has been vetted and therefore is
accurate and is useful.
Q124 Mr Jack: You said a second ago that
consumers do not trust, yet in all the areas where
consumers are said not to trust something, very large
quantities of these things are sold. If people did not
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trust, you would think that they would not be sold.
Why is there this lack of fit between purchase and
trust?
Ms Davies: It is interesting. When we have done
research, we have asked people “Do you find claims
on foods useful?” and people say they find them a
helpful way to identify products when they are
shopping in a hurry because they can look for the
claim. When you ask them “Do you trust the
claims?” they are sceptical about the claims.
Q125 Mr Jack: You have just said that your research
shows, so this is people saying they look for the
claim, but then they do not trust their own judgment.
That is eVectively what it says.
Ms Davies: If you put yourself in a supermarket, you
see claims, and if you are interested in buying a
healthy product, it is an easy way of identifying a
healthy product, so they are tempted to buy the
claims, but they are sceptical about them.
Q126 Mr Jack: Let me ask you the same question as
I asked our previous witnesses: what does your
research show that people do believe about what is
said, in general terms, about food and food claims?
What are the believable bits?
Ms Davies: Specifically in relation to claims, we have
not asked people which claims they are more likely
to believe or not. Certainly, when we have asked
whether or not people think that claims should be
approved and should be vetted, there is strong
support for government doing that, so that they can
be sure that they can rely on the claims.
Q127 Mr Jack: In terms of food messages in general,
because we have had a long discussion about specific
conveyance of information about individual
products via labelling, but this is in the context of
some wider messages about what is good and bad to
eat and in what relative quantities, what can you tell
us about how people form their judgment for
themselves as to how they answer those questions in
relation to their own individual consumption of
food?
Ms Davies: In terms of which bodies they are likely
to trust for advice?
Q128 Mr Jack: In terms of when I am making a
choice about whether to buy product A or B, or how
much of X or Y to consume a week, for example, if
somebody tells me that certain types of red meat are
high in cholesterol but on the other hand there are
beneficial vitamins and other chemicals in meat, so I
take a decision, what are the things that people
believe to inform their judgment as to what they
should and should not eat?
Ms Davies: It is not something that we have
specifically asked in those terms, but I think it will
depend on your own particular circumstances and
what issues particularly matter to you.
Q129 Mr Jack: If you cannot answer that question,
and we have talked about the way we communicate
on packaged food with a vast amount of labelling
information, and we do not know what forms the
judgment basis for people to decide on what they will
or will not eat, how can you decide on the message
about food to them?
Ms Davies: I am not sure I completely understand
your point.
Q130 Mr Jack: For example, if I am going to buy a
car, I might say that fuel economy and the comfort
of the driver’s seat are the two most important
things. I can define very clearly what it is I am
looking for. I could go out and test every car in the
marketplace and if those were my two criteria, I
could make my choice. As I add more criteria to it,
it becomes a much more complicated choice and I
therefore might look, for example, to authoritative
motoring magazines to help me sift out till I got
down to my shortlist, and then I would make my
choice. So I could go through if I wanted to a very
rigorous piece of analysis against a predetermined
set of selection criteria to choose the car which most
met my needs. I suspect with food we do not go
through anything quite like that, but in terms of the
myriad of messages which are currently whizzing
around out there about “Eat more of this, eat less of
that, do this, do that”, what are the things that
people believe? Where do they go for their
authoritative information that they say, “Yes, I do
believe that, therefore I will use that piece of
information, that source of information, to inform
me about my dietary requirements, my food
buying habits”?
Ms Davies: The research that we have done, which
was a few years ago now, showed that on the whole,
it is consumer organisations and health
professionals that are seen to be the most trusted
source of information, and subsequent research by
other bodies has reinforced that point. One of the
reasons that we campaigned for the Food Standards
Agency to be set up was to have a single,
independent, trusted source of information on food
issues, and I think the Food Standards Agency has
gone some way to do that in certain areas of its work,
but it still needs to increase its profile on issues like
dietary advice, where it is very diYcult to actually
have that information. In terms of what is most
important and what people trust, it is very diYcult to
say because I think it depends on people’s individual
circumstances, their particular values, what they
think is important. We know that an increasing
number of people want to buy organic. Our research
has shown that people are concerned about things
like animal welfare issues, use of veterinary drugs,
that kind of thing, which fits in with that. As we
know, people do not always look at nutrition
information, but that is a challenge, because we
know the problems that are linked to diet, that that
may not be a priority, but that is not a reason for not
putting the information on the label; it is a reason for
putting it on in a clearer way and actually
encouraging people to make use of that information
and showing what the benefits of that are. The same
goes for more straightforward food safety
information. Again, it may not be something that
you particularly want to even think about when you
are buying a product, but if you are buying raw milk,
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for example, you need to be told that you are taking
a particular risk by buying that product, and then
you can decide whether or not you want to carry on
and drink something that may have a higher risk of
E. coli or listeria.
Q131 Mr Drew: We are going to go on and look at
food safety and allergens, but I want to ask you a
general question on that. Clearly, to some people,
what they eat is a matter of life or death. In the
generality, there are strong ethical reasons why we
would want to give the consumer more information,
but for some people, the knowledge that that
information is right outweighs all the other issues,
because this is about somebody’s life being on the
line. How do you prioritise that? It has got a lot
better. My father-in-law is a celiac and to be fair, the
information is now much better than it ever has
been, but it is becoming more complicated.
Obviously, to some extent it is up to the individual to
carry their little booklet around and to then try and
match that against what the packaging actually says.
Presumably you have had these debates and there is
not an easy answer, but there is an issue about
prioritisation.
Ms Smyth: No, clearly there is not an easy answer,
but we have certainly been very supportive of
legislation—again, Brussels-based—which has got
rid of what is termed the 25% rule, and this will come
into force later on this year and will mean that you
will have more information on the label in the sense
that the ingredients listing will be broken down even
further, precisely to enable those consumers that do
suVer various allergies, very serious food
intolerances, etc, to have even more information in
terms of the ingredients. Before, it used to be
wrapped up or not mentioned if a food ingredient
made up less than 25% of the overall ingredients.
Also, we have been very supportive of EU-wide
legislation that will set out a positive list of food
ingredients that can cause allergies, and for that to
be clearly labelled on the product. We would
certainly want to see this information very clearly
labelled on the product because, as you rightly say,
for some people it can be a matter of life or death.
Q132 Joan Ruddock: Are you saying there is going
to be a stricter legal requirement in this area and
everything will have to be listed?
Ms Smyth: Yes.
Q133 Joan Ruddock: How will this product here
comply? We cannot read the Pringles multilanguage presentation at the moment.
Ms Smyth: That will certainly be a challenge for the
manufacturers in relation to how they will comply,
absolutely.
Ms Davies: The legislation will not deal with clarity,
unfortunately. It will say that they will have to list
the allergens if they are included in the product, and
there is a list of the ten most common allergens. It
will also extend the list of ingredients so that
compound ingredients that make up less than 25% of
the overall product will now have to be labelled
whereas they did not have to be before. There is still
the issue about presenting that in a clear way so that
you can easily see that information, which, again, is
really a voluntary issue. As you will see with the tart
there, that is very clearly presented and there is a
clear box setting out any potential allergens, whereas
with the other products it can still be included in the
list of ingredients.
Q134 Joan Ruddock: When you say the ten most
common allergens, are we talking about listing food
ingredients that are known to cause the 10 most
common allergens and therefore you do not have to
list things that we have not yet discovered do cause
an allergy?
Ms Davies: Yes. There are two things. The
ingredients list overall has been extended, because
there used to be an exemption for compound
ingredients that made up less than 25% of the overall
product. If you have a pizza, for example, and it has
a bit of ham on it which makes up less than 25% of
the pizza, you would not have to say what was in the
ham; you could just say “ham.” It has broken that
down so there will be much fuller ingredients
labelling. Potentially, if you have a more unusual
allergic reaction, you will be able to see if that
particular ingredient is in the product, but regardless
of that, the ten more common allergens will have to
be labelled. In the case of alcoholic drinks for
example, there is no requirement for ingredients
listing, but if it contains something that people could
have an allergic reaction to, that would have to be
labelled now, so you will not get a full list of
ingredients but you will have the allergens specified
now.
Q135 Joan Ruddock: We are dealing with
ingredients that are known to cause allergies. Where
does GM lie in this? If you have GM derivatives
which come below the labelling threshold for GM,
but it is believed by many that some kinds of GM
products could be the cause of allergies but it is not
yet proven, you would not know, so we have no way
of tracing that this might prove to be the case.
Ms Davies: There is obviously separate legislation
dealing with GM, and we have been pleased that
finally now that it is being extended to GM
derivatives and will be based on traceability rather
than based on what you can detect in the final
product. There are guidance notes at the moment
that the Food Standards Agency and Defra have put
out, consulting on how that will actually be applied
here. Obviously, there are still concerns about GM
and the potential for introducing unknown allergens
that need to be addressed.
Q136 Joan Ruddock: What about E numbers? How
do they lie in relation to this new procedure?
Ms Davies: Again, that is separate, in that they
would have to be shown in the list of ingredients.
Q137 Joan Ruddock: But not related to allergens,
although some of them cause allergies, I understand.
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Ms Smyth: It is separate legislation.
Q138 Mr Jack: Do you feel the Food Standards
Agency is doing a good job in dealing with food
risk issues?
Ms Davies: We think it has really changed things. It
has done some really good things. One of the big
tests for it when it was set up was BSE. Obviously, it
was set up on the back of all of the problems with the
way that BSE was dealt with. We have certainly
found it has been much more open and transparent
in the way that it deals with food risks. One of the
things we think it has done particularly well is the
whole issue around BSE and the possibility of
whether or not BSE could have passed to sheep, for
example, where it has decided to deal with that in a
very open way, and explained that on the one hand,
it is known that BSE can be transmitted orally in
experiments to sheep, it is known that sheep have
been fed potentially infected feed, but it is not known
whether sheep have developed BSE in practice, but
if they do have BSE or did have BSE, the controls
that we have in place would not be adequate
because, unlike cattle, BSE would actually be in the
muscle meat in sheep. Issues like that, which a few
years ago would never have even reached the public
domain, the Food Standards Agency, responding to
the criticisms in the BSE inquiry report, have been
much more open and have allowed the public to
have that information and have accepted that if you
are more open, people will not just panic; they can
accept that you cannot have 100% certainty about
food risks. That is something that we think they have
handled well. Other areas we think they are still
fairly weak on and could do better. One of the
complicated areas that it has had to deal with a lot
recently is the whole issue of chemical contaminants
in food. We have had lots of individual scares that
have come up. For example, there was the issue of
acrylamide in fried and baked foods, which is still
being investigated further; the issue of
semicarbazide, which was formed in the seals on
jars; then the issues of dioxins and PCBs, for
example, in oily fish. That is a really diYcult issue
because on the one hand, there is clear evidence that
we should be eating more oily fish because it is
beneficial for our heart, but on the other hand, if you
eat too many dioxins and PCBs, and it is known that
there are high levels in some oily fish, we are
increasing our cancer risk. So there is a risk/benefit
balance that the Food Standards Agency has to
weigh up. We still feel that it could have been much
more explicit in its advice, because it puts it out in a
back-to-front kind of way, where it says at the
moment that you should eat two portions of fish a
week, one of which should be oily. If you ask, “Does
that mean we should not be eating more than one
portion of oily fish on average a week?” you do not
get a straight answer. The other issue, but it is
perhaps diYcult to criticise them on this because it is
a very complex area, is that we get lots of individual
food scares that come out in relation to specific
carcinogens, but it is very rarely communicated to
the public in terms of what that means overall,
because we go out and we choose food. If you think
you have been exposed to one particular carcinogen
on a regular basis, when you get another food scare
coming up, how significant is that in relation to your
risk overall? We should be trying to put some of
these scares in a broader context and explain what
that means in terms of whether or not it is worth
changing your eating habits.
Q139 Mr Jack: You have put your finger on it
because if you smoke, you can put a pretty high
number on the risk factors, but given the risks that
potentially come, for example, on the oily fish
carcinogens argument, you do not really know at the
starting point what risks you are exposed to.
Nobody says you have a one in 10 million chance of
dying if you go over two oily fish portions a week. It
is never put in terms like that. Why not?
Ms Davies: It is just so diYcult to do, and often there
is a great deal of uncertainty about these issues.
Q140 Mr Jack: I do not accept that it is too diYcult
to do. You put very proper emphasis in your earlier
remarks on BSE. The Government decided on a one
in 5 million chance to say that the sale of beef on the
bone should be stopped. The Government was quite
capable of quantifying a very large risk and stopping
something happening, yet you have just said it is all
too diYcult in other areas. When the government of
the day chooses to quantify risk, it appears to be able
to do so.
Ms Davies: There is often pressure to quantify risks.
Q141 Mr Jack: What brings the pressure?
Ms Davies: Ideally, people want to have quite
straightforward information to be able to compare
risks.
Q142 Mr Jack: What you are saying is that on the
other things you have identified, there is not the
pressure to be able to make this risk comparison.
Ms Davies: I think that there is, and sometimes there
can be a temptation to try and put a figure on the
risk, but in the case of beef on the bone, that was a
very diYcult issue because . . .
Q143 Mr Jack: Surely you have got to be able to
quantify risk, otherwise it is a risk where the odds are
so long that it is not worth bothering about. Either
it is dangerous and quantifiable or it is not.
Otherwise, you are into the realm of supposition, are
you not? Does this not lie at the heart of some of the
problems of communicating risk? There is always
the possibility that almost anything—life itself—is
dangerous, but you take the risk. You do not
actually sit and do a risk calculation. You do not
have a spectrum of them. Yet we are being told that
we have got to look at this potential carcinogen, but
with no numbers because it is all too diYcult.
Ms Davies: Ideally, yes, it would be much easier if
you could quantify the risk but if you take BSE, for
example, where we do not really know what the
infective dose is, it is not clear what the incubation
period is, it is not clear whether certain groups in the
population are protected against BSE, it is not
known whether or not it is in sheep. There are so
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many things that we still do not know about BSE, so
you can not put a figure on it. If you look at the over
30 months rule, the Food Standards Agency put a
figure on what they thought the risk would be of
removing the over 30 months rule compared with the
risk that . . .
Q144 Mr Jack: What I am driving at—and you have
answered the question immaculately—is at what
point should we be bothered in communicating a
risk? What you have described in your earlier
remarks was a whole series of possible risks. You
then said it is too complicated to work out a number,
yet earlier on in our evidence we were talking about
the benefits of a simple traYc light approach. Should
we have green risks, amber risks and red risks?
Ms Davies: I think those are quite diVerent issues
though, because there you are dealing with
something where there is very strong evidence that
we should be trying to cut down on fat, sugar and
salt and that there are clear health benefits if we do
that for a lot of people, whereas with some of the
contaminants and safety issues that you are just
mentioning, there is still a great deal of uncertainty
about those, and it can be very diYcult to be specific.
Q145 Mr Jack: Are you saying we should simply
follow a precautionary process on every one, cut out
trying to quantify it and just say that there could be
a danger?
Ms Davies: I think we should try to quantify it, but
we have to expect that in some cases it is not going
to be possible to quantify it. When you are talking
about precautionary measures, we are getting into
the realms of how precautionary you should be, and
how you deal with the potential risks and benefits in
relation to particular safety issues.
Q146 Mr Jack: If, for example, with oily fish, there
was a high percentage of an improvement in
somebody’s health through eating more than two
portions a day, are we not going to be able to balance
that oV against the risk factors that go with it?
Ms Davies: That is where the Food Standards
Agency has come up with its advice, which we think
could be clearer, that you eat two portions of fish a
week, one of which should be oily. The Food
Standards Agency has been very good at this in a lot
of areas, of actually explaining what is and is not
known. There is the issue of to what extent you
regulate when you have uncertainty and to what
extent you need to have further risk management
measures, but in some cases—and again, BSE
illustrates it well, where it is estimated that if we did
have BSE in sheep, the measures would only in fact
remove a third of the infectivity in sheep. Then you
need to communicate that uncertainty, even if it is
not possible to quantify what that risk is. Some
people may have been exposed to BSE through beef,
you may have children that were not exposed to that,
so what is the relative risk for them? You have to
explain to people what is and is not known, how
eVective the measures would be if that particular risk
was realised, and then at least people are in a
position to make up their own minds about whether
or not they take their own precautionary measures
and whether they change their own eating habits or
those of their children as a result of that information.
I think it is incredibly complicated, and in a lot of
cases you can only really quantify the risk on a case
by case basis, based on what is and is not known,
always trying to do more research in order to
become more specific about what the risk is.
Q147 Joan Ruddock: I wanted to ask you about food
assurance schemes, because you have given us some
evidence which suggests that perhaps they do not do
all it says on the label. I wonder if you could just
expand a bit on that.
Ms Smyth: We have looked at food assurance
schemes in our Which? magazines a number of times
over many years and yes, we have increasingly found
that there are more and more of these schemes out
there. There is confusion really, in the sense that
consumers, from our research, are not necessarily
aware of what that particular scheme means. They
may think that scheme means more than it does,
perhaps from an animal welfare perspective, for
instance. A few months ago we did a report in our
Which? magazine looking at meat assurance
schemes, with the red tractor logo as one example.
We found that there were some retailers that comply
with those standards but do not put the logo on the
food product, or actually have standards that go a
little bit beyond that, etc. There are many variations
out there in the marketplace which mean that it is
diYcult for consumers to have real certainty as to
what it means, particularly if you want to make
ethical choices, for instance, when you are buying
your food. We would suggest that the challenge that
lies ahead for these schemes is that the
communication channels are improved, that there is
greater awareness among consumers as to what
exactly it means, and obviously that there is
transparency within these schemes in the sense that
it is clear what the criteria are, it is clear that they are
regularly enforced and inspected, and also it is clear
what happens if it is found that there is a particular
manufacturer who is not complying with the scheme
and needs to be struck oV. Clarity is needed, and also
making the public more aware of what they
actually mean.
Q148 Joan Ruddock: It is obviously confusing. Are
you suggesting some of them might be misleading
as well?
Ms Smyth: There are just so many out there that it
is very diYcult to have certainty when you are
buying your eggs, for instance, exactly what a
particular mark may mean. We just need
improvement on the communication side, and
transparency as well, so that if there are any
misleading elements to any schemes, that is quickly
cleared up.
Q149 Joan Ruddock: Should they not be massively
reduced so that we could have a small number of
schemes that people could then understand, get the
message, and they could be policed? At the moment,
I suspect they just are not.
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Ms Smyth: That could certainly be a potential
solution in looking at means of communication. One
means of communication may be to start by
reducing the number of these schemes so that it is
clearer to the consumer.
Q150 Chairman: Do you have any idea how many
such schemes are actually in existence?
Ms Davies: No.
Ms Smyth: We can let you know that in writing, but
we do not know oVhand, I am afraid.
Chairman: It would be useful to know how many of
these schemes have a genuine, independent audit of
the claims that are made.
Q151 Joan Ruddock: It would be useful to know how
the Red Tractor scheme is working.
Ms Smyth: Can we send that in to you?
Chairman: It would be very helpful if you could
provide that information.
Q152 Mr Drew: Looking at this idea of public
participation in the process of labelling, you have
already touched on this so I will not go into it in any
great detail, but is there not a danger of consumer
activism, and they are the people who will determine
what they want to see in terms of labelling? How do
you get to the wider public and get a feel for what
information they feel is appropriate?
Ms Davies: There are more methods available now
to try and find out what the public thinks about
diVerent issues. Last year, for example, we jointly
organised a citizens’ jury together with Greenpeace,
Unilever and the Co-Op to try and get a better
understanding of people’s attitudes towards GM
and feed that into the public debate. That is just one
example of the sorts of methods that are available.
GM is quite a good example of failure to try and
listen to the public and find out what people would
think about the technology, about the potential
benefits, information requirements at an early stage,
which has now resulted in large-scale rejection of the
technology. When looking at other changes at that
kind of level to the food chain, it is important to
involve the public at an early stage, ideally at the
research stage and, as you say, not just have people
who have a particular interest in the issue but make
sure that you are talking to representative groups of
the population and trying to understand what their
limits of acceptability are, where particular
developments could be useful, and not waiting until
it is ready to come to market before you have that
kind of debate.
Q153 Joan Ruddock: We are going to wind up the
session on this last point, which is to look very
quickly at the biggest international issue, which is
the World Trade Organisation and globalisation of
food, and the extent to which that might be
mitigating against consumers’ ability to make
decisions on ethical grounds, particularly. Is there
anything you would like to say to us on that?
Ms Davies: We think it is interesting that, on the one
hand, as a result of globalisation, and because the
food supply chain has become much longer, we have
become much more removed from where our food is
originally produced, we want to have much more
information about food because we want to know
about it and there is greater demand for traceability,
for example. As a result of that, there is a greater
focus on international harmonisation and setting
of standards. Under the WTO, there are two
agreements, the sanitary and phytosanitary
agreement, which deals with plant and animal
health, and the technical barriers to trade
agreement. Those agreements reference the Codex
Alimentarius Commission, which has an
unfortunate name in that it automatically sounds
incredibly uninteresting. That is a joint Food and
Agriculture Organisation and World Health
Organisation body that sets international standards
and it has a dual mandate, which is to protect public
health and also to facilitate fair practices in the food
trade. This is something that we have followed for
many years, because we are members of Consumers
International, a global consumer association with
230 members around the world, and they are
recognised as observers at Codex. Codex existed
before the World Trade Organisation and was a way
of coming up with common understandings on
issues like labelling and food quality, but since the
WTO was established, and it has this new status as
a reference text, it has become very diYcult to ensure
that issues around ethics and consumer information
requirements are adequately addressed within
Codex. Certainly, when we have gone to meetings in
recent years, for example, the Food Labelling
Committee which took place a couple of months
ago, it is clear that trade concerns are becoming
much more prominent in those discussions. In many
ways, Codex should be the mechanism to make sure
that we can have this information on a global basis.
If we are talking about GM labelling or country of
origin for example, international standards are
important. Certainly Consumers International is
able to develop global positions from its
membership to present at Codex, but things have
become so slow now because everything is always
dominated by trade interests, and discussions about
the role that science should play versus other
legitimate factors like ethics and broader societal
concerns. In many ways, they are becoming
increasingly marginalised. It is something that we
are concerned about. There was a review of Codex
last year, and we hoped that that would be an
opportunity for the governing bodies, the FAO and
the WHO, to try and confront these issues, but it was
not really addressed at all. If you look at some of the
issues that are on Codex’s agenda in terms of
labelling, GM labelling has been around for seven or
eight years, and every year countries from all around
the world discuss it and no progress is made, and
they go away and go back again the next year,
because the fear is that as soon as you have a
standard on GM labelling that would allow for
comprehensive consumer information, it would
prevent certain countries from making complaints
to the World Trade Organisation because it would
aVect their trade interests. It is a real shame, we feel,
that consumer interests are sidelined by too many
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countries. Although certainly this does not apply for
all countries, and it is very important that the EU
and the UK government takes a strong stance in
these kinds of international discussions, but it is very
diYcult to get these ethical issues recognised there.
Q154 Joan Ruddock: Overall, you are clearly
pessimistic. Is Codex making any progress in any of
the areas that we have discussed today?
Ms Davies: The diYculty is that Codex is very slow
anyway, because it makes decisions based on
consensus, and when you have so many countries
from around the world, it is very diYcult to reach a
consensus on issues. If you look at the Labelling
Committee, there are issues there now like country
of origin labelling, which has not really made any
progress; there is GM labelling, where there is a
proposal on the table which would actually allow for
three types of labelling, which should satisfy the
systems that are used in most countries; the narrow
labelling in the US based on any compositional
changes or introduction of allergens, labelling based
on what you can detect in the final product, as well
as the new EU rules based on labelling of derivatives,
but that still has not been able to progress even with
those three options, because of the idea that there
would be a standard and the potential WTO
implications. Codex did agree a couple of years ago
that it did have a role taking into account other
legitimate factors, and that that would be dealt with
on a case by case basis. So there is the flexibility to
take account of ethical and environmental issues,
but again, when they are considered they have to be
decided on the basis of consensus, which is right
when you are setting international standards, and it
is very diYcult to make progress. They are also
discussing a code of ethics, for example, in
international trade, and that will go to the Codex
Commission meeting in July this year. That has
become bogged down in debates about trade issues,
and rather than actually having any reference to
ethics, many countries just want it to have constant
references to the WTO and its trade agreements. It is
a shame that what is important, a body that is
harmonising food standards and is a way to
facilitate greater consumer information and greater
consumer protection, is getting bogged down in its
relationship with the WTO.
Chairman: Thank you very much indeed for
answering our questions so fully. It has been
extremely useful.
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on Tuesday 22 June 2004
Members present:
Mr Michael Jack
Mr Austin Mitchell
Joan Ruddock
Mr Bill Wiggin
Memorandum submitted by the Medical Research Council’s Centre for Human Nutrition Research
Executive Summary
Consumers need enhanced quality not quantity of information on nutrition issues. Public policy about
food and diet must be built on evidence-based nutrition science. Many stakeholders play a role in
communicating food messages. A holistic approach is urgently needed to set an overall context, to ensure
a consistency of approach and to build a nationwide framework that facilitates the necessary changes,
from a public health perspective, in lifestyle and diet. Government must take a central steering role and
encourage others to make the promotion of positive messages about food and diet a higher priority.
HNR supports the FSA in its encouragement of industry to take a responsible approach to food
promotion. Journalists and scientists need to work in partnership to ensure that media reporting becomes
a more consistent force for good in the promotion of messages about food and diet. Health professionals
need to be given greater support and improved training in nutrition in order that they may fulfil their
critical roles in this complex area.
1. MRC Human Nutrition Research
In the UK, the Medical Research Council (MRC) has a commitment to the dissemination of scientific
knowledge to improve public health. The Nutrition and Health Communications group at MRC Human
Nutrition Research, Cambridge, has a particular responsibility for the translation of nutrition science
into policy and practice. We liaise with other parts of government, industry, the media, charities and
others to respond to their individual needs with respect to obesity and other areas where nutrition makes
a significant contribution to public health. The group provides independent scientific information on
nutrition and health to external stakeholders and a balanced perspective on recent scientific developments.
2. Introduction
2.1 Stories about food and links to public health appear almost daily in the media. There is no shortage
of information available to the public through a wide variety of sources, though a significant proportion
of it either contains inaccuracies or represents the views of vested interests. Consumers need enhanced
quality not quantity of information on nutrition issues.
2.2 The recent Wanless Report1 has highlighted once again that a poor diet is one of the key factors
underpinning the rising burden of ill health. This can only be addressed by raising awareness, improving
knowledge and initiating long-term lifestyle changes across society at large. But public policy about food
and diet must be built on evidence-based nutrition science. In promoting this, communication must be
eVective enough to “fill the gap” between scientific and technical experts, government and other policy
makers and the general public.
2.3 Each of us is exposed to thousands of messages every day, many of which relate to food and
lifestyles. Many diVerent stakeholders have a role in communicating messages about food to either groups
of or individual consumers. These include government, both central and local, manufacturers and
retailers, employers, schools, health professionals, parents and individuals. Scientists have a role in helping
to frame the debate about what information is important for consumers and to comment on proposed
campaigns and messages from many of these groups. A holistic approach is needed to set an overall
context for communicating messages about food to consumers and to ensure a consistency of approach.
In addition, eVective communication between the diVerent stakeholders is essential to build a nationwide
framework to facilitate the necessary changes in lifestyle needed to make individual food choices more
beneficial from a health perspective.
1
Securing Good Health for the Whole Population Final Report by Derek Wanless.
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3. Government
3.1 HNR is involved in consultations on food information schemes initiated through the Department
of Health and the Food Standards Agency and EU. Our own communications experience suggests that
government departments must act in unison if they are to play a central steering role in delivering
consistent, simple and well-researched messages, which are flexible enough to remain relevant to diVerent
ages throughout the life-course. In addition, since many dietary issues are strongly correlated to socioeconomic factors, consumer-oriented messages must address the needs of the poorest and most vulnerable
sectors of society. In order to achieve maximum eVectiveness, government would ideally catalyse the
development of a multi-sectoral and long-term communications strategy, which would encompass all
dietary and physical activity risks for chronic diseases together, alongside other public health risks such
as smoking and ensure that it was adequately resourced, monitored and evaluated.
4. Schools
4.1 A recent HNR initiative, A Leaner Fitter Future2 showed that many school management teams
are too preoccupied with funding crises and work force issues to consider food information a priority.
This is unfortunate as schools are in a powerful position to promote positive messages about food and
diet, both through finding time in the school curriculum and through catering and other policies adopted
by the school. For example, renewed emphasis on nutrition in the curriculum, the promotion of costeVective healthy eating options and rigorous vending machines policies would send consistent messages
to pupils and would support, rather than hinder, healthy eating habits. In addition, schools should be
encouraged to develop partnerships with parents to continue to communicate about food appropriately.
5. Industry
5.1 HNR regularly engages with industry in both formal and informal dialogue and is consulted on
nutrition and health issues relevant to the food industry. We have undertaken specific projects with
industry, including data analysis, scientific reviews and consumer awareness programmes. The food
industry is estimated to spend £450 million each year on advertising in the UK. According to the recent
FSA Hastings review on advertising to children, 75% is spent advertising breakfast cereals, confectionary,
soft drinks and savoury snacks to children. Several major companies are now taking active steps to
investigate how the communications of nutrient information may be improved, such as “nutritional
benchmarking”, although this can sometimes lead to potential for confusion in the minds of the consumer,
or at least diluted impact, as in the case of “own-brand” five-a-day logos for fruit and vegetables. HNR
supports the eVorts of the FSA to encourage industry to take a more responsible approach to the
promotion of food and the related nutrition messages.
6. Media
6.1 The main way in which HNR scientists communicate messages about food to the public is through
the media. Managing the flow of scientific information to the public has become especially challenging
in recent years. Most people get information from television, newspapers, radio and the Internet, with
relatively little coming from the scientific press.
6.2 In a culture that demands openness and transparency, the concept that scientific debate can be
held behind closed doors is outdated. A responsible media can facilitate an informed dialogue between
authoritative scientists and the public and advances in information technology allow the dissemination
of scientific developments to the public more quickly than ever before. In addition, the ever-growing
requirement for a greater consumer involvement in decision making, especially in the context of issues
such as nutrition, which have a direct impact on public health. Both of these factors demand a
sophisticated communication network.
6.3 The provision of independent and authoritative information on nutrition in a timely manner is an
important step in promoting accurate and responsible reporting of food and diet related stories. This is
a particular challenge in a field as broad as nutrition, which lacks a clearly defined professional status.
7. Scientists
7.1 Journalists are keen to seek out independent voices and this has resulted in scientists becoming
increasingly visible in the public arena. Scientists can help the media through identifying the source and
status of new information, thus allowing consumers to make informed judgement about its credibility
and putting findings in a context that can be useful for consumers, such as by contrasting with existing
knowledge and future research needs. If journalists and scientists work in partnership, it can help to
reduce the risk of new and unconfirmed reports reaching the front pages, only to be apparently refuted
the following week.
2
A Leaner Fitter Future—Options for Action is available from www.mrc-hnr.cam.ac.uk
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7.2 Inaccurate or partial media reporting of food stories, however, can also undermine the interests
of both parties. This can happen, for instance, in the reporting of studies involving a small sample size
or where they have been inadequately peer-reviewed, or where preliminary scientific findings are being
reported. In addition, the media can sometimes foster controversy where little or none exists, such as
industrial collaboration with scientists, which can also have the eVect of undermining public confidence
in scientific communications.
8. Scientific Method
8.1 The media likes clear-cut stories, or controversial ones, but there is a potential conflict here with
established scientific method, which doesn’t deal with certainties. Public understanding of the scientific
method is also highly variable, and the process by which scientific evidence is translated into policy is
frequently unclear. This can lead to public misunderstanding of science or enhanced perceptions that
scientific advice changes too frequently.
9. Food Labelling
9.1 Food labelling is an important element in the provision of nutrition information to consumers,
but consumers must be able to interpret the data appropriately to make meaningful choices and changes
to their diet.
9.2 HNR supports the work of the Joint Health Claims Initiative, but recognises that this will be
superseded by forthcoming EU legislation.
10. Health Practitioners
10.1 Health practitioners are an important source of information on food and nutrition and HNR
would like to see more emphasis placed on nutrition in their training, especially in formal nutrition and
medical curricula. It is also important that the public are able to identify appropriate trained nutritionists
and we support the development of a Register of Nutritionists and accreditation of nutrition courses by
the Nutrition Society.
11. Educational Campaigns
11.1 Educational campaigns require a long-term strategy and adequate resourcing to be successful. In
recent years, the government-led campaigns to encourage consumers to eat more fruit and vegetables
and to consume more oily fish have increased the level of awareness of the importance of these food
groups at least in some sub-groups of the population. Diet composition is a complex subject to
communicate, requiring separate messages about calories, the proportion of specific types of fat, protein
and carbohydrates and the additional health eVects of food groups such as fruits and vegetables and
alcohol and the importance and health eVects of micronutrients. Such a diverse range of messages about
food can be diYcult for consumers to assimilate, potentially leading to a perception of scientific discord
or confused public policy.
11.2 Educational campaigns about food and diet also need to be flexible enough to meet the needs
of individuals at diVerent stages of “lifestyle change”. For example, research in the behavioural sciences
into obesity has developed useful models to describe the “stage of change” of an individual at any moment
in time, ranging through pre-contemplation, contemplation, preparation, action, maintenance and
relapse. These models acknowledge that the messages for individuals need to be tailored to their needs
at the time. Thus a pre-contemplation individual needs the motivation to even consider the need to make
lifestyle changes, while an individual who has arrived at the action stage needs practical implementation
strategies. Newspapers, and to a lesser extent magazines, sell to a broad cross-section of society with
respect to their personal weight agenda. There is a temptation for scientists and journalists to leap to
providing action-orientated messages, yet the majority of the population have not yet reached this stage
of change and hence the information fails to initiate change. Instead, a greater emphasis on messages
that raise awareness of the links between food and health in order to move individuals into the
preparation stage is needed.
12. Advertising
12.1 HNR has no specific scientific expertise in the impact of advertising on food choices.
April 2004
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Witnesses: Dr Susan Jebb, and Mr Adrian Penrose, Medical Research Council’s Centre for Human
Nutrition Research, examined
Q155 Chairman: Good afternoon, Dr Jebb, and
Mr Penrose. Welcome to the meeting of the Food
Information Sub-Committee. I look forward to
what you have to tell us about today. I understand
you want to make a very short statement before we
ask you about your work done at the centre. We
do have a very heavy timetable this afternoon, so
if you want to make that statement as briefly as
possible we would appreciate that. If you would
like to make that brief statement at this point.
Dr Jebb: Firstly, thank you for the opportunity to
come and speak with you today. We are here really
representing the Medical Research Council Human
Nutritional Research Centre based in Cambridge.
Our emphasis is really on strategic and applied
aspects of public health nutrition; we are first and
foremost a research unit. What makes us slightly
diVerent from most other research institutes, and
certainly within the MRC, is that we have a specific
communications function which is in-house and
headed up by myself as a research scientist. I, in
parallel, am responsible for our programme of work
on nutrition and long-term health outcomes as well
as heading our nutrition communications group,
which works with consumers, the media, and also a
wide range of other stakeholders, including
industry, health professionals and the Government.
I think that puts us at a particularly interesting niche
as far as this particular inquiry is concerned with, if
you like, a foot in both camps in terms of the
evidence base, and, secondly, the translation into
policy and practice. I am really going to be trying to
speak to you today with that perspective, which is
perhaps a little bit diVerent than you may be
accustomed to with other MRC scientists.
Q156 Chairman: Thank you. That is very helpful
indeed.
Dr Jebb: I should perhaps introduce my colleague,
Adrian Penrose, who is our communications
manager and has a background and expertise in
communications as opposed to my own expertise in
nutritional science first and foremost.
Q157 Chairman: I was very struck by the first
statement in your written evidence that consumers
need enhanced quality not quantity of information
on nutrition issues. I think that has been a theme of
much of the evidence that we have had. Everyone
comes up with a long list of information which
should be provided; that, of course, illustrates the
problem. I was struck by your point regarding the
diversity of messages amongst both the scientific and
the public policy communities on these issues. How
far is it possible to say there is actually a general
body of agreement amongst those scientists and
policy makers on some of the key matters relating to
food and diet, the key messages that should be given
out to the public?
Dr Jebb: I think there is very good agreement on the
headline issues, the big topics. Those would be, for
example, fruit and vegetables; the need to increase
fruit and vegetable consumption. We have the five a
day programme. There would also be the need to cut
salt; we have seen particular emphasis of that in
recent years. There is also a recognition of the need
to cut saturated fat. That is an interesting message
because it is a very clear and widespread agreement
between scientists and policy makers. It is also one
of the messages which maybe 20 years ago was
clearer than it is now. Consumers are increasingly
confused about the diVerent types of fat and the
issues in relation to saturates, monounsaturates,
polyunsaturates: Is the issue obesity? Is it heart
disease? Is it cancer? I think that is a classic area
where the science is very clear that we should be
cutting saturated fat. That is the key message. The
policy is actually very clear, but I think for a variety
of reasons consumers are increasingly confused.
Q158 Chairman: Which types of messengers do you
think are the best to deliver that message to the
public? We heard evidence last week that the public
really did not trust messages coming from not just
government but government-related oYcial bodies
when it comes to food information. Who do you feel
the public trust most and how should these messages
best be conveyed?
Dr Jebb: There are many ways of answering that
question. The surveys show that people trust health
professionals, their doctors, very highly. They rate
them very highly, but if we think that we are going to
improve the nutritional understanding of the entire
nation doing this through health professionals, that
would be naive. The question is not so much the best,
the most trusted group, but which is going to be the
best strategy? If you take that approach, I think the
answer is that there is no one group who are well
positioned to take that on in a single-handed
fashion. The reason we have problems at the
moment I think is the inconsistency between
diVerent groups, not only sometimes in the core
messages but certainly in the way they are portrayed.
What I think we really need is for there to be
consistency of messages across the diVerent
people communicating. DiVerent people, diVerent
stakeholders are able to communicate well to
diVerent groups at diVerent times and in diVerent
places. There is no one organisation which is going
to be able to address everybody equally and
eVectively all of the time.
Mr Penrose: I think it is important to remember as
well that science is very diVerent to policy. Science is
there to answer specific questions, but it is ethically
neutral. It does not make assessments about risk or
benefit. What we are looking for is some kind of
system that can mind the gap between scientists,
what Government is saying and what consumers are
understanding, that is really what we are looking
for now.
Chairman: Austin, do you want to follow that up?
Q159 Mr Mitchell: What should I rely on in terms of
the kind of food that we should eat or should not
eat? As you say, saturated fats are bad for us; where
do I get saturated fats? I am made to eat forcibly
(because my wife is a New Zealander), butter in
enormous quantities to help the export market in
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Dr Susan Jebb and Mr Adrian Penrose
New Zealand. Is she killing me? Should I be eating
Flora? What is the impact of your research on a
market which is dominated by commercial
products? The butter makers attack, wanting you to
take butter or the sugar makers, sugar. How do you
fit your advice into the commercial market?
Dr Jebb: Of course, one of the huge benefits of being
a Medical Research Council is that we do have the
luxury of that commercial independence. That is not
to say that we do not work with the food industry.
We do, but we are able to do it from a position in
which we are predominantly independently funded
and which we are known for the quality and
credibility of our research. So we are able to take
forward our research agenda I think in a very
rigorous and robust way which is free of vested
interests.
Q160 Mr Mitchell: Do you say: “Do not eat butter”?
Dr Jebb: I do say that you will be better oV choosing
an alternative spread, yes.
Q161 Mr Jack: In paragraph 11.2 of your evidence,
you say there is a temptation for scientists and
journalists to leap to providing action-orientated
messages, yet the majority of the population have
not yet reached this stage. What evidence do you
have for that statement?
Dr Jebb: There is quite a body of research, not our
own I hasten to add, which has looked at people’s
readiness to change in a whole variety of diVerent
aspects of their life. The one I am most familiar with,
of course, is obesity. We, as health professionals
assume, say, as clinical dieticians, if somebody
comes in through the door who needs to lose weight,
there is a tendency to assume that they are ready to
do it, they are motivated, they want to lose weight,
and so forth. In fact, sometimes they are simply there
because their doctor told them to go and see the
dietician. They have not made that mind shift that
this is an important issue for them, that they need to
take some action. So if you are dealing with
somebody who is in this stage where it is not even on
their agenda why they should change then what you
need to be doing is giving them messages which
explain to them the health benefits or what they
might hope to achieve by the change; rather than
telling them they should have Flora rather than
butter.
Q162 Mr Jack: Not everybody has the benefit of a
one-to-one with you?
Dr Jebb: Yes, that’s true
Q163 Mr Jack: What, from your experience, are the
things that people believe? I asked this question last
week so I shall ask it to you. I have been struck by the
unbelievable take-up of the Atkins Diet. From being
not on the radar it suddenly becomes the number
one thing that people are doing. I was interested to
know what actually motivated people to accept lock,
stock and barrel a diet which has been the subject
of considerable debate but where advocates
immediately start to become Evangelists and there
was no oYcial input. They just said, “That is for
me—I did it”. Why has there been such an uptake for
that, and yet trying to get through the message that
you started your evidence with seems to be so
darned hard?
Dr Jebb: I think that is a classic example of where
anecdote, endorsement and culture has steered
public habits, dietary habits in a way that scientific
evidence does not always achieve. Of course, there
are some examples where scientific evidence has
moved it, but in that example, it was a whole range
of social and cultural factors which encouraged
people to adopt that particular dietary approach.
What it shows is that dietary habits are not set just
by science or by health priorities. They are set by a
whole range of other issues which are going on. We
need to understand that and to understand why it is
so diYcult to change behaviour through the
mechanisms which you, as policy makers, or we, as
scientists, have at our disposal.
Q164 Mr Jack: If I have heard you correctly, we are
not communicating the messages properly?
Dr Jebb: We are not always communicating them in
a way which motivates people to adopt them.
Q165 Mr Jack: Safe and sensible does not sound to
me like a very good way forward. Anecdote,
promise, chat, grapevine: those might be better ways
to get our messages across.
Dr Jebb: The grapevine is a fantastic way of doing it.
We have seen—I think Mr Mitchell mentioned
Flora early on—Flora was an example of where
marketeers within the food industry brought the
word “polyunsaturates” to public attention. They
had a very sophisticated advertising campaign. That
was founded on scientific evidence that there were
real health benefits in switching from saturated to
polyunsaturated margarine. That was a time where
we had the scientists giving out the scientific message
and the marketeers marketing that message in a way
which neither Government nor scientists tend to do
in a more entertaining way perhaps and also we have
the food industry providing a product which met
that need. Then we got real change and there was a
dramatic shift in eating habits.
Q166 Mr Jack: Is there a paradox between the
purveyors of a spread which claims to reduce
cholesterol in terms of the message: “spread fat:
reduce cholesterol”?
Dr Jebb: That has been a tricky one. But I think that
the manufacturers of plant stanols and plant sterol
esters have worked very hard to do it in a very
responsible way, not least ensuring that they provide
low fat options for each of those products so that
one can get the same cholesterol lowering benefits
from a plant sterol ester low fat product. I think
ideally one would like to see it in a fat-free product,
but they have really tried to do that in a very
responsible way.
Q167 Mr Jack: Let me finally take you up on a point
that you make in paragraph 5.1 of your evidence.
You say: “Several major companies are now taking
active steps to investigate how the communications
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of nutrient information may be improved such
as nutritional benchmarking.” That is terribly
responsible and very scientific. Does that mean they
do not stand a prayer of getting that information
through in the light of what you said earlier about
people picking up on and acting on things like the
Atkins Diet?
Dr Jebb: No, I do not think it does. The point I was
making earlier is that people make their dietary
choices for all sorts of reasons. DiVerent factors
motivate people at diVerent times and in diVerent
places. Often the people who are the most educated
and health conscious, who have made the
fundamental decision, they want to change their
diet, they know what it is they are trying to do. They
are the people who need the nutrition labelling.
When they are in the supermarket they can look at
the labels and they can make the right choice. For
them, improving nutritional labelling, making it
more sophisticated will be really helpful to move
those people a little bit further on into a healthier
diet.
Q168 Chairman: You point out in the same
paragraph that Michael just referred to that the food
industry is estimated to spend £450 million each year
advertising in the UK. Is it not predominantly a
result of a factor that when a product is advertised
every half an hour or so on commercial TV it has a
much higher likelihood of persuading people of its
content than the occasional food information
message from Government? How far, in fact, can the
free information in messages compete with the
weight of advertising?
Dr Jebb: As we have said earlier, there is a whole mix
of influences on what people are choosing to do.
Advertising is one of them. I can only refer you—I
am sure you have seen it already—to the FSA
commissioned review from Gerard Hastings which
looked at the impact of advertising on food choices
in children in great detail. It showed that, yes, it did
impact, but that it was almost impossible to quantify
the magnitude of that impact alongside all the other
influences on food choices.
Mr Penrose: Food budgeting is very complex
because of the kinds of people who are likely to be
interested in reading the nutrient labels are probably
also making decisions about things like
sustainability, where the food is coming from,
whether it is organic, whether it is produced locally
which makes the actual purchasing decision very
complex for that person.
Q169 Joan Ruddock: I wanted to ask you to look at
the Government’s role in transmitting food
information messages. You said I think in your
evidence that you were involved with the
Department of Health, the FSA and the EU, not
Defra. Where, in fact, food is split in terms of
government departments between Defra and the
FSA, which of course reports to health ministers. I
just wonder how diYcult it is for organisations like
your own and lobby groups in general to interface
with government, how much confusion you find the
government overlap, or whatever. What are your
views of how the Government itself is approaching
these issues?
Dr Jebb: I think there are two parts to that one
question. One is how Government is approaching
those issues. Secondly, how easy scientists find it.
Perhaps I will take them in that order. We certainly
perceive, and I do not think we are alone amongst
the academic community, in feeling that there is too
much fragmentation in government action in
relation to food, that there is a lack of joined up
initiatives across a whole range of diVerent areas,
that there are competing priorities coming from
diVerent departments and that makes it diYcult for
everybody: for scientists, for the food industry, for
consumers, for anybody to know quite where they
are. I am cautiously optimistic that that message has
been heard by Government. Particularly over recent
months the obesity issue has highlighted that
enormously at the Select Committee inquiry; in
other areas too. Now we have things like the Activity
Coordination Team, the Food and Health Action
Plan, both of which are in principle across
government. So I think it seems to me that the
message has been heard. Whether it has been fully
acted upon is probably too early to judge, but I really
truly hope that that is the case because food cuts
right across government. We get into DFES with
issues in schools. We get into DFID. All over if we
are going to make progress, it has to be joined up. As
far as scientists are concerned, having a joined-up
government would help us enormously to interact.
Scientists are not trained in policy issues at all—I
have sort of slipped into this. When faced with policy
consultations I notice that we are one of relatively
few academic institutions who actually respond to
those consultations. They take an enormous amount
of time. We sometimes feel like we are drowning.
Just recently we have the White Paper, the Food and
Health Action Plan, we have the activity plan, the
FSA Strategic Plan, this Defra one, the promotion
of foods to children. It is absolutely mind boggling.
We try to respond to those and that is really our
eVort to engage with Government. The fact is that I
think it would not occur to us really to come directly,
in most instances, to ministries to talk about issues.
That is not really the way scientists work. We tend
to sit there and wait to be summoned. I think it is
unfortunate that Government does not make more
use of scientists to help them in developing the
evidence base, in developing policy. There are clearly
one or two important advisory committees, but
perhaps they are not even used as much as they
might be.
Q170 Joan Ruddock: If I may interrupt you, do you
have a suggestion to make? You are already
overwhelmed you told us, how would you like to do
more work?
Dr Jebb: I think that certainly at the Medical
Research Council we are part of Government. I
think that there could be some useful discussions at
a very senior level as to how the Medical Research
Council should best be using its science to inform
policy because it certainly seems to me that it is a
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rather ad hoc arrangement at the present time.
Looking at it from the other angle, I am acutely
aware, talking with the nutrition scientists in the
Department of Health, that there are fewer of them
than ever before.
Q171 Joan Ruddock: Really?
Dr Jebb: Yet nutrition is on the agenda in such a
major way that they are under enormous pressure. I
think that we have to find a way of getting in skilled
expertise from outside in order to inform policy;
consultations are one way of doing it, but I am not
sure it is always the most eVective.
Q172 Joan Ruddock: I think you have just written a
Parliamentary question on how many nutrition
scientists there are in the Department of Health.
Thank you for that.
Dr Jebb: Certainly, there are fewer than there were
a couple of years ago.
Q173 Joan Ruddock: Should that prove to be the
case, and I have no doubt you must be right, that is
a serious matter I think for us to consider. I would
like to just refer also to a point that you yourself
made about the Minister for Public Health and the
messages about cutting salt. Do you think that was
a useful initiative and is it your belief that
Government needs to legislate in this area because
we know there is a lot of voluntarism in this cut.
Clearly, there are messages going to people who are
taking very little or no notice of the previous pleas of
Government.
Dr Jebb: Firstly, it has been absolutely essential,
vital and very important that Government has said
loud and clearly that salt matters, and called upon
the food industry in no uncertain terms to cut salt
intakes. That has been critical; the salt debate has
been rumbling for years. There has been actually
stunningly little progress until the last six months or
a year. Some progress: we have seen salt in bread
come down over the last few years. I have to say my
feeling, and I think it is shared by my colleagues, is
that we are seeing real progress on salt within the
food industry. Of course, we would all like more and
more quickly, and so forth, but we are seeing such
substantive progress compared to what we have had
two, three, four years ago. My own feeling is that at
this stage of the game we should be highlighting
those people who have done the most, achieved the
most, and applauding that. That might actually be a
more constructive strategy. So naming and praising
rather than naming and shaming I think would have
been my choice. We are moving in the right direction
and what we want is to keep that bandwagon going
and going at an impressive rate. I think we need to
remember that with these nutrition things—if we
want the food industry to start producing healthier
options and marketing and supporting those—we
have to do it with them. If they dig their heels in and
refuse to do anything we will all be worse oV. I really
do believe we have to do this in partnership and a
spirit of constructive engagement is what is required.
I think they are making progress with salt. We need
to keep the pressure on, but we need them to do
much more on fat and sugar and a whole load of
other things too. We have to stay positively engaged.
Q174 Joan Ruddock: Are you saying: “do not
regulate, just put more pressure on getting
agreement”?
Dr Jebb: At this stage, I think we are making
significant progress with voluntary action. I think
that if we can continue to do that then that is what
we should do. Because if we go for regulation what
we will end up with is diverting a proportion of the
industry into finding a loophole rather than trying to
find positive ways of making progress. Having said
that, regulation clearly has to be there as the stick,
the Government needs to wield a regulatory stick
and be prepared to use it if necessary, but I am not
sure that we are at that point yet.
Q175 Mr Mitchell: Does that mean you are not
happy with the European Union’s approach? It
seems to me to be a matter of imposing labelling
definitions on the consumer. If you say your
preference is for the voluntary approach when
making progress, what is going to happen when this
is imposed on us?
Dr Jebb: There are two separate issues here. I was
talking about voluntary changes in product
composition and product innovation and so forth.
That is quite diVerent from regulation in relation to
labelling. There is already labelling taking place. I
think that regulation may be necessary in order to
ensure it is done in a consistent way, but again, with
labelling, it seems to me that there is actually a lot of
agreement that we need good, informative labelling.
Consumers want it, Government wants it, scientists
want it and I certainly have not heard the food
industry objecting to having clear and informative
labelling. The question is how can we do that? What
we really need to do is to get people together and
come up with a better system. I think we have to stop
pretending there is a perfect system. I am not sure
there is, but we need a better system which people are
prepared to sign up to and use consistently. At the
moment, labelling is becoming bigger than it ought
to be. It is becoming a bit of a diversion. We spend
so much time and energy worrying about labelling
when it is only one small part of the overall issue of
how are we going to improve things to help
consumers to help themselves to a better diet. We
need to ring fence labelling into a discreet working
group who get on and come up with some practical,
workable solutions and the rest of us should get on
in making progress in other areas.
Q176 Mr Mitchell: That depends on receptive
consumers at the other end. You worried me there
earlier by your emphasis on the grapevine. The
grapevine is like the internet; is it not? All sorts of
rubbish flows through it. You mentioned earlier
Flora. From time to time there are articles saying
Flora is a waste of money, it is overpriced and is not
going to do you any good. You might as well stick
to butter. You see all sorts of stuV about drinking a
glass of red wine a day. So I inevitably go in for
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excess and drink three or four, but it helps your
heart. You see organic food: that is good for you and
good for your children. Yet the Food Standards
Agency tells us it is a lot of rubbish. We feed milk to
kids at school then tell them not to drink milk when
they get older. The fish and chip shops were strung
up with posters saying: “fish and chips, the health
food”. Now we are told fish and chips are bad for
you, but then we are told fish is a brain food. What
is the consumer to believe in all this?
Dr Jebb: I recognise absolutely all of that and I
completely understand and share your concerns that
consumers are confused. They are confused because
there are so many messages. This comes back to the
whole issue that nutrition science is not straight
forward. This is not smoking where the one message
“stop smoking” meets all circumstances, all
eventualities. With nutrition science you have
endless diVerent nutrients, endless diVerent foods. It
is probably at the end of the day the combination of
that which really matters. That makes it
phenomenally complicated for people to work their
way through. Where do they look to for good
information? That is hard. I think they do still have
some trust in independent scientists. They still like to
hear that the scientists have said something. Of
course, that has been hit by some of the recent scare
stories and worries, not least BSE, but scientists are
still there and I think have some trust with the
public. I think Government still does have some
trust. The Food Standards Agency has done a lot to
work with consumers and to bring the evidence in
front of consumers. We are not going to solve this
overnight, but we all have to be working in the same
direction. The other thing we have to recognise is
that consumers’ level of scientific understanding is
actually very low. That makes it diYcult not just to
teach them about good nutrition but about so many
other things as well. It is about risk. Consumer
understanding of risk is very confused. It is even
about averages. People have real diYculty grasping
the basic concepts. So we need to up-skill consumers
in their basic understanding of science alongside
more specific nutritional issues.
Q177 Mr Mitchell: You are going to tell me I am too
old for it. How useful would labelling be in this?
Nutrition: it is diYcult for consumers to choose
what a nutritious diet is. Should provision of
nutritional information be part of a label system?
Should that be compulsory?
Dr Jebb: Of course, we have nutritional labelling and
information in the declaration at the moment, but I
guess what you are getting at is the idea of a firmer
guide as to what is healthier food. This is an issue
which the Food Standards Agency is working on
actively at the moment as part of their work on the
promotion of foods to children. I guess it brings us
to the heart of the good food/ bad food, good diet/
bad diet story.
Q178 Mr Mitchell: It also takes us to the traYc light
system. Should you tell them what the nutrients are
and should they be signalled by a kind of traYc
light system?
Dr Jebb: Let us take traYc lights head on. The traYc
light system is initially attractive because it sounds
so simple and it sounds like it is going to cut through
all this and give the consumers a simple red, yellow,
green signal. That is its attraction; it is also its flaw.
Because it is so simplistic how on earth are you going
to compress all this great complexity of nutritional
science into a single three point system? To give you
some of the issues: are you going to use these traYc
lights to indicate to consumers the choices within a
category or across categories? What I mean by that
is, take reduced fat crisps. Reduced fat crisps clearly
have less fat in than the original. Does that mean
that the original is a red food but the reduced fat is
a yellow food because it is a healthier choice relative
to the full fat variety. It is not a healthier choice
compared with a banana. So if you are trying to have
one traYc light system which works across
categories it becomes very diYcult. Then if you were
doing it across categories probably all of these high
fat savoury snacks would all be red. That would
instantly discourage food companies from
producing healthier versions of those because they
were always going to be a red. A traYc light becomes
very diYcult if you are trying to match up the
maximum benefits within a category, with a cross
category cutting scheme. The other issue is what
nutrient are you going to focus on? Is this just about
fat, which I was talking about, or is it about fat and
salt or salt and sugar, and what about micro
nutrients? Then you got into the whole issue of
producing a very complex nutritional score. That
becomes mind bogglingly diYcult. It may be
necessary for foods like cheese because cheese is high
in fat, it is high in salt but it is an important source
of calcium. Would we really want to label cheese as
red because it is high in fat and salt? Maybe not. This
is not the time or place to go into the pros and cons
of all the systems, but I can assure you this exactly
what the FSA working group, which I sit on, is
looking at in great detail, not only for a traYc light
system but looking at a whole range of options
which are being used nationally and internationally.
Q179 Mr Mitchell: It sounds impossibly
complicated. What you are saying, I take it, is it is
diYcult to provide additional labelling information
to show information to the consumers unless you
also educate consumers. The two steps have to go
hand in hand.
Dr Jebb: Absolutely, yes. You need an educated
consumer who knows how to use the label, knows
what they are looking for and is also already
motivated to want to go to that time and trouble.
Q180 Mr Mitchell: Okay. Are you also saying the
diVerences in traYc lights, between diVerent kinds of
food, but there is no such thing as good food? There
is such a thing as good diet but good food, bad food
is not on the same dimension?
Dr Jebb: To some extent. Clearly, there are no foods
which are so good that if you eat them they override
everything else in your diet. Clearly, there are no
single foods which are, to put it bluntly, going to kill
you tomorrow. It does not work like that. It is about
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the overall balance. If you just talk about good
foods, bad foods, it ignores all of the important
issues about how often you consume that food,
about the portion and size that you consume. So, of
course, one has to say there are good diets and poor
diets, but the problem is that this has become a real
mantra. The food industry uses it to hide behind.
There are no good and bad foods: end of story. They
use it as a closing statement to avoid moving any
further forward. I think it is quite clear, common
sense and rational consumers are quite clear that
there are some foods which provide quite a lot of
energy and virtually no other nutrients. Sugar-rich
soft drinks would be a prime example of that. They
know it is perfectly possible to get the same number
of calories from a diVerent food which contains a lot
of other nutrients and that that other food would be
a healthier choice than the food which is just calorie
rich which contains no nutrients. I think the Food
Standards Agency has done a good job, in a way, of
putting the whole issue in the spotlight and saying
quite pragmatically: surely it is clear that there are
some foods which are healthier than others? Whilst
it may sound like a bit of a cop out I think it has
actually moved the discussion on a bit to start saying
that there are some healthier and some less healthy
options.
Q181 Mr Jack: How do you communicate the
benchmarking messages? Because listening to what
you were saying earlier on about micro nutrients,
vitamins, salt, sugar, fat, it is quite diYcult if you are
where you are to then say: how do I benchmark where
I ought to be? How do I know how many grammes of
this, that and the other thing I ought to be consuming?
How do I develop the awareness so that in my
everyday workings where I have for some period of
time control over what I eat because I prepare it and
other times I have subcontracted that to a whole
variety of people who have provided me with my
meal? How do you get through to people the starting
point and also the simple information that enables
them, to at least be aware at the back of their minds
that, as they go through their week consuming all this
variety of foods prepared in all these variety of ways
that, they are either above or below where they ought
to be to hit the Nirvana of the perfect diet.
Dr Jebb: It is diYcult and you are absolutely right that
this is an important secondary element of the
labelling. We have started this by putting the
guideline daily amounts on packets which tell you
typically that a woman needs 2,000 calories and a
man needs 2,500, and sets out the goals for fat, for
example.
Q182 Mr Jack: Like: “A Mars a day helps you work,
rest and play”?
Dr Jebb: Fortunately they do not use that any more.
So we have started to do that, to give people the
benchmarks about where they should be. They can,
therefore, look and let us use the Mars bar example.
They can take a king size Mars bar versus a snack size
one. They can see the king size provides about 20% of
their daily energy needs in a single item, whereas the
snack one provides only 10%. They can then decide
what proportion of their calories they want to spend
on this snack. I think that is a start. It is a rather simple
thing but rather helpful to people. The complexity
comes with how many nutrients do you want to do
that for? That is where it becomes much, much harder
and also harder at a population level. We can say if we
think of macro nutrients, the energy providing
nutrients, that in general people are consuming too
many calories for their energy needs, which is why
most people are getting fatter. In general, they are
consuming too much saturated fat and are
consuming too much salt. We can set some guidelines
for those, but if you start looking at micro nutrients
you get much bigger disparities with the population.
Q183 Mr Jack: I am going to stop you there. Is there
any research to show us of all the things you have just
discussed, what the relative levels of awareness are
from people? In other words, what messages get
through about all these things and upon those
messages? What proportion of the population
actually reacts to them? You said that: “I think the
message was much clearer 20 years ago”, about
saturated fat. I suppose my sort of question is, as the
fat issue has come up the agenda, what has clouded
the message? What makes it less clear? Was there
some period where people had a much better idea of
what they ought to be eating and had worked out
strategies to achieve a good diet? But now we
eVectively are getting a message saying that people
have picked up a lot of bad messages, so they have
bad diets.
Dr Jebb: They have become confused. I think the fat
one I would specifically put at Atkins’ door where we
have had the emphasis that actually eat as much fat as
you like, it is absolutely fine. That I think has really
undermined what had been a very consistent and
coherent message that too much saturated fat was
bad for your heart.
Q184 Mr Wiggin: Can you accept with the Atkins
Diet the reason that people do it is that it actually
works, whereas all the other diets we have been told
about running up to now: “I have tried it and it
works”.
Mr Jack: What do you mean by “works”?
Q185 Mr Wiggin: It works. It does what the book
says; it works. None of the others do.
Dr Jebb: All diets, if you do what it says in the book,
work because they are all low calorie diets. The
problem is that people find them diYcult to stick to.
For some people, by no means everybody, some
people have found that the Atkins Diet works for
them in the sense that it fits in with their lifestyle. The
research evidence shows that if you look at people
over the course of a year within the context of a
clinical trial people do equally as well, or equally as
poorly following, Atkins as they do following a
traditional low fat diet. The anecdotal impression at
the moment is that it is wildly successful. The research
evidence is that it is equally as eVective as other diets.
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Q186 Mr Wiggin: The diYculty is, and I think this is
why it is so important, a lot of what you have been
saying has been about what is good for you and what
is not. The only message—I think Austin said it
earlier—was that a glass of wine was actually good for
your heart, it was red wine. A lot of the information
we have been given about food has been, “if you eat
too much salt it will harden your arteries, and that is
bad for you”. At that point you say, “I will try and eat
a bit less”, but it is already in the processed food.
There is no control that an individual can actually
take, in real terms, over their diet until they do
something fairly extreme like Atkins.
Dr Jebb: I refute that. Salt is an unusual one because
around 75% of the salt people consume is consumed
as part of processed food. So they have less control
over their salt intake than they do over other things.
Of course, one does choose to what extent you use
processed foods versus fresh foods, but that decision
is made for all sorts of reasons. For other areas people
have a huge amount of choice: they choose how much
fruit and vegetables they consume; they choose
whether they cut the fat oV their meat or not; they
choose what kind of breakfast cereal they have. I
think you make an interesting point about the
diVerence between positive and negative messages.
We have become much more aware of using positive
messages. We have seen five a day for fruit and veg. It
is a very positive campaign. We are seeing in the
United States things like whole grain, putting the
emphasis on choosing good carbohydrates with the
low glycaemic index message being promoted. I think
that is a learning curve we have been through and we
are now trying to adopt more positive messages.
Q187 Joan Ruddock: I just wanted to take you back
for a moment to the traYc light system. As you say, it
is so simple and so attractive. When we began this
inquiry I was hoping very much we might end up
saying “Do that”, if the one thing we could say would
be do that. So I am concerned, but I understand
exactly why you said it is a flaw. Can you not envisage
any system that is as simple as that in terms of the
consumer looking at the product that could be
accompanied by a framework? So, for example, if you
are eating more than X reds per week you must stop
and think. If you are eating this combination your
picture looks like a nice sunny yellow, you are
probably okay. Is there any way we might be looking
to achieve something that has a simplicity? I know
when I shop I have no time, and most women that are
shoppers are like me, they just do not have the time.
Dr Jebb: I do not think you should throw the traYc
light system out altogether at this point. What I was
trying to do is to illustrate some of the complexities of
it. However, it is perfectly possible that one has an
incredibly complex system of definitions and
profiling which all goes on behind the scenes, which
policy makers have set, which scientists have agreed,
which the food industry are very aware of, and that
actually the manifestation of that is something very
simple on the front of the packet. That is not out of the
bounds of possibility but it will require a lot of careful
working up to sort that out. I think what you may be
asking for is something which is perhaps a little bit
diVerent and is perhaps more analogous to some of
the flashes we see, logos we see on products already.
So things like, for example, the folic acid logo. If you
are trying to increase your folic acid there is a logo
which some companies use which tells you that this
product is particularly high in folic acid. This is also
used in a more medical context for people with
allergies. They are marked up and used to indicate a
vegetarian food and so on. I think there may be
opportunities for again coming back to using positive
messages to flag up that there are particular attributes
of this food which might mean you really might
actively want to choose this. In doing so, we have to
make the hope that that displaces something else
from the diet. If one is going to go down that route
clearly you need to do a lot of research to ensure you
are achieving what you thought it was you were
doing, but there may be some mileage in that which
harnesses many of the points you are making about
simplicity, about positive messages, and so forth.
Mr Penrose: I think underlying this is the need to
communicate the whole message. Part of the problem
at the moment is that we have food messages, dietary
messages and physical activity messages. Whatever
system we choose we have to make sure that the
nutrients and concepts are linked to specific foods to
enable us to be able to turn these abstracts into
shopping lists so that people can do something
tangible.
Q188 Mr Jack: You have sent me a complex message:
what is the hypo—whatever it was—index?
Dr Jebb: Low glycaemic index. Glycaemic index is a
measure of the extent to which a food raises your
blood sugar level. Quite clearly for people who suVer
from diabetes it is extremely helpful and valuable to
choose foods which have a rather low tendency or
make a small increase in your blood glucose levels.
But this message, to my mind, is being portrayed
more generally to consumers in advance of the
scientific evidence really being marshalled. We do not
have any good categorical evidence that for the
average person choosing low glycaemic index foods is
going to make you lose weight or reduce your risk to
these various diseases. It is probable, the evidence is
tending in that direction, but it is by no means
concrete yet.
Mr Jack: I feel better already.
Q189 Chairman: Thank you very much indeed for
coming along to give us your evidence. It has been
very interesting. If there is anything you want to add
in writing having given us evidence today, in light of
what you said, feel free to send it in to us in due course.
Otherwise I thank you very much indeed for your
evidence this afternoon.
Dr Jebb: Thank you.
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Memorandum submitted by Sustain: the alliance for better food and farming
1. Introduction
Sustain advocates food and agriculture policies and practices that enhance the health and welfare of people
and animals, improve the working and living environment, enrich society and culture and promote equity. We
represent around 100 national public interest organisations, and are independent of the agri-food industry.
Current work includes:
— Promoting citizens’ participation in food policy making processes.
— Reforming farming and food systems, in the UK, via the Common Agricultural Policy and through
the World Trade Organisation.
— Tackling food poverty.
— Promoting five portions of fruit and veg a day.
— Facilitating a sustainable London food economy.
— Encouraging sustainable food supplies in public sector catering.
— Protecting children from junk food marketing.
Unfortunately, there has not been time to consult fully with our membership on this submission so it does
not represent the detailed views of all relevant members. However, it is based on extensive work we have
done with them in the past, and on their respective published policy positions on the issues covered by this
inquiry, so the general principles outlined are widely supported. Given the very broad scope of the inquiry,
which we warmly welcome, Sustain would be very happy to appear before the committee to expand on the
range of issues summarised in this submission.
2. Why do we Need Food Information?
One of the main conclusions of Sir Don Curry’s report into the future of farming and food3 was that
citizens have become almost entirely disconnected from the land and from the farming systems that produce
our food, and that this has a number of negative consequences. One of these is that people know very little
about the realities of food production. Surveys continue to show that, for example, some children think
oranges are grown in Britain4 and some people think margarine is made from milk.5
In a largely urban society, these gaps in our knowledge are perhaps not surprising. In previous decades
these gaps may have been filled by schools teaching about farming and food in the curriculum,
complemented by practical skills such as cooking in fully equipped domestic science rooms and growing in
school farms and gardens. However, although food education and skills have a place in the National
Curriculum, the content and practice vary widely. There is much anecdotal evidence indicating that children
are as likely to be engaged in designing a box for a pizza, as they are creating and baking one or—even less
likely—growing any of the ingredients.
Even if we were fully connected to and informed about the farming and food system, most of the food
we buy now comes packaged, and often processed, so the ingredients are simply not visible. Information
about what is in the package is therefore essential if the market is to work eVectively and consumers are to
make informed choices. However, it has been argued that inadequate food labelling is an example of market
failure.6. This submission will also argue that the information that consumers need to exercise choice and
send the correct signals to the market has, over decades, been distorted, oVered only partially and often
simply withheld.
This is despite the fact that public interest groups have been campaigning over the same decades for
citizens’ right to compulsory, comprehensive and comprehensible food labelling. These demands have been
supported by a large volume of research over the years, both from these organisations,7 and from
government (dating back to the now defunct Ministry of Agriculture Fisheries and Food, and currently the
Food Standards Agency). Each survey continues to show that citizens want a great deal of information
about the food they eat, and find current labelling information inadequate, almost impossible to understand
and frequently illegible.
3
4
5
6
7
Policy Commission on the Future of Farming and Food (2002) Farming and Food: A sustainable future. www.cabinetoYce.gov.uk/farming.
National Farmers Union (1999) Ham from Deer and Margarine from Cows? NFU: London.
c/o British Farming (2003) Survey of the public’s understanding of food and the countryside. www.cobritishfarming.org.uk
Lang, T (1995) The contradictions of food labelling policy. Information Design Journal 8/1, 3–16.
In particular, the Consumers Association, www.which.net/campaigns/food/nutrition/index.html, the Food Commission,
www.foodcomm.org.uk, and the National Consumer Council www.ncc.org.uk
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3. How can we Obtain Food Information?
— Labelling.
The list of information which must appear on a label is rather short.8 It comprises the name of the product,
its weight or volume, the ingredients, the date by which the product should be consumed, and the name and
address of the manufacturer or distributor. However, there are some loopholes even to this short list, for
example some baked goods seem to be exempt from declaring their weight, and alcoholic drinks still do not
need to list their ingredients.9 Even the name can be misleading, since it is still legal that, for example, cheese
flavour crisps contain no cheese whatsoever, while cheese flavoured crisps should contain at least some
cheese. More information than the legal minimum is often given, and we cover most of this in section 4
below, but surveys continue to show a small number of products fail even to carry the legal minimum
information.10 New survey work in the sector of fruit juice and juice drinks shows that many imported
products may carry, for instance, nutritional information—but in a non-EU standard format, usually
American, using scientific terminology unfamiliar to a UK market.11
Education
We have argued above that provision of food education and skills in schools is not universally adequate.
Even if it were, however, schools-based education would fail to reach those who have already left school,
except indirectly via schoolchildren in their families. Thus a number of other mechanisms are being used,
as described below.
Other means of communication
In the past, government has produced vast quantities of leaflets intended to inform citizens about various
aspects of food, all of which have been almost entirely useless.12 Increasingly, the Food Standards Agency,
as the oYcial body with responsibility for most food labelling and information, is using electronic media,
particularly its website and, for particular campaigns, TV and radio ads and articles placed in a variety of
print media. While cheaper, and less environmentally wasteful than printing hundreds of thousands of
leaflets, eVectiveness in raising awareness varies a great deal.
Food companies also generate a huge volume of information about their products through all media, both
paid for and as part of editorial coverage, and retailers often also provide a variety of information in-store.
Evidence on the eVectiveness of this commercially generated information is, as far as we know, not in the
public domain. However, the Co-op has been unique among retailers since it has not only provided its
customers with information, but also produced a series of campaigning reports, arguing for improvements
in food labelling, information and food quality. The Co-op has also deliberately broken food laws where it
considers that, based on good research, doing so improves the information available to citizens.13
Public interest groups also provide citizens with information through their campaigns and other activities,
mentioned throughout this submission. Many are engaged in work, in tune with the Curry Commission
recommendations, to reconnect people—particularly children—with our food supply, including: farm visits,
allotment regeneration, curriculum materials, farmers markets, teacher training, farms and gardens in or
near schools, and cooking clubs in community settings. This work is often highly valued by the people
involved but it is, by its nature, fragmented and piecemeal, only reaching a small proportion of the
population.
8
9
10
11
12
13
Food Commission (2001) Reading food labels. Food Commission: London.
See the longstanding work by the Campaign for Real Ale www.camra.org.uk
Organix (2004) Carrots or Chemistry? Snacking and child health. Organix: Christchurch. www.babyorganix.co.uk. This
survey found 10% of children’s snack products had no weight declaration.
Food Standards Agency, in press (due June 2004) “Labelling of fruit juices, fruit juice drinks and other similar products”.
London: Food Standards Agency.
Health Promotion Authority for Wales (1992) Crutches, confetti, or useful tools Good Health Wales Technical Report
Number 3. Health Promotion Authority for Wales: CardiV.
The Co-op (2002) The Lie of the Label II. The Co-operative Group: Manchester. www.co-op.co.uk. See also The Lie of the
Label (1997) and a series of reports on issues such as food advertising to children, pesticides, social inclusion and animal
welfare.
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4. What Kind of Food Information do Citizens Want?
The following merely sketches the potential for and limitations of information oVered to consumers about
a wide range of inter-related issues.
Nutrition
Legal requirements state that nutrition information need only be given on a label if a nutrition or health
claim is made, or if foods are designed for particular nutritional uses. In practice, most companies do oVer
some nutrition information on their products, even when not legally obliged to do so, but it is rarely
comprehensive, and even more rarely comprehensible. Where nutrition is given on a voluntary basis, the
following restrictions apply:
— Energy. This must be given in terms of kilojoules (kJ) which almost no non-experts understand,
and kilocalories (kcal), almost universally referred to and understood as calories.
— Protein. This information must be given (along with energy, total fat and total carbohydrate) if any
nutrition information is listed. However, protein content information is almost completely useless,
since protein deficiency is virtually unheard of in rich countries.
— Fats. Information about fat content is useful to consumers, and indeed many producers make
claims about the fat content of their product, but these are almost always misleading. For example:
despite oYcial advice to avoid “% fat-free” claims on food (as these usually give the false
impression that the product is low fat), the practice continues. By contrast, information about
hydrogenated (or trans) fats is almost completely absent, despite Food Standards Agency advice
that this type of fat is even more damaging than saturated fat in increases the risk of coronary
heart disease.
— Sugars and other carbohydrates. A total carbohydrate figure on a food label is worthless, since we
should be eating more of one type (complex) and less of another (simple—also known as sugars).
Sugar information is often hidden on a label’s ingredients list under several diVerent ingredient
headings such as sucrose, fructose, glucose, dextrose, maltose and others.
— Fibre. There are currently three diVerent methods of measuring fibre which produce diVerent
figures. After years of haggling over the definition of fibre for food labelling purposes there is still
no “oYcial” method, so comparing products for their fibre content (if fibre information is given
or claims about fibre content are made) is just impossible.14
— Sodium and salt. While technically correct to label sodium, since this is the element of sodium
chloride (salt) responsible for raising blood pressure, very few citizens are aware of this fact. Nor
do most people know that, to obtain a salt equivalent figure from the sodium that may be declared
on the label, it is necessary to multiply it by roughly 2.5, then compare the resulting figure to the
recommended daily maximum intake.
— Vitamins and minerals. Although essential for good health, when they are consumed in foods that
are naturally rich in useful micronutrients, vitamins and minerals are often added to “junk” foods
(processed foods high in fat, salt or sugar). Many products fortified in this way overstate the
importance of the added vitamins and minerals—especially in foods targeted at young children.
— Health claims. The Joint Health Claims Initiative,15 a tripartite initiative involving the food
industry, food law enforcement oYcers and consumers, has developed a robust system for
developing health claims that withstand independent scientific scrutiny. Unfortunately, the system
is voluntary and not widely used, and the EU health claims directive, which would have given
statutory backing to a similarly robust system, has recently been delayed, yet again.16
A scientifically rigorous system has been devised17 to label nutrients high, medium or low. This system
has been used by the Co-op on its own-label products for a decade, and a number of government-funded
research projects have shown that people find it easy to understand and to use. It would be straightforward
to link this system to “traYc light” labelling, a proposal with a long history which has recently been
resurrected.
14
15
16
17
Food Magazine (2001) Fibre labelling—a bad situation is about to get worse. No 52 January/March 2001. Food
Commission: London.
www.jhci.co.uk
Food Standards Agency (2004) Nutrition and health claims proposal: com(2003)424. Bulletin on the Brussels negotiations.
Issue 12, April 2004. FSA: London.
Coronary Prevention Group (1990). Nutrition banding. A scientific system for labelling the nutrient content of foods. CPG:
London; Black A, Rayner M (1992). Just read the label. London: HMSO.
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Safety
Despite being a vital aspect of food information, safety information remains flawed.
— Storage and cooking instructions. Many people remain confused about the diVerence between
“use-by” dates (on highly perishable food) and “best before” dates on less perishable items. A
recent survey found information about the dangers of unpasteurised dairy products for pregnant
women was rarely on the label or available at retailer “deli” counters18.
— Allergens. Many manufacturers and retailers are now improving the information available to
people suVering from a range of allergic/intolerant reactions to some foods/ ingredients, though
this remains inconsistent and inadequate. However, the defensive use of “may contain nuts” on a
very wide range of products has been widely criticised as being unhelpful to people with nut
allergy.
— Additives. A recent study19 has revealed that some children may be consuming as many as 80
diVerent additives each day, some of which are banned in other countries due to safety concerns20.
Even where rules exist on the prominence to be given to additives causing concern eg on labelling
of sweeteners, some manufacturers persist in concealing the information.
— Agrichemical residues. EU laws specify the maximum amount of residues of pesticides and
veterinary medicines that should be found in food. While most citizens would not want any such
residues left in their food, regular surveys continue to find them, sometimes above what is legally
permitted21 and in “cocktails” of combinations that have not been tested.
— Strength of alcoholic drinks. As far as we are aware, the Co-op remains the only retailer to label
alcoholic drinks with the number of units of alcohol they contain. This allows customers to link
their consumption directly to government information on the number of alcohol units that can
safely be consumed by men (21 per week) and women (14 per week). This task is virtually
impossible with customary alcohol by volume (ABV) labelling.
Production and processing methods
Historically, this area of food information has received less attention than nutrition and safety, but seems
to be growing in importance as issues around sustainable development become more integrated into the
mainstream.
— Quality marks and assurance schemes. These include, but are not restricted to organic and other
sustainable farming (or fishing) methods. A recent Sustain publication22 lists over 30 such schemes,
without claiming to be comprehensive, and the number continues to grow. The National
Consumer Council has noted23 that these schemes are often “more likely to confuse and mislead
consumers rather than inform them” and made a number of recommendations for improvement.
— Genetically Modified Organisms. It is clear from a variety of sources that most citizens have
profound reservations about GMOs or any derivatives in their food, and their minimum
requirement is information to be able to choose to avoid this technology in its entirety if they wish.
So far, despite recent legislation to improve labelling, this requirement remains unfulfilled24.
— Irradiation. As with GMOs, there are serious concerns about the use of this technology, and in
practice the only irradiated food products on the UK market are some herbs, spices and dietary
supplements. These must be labelled as having been treated with ionising irradiation. However,
FSA surveys have shown some products, particularly food supplements, are being sold illegally,
with their irradiated ingredients undeclared.
— Country and region of origin. Increasing numbers of citizens want to support sustainable
development by buying local produce25. However, few realise that the presence of a union flag on
a product may mean merely that imported ingredients have been processed here.
— Meaningless claims. Despite volumes of guidance exhorting companies not to use claims with no
legal status, or with no supporting standards, terms such as “traditional”, “farmhouse”,
“selected”, “wholesome” and so forth continue to be widely used. Similarly pictures of fruit and
vegetables continue to adorn packages of products containing little—and often no—fruit or
vegetables.
18
19
20
21
22
23
24
25
HUSH. UK E.Coli Support Group. Survey published in 2003. www.ecoli-uk.com
Organix (2004) Carrots or Chemistry? Snacking and child health. Organix: Christchurch. www.babyorganix.co.uk
See information produced by the Hyperactive Children’s Support Group, www.hacsg.org.uk
See regular analyses of statistics produced by the Pesticides Safety Directorate and the Veterinary Medicines Directorate by,
among others, Friends of the Earth (www.foe.co.uk) and the Soil Association (www.soilassociation.org).
Petts J, Peckham, C (2003) Good Food on the Public Plate: A manual for sustainability in public sector food and catering.
Sustain: London.
National Consumer Council (2003) Bamboozled, BaZed and Bombarded. NCC: London.
For the most up-to-date information about legislative developments, please see the website of the Five Year Freeze, the multisector coalition urging caution in this field www.fiveyearfreeze.org
Jones, A (2001) Eating Oil: Food supply in a changing climate. Sustain/Elm Farm Research Centre: London.
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Ethical considerations
As with production and processing methods, ethical considerations seem to be growing in importance for
increasing numbers of citizens.
— Animal welfare. Vegetarian and vegans continue to find labelling unhelpful in following their
ethical principles, particularly for ingredients derived from animal sources26. Those who wish to
eat animal products from high welfare systems are faced with a range of confusing choices
including organic labelling, the RSPCA’s Freedom Food scheme, and a variety of smaller schemes.
— Fair trade. The Fair Trade Foundation27 (and also Oxfam and Traidcraft) independently certify
products to ensure that producers in the South receive a fair price and have decent working
conditions. Given the inadequacy of the voluntary code of practice covering supermarkets’ dealing
with their suppliers, many are arguing for a similar “fair trade” approach for producers in the
North28.
— Religious requirements. While it is essential for some faith groups to consume only those products
certified by their religion, citizens of other religions or with ethical concerns may wish to avoid
precisely these products. They may consider, for example, that some slaughter methods undermine
animal welfare. However, surplus products from religious slaughter can be used, unlabelled, in the
food chain.
5. Why aren’t Citizens Getting the Food Information They Want?
The previous analysis of food information, albeit in outline, demonstrates that parts of the food industry
remain unwilling to provide accurate, full and clear information. This is not surprising since, unless all
companies are legally obliged to provide it (and they are not) and until the legislation is rigorously enforced
(and it is not, see below) companies will be at a competitive disadvantage if they reveal more than their rival
firms. It is significant, therefore, that the company that has oVered most food information—the Co-op—is
not a plc.
In the USA legislation has compelled companies to give more nutrition information than is required in
the EU, and restricted the health claims that can be made on labels. Unsurprisingly, research has shown this
approach to be popular among citizens, but less so among food companies, as a result of which restrictions
on health claims are now being weakened29.
Food companies often claim that there is not enough room on the label, to provide all the information
that people want. While this has some validity for very small packages, a cursory glance at food packaging
will demonstrate that non-essential marketing material takes up the majority of space. However, there is a
genuine problem with providing information about the increasing proportion of our food that is eaten
outside the home, particularly from catering outlets.
Even if legislation about food information and labelling was improved, the issue of enforcement would
need to be tackled. Every issue of the quarterly Food Magazine30 catalogues misleading and possibly illegal
labelling, and written complaints are regularly sent to the relevant local authority trading standards oYce.
However, prosecutions for breaking food labelling laws are extremely rare. Local authority trading
standards departments often do not have enough staV or money to take food companies (often major
multinational firms) to court. Central government support for food law enforcement has focused exclusively
(and perhaps understandably) on food safety issues such as fraud in the meat trade. Even if a court case is
brought and won by a local authority, penalties for the company are weak, with low fines and precious little
adverse publicity. In other words, most companies who break food labelling laws are likely to get away
with it.
Moreover, the information and, perhaps more relevant, imagery conveyed in advertising and other
marketing promotions can eclipse any details that might be provided on a label. The case for prohibiting
junk food marketing to children is now well-known31. While marketing does not aVect adults in the same
way as children, it is clearly intended to influence adults’ purchasing patterns and, although comparative
figures are not available, it is likely that considerably more money is spent on marketing campaigns than on
26
27
28
29
30
31
See information provided by the Vegetarian Society, www.vegsoc.org and by Vega Research, www.vegaresearch.org
See www.fairtrade.org.uk
The Soil Association may shortly be launching such a scheme, www.soilassociation.org
See information from the Washington-based Center for Science in the Public Interest, www.cspinet.org
Produced by the Food Commission: London, www.foodcomm.org.uk
Powell, C. (2004) Children’s Food and Health: Why legislation is urgently required to protect children from unhealthy food
advertising and promotions. A submission to government in March 2004. Sustain: London.
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providing information on labelling and in other ways. Moreover, if enforcement of food labelling laws is
inadequate, then enforcement of codes of practice supposedly controlling broadcast32 and non-broadcast
advertising is close to non-existent, and actually non-existent for the internet33.
There is, it is true, limited room for the UK Government to manoeuvre on food labelling issues in
particular, given that all labelling legislation is set at EU level. However, as noted above, where there is good
evidence that citizens will be helped, not harmed by breaking EU labelling laws, the Co-op has broken them
in citizens’ interests.
The World Trade Organisation (WTO) adds another layer of diYculty. The USA has been particularly
vocal in arguing that governments who require labelling of, for example, country of origin or processing and
production methods are erecting unjustifiable, and therefore illegal barriers to trade. However, it is helpful
that the WTO has recently overturned its previous two decisions, in the shrimp-turtle case, so that countries
may indeed specify processing and production methods that, say, protect wildlife so long as these are not
applied in a discriminatory manner34. It is less helpful that the WTO often takes its cue, on food matters,
from the Codex Alimentarius, the UN system for setting rules about food which is globally traded, since
global corporations play a large and unwarranted role in how these rules are set35.
6. What should be done, and by whom, to improve the quality of food (and information)?
We are led, by the weakness described in the availability of food information, to the following general
recommendations:
— The UK government should join with other EU states to demand changes in the WTO approach
to food information. Currently trade considerations are treated as more important than citizens’
right to know about their food. This is not acceptable. If Codex is to be used to set standards, the
influence of private companies must be reduced and the food standards set should be a floor
(below which food traders must not fall) not a ceiling (allowing countries to set higher standards
if they wish).
— EU rules on food information across the full range of issues should also be improved. However,
based on past experience, this will take considerable time. In the meantime, member states that can
demonstrate that their non-EU conforming systems provide better food information for citizens
should not be penalised, but encouraged.
— At UK level, there is an urgent need to toughen up the enforcement of rules on food information,
except where this would inhibit helpful information and/or formats (see EU recommendation
above). As a matter of urgency, given the obesity epidemic, government should introduce legal
protection for children from junk food marketing. There is a high and growing level of public
support for this measure.36 Broadcast and non-broadcast advertising, including the internet,
should be more—not less—tightly regulated. However, Government appears to be encouraging
Ofcom down the path of “light-touch” self-regulation, an approach which has been shown not to
work in the Advertising Standards Authority’s sphere of non-broadcast advertising.37
At the same time, the Food Standards Agency should oVer support and funding for trading
standards oYcers to prosecute companies breaking food labelling laws. In addition, the Agency
has a practice of “naming and shaming” companies who, for example, have too much salt in their
products. This approach could usefully be extended to include companies who routinely flout
labelling laws and guidance. Some further research may need to be funded to solve the problems
of communicating information about food sold without packaging, and in catering outlets.
— There appears to be overwhelming support for making food education and skills a more central
part of school life, both in the curriculum and outside it. Legislation may be needed to prevent the
wide variations in practice that are reported. Meanwhile, Government could instruct Ofsted to
make food education and skills an integral part of school inspections.
Pending these changes, public interest organisations, such as those referenced in this submission, will
continue to do their best to encourage citizens to demand better food information, including on labelling,
complain more when this information is inadequate and use their purchasing power to reward good practice
and punish recalcitrant companies.
32
33
34
35
36
37
Powell, C (2004) The future regulation of broadcast advertising: Response to the Ofcom consultation by Sustain. January 2004.
Sustain: London.
The Food Commission (2002) Advertising authorities fail to regulate internet slimming ads. The Food Magazine February
2002.
Commission by Compassion in World Farming (2003) WTO—the Greatest Threat Facing Animal Protection Today. CIWF
Trust: Petersfield.
Avery, N, Drake, M, Lang, T (1993) Cracking the Codex: An analysis of who sets world food trade standards. National Food
Alliance. Available from Sustain: London.
At time of writing, the Sustain campaign on this issue has the support of 113 national organisations. Please check the website
for the latest number, www.sustainweb.org
Dibb, S (1996) Slim hopes: The results of a survey of slimming advertising. National Food Alliance. Available from
Sustain: London.
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However, experience to date shows that improving the quality of food information is necessary, but not
suYcient to improve the sustainability of our farming and food system. The recommendations in the Curry
report, complex and interconnected as they are, need to be implemented by Government as a whole, not
piecemeal.
23 April 2004
Witness: Ms Jeanette Longfield, Sustain, examined
Q190 Chairman: Good afternoon, Jeanette
Longfield. You are the coordinator of Sustain?
22 June 2004 Ms Jeanette Longfield
Ms Longfield: Yes, that is me.
Chairman: Welcome to the Committee this
afternoon. Thank you for coming along to give oral
evidence this afternoon. Bill Wiggin will start the
questions.
Q191 Mr Wiggin: How helpful is the current food
labelling requirements assisting consumers in
following a balanced diet?
Ms Longfield: Mainly rubbish, really. They are
incomplete, incomprehensible, voluntary, confusing,
and fairly useless.
Q192 Mr Wiggin: In your evidence you refer to
loopholes in the current labelling regulation, for
example baked goods are exempt from declaring
their weight, alcoholic drinks from their list of
ingredients. Excepting for a moment the limitations
of information required by present legislation, what
about the uniform application? What do you feel
about that?
Ms Longfield: That some goods seem to be exempt?
Q193 Mr Wiggin: Sorry?
Ms Longfield: What do I feel about some goods
apparently being exempt?
Q194 Mr Wiggin: The fact that it does not apply
uniformly across all goods.
Ms Longfield: I rang up a colleague in Laycors this
afternoon before I came: that is the Local
Authority’s Coordinators of Regulatory Services,
the Trading Standards OYcers who enforce food
labelling law. I said: “Why is it that some products
do not seem to be weighed, measured?” He said to
me: “Ah, well”. I will truncate the half an hour into a
couple of minutes. It is some relic of old weights and
measures legislation, apparently, and cross-referring
to food legislation because weights and measures
covers more than just food and taking definitions
from one bit of law that does not really apply to
another bit of law and you just end up with these
stupid gaps. He agreed that it was anomalous and
ought to be sorted out and it was probably on
somebody’s list of things to do at some point, but
nobody has done it because it is kind of boring.
Q195 Mr Wiggin: How would you like to see it
develop?
Ms Longfield: I just cannot see—there is no reason
that I can see that is defensible for having any foods
that are exempt. It surely cannot be beyond the
wit of the collective expertise of the scientific
community, of oYcials and legislators to come up
with a system where everything is covered? How
hard can that be?
Q196 Mr Wiggin: It is expensive. What about traYc
lights; you heard about that I think. What does
Sustain feel about the traYc light system?
Ms Longfield: Sorry, the reason why I am grinning
is because about 20 years ago, I think, a very similar
system was suggested, explored exhaustively, and
everybody said, “That is too hard, we do not
understand it” and, now we are having another look.
Again, I think it is not beyond the wit of man,
woman and beast to come up with a system that
makes it easier. In Australia they have Pick the Tick,
and in Sweden they still have the key hole system, in
other parts of the world they probably have other
ways of doing it. None of them is perfect, but it is
surely not impossible to make it easier; even if they
do not turn out to be traYc lights it will be something
that makes it easier.
Q197 Mr Wiggin: What do you do with things like
very small amounts or diYcult foods: unpackaged
meat, vegetables, that kind of stuV?
Ms Longfield: With loose foods I am sure if you
could solve the problem of simplifying the
information you want to give, you have to have
labels and tickets somewhere, stuV with a price on.
Q198 Mr Wiggin: On the menu when you go into the
restaurant, I think?
Ms Longfield: With loose foods you can put it on
wherever you put the ticket information, what the
price is and what have you. With catering, it depends
on the catering. If it is in a sandwich shop or a fast
food restaurant where basically day in and day out
you are selling the same stuV, made to a recipe, do
the analysis, get the label: not hard. If you are eating
somewhere posh where it is cooked from scratch
every day and you are probably not going to eat
there very often because it is posh, so it does not
matter if you eat there to be honest.
Mr Wiggin: It does if you are legislating there
unfortunately, but thank you very much.
Q199 Joan Ruddock: I want to ask you about action
at government level and how well coordinated you
think the departments are in terms of food policy
and the communication of food messages et cetera?
Ms Longfield: They are not. The Department of
Health and Food Standards Agency fight. Defra
does not really get involved most of the time. DfES
is too busy with other stuV. It is just a complete dog’s
breakfast really.
Mr Wiggin: On labels.
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Ms Jeanette Longfield
Q200 Chairman: This is a joined-up Government, do
you mind?
Ms Longfield: Yes. It is a really good idea. I think
that somebody should do it.
Q201 Joan Ruddock: When you hear messages
coming out, such as came out from the Public Health
Minister recently, is that something that you think is
useful or do you just say: “what does that count
because nobody else is going to follow through?”
Ms Longfield: I have a suspicion that is probably the
result of some departmental warfare really, not part
of an integrated approach to try to get the industry
to do the right thing. I think there is probably blood
splattered all over someone’s carpet over that one.
Q202 Joan Ruddock: That is a very cynical view you
have here.
Ms Longfield: I am sorry. I have been doing it too
long, have I not? I should be a dancing teacher,
which is what I wanted to do in the first place.
Mr Jack: We do special camps. Mr Mitchell does
strictly ballroom.
Q203 Joan Ruddock: The FSA has set up a consumer
committee “to help ensure the views and interests of
consumers are represented”, and indeed Sustain is
on that committee. Tell us something about your
experiences on that committee.
Ms Longfield: I think we spent a good 12 months
trying to work out what the agency wanted us to do.
There have been some unfortunate problems with
rapid turnover of representatives of the committee
and so we have not been able to settle all that kind
of stuV. Because the agency is the whole thing set up
to be the consumer champion, and I am not sure it
has entirely achieved that yet but at least it is trying.
It is not entirely obvious what a special consumer
committee would do in an organisation that is
entirely dedicated, at least on the face of it, to
promoting a consumer view. We have discussed
some extremely interesting issues. We have looked at
food promotion to children, food irradiation, GM
food. What else? Food authenticity and also some
labelling issues, but I have to say I could not hand on
heart say that it has been a wild success and shows
the way that we should go. I think it has struggled a
bit, to be honest.
Q204 Joan Ruddock: So if the Committee has not
had the kind of input that we might imagine, people
would be saying this is how consumers behave. This
is the diYculty consumers have absorbing messages,
the time problems with seeing what is on the label.
They are too complicated. It has not had that kind
of input on that issue of labelling.
Ms Longfield: No, it has not. In fact, there is a whole
separate bit of FSA machinery dealing with labelling
to which we have made bits of contributions as the
consumer committee, but I think one of the
problems with labelling has been not just the sheer
volume of labelling and legislation that comes at it
from Brussels dealing with all of that, but also the
issue of enforcement of food labelling and legislation
which they are not in control of. Because they do not
enforce it, it is then enforced at local level. That is a
whole new area of diYculty and problems. It is not
beyond possibility that the consumer committee
could get better and could get a grip of things like
food labelling, and that is part of food information.
We just have not done it yet. Perhaps a good prod
from the committee might help.
Q205 Mr Jack: Can I just take you to paragraph 5
of your written evidence? You make an interesting
observation. You say: “In the USA the legislation
has compelled companies to give more nutrition
information than is required in the European Union
and restricted the health claims that can be made on
labels.” Then you go on to say: “Unsurprisingly, this
approach has shown to be popular amongst
citizens”. Can you expand and a bit on that?
Ms Longfield: Yes. They did research to see if people
could use it and understand it; they could. It is a clear
white box with black lettering, quite large type, as
large as you can get on the size of the packaging. It
is standardised so it looks exactly the same on every
single packet. People like it because they can see it
easily. They know what it is meant to mean. Clearly,
it is not perfect because it has not revolutionised the
American dietary patterns but at least it is not for
knowing what is in the packet.
Q206 Mr Jack: Given that one is trying to
understand what consumers believe and then what
they do with that information, does this research
actually go the next step and say, “Having seen
information which they say is good and it is popular,
is that part of an information exercise which the
individuals are carrying out saying, I can now work
out buying this, buying that adds up to a good diet.”
I was interested to know what use people made of
this information.
Ms Longfield: I do not think the research went that
far. I think it was looking at recognition and
comprehension and working with the formats side. I
do not think it went as far as working out what
impact it had on their buying habits. I may be wrong.
Q207 Mr Jack: The reason I ask that question, and
we saw some examples of it last week here, was that
the Co-op has gone beyond the requirements of the
EU labelling law. The Coop has decided that
producing panels, I think we saw it on a packet of
jam tarts: very clear, lots of information, but
eVectively they had broken the law. Is it right that
companies do that? What is your view about what
the Co-op did?
Ms Longfield: I think if you could show, and I think
you have shown, that it is helpful when people are
looking for information on a label that the way that
they have broken the law makes it easier rather than
harder, then frankly I am all for it. If they had
broken the law and made it even worse than it
already is, then obviously I would not be in favour,
but if you can demonstrate by robust research that
it is helping, then why not?
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Q208 Mr Jack: What does that say in your judgment
about EU labelling requirements then?
Ms Longfield: EU labelling legislation is just a
nightmare. It was never designed when it was
established, certainly for nutrition, probably for lots
of other issues as well, it was never designed purely
to help citizens make good choices. It was the result
of, and continues to be the result of, the usual
political compromises that have to be made between
various lobby groups and industries and diVerent
political factions. What you end up with is a dog’s
breakfast of labelling, which was never designed in
the first place to help consumers and so it does not.
Q209 Mr Jack: Do you think that the UK
Government has a role to give advice about perhaps
what those who use labelling to communicate
messages should do, if you like, to go beyond the
minimum requirements in terms of EU labelling
regimes?
Ms Longfield: Absolutely. There are clearly two
things that a UK Government can do. You can go
into Europe to say, “This is rubbish, it needs to be
changed. Do what you need to do; make certain to
get friends to help to do that. That is going to take a
long time.” Meanwhile, you say, “okay, let us see
what can work better and let us encourage people to
do it.” If that is breaking the law, well, take us to
court then. I simply cannot imagine that anybody in
the European Commission were to take a country to
court for making labelling easy to understand for
consumers.
Q210 Mr Jack: Finally, one question. Is there any
research to show, if you like, it might sound like the
idiot question, what use people make of labelling
apart from identifying the product is the one that
they actually want to buy?
Ms Longfield: There is loads of research on what use
consumers make of labelling. It depends on what
research question you are asking. When you do your
research you have to have a very tightly defined
question, otherwise it is too big and you cannot get
anything sensible out. Depending on what you ask,
you can come out with research that consumers
never look at labels, they think it is completely
pointless, they always buy the same thing, or
research at the other end of the spectrum that shows
that people always look at labelling and find it
extremely important to look for particular
ingredients or provenance or whatever it is they are
looking for. You get completely contradictory
results depending on which research question you
ask. Sometimes people look and look really carefully
because they have particular reasons for doing that.
Sometimes they just have a quick glance and
sometimes they do not look at all.
Q211 Mr Jack: I think what was going through my
mind is that you might say that 100% of people will
quickly look at a label to make certain it is what they
thought it was, what they were going to buy. As you
go down through all the categories of information
that were available on labels there must again, by
definition, be a diVerent proportion of consumers at
the moment of selection of the item who may then
subsequently make use of all the information that is
on the label. I suppose the short answer is what is the
most read part of the label? What do people react to?
Miss Ruddock was asking the question earlier on
about traYc lights, in other words, labelling is being
oVered up by many people as a principal form of
communication of a wide variety of pieces of
information about a particular manufactured food
item in all kinds of context. I am just intrigued to
know what use is made of all that information by
diVerent categories of people.
Ms Longfield: I think probably you are going to be
having evidence from other people in the food
industry later on in these sessions, are you not? It
would be really interesting to know if they bring with
them any of their label’s designers, the people who
make packaging really attractive, so that you reach
out and buy it oV the shelf. They know what kinds of
things catch people’s eyes: what colours work, what
shapes work, what images work. What makes a piece
of packaging, not just the label but the shape, and
what makes it attractive? But of course they use that
to sell you stuV, not necessarily to tell any of us what
we want to know. That is the stuV that is shoved
round the back in the small print and tiny box, what
have you. So the extent to which people look at and
use particular bits of information depends quite a
lot, I think, on how the whole thing is designed. You
can design it so that it is attractive and easy or you
can design it so it is hard.
Q212 Chairman: How far do any of the regulations
about the information contained in labels
counterbalance the type of message that is given over
by advertising? On the rare occasions I unwisely go
with one of my children to the supermarket, they
immediately go to the highest sugar content
breakfast cereal they can find. They point out, “It
says here it has five vitamins”. How far does that
kind of overall packaging counteract the overall
message it wants to get over?
Ms Longfield: I think one of the things that was
really interesting about the remit that this committee
took was that you called the whole thing Food
Information, and labelling is only one of the things
you are looking at. You are looking at advertising
and Government communications and world trade,
the whole world of information that is available to
people when they are choosing food, and you are
right: labelling is just a tidgy bit. It is absolutely
necessary to get it right and as clear as possible but
on its own is completely insuYcient. There are all
sorts of other things that encourage people to choose
what they choose or discourage people from
choosing things; advertising is clearly one of them. I
am sure that some of the Members of the Committee
might know that Sustain is running a children’s food
bill campaign to try to get legal protection for
children from junk food advertising for precisely
that reason.
Q213 Mr Wiggin: How do you decide what is junk
food and what is good for them?
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Ms Longfield: It comes back to what Susan Jebb was
talking about before about developing the criteria,
which is this huge lump of iceberg underneath the
surface which will come up with what we hope will
be a single definition. There is a paper which has
been produced by Dr Mike Raynor who is doing
some of the work in the Food Standards Agency in
the Committee on which Susan Jebb sits. It is doing
exactly that kind of working on the definition of the
iceberg because it looks at levels of total fat, diVerent
kinds of fat, sugar, salt and so on. It is complicated
but it can be done and, as I said before, has already
been done in several countries so it is not that hard
to do.
Q214 Mr Mitchell: There are not many—I do not
know of any—prosecutions for breaking the
labelling law. Why is that? Is that because the
manufacturers are so virtuous and fully compliant
or is it because they are not bothering to prosecute?
Ms Longfield: There is a real problem with food
labelling prosecutions. First of all, there are not
enough trading standards oYcers to go round and
they have to cover all trading standards not just food
so in the list of priorities it is not all that high
because, apart from extremely rare examples like nut
allergy and anaphylactic shock, people are not going
to die from bad food labelling. It is an accumulation
of misinformation and misleading information that
causes the problem, so it is not high on their list of
things to do. Also you need cash to take these cases
to court and because it is done at a local level and
because there are not very many trading standards
oYcers and they have not got very big budgets, then
taking a multi-national food company to court for a
misleading label is quite risky and expensive and
understandably, not very many of them want to do
it so in the end what happens is companies get away
with it.
Q215 Mr Mitchell: Has any multi-national company
been taken to court?
Ms Longfield: Yes, there is a particularly vigorous
and good trading standards oYcer in Shropshire
called David Walker. He has been a senior trading
standards oYcer for a lot of years now and has the
backing of his local council. He has taken a lot of
companies to court over his career but a recent one
was Nestlé because at the time they had some heart
packaging and heart disease risk reduction claims all
over their shredded wheat and he considered that
that was an illegal medicinal claim, took them to
court and won, which was an extremely brave
thing do.
Q216 Mr Mitchell: What was the fine?
Ms Longfield: It was derisory, a few thousand
pounds I think. It is less than Nestlé’s paperclip
budget probably and all that eVort for that, so it is
really diYcult for them.
Q217 Mr Mitchell: Yes, what is a problem in a sense
is that we are a nice government and we want
friendly relations with business and capital, we do
not want to be sitting in trenches sniping at each
other, I am speaking as a Labour MP now and that
is our position. If there are going to be prosecutions
it is going to develop an antagonistic relationship, is
it not? Are we not better seeking co-operation?
Ms Longfield: Should they not just be abiding by the
law? I have not got a problem with being
antagonistic against companies that are breaking
the law.
Q218 Mr Wiggin: Like the Co-op.
Ms Longfield: Exactly, if you can show that it is
helpful, if you can show that you are doing it for a
reason.
Q219 Mr Wiggin: Do you not feel that that puts you
in a very awkward position because the shredded
wheat advertisement saying it is good for your heart
was supposed to be encouraging you to look after
your heart as well?
Ms Longfield: The problem was that the type of fibre
in shredded wheat was not at the time that they were
making those claims the kind of fibre that is
supposed to help you reduce heart disease, so it was
not all that helpful, and indeed arguably not true.
Q220 Mr Mitchell: So you would advocate a more
vigorous checking of claims and an increase in
penalties?
Ms Longfield: Absolutely because once companies
have got the idea that they are not going to be getting
away with it then I am sure that they will quite
quickly start behaving. In fact, there is an incentive
to push the boundaries of the law as far as you
possibly can and beyond because you know you can
get away with it, by and large, and if you do not do
it then your competitor will and you will be at a
competitive disadvantage. The mythical level
playing field—at least the law should do that.
Mr Mitchell: Thank you.
Q221 Mr Wiggin: My question is to some extent
covered already. What leads you to conclude that
global corporations play a large and unwarranted
rule in how the Codex rules are set?
Ms Longfield: We did some research, admittedly
rather elderly research now, looking at the
composition of the committees that advise Codex
and we found a preponderance of companies from
rich, northern companies on those committees and
we thought that that was probably not right given it
is supposed to be an inter-governmental agency.
Governments around the world were relying rather
heavily on expertise from private industry and
governments in poorer countries were not getting
much of a look in either and consumer organisations
and environmental organisations and others, who
might be expected to try to counter-balance the
private sector interest, were almost invisible just
because they could not aVord to get to all of the
international meetings, so it is horribly skewed in
favour of rich countries and rich companies.
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Q222 Mr Wiggin: That is one side of it. The other
side, of course, is the way things are produced and
how much consumers want to know about that and
whether that constitutes good information or an
actual barrier to trade. How do we deal with that?
Ms Longfield: There are lots of conflicting
interpretations about what you can and cannot do in
this area. Some people say, “Well, of course the
World Trade Organisation says you cannot do
that.” I think it is called PPMs, processing and
production methods. Other people have looked at
their interpretation of the rules and the law and
various test cases and said, “No you can, provided
that . . . “ So, for example, there have been cases to
do with dolphin-friendly tuna and turtle-friendly
shrimps where restrictions have been imposed to try
to protect wildlife and the countries whose exports
have been aVected by this have said, “Excuse me,
you can’t do that.” It appears that provided you do
not discriminate between countries and say that one
has to protect dolphins and one does not or one has
to protect turtles and one does not, and provided
that you are not overly prescriptive in how the
protection occurs, then you can indeed do these
kinds of things, or this is what I am told by people
who know more about these things than I do. It is
absolutely essential that it is allowed, not only
allowed but encouraged because what is the point in
having a world full of free trade when the
environment is shot to hell? It makes no sense.
Q223 Mr Wiggin: Perhaps you would like to say a
little bit more about the shrimp-turtle case because I
feel the same way about it as you in terms of dolphinfriendly tuna and then I get really cross when this
select committee looks into the dolphin by-catch and
finds that the bass fishermen are slaughtering
dolphins with their nets and we are not allowed to
say anything about that. Perhaps you can talk about
the shrimp-turtle case.
Ms Longfield: My understanding is that it was a
ruling by the US that said they would not import
shrimps from a range of countries because the way
they caught the shrimps had an unacceptably high
casualty rate amongst turtles who were getting
caught so they said, “We are not going to import
them any more.” The countries concerned said,
“You cannot do that, that is a barrier to trade,”
complained to the WTO and I think the WTO at first
said, “Oh yes, that is quite right, you cannot do
that,” but then there was an appeal and counterappeal. The final ruling, I think, is that the US can
indeed impose restrictions on the types of shrimp
that are imported and they must indeed protect
turtles but they have to apply that to their own
fishing fleet. They have to apply it to everybody’s
fishing fleet not just particular countries, so provided
that the rules are implemented fairly and openly, my
understanding is that you can do it, but it is too
much eVort and you should not have to go through
all of that to get there. It should be something that is
encouraged rather than something that you have to
battle for.
Q224 Chairman: Turning away from turtles to
another subject close to the Committee’s heart—
alcohol—why do you think that very few retailers or
producers give information about the number of
units of alcohol contained in a bottle or other
container?
Ms Longfield: I imagine it is because they do not
particularly want to tell people because it is helpful
information. It is deeply depressing that the whole
alcohol labelling field has languished behind even
food, which is bad enough. You cannot get
ingredient labelling, you do not get clear unit
labelling (apart from the Co-op) and when we are
facing an alcohol problem in this country you would
think that more eVort would be put into that
direction. I do not think it is a technical problem. In
fact, it cannot be a technical problem because the
Co-op has done it. It is simply a lack of willingness,
as far as I can see.
coming along to give us evidence this afternoon.
What you have had to say to us has been veryhelpful.
If after today’s session there is any additional written
information you think it would be useful for us to
have in light of what you have said today then
obviously we will be happy to receive that. Once
again, thank you for coming along this afternoon.
Ms Longfield: Thank you very much for asking me.
Memorandum submitted by the Product Authentication Inspectorate Ltd (PAI)
1. Product Authentication Inspectorate Ltd (PAI) is one of the leading approved certifiers of food
products, food authenticity, labelling claims and food chain traceability in Europe. PAI is well known in
the British Food Industry and has developed a strong reputation for its knowledge, skills and appreciation
of the issues concerning food product certification. It is also perceived by many as the only truly independent
Food Certification Body in the UK.
2. Company Background
2.1 PAI was launched in 1997 to meet a new need in the food industry caused by a collapse of consumer
confidence in the food chain throughout Europe and inadequate and misleading food labelling. It provides
UKAS accredited independent certification and inspection services to the food industry.
2.2 A subsidiary Italian company was formed at the same time to meet the needs of a similar situation
in Italy, which is the largest food-producing region in Europe.
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2.3 PAI has developed with specially appointed technical advisory panels a range of standards in the food
chain, which are accepted as leading edge in terms of quality, safety, environment and animal welfare.
2.4 PAI holds accreditations by the United Kingdom Accreditation Service (UKAS) for EN 45011.
2.5 PAI is responsible for certifying a number of food products throughout Europe. These include beers,
cheeses, vegetables, cooked meats and shellfish. PAI’s business also includes the traceability, quality and
welfare of Pig Farms and Beef Herds.
2.6 Another significant areas of PAI’s work is the assurance of all feed materials used in the production
of animal feed, whether they are primary products of processing or by-products and regardless of their
country of origin.
2.7 It counts amongst its UK clients: Stilton Cheeses, Scottish Courage, Shepherd Neame, United
Kingdom Agricultural Supplies Trade Association (UKASTA), West Country Farmhouse Cheddar,
Meadow Valley Livestock, most major UK retailers, Diageo, British Sugar, Genesis, Assured British Pigs.
3. Communication
3.1 PAI welcomes the setting up of the sub-committee. It shares the concern regarding messages about
food. It considers there is a need to simplify and at the same time improve the information provided to the
consumer.
3.2 One of the problems facing the consumer is the multiplicity of marks coupled with a lack of
information in support of the marks. This can mislead the consumer rather than enable a truly informed
choice.
3.3 It is diYcult for the consumer to distinguish between marketing claims and independently verified
product information. Also to diVerentiate between the merits of the various schemes.
3.4 The consumer would benefit from an awareness programme relating to product marking.
3.4.1 Education would enable the market to operate more eVectively in that the choice of schemes need
not be limited other than by market forces and safety requirements. A better informed consumer is in a
position to purchase the level of assurance desired over and above the minimum legal requirements eg the
importance of animal welfare or flavour or production methods etc
3.4.2 The awareness programme should include the merits for consumers of looking for independent
accredited product certification to provide confidence that the product meets the specified standard.
4. Food Safety
4.1 Whilst considering messages about food safety, PAI would like to draw the committee’s attention to
the importance of emphasising a need for full traceability of all animal feed materials and other food
ingredients as contributors to overall food safety.
4.1.1 The safety of the ingredients that go into animal feed is critical to the safety of the meat related food
chain. Messages about food safety are potentially misleading if they simply begin with food production and
do not address the integrity of the ingredients.
4.1.2 Assurances regarding food safety need to be able to demonstrate full traceability of the raw
materials, through production and distribution and through to the supermarket shelf.
4.1.3 The same equally applies to all ingredients that are supplied into the food chain whether they be
spices from the Far East or soya from Brazil or rice from India or chickens from Poland.
19 April 2004
Witnesses: Ms Linda Campbell, Chairman, and Mr Paul Wright, Managing Director, Product
Authentication Inspectorate, examined.
Q226 Chairman: Good afternoon, Ms Campbell and
Mr Wright, welcome to the Committee this
afternoon. I hope we have not disturbed you by
bringing you along a little earlier in the programme
than was originally indicated. We are very grateful
indeed that you were here a bit ahead of time so that
we can use the time usefully. We would like to thank
you for the evidence you sent in in writing and look
forward to what you have got to tell us today in your
oral evidence. Linda Campbell, I understand that
you are the Chairman of the Product Authentication
Inspectorate and, Mr Wright, you are the Managing
Director; is that correct?
Mr Wright: Yes.
Q227 Chairman: I wonder if I could begin by asking
you to tell us a bit about what is involved in
certifying a farm assurance scheme. Take the
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22 June 2004 Ms Linda Campbell and Mr Paul Wright
National Goats’ Milk Scheme as an example; what
inspections do you carry out, how regularly, where
do you go, what do you look for?
Ms Campbell: Paul is the goat man!
Mr Wright: We are the verifiers for the National
Goats’ Milk Scheme which was a scheme that was
developed to allow it to attract a red tractor logo
marking and the Goats’ Milk Scheme is built around
the current national dairy farm assurance scheme for
cows’ milk. Because there are certain diVerences
between goats and cows it was a scheme that was
adapted for goats’ milk. There are only a very, very
small number of goat farms that are actually in this
scheme, probably as few as 13 or 14, and in order to
get the red tractor logo they were advised to have
independent verification and certification of their
farms meeting those standards. In order to comply
with the standards that have been prepared we visit
each of the goat farms once a year with our auditors
and confirm and check that they are in compliance
with their own standards. If they are in compliance
then they continue to be certified and if they are not
in compliance then we do what is commonly called
“raised non-conformances”, which they have to
address before certification can continue. Each audit
will take something in the order, depending on the
scale and size, of two and a half to three and a half
hours on site.
Q228 Chairman: What actually happens? How
many of your staV or the people you are contracting
go out to the particular farms? What do they look
for?
Mr Wright: Just one member goes out and he has the
scheme standard and he has the check list, which
might cover a variety of things. I am not totally
familiar with every aspect of the Goats’ Milk
Scheme but it will actually examine production, it
will examine welfare, it will examine husbandry, it
will examine medical records, it will examine
veterinary reports, and it will seek confirmation that
they are adequate in compliance with the standards.
One person will do that. Those reports are then
submitted back to us by the auditor, who is a
contracted auditor to us and who has experience in
that particular industry, and they are then subject to
review by other experienced reviewers and at that
point the report is reviewed for accuracy, objectivity,
impartiality and completeness.
Q229 Chairman: What sanctions do you employ if
the recommendations of the review team are not
complied with?
Mr Wright: In the first instance of the
recommendation if they are not in compliance they
do not get certified. They are then asked to put
forward their corrective actions for any noncompliances and immediately on confirmation that
all their all non-compliances are what is called closed
oV they will be certified. For continuing certification
at the end of each surveillance visit, if there are seen
to be non-compliances, certification will continue
for a period of 30 days during which time they are
asked to address those non-compliances again.
Providing they do address those non-compliances
and they satisfy us that they have been addressed,
certification will continue. If not, it will be
withdrawn.
Q230 Chairman: One suggestion is that there are
about 30 or so such farm assurance schemes
operating in the country, maybe more. Can you give
us an estimate of the number of farm assurance
schemes currently operating in Britain?
Ms Campbell: It will be quite diYcult to give you a
precise number because there are so many diVerent
reasons why there may be a scheme. The 30 probably
is conservative but it might be in the right region and
I think the thing to recognise about the number of
diVerent schemes is that they are covering so many
diVerent aspects. There may be schemes there that
are covering quality, there may be other things to do
with safety or animal welfare, or it could even be to
do with regionality of foods. There are just so much
diVerent aspects that might require a scheme.
Following on from what Paul said about the Goats’
Milk Scheme, when you are asking what is involved
in a farm assurance scheme I think the key thing to
bear in mind is what is involved depends entirely
upon what is in the standard and so that is actually
the nub of the issue, what is actually in the standard,
rather than saying typically a farm assurance scheme
is X or Y. A farm assurance scheme will assure you
that that farm complies with whatever is in the
particular standard against which they are requiring
certification.
Q231 Chairman: In the guidance from the FSA it
states, I understand, that all the food assurance
schemes in the UK should be accredited to
European Standard EN 45011 by the UK
Accreditation Service. What proportion of these
schemes actually achieves that accreditation at the
moment?
Ms Campbell: Again, I would not be able to answer
that. I am not even sure UKAS could answer it
because it would not necessarily know what schemes
have not complied. It is guidance and I think most
of the scheme owners would seek to ensure that their
schemes are accredited, but I do not think that it is
necessary that all the schemes do meet that
requirement. Also what tends to happen in terms of
accreditation is that some schemes can predate this
requirement so there tends to be a practical
arrangement to enable schemes to come into
compliance with it. Again, a lot will depend on the
particular owners of the standards or schemes as to
how definitive they are about the need to meet that
requirement and/or what terms of time they give in
order for schemes to become compliant with it.
Q232 Chairman: Take, for example, the schemes
which you certify, how many of the ones for which
you are responsible in some way meet the European
standard?
Ms Campbell: I should think probably most of them,
do they not, Paul?
Mr Wright: Where there is a specific requirement for
EN 45011 accreditation, it is always our policy to
pursue those accreditations. Accreditation can take
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a year. It can take 18 months to build a scheme and
satisfy UKAS that this scheme is in compliance.
Where there are schemes that do not require 45011—
and I am hesitant to think of any at the present
time—then we would not necessarily go for EN
45011 because it is an expensive cost burden to the
smaller schemes. I will give you an example of that.
We certify Whitstable oysters and it is a requirement
under EU regulations that the scheme operates to
EN 45011 accreditation. Whitstable oysters,
however, is one single producer in Whitstable in
Kent where to develop a scheme and to accredit that
particular scheme would be so burdensome to the
organisation concerned that what we do is we simply
operate to EN 45011 in that instance. Very rarely is
that the case but it is such a small operation that it
is agreed with Defra that in that instance we simply
operate to EN 45011. It does not make any
fundamental diVerence, it is just less burdensome on
the poor old Whitstable oyster catcher.
Q233 Mr Jack: In evidence to the Committee from
Mr Clive Dibben, an independent consultant, he
said that the majority of these schemes in which you
are involved, certifying simply mirrors the basic legal
requirements in their respective areas of operation
so they give some degree of assurance that people are
playing by the rules but they do not, if you like, go
beyond the minimum standard. Do you agree with
Mr Dibben’s assessment?
Ms Campbell: I think there will be a number of
schemes that are predominantly based on minimum
requirements and you could perhaps ask yourself the
question why bother with the schemes if they are
merely minimum requirements? I think that is
because producers have seen the need to be able to
demonstrate that they are in fact meeting those
minimum requirements and that it is quite important
to purchasers, not necessarily the consumer but in
the food chain, to know that they are meeting those
minimum requirements because obviously there is
no policing of every individual producer to be able
to demonstrate that, so this is one means of being
able to show that. I think there are, though, many,
many schemes where they do go beyond the
minimum legal requirement when they are
responding to what consumer needs are because
again it is often consumers who are asking for things
that go way beyond what is sensible to legislate for,
and therefore there is a need in the voluntary sector
to be able to develop schemes in response to that, so
again things that we are seeing to do with animal
welfare or the provenance of products may be
something that will go beyond legislation but they
are a particular producer seeing that they are
responding to consumer needs, so I do think you
have a mixture of both.
Q234 Mr Jack: Do you not therefore think the
implication is that if people see some kind of
message of assurance, some kind of scheme, that
they think that the product area is better than the
minimum? Do you not think that informing people
(because these schemes are designed to send out
some kind of message) either about the nature of the
end product or the way that it is being produced, that
you should be able to diVerentiate between those
who are simply saying, “I am having a rigorous
assessment and I am meeting the minimum,” as
opposed to, in whatever way they do, exceeding the
minimum and perhaps adding something on as well?
Ms Campbell: Very much so. I think there is a need
for consumers to be able to understand what the
various schemes deliver. In many respects many of
the schemes are not necessarily developed in
response to consumer needs. They may be there in
response to purchasers’ needs further back in the
food chain, not the end consumer, and there is a
danger that we do as a consumer pick up completely
mixed messages. We do not actually know what the
various logos mean. It is not easy for us to be able to
tell, as a consumer, whether it is a marketing claim or
whether it is an independently verified scheme. From
the basic level it is quite hard for a consumer to
diVerentiate between those two things, so I think it
is quite important that there is an ability to be able to
demonstrate that something has been independently
verified and that this is not just a marketing claim.
Q235 Mr Jack: Have you seen any research to talk
about what consumers’ perceptions are of the
multiplicity of schemes that are around, in other
words what they understand? It is quite interesting
to see sitting in this Committee the number of people
who, for example, have organic schemes, which have
a variety of diVerent requirements for products
under that scheme’s certification process to be
counted as organic. There are European legal
requirements to set minimum baseline standards but
some schemes are far more rigorous in their
application than others. It is very diYcult for
somebody who says, “I would like to try organic for
the first time,” to know whether they were getting the
most rigorous or just the basic.
Ms Campbell: I think it is extremely diYcult because
again government has got the very hard choice of
deciding whether it tries to enforce standards that
are beyond the legal requirement. We have seen
recently this week someone, I cannot precisely
remember who it was, who was confirming that there
was a feeling in the UK that sometimes we
interpreted the EU standards beyond that which our
European neighbours did, and certainly in terms of
the organic area, I know there was a lot of debate in
terms of whether UK organics should be allowed to
lower their standards, if you like, to comply with the
EU requirements, lower than many of the existing
organic schemes that were here in the UK, and it was
an extremely diYcult area. I think overall there was
a feel that as a minimum there has to be a level
playing field between the UK and Europe and that
we should not penalise UK organic farmers but,
equally, there should be the opportunity, if
consumers are demanding more than that standard,
to be able to promote organic schemes that meet
higher standards and to be able to build beyond that
minimum legal requirement. Again, like all things,
the more choice that you have the more diYcult it is
to get a message over to the consumer. That does
make it much more complex, but I think on balance
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the preference would be to enable that choice and we
have to work harder at trying to simplify the many
messages that are there and to hopefully make it a
little bit easier for people to quite quickly establish
benchmark baselines and then those that are
interested, and we have to accept that not all of us
are prepared to put that eVort into our shopping
necessarily to research what each individual schemes
means but that those of us who are interested and do
wish to know more about what is behind the various
schemes we have easier access to that information.
Q236 Mr Wiggin: I am very curious about this
because a lot of my constituents who are farmers
complain that they pay to join various schemes and
they do not get much for it. Do you not feel that the
boot is really on the wrong foot and it should be us
the consumers who are paying for your schemes? I
have no diYculty with what you are doing.
Essentially you are policing to ensure that we the
consumers get what we think we are going to get.
Should not the supermarkets be paying for that?
Ms Campbell: When you say “our” schemes, we are
the independent verifier of other people’s schemes.
They are not our schemes and our job is purely to be
able to come in and be able to verify those claims.
That is not to say we are not involved in helping to
develop certain schemes because obviously as part of
developing any scheme if you are going to have it
assessed you need to consider certain elements in it
as you develop that scheme otherwise it would be
impossible to assess that scheme. At the end of the
day the consumer always pays, do they not?
Q237 Mr Wiggin: No, definitely they do not pay
when it comes to farm assurance, definitely they do
not, because there are diVerent schemes, as you
rightly identified, and some will be better, some will
be diVerent, some will be cheaper, some will be more
expensive. Very often, with farm assurance schemes
particularly, ultimately the farmer pays and there is
no actual premium for selling an accredited product
and that is the point, I am trying to get to.
Mr Wright: I think you have to go back to the
history of farm assurance schemes which were
originally membership driven. They were there to
respond to the scares of the early 1990s and BSE in
the mid-1990s. If you take the farm assurance
schemes as they are now there is a negative to it
nowadays because if you are not farm assured you
often cannot shift your stock. That is the negative.
Q238 Mr Wiggin: That is why I am putting it to you
that whilst what you are doing is great, the problem
for us with food is this is a very negative type
problem we have got now. People are putting in
schemes whereby they cannot sell otherwise but that
is the wrong way round. Surely it should be the
supermarkets saying, “We will only buy from the
schemes we run”? You may well be the verifier of
that but that is not the way it is happening at the
moment. The scheme managers are the ones
insisting that farmers cannot sell their crop
otherwise.
Mr Wright: If you take food safety schemes such as
the BRC scheme that is where the manufacturers pay
for that assurance, usually at the behest of the
retailers one has to say, but it is a common enough
problem that you define and it is not one that we
should have a view on.
Q239 Mr Wiggin: You are in the middle but the
diYculty for us is that we are trying to talk about
food information and it is all the wrong way round.
The people who will actually be serving the
consumers are the supermarkets/the shops but they
are not the ones who are taking a great deal of
interest in this. It is the producers who are doing it
to promote their product.
Mr Wright: You have to identify benefits too and
that is probably the trick for scheme owners. If they
are having to sell that to their members, bearing in
mind that most of the traditional schemes have been
NFU driven in the past, quite obviously it is the
NFU’s members to some extent whom they are
trying to represent. If you are looking at it from that
viewpoint and the way it was marketed in the past—
to actually give benefits and put assurance back into
the food chain where there was a degree of cynicism
and scepticism with all the claims being made
particularly from the farm side (and most of the food
scares have emanated from the farm side in latter
years)—then there was a genuine desire in the
industry to put more confidence back into the food
chain by having assurance schemes, so there is some
benefit to it. Would we have been so successful in
getting beef back on the menu without farm
assurance schemes? It is an open question.
Q240 Joan Ruddock: I suspect that it may not be
about getting a market edge in terms of premium but
it may be about market share and people are having
these schemes to make sure they can actually sell
their produce and that that is part of it. As a person
who only buys organic I have to say I have no
experience of these schemes whatsoever. As a
consumer I do not take any notice of them. What is
the evidence that others are taking notice? It sounds
from what you have been saying that there is a lot of
confusion, that it may not be consumer led, so to
what extent are consumers aware of the diVerences
in schemes? Is there research on this?
Mr Wright: A lot of this is the confusion of these
schemes themselves. Do they represent quality? Do
they represent welfare? Do they represent safety? Do
they represent something else? If the message is
mixed, as I believe it is, and if we are looking at the
little red tractor as an example of that, I am not so
certain that means an awful lot to people because I
am not awfully certain that anybody knows what it
does represent—British farm standards or not
British farm standards, quality or not quality? A red
tractor mark on a scrag end of lamb? Who knows?
To enhance the point that Mr Jack made with regard
to organics, with organics of course you have a
generally discerning purchaser who does know what
organic means. When you have got a little red
tractor sitting on a logo in a small supermarket that
discernment is not there and that is where the
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education comes into it, which is what we are saying
here, and part of the remit of the committee is how
far you take the education on it, but I am not certain
that any of the major schemes actually have the
consumer recognition that they should have.
Q241 Joan Ruddock: Clearly that is an example of a
less well-understood scheme. Have you got an
example of a particularly well-run scheme?
Mr Wright: I would mention the Soil Association
schemes as being particularly well-known and I
think most people who buy a Soil Associationcertified product know pretty well what they are
getting, but that is down to their discernment. I
cannot think of any others that immediately spring
to mind.
Q242 Joan Ruddock: I was going to suggest that you
leave that aside because it is not really comparable
because it is a whole category of produce right across
the board and there is a diVerent connotation to
organics which is a single word and which means
something precise. There is no other scheme like the
badging schemes that you can point to as being
successful?
Mr Wright: The one that has got nearest to public
acceptance is probably Quality British pork. I think
people do recognise that as a valiant attempt at
putting quality into the British pig business.
Q243 Joan Ruddock: What does it mean?
Mr Wright: Quality.
Q244 Joan Ruddock: What does quality mean?
Mr Wright: Well, it is a mixture of things but they do
market it as quality whereas some of the other
schemes do not.
Q245 Joan Ruddock: I think I have seen it, yes.
Mr Wright: They do market it as quality whereas
some of the others do not. They are certified to a
particular standard.
Q246 Joan Ruddock: We had some evidence again
from Clive Dibben, who has been referred to
previously, saying that “various attempts have
already been made to develop an overarching body
to explain the merits of assurance schemes to UK
consumers . . .” Do you think there is any value in
that?
Ms Campbell: An overarching body? I think there is
always a benefit if you can gain co-operation and
consolidation so you can simplify the message. I
think that there are already organisations out there
that may be able to extend their remit to enable them
to fulfil their role. I am not sure whether there is
necessarily any great benefit in reinventing the
wheel. Potentially you have got the Food Standards
Agency whose remit could be extended. You have
also got UKAS, which we heard earlier is the UK
Accreditation Service, whose job is to ensure that
anybody like PAI, who provides independent
validation, is competent to do so, and I think the key
thing both about the FSA and UKAS that is quite
important to anything that you are trying to do in
terms of getting over a credible message is that both
organisations are seen as being impartial,
independent and competent, and I think for
anybody to listen to any message that is coming out
of anywhere it is essential that they are able to
demonstrate that. So for me looking for somewhere
to start to help to bring the messages together and to
be able to provide something that consumers could
trust, I would start by looking at those two
organisations and seeing if there was any way in
which either their remit or their resources could be
extended and, with co-operation between the two
organisations, whether they would be able to help to
deliver a solution to it.
Q247 Joan Ruddock: Are you conscious of new
schemes being on the drawing board?
Ms Campbell: I think there are probably new
schemes all the time, yes, absolutely.
Q248 Joan Ruddock: So we can see an even greater
increase of schemes and greater confusion arising if
nothing is done?
Mr Wright: You might see a greater increase but you
also might see a better result because in the past farm
assurance schemes particularly have been quite
prescriptive in the way they stipulate what you must
have and what you must do and what you must not
do. That is good and that is sound but the modern
way of thinking about farm assurance schemes is
that they should be outcome based so you are
actually looking at the outcomes and how they get to
the outcomes is of interest obviously because if they
are doing anything illegal that would not satisfy the
outcome. Generally speaking, if you are looking at
an outcome that is the way modern farm assurance
schemes are going.
Ms Campbell: I think there are many, many drivers
that are going to say there are going to be more and
more schemes, and not least the drivers are the
consumers themselves because we are getting more
and more discerning consumers who want to know
more about where their products come from and
associated with that of course we have got the
increasing globalisation of food and where we
source our ingredients from, and people are getting
more and more concerned about traceability of the
food chain. We were all very comfortable when we
were buying it from our local producer and we all are
perhaps much more sceptical now that we are very
much based in a supermarket economy in the UK
and perhaps we are getting increasingly concerned
because we are seeing even more of that sourcing
having to go overseas. I think the drivers are there
for more schemes not less schemes and therefore I
suppose it is beholden upon us to try and find ways
in which we can ensure that whilst there may be more
schemes because we have many more choices we
have got to work harder at trying to enable that
information to be digestible to those who are seeking
the information.
Q249 Chairman: You have hit upon a crucial point
because we had written evidence from the National
Consumer Council to the eVect that having studied
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consumers’ views on voluntary schemes their
conclusion was that the schemes were more likely to
confuse and mislead consumers rather than inform
them. We are getting more and more schemes both
domestically and from other countries and most of
us will recognise some of the marks from Germany
saying recycled material is being used in a container
by the Soil Association, or the equivalent. If we are
going to get more and more of these kinds of
schemes it is going to cause both confusion of the
consumer and further devalue the schemes which
you currently verify.
Ms Campbell: I think there are problems. We cannot
ignore the internationalisation and we cannot ignore
the fact that consumers have strong opinions. They
may be many and varied and they may want to be
able to meet their particular desires. I think it is
important, therefore, that we maintain a focus that
the schemes are independently verified because I
think that is one way that you can start to increase
the confidence levels. That is the first thing—that
they cannot just self-declare, if you like, that they
meet those criteria—and I think independent
verification is very important. I also think that as
part of that independent verification should be the
ability to access information on what the various
schemes mean. If you take the organic one, if you
look at that internationally, it is very diVerent and
you are not necessarily getting the same things. You
may know what the Soil Association label means but
there are other organic schemes and they mean
something diVerent, so you have, I would think,
exactly the same issues in the organic sector as you
do in the normal farm assurance sector because you
will have certain schemes that are driven by the
particular needs of a market-place and the consumer
who wants to set those higher standards, and it is
worthwhile developing a scheme because people will
respond to it and, equally, as we talked about earlier,
you have got the EU requirements on organics
which do not require necessarily all the extra
safeguards that we may prefer in the UK, so there
are many issues in terms of imported foods that can
come in with the various diVerent labels as well as
the various schemes that we can invent ourselves in
the UK, so I think the answer is that we are certainly
going to have to work harder at trying to make that
information available and, regrettably, the
consumer is probably going to have to work harder
bothering to find out that information, but we have
just got to make it as easy as possible to make it
available.
Q250 Chairman: A body like yours can only verify
independently the claims which you have been asked
to verify. You do not control how they are marketed,
you do not specify what criteria are to be verified. It
is very much “we develop a scheme and we decide
what is to be in the scheme.”
Mr Wright: If we are asked to help develop schemes
then we will develop schemes but we do not sit there
in adjudication as to what is a good scheme or is not
a good scheme. We are asked to develop things. The
one thing that you should take into account when
you are looking at the development of a scheme is
the retailers’ involvement in it. Retailers are always
going to be competitive, they are always looking for
an edge on it. One of the questions you might ask of
the retailers is what is driving them? Is it due
diligence, is it consumer trust or a variety of other
things that is doing it? To actually ask for a
reduction in the number of schemes is almost an
impossibility because every retailer is looking for an
edge on their competitors in that regard usually with
a view to gaining trust but very often for due
diligence purposes.
Ms Campbell: It is also perhaps worthwhile
mentioning that the panel talked about the 445011
standard, and that is the standard the independent
verifier, the PAI (if we are accredited by UKAS) has
to meet and ensure that schemes meet. The one thing
that it does do is that whilst we do not set the actual
standards if they are to meet 45011 we have to be
able to demonstrate that that standard or that
scheme did have input from all the key interested
parties. I still think that potentially it is quite hard
for consumers to input into those schemes but there
is a mechanism to say it should not be driven by a
particular interest. Quite a lot of eVort does go into
trying to ensure that appropriate people are around
the table in developing those schemes and at times it
is probably quite hard to be able to get consumer
input because again it is quite time-consuming and
demanding. That is one of the diYculties I know the
schemes themselves face—trying to be able to get
that input.
Q251 Mr Wiggin: Taking a wheat scheme, you go
around and you make sure there are no light bulbs
so that no glass can fall into the wheat and no birds
can get into grain store, but the wheat goes oV to the
miller, he turns it into bread which goes into a
supermarket, and if the wheat is not the right price
he will buy his wheat from another country abroad
which will not have been verified perhaps by you. So
now we have got as consumers the problem of
choosing the shop we go to, then buying bread
produced by a type of miller which we hope will have
used grain from one of your verified schemes, so then
we have to make sure we have got the right verifier
as well and that it comes from a scheme that we think
is a good scheme, and again Ms Ruddock was
talking about her organic interest but that applies in
organic just as much as in any other sort. Now we
have got an even more complicated system of
choosing what is good for us than we had before.
Surely by having this legislation we can get rid of the
assurances because all food must live up to the
standard otherwise the law has been broken, so your
role is just as important but you should be policing
as opposed to verifying that people are complying
with the scheme and that would simplify it surely? Is
that one of the things we should be looking at?
Mr Wright: Maybe you should be looking at it but
it is market pressures. I know increasingly that the
millers are sourcing their wheat from assured
sources in the UK but in times of shortage
commercial considerations come into play and that
is a question that you must ask of them. There is a
lot coming in and pressures are developing in
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production so that over a period of time,
increasingly so, assured wheat in your example is
actually being consumed by us in the bread that we
eat.
Ms Campbell: I think there would be diYculties
because you have got to look at the whole food chain
and policing the end product would not necessarily
be able to tell you everything.
Q252 Mr Wiggin: I meant policing the process
because we cannot police the end product. As a
consumer we are doing that eVectively with our
money. We need to be sure that whatever is for sale
in our supermarkets is as healthy as it is supposed
to be.
Ms Campbell: Which is what the validation process
tries to do. Depending on the various schemes, the
whole chain is traceable going back the way from the
ingredients that come in in feed, et cetera.
Q253 Mr Wiggin: That is right because now as a
consumer I have to not only check the E-numbers
but I also have to check who validated it. That is the
problem.
Mr Wright: In the submission we talk about (or
perhaps we do not and perhaps we talked about it
afterwards) the fact that the verification of all claims
should be independently verified. That would be our
position. We would say that, would we not, but we
think that is a sound start point.
Q254 Mr Wiggin: I agree with you on that, that
every claim should be policed eVectively.
Mr Wright: That is right and if we go back to
something like the animal feed materials, we can do
an awful lot of traceability of the raw materials that
goes into animal feed and there is no doubt there is
more integrity in animal feed than there is in the
human food chain at the moment. It is because of the
scares in the past that we are deploying a standard
that makes sure that anything that is produced for
the animal feed industry in the UK has got product
integrity associated with it. Having said that, I
suppose it is only because we eat the livestock that it
can have that impact. It is interesting that what we
do in the animal feed chain is not necessarily what we
are doing in the human food chain and it is no good,
in our view, having a food safety standard that sits
above the processing of it and manufacturing of it if
you do not know that what you have imported from
Brazil or the Eastern Bloc or Far East in terms of
spices and all the other things have got integrity
themselves. We open a can of worms with that but I
am absolutely convinced that it is insuYcient to just
look at safety in the manufacturing process. What
about the integrity of the materials? We have done it
in our animal feed; we should be able to do it in
human food.
Chairman: Thank you very much indeed for coming
along this afternoon to give us evidence. It has been
very helpful indeed. If there is any additional written
evidence you want to submit in the light of your
comments today feel free to do so if you so wish. It
will be useful to us. Thank you very much indeed.
Memorandum submitted by the National Farmers’ Union
The NFU represents approximately 75% of farm production in England and Wales. We represent sectors
as diverse as dairy, cereals, sugar, livestock (beef and lamb), poultry, horticulture and potatoes. The
majority of our members produce primary agricultural product although an increasingly large number are
adding value through further processing or packaging to produce a finished food product. In addition we
represent a number of farmer controlled businesses or co-operatives many of which are involved in further
processing but on a much larger scale.
The Committee’s terms of reference are quite broad. Several of the issues raised are of primary importance
to the British farmer, whilst others are very important to the food chain as a whole. Please find attached a
joint response made by the NFU together with the British Retail Consortium, the Food and Drink
Federation and the British Hospitality Association, to a Department of Health Nutrition forum paper last
year, which highlights our position on food relating to health and nutrition [not printed].
The overarching need should be to provide the general population with a better understanding of what
is meant by a healthy lifestyle and diet. This has to be balanced against what is a reasonable level of
physical activity.
Whilst the important areas of nutrition, safety, and production standards are considered under the broad
heading of food information, the NFU would also ask that the Committee have careful regard to the
importance of country of origin labelling of foodstuVs. Consumers have a clear interest in where food was
primarily produced and processed, and we are concerned that under current regulation and practice labels
can be highly misleading. The NFU supports the clear labelling of foodstuVs and country of origin must be
a priority within this.
On a related point the terms of reference also appear to be confined to production and retailing. The NFU
would urge the Committee to consider the role of the food service sector in delivering food information to
consumers as well. The NFU fully supports the MLC’s Menu Transparency initiative in this regard.
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In addition to the issues covered in the Food and Health Action Plan policy statement referred to above,
the NFU would like to make the following points:
Food safety
All links of the supply chain have responsibility for food safety. As part of the food chain, British
agriculture wants to act responsibly and has put in place a number of measures to ensure that food is safe.
In particular Assurance Scheme protocols have been designed with food safety as a primary objective. Clear
labelling of food with the Red Tractor logo denotes that it is farm assured. The NFU works closely with
industry and government to ensure that standards are maintained and regularly reviewed. Through the
consolidation of all the assurance schemes under one logo, the consumer is better able to recognise farm
assured product. Indeed a key driver in the development of Red Tractor was to reduce the number of logos
associated with farm assurance to assist consumers in their purchasing decisions
Production systems
These are also covered by assurance schemes. The NFU supports all forms of primary production
providing all the necessary requirements of health and safety are maintained. If foodstuVs are labelled to
denote the system of production employed then this labelling must not mislead the consumer. Furthermore
if labelling is used to denote production systems then it must be used positively, informing customers rather
than using subjective claims, which are made at the expense of other systems.
The NFU works with unions, regulators and government to ensure that labour standards meet statutory
requirements. We strongly support Jim Sheridan’s Bill to introduce a licensing scheme for gangmasters in
our industry. Again the NFU would support clear and accurate labelling in this area so consumers are not
confused.
Information currently provided on food in the retail sector is generally of a good standard. Nutritional
information, sell-by and use-by dates are on the whole accurate, while information on assurance schemes
and production methods are now more widely available. Above all labelling should be clear and inform the
consumer. The industry should guard against information overload as well. If too much information
appears on the label then consumers may not always discern the key information they require.
April 2004
Witnesses: Mr Tim Bennett, President, and Mr Robin Tapper, Head of Food and Farming, National
Farmers’ Union, examined.
Chairman: Good afternoon, Mr Bennett and Mr
Tapper. First of all, my apologies for changing the
agenda round so you are a bit later than you
otherwise would have been but, as you will
appreciate, we wanted to make the best use of the
time available as we had moved slightly ahead of our
time table. Welcome this afternoon. Could I thank
you for the written evidence which you have
submitted to us and we look forward to what you
have got to give us in oral evidence this afternoon.
Could I invite Joan Ruddock to start the questions.
Q255 Joan Ruddock: To start with food safety, as so
often is the case with these inquiries, we have
received written evidence which is quite
contradictory. We have the British Retail
Consortium saying that food safety is not a
significant problem. They say that: “UK legislation
is quite clear—all marketed food that is properly
processed, stored and prepared is safe for general
consumption.” We also have evidence from Dr
Richard Bain from the Royal Agricultural College
in Gloucester suggesting that: “ . . . home-grown
produce is largely unregulated in terms of food
hygiene.” How do you react to those two bits of
evidence?
Mr Bennett: I am rather surprised by the latter one
as someone who is a farmer as well as President of
the NFU because over the last few years there has
been quite a marked tightening of regulation in
terms of food safety, and quite rightly so. As a
farmer I am subject to very stringent hygiene
through the meat chain and in terms of pesticide
usage and in the way that pesticides are authorised
there is very tight regulation but what the industry
also does is go beyond that and look at the industry
doing things like the voluntary initiative in the use of
pesticides. We are also a key part of the responsible
use of medicines initiative working with others, so I
think regulation has tightened up considerably in
recent years and if you look at the results in terms of
food safety then you see some results from that, and
certainly if you go abroad and look at the way
hygiene regulation is applied and the way the
regulation is there you will find significantly more
attempt to do it correctly, with greater cost to our
industry I may add, than you get abroad, but I think
also we as an industry have always tried to look
ahead and see what are the problems that are coming
because sometimes, if there is an issue, legislation
trails behind problems and that is why we try to be
proactive in these areas as well.
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22 June 2004 Mr Tim Bennett and Mr Robin Tapper
Q256 Joan Ruddock: Could it be the case that good
farmers like yourself are obviously pitching up for
the highest possible standards but others in the UK
are not and that might have led to this comment?
What precise regulations are you required to meet in
terms of hygiene?
Mr Bennett: It depends what sector of agriculture
you are in but if you were like me—and I have just
recently given up dairy farming—I would be subject
to the milk and hygiene regulations on which there
will be a spot inspection not an announced
inspection. We are also subject to trading standards
inspection in terms of animal records and indeed
making sure that the milk is milk and there is no
water in it. You have got all that. If you are a beef
farmer you have got the animal identification, not
only through trading standards but also for the
British Cattle Movement Service so if you have not
got a passport for an animal and you have not got
a history of that animal and where it has been, then
eVectively it is worthless because you have not got a
market. There is lots of regulation. Recently I had an
inspection, for example, for checking the welfare of
the animals, calves as it happened to be, from a
Ministry inspector. While they were there they
checked the records to see what medicines I had used
and whether I had used them correctly and also what
we call the movement book to check that my records
are up-to-date. A lot of us farmers would say that
there are quite a lot of people who can check what
we do in terms of food safety. What we would want
to do, of course, is we are in a global world and we
have to be shown to be better than anyone else
because hopefully that will give us an edge with our
consumer. I have to say that farmers who do not
practise good practice probably will not have a
market-place. If they have not got one today they
certainly will not have one in the future.
Q257 Joan Ruddock: Unless they are selling it down
a local market and they are not requiring themselves
to go through retailers and supermarkets or
whatever. So there is some escape route for some
people, is there not?
Mr Bennett: If you are selling meat you have to go
through an oYcial slaughter house so you are
subject to all those sorts of regulations. You still
have inspections even if you sell eggs at a farmers’
market. You would still be subject to the regulations
on farm. There is no doubt at all however in terms of
the market-place that if you are selling into the retail
sector the market-place itself drives very high
standards because the consumer through the
customers and the retailers in the food chain set the
standards and those standards can vary because
every retailer, particularly the ones that go for
quality produce in the south of England, would
probably add extra conditions for being a customer
of theirs.
Mr Tapper: I think the household-type markets or
the street-type markets that you referred to really is
the last chance saloon. We are talking about return
here and people who are selling into these markets
are probably receiving a much lower rate of return
for their product than those that are selling into the
organised market that Tim refers to.
Joan Ruddock: So the Eddy Grundy incident on The
Archers is complete fantasy, is it?
Q258 Mr Jack: Not as far as Eddy is concerned.
Mr Tapper: I am not an Archers’ listener but, yes,
everything has got a market at a price and I think our
job is to ensure that the best product gets the best
price in the best market and that we can literally
market that, we can inform the customer that those
products have had due diligence.
Q259 Joan Ruddock: Would you share the British
Retail Consortium’s view then that British food is
safe, that is it?
Mr Bennett: British food has got good regulation
behind it. I think the industry itself puts a lot of eVort
into making sure it is safe. To be quite blunt about
it, if our consumers do not feel safe then we have not
got a business and so it is our job to make sure if
there is some perception or even genuine concerns
from the people to whom we sell then we have to put
that right. Sometimes you try to put things right even
if there is not necessarily a health scare. It is not just
about getting it right for the consumer, it is also
about making sure the consumer is completely
happy and you get the nuances from them about
their perceptions.
Q260 Chairman: I think you heard part of our
discussion about the question of food assurance
schemes. Could you first of all give us your estimate
of the number of such schemes that are in operation
in Britain and then tell us whether you are in favour
of fewer such schemes or a consolidation of such
schemes being brought into eVect? Could you
perhaps say whether you favour a consolidation or
reduction in the number of such schemes and if you
would, perhaps most importantly, how would you
achieve that?
Mr Bennett: I would not know the exact number of
schemes out there but I agree that there are probably
too many. I think it depends how you determine
those schemes. Farm assurance really got going in
terms of independent verification of farm standards
back in mid-1995–96, somewhere round the BSE
scare, and the schemes developed on a sector-bysector basis. As those schemes developed we in the
NFU felt that we had got lots of schemes, lots of
inspections and we needed to consolidate them. We
have been working to try and get some consolidation
in. We have got the Assured Food Standards whose
ultimate remit hopefully will then control that. It is
an independent body which as part of it will
hopefully end up consolidating a lot of the schemes.
We have had some success. At least we tend to get
single inspections. If you are a cereal and beef farmer
or dairy and beef farmer, for example, which is a
scheme we are working on now, you now get single
inspections so there is some sort of integration.
What you cannot avoid is that there will be some
retailers who for competitive reasons or their own
particular market-place will want to add something
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to basic farm assurance schemes. Even then there is
no reason at all why that cannot be done at the same
time. So we are in favour of consolidation but we
want something like Assured Food Standards to
drive it to make sure that it is being done correctly so
that it is not just a trade association doing it. I think
it is very important for the independence and
integrity of these schemes that it is done properly
and not just farmers saying that they want to make
this a bit simpler. However, we agree with the
consolidation.
Q261 Chairman: Is it not a bit odd that in a world
where the food retail sector is heavily dominated by
a very few major players that no-one seems to be able
to tell us how many schemes are in operation or
indeed just simply give us a list of the fields which
they cover? I am not blaming you for that but these
do purport to be national schemes in most cases, I
understand, and yet nobody seems to know what is
out there. Does that in itself not say something about
the problem?
Mr Bennett: We could probably give you a fairly
comprehensive list of schemes but I would take the
point that I think we need to consolidate those
schemes because across all those sectors there tend
to be diVerent schemes and indeed in the organic
sector there are diVerent inspection schemes so there
is an opportunity to do that and we are encouraging
people to do that, and I think we are having some
success certainly in the sector schemes.
Mr Tapper: There is a dichotomy there as well. You
have got schemes which are set up such as the red
tractor scheme which is eVectively a standard, a sort
of kite mark if you like, and then you have got other
schemes which I think were mentioned by previous
witnesses which may refer to provenance or
particular elements of a product. It is very diYcult to
draw a line there. Certainly from the retail point of
view and from the customer point of view they
would say they are too many schemes and again we
are trying to get to one standard which forms the
basis upon which other people may want to build
extra bits and pieces if they so wish. We need one
standard across the chain so the consumer knows
that what they are buying is safe and meets certain
guidelines.
Mr Bennett: The rationale of the red tractor was to
try and put a logo that reflected a multitude of
schemes that were designed to give consumer
reassurance. That is what we are still trying to do.
Chairman: That leads neatly to Michael Jack who
wants to ask about the red tractor scheme.
Q262 Mr Jack: What research has the red tractor
scheme done to see what messages the consumers are
actually picking up of assurance (because this
inquiry is about food information) and to check that
the scheme is designed in as simple a way as possible
to send out some indication about the way that the
food is produced to the consumer? Have you done
any research to find out what people actually believe
it all means?
Mr Tapper: Yes, we have done two pieces of
research. First of all, there was some research on
recognition and the red tractor has something like
47% recognition amongst customers. That is second
only to the lion mark on eggs, so it was a great
success from that point of view. The least success is
on the understanding of what the red tractor means
and there the recognition is low. I think it is low for
two reasons. First of all, there is confusion. People
see it as a nationality mark sometimes when it is not.
We would like to think that people thought of it as
British but we certainly cannot promote it as that
because of the state aid rules, amongst other things.
There is also the issue that we are very conscious of
that we have not marketed what exactly it does
mean. Of course, unlike eggs where you have got a
one-product industry, the message in agriculture is
much more complicated. You might have carrots at
one end of the scheme, which is fairly
straightforward, but you might have a meat product
at the other end which could be very complex, and
so trying to get a simple message across the whole of
agriculture is quite diYcult, but we are trying to
develop such a scheme.
Q263 Mr Jack: So you have 47% of consumers
recognising a label with a meaningless background
to it? They have not got a clue what they are
recognising.
Mr Bennett: I think it is fair to say that it signifies
someone has put some assurance in there but they
would not know exactly what that is. That would be
true of most of these logos. Even the organic labels
of the Soil Association people know it is organic but
not many would know the detailed scheme
standards.
Q264 Mr Jack: Do you not think in a way if one
were to do an article in some salacious newspaper
and it said “owners of red tractor scheme
acknowledge that lots of people recognise the label
but the whole thing is a meaningless myth” that the
whole thing would collapse round its ears, would it
not?
Mr Bennett: I do not think that is the case. I think the
Food Standards Agency came up with that research,
they quoted something like 40% a couple of years
back, and then also stated that there was a need to
increase the understanding behind those logos,
which is the same as Tim says.
Q265 Mr Jack: What are you doing to address that?
Mr Bennett: I think that is important. It goes along
the lines in a sense we have tried to integrate the
schemes into Assured Farm Standards which the
scheme is part of and obviously there are
independents on that board and that is an
independent body and they will actually market
what is behind that red tractor. We will obviously
help promote that as the NFU but it is for Assured
Food Standards to get the commercial plan about
how to explain the standards. We are in discussions
with them on that at this particular time.
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Mr Jack: You may be in discussions but you have
allowed this thing to promulgate that so people do,
I am afraid, think it is a country of origin marking.
You have been quite candid with the Committee in
saying that as a piece of communication you cannot
market it as such, and you acknowledge the fact that
people outside the United Kingdom could come into
the scheme, but you have not at this stage said to me,
“We are going to do something comprehensive.”
“We are in discussion,” is what I hear and yet people
are supposed to derive a glowing sense that if they
get a product with the red tractor on, somehow it is
good, wholesome, high standard—
Joan Ruddock: Who says so?
Q266 Mr Jack: Just a minute, I have not finished the
sentence. When I was looking at a publication which
the Consumers’ Association sent to the Committee
they said: “The red tractor scheme also allows
birds”—this is in connection with poultry—“to be
reared in more cramped conditions than
recommended by the Government.” Is that a correct
statement?
Mr Bennett: I could look at the standards of every
single scheme and come back with an answer to you
on that one. It certainly would not be below the legal
standards, I can assure you of that. In fact the lion
eggs scheme is not part of the red tractor scheme.
Q267 Mr Jack: So the best you can say to us is that
this great scheme of assurance simply reassures the
public (or if they really understood—the 47%—what
was behind it) that farmers have met the basic
minimum criteria?
Mr Bennett: We are saying a lot more than that.
What we are actually saying is that these are the legal
requirements (and very often the schemes go beyond
that) but on top of that these schemes have been
independently verified to make sure that this
product has been independently verified, and I think
that is an important reassurance for consumers.
Q268 Mr Jack: But in terms of the many things that
you might want to get across to consumers—for
example, animal welfare, which very important,
good biosecurity, disease control, the quality of the
food that is being produced in terms of meeting
specification and so on and so forth, is it right to
have a system that dilutes all of that into one label
when in actual fact the power of any one of the areas,
as just indicated, may be of greater advantage to
farmers trying to sell and diVerentiate product—and
I will say British product—from other people
because you have diluted it all under one rather
meaningless label that people do not understand so
that a lot of very good messages are not actually
getting out?
Mr Bennett: The intention of farm assurance and the
red tractor was to make sure that there was good
practice taking place on farms that was
independently verified to show that legal standards
were being met, and that is what the schemes have
achieved and that fulfils our place in the marketplace. You are quite right that beyond that you can
add, in terms of eating quality and things like that,
other things. Can I go back on the British thing;
because of state aid rules, whether we like them or
not, we cannot claim it as a British logo. We did not
set the rules on that, they were set by politicians, if I
may say so, whether we think them right or not.
What we have got at the moment is that it has to be
licensed and what we do know is that no product has
been licensed to the red tractor other than British
product and the customers/the retailers have only
brought red tractor produce that is British because
they can do it in the market-place as customers to say
it is only British with the red tractor, but what we
cannot do because of the Single Market is state
equivocally that the red tractor is British; that is
illegal.
Q269 Chairman: Just one point if I may. You did
indicate that you thought it would be relatively
simple to produce a list of the various farm
assurance schemes which as far as you knew were in
existence. I am sure that it would indeed be very
helpful to the Committee if you were to provide us
with that type of arrangement. If you could do that,
that would be very helpful.
Mr Bennett: We would be delighted to do that,
Chairman.
Q270 Mr Wiggin: I am a big fan of the red tractor
scheme, as you might imagine, because I laid out an
example to the previous witnesses about how the
farmer can go to the trouble to go through all the
assurance scheme and then watch in horror as
perhaps his miller will simply buy in cheaper wheat
from abroad. One of the questions I wanted to know
is once I have got my little red tractor I know that all
the way through—if it is on a loaf of bread—that the
wheat will be have been properly assured, will it not?
How many people are trying to put little red tractors
on their production who should not be? I have read
about something in Spain where we suddenly saw
little red tractors appearing. How much of that
goes on?
Mr Tapper: Very, very, very little. Certainly in the
two instances that I am aware of that happened in
the last six months they have been purely production
errors and in both cases the product was withdrawn
from display, returned and not put back into the
food chain, and I believe that is a responsible
approach. So we are pretty certain that everything
that is assured is assured and is at the moment
British.
Q271 Mr Wiggin: What about people trying to
pretend that they qualify for little red tractors when
they do not?
Mr Tapper: We are certainly not aware of that.
Q272 Joan Ruddock: Just on this little red tractor
business, is there any evidence that people are more
likely to buy something that is labelled little red
tractor than not?
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Mr Bennett: We have certainly had support from the
food chain for this little red tractor so normally if
there is support from our ultimate customers for it
then they feel that that is something that people
value.
Q273 Joan Ruddock: It is not the same as saying they
choose it because it has got the little red tractor on it
when they are doing their own shopping.
Mr Bennett: There is a process to this. First of all, we
had farm assurance to reassure people at our end of
the supply chain. Having done that, we looked at
how we could develop a logo that indicated to the
consumer we have done that. We have got to that
process and recognition is reasonably good. What
we have now got to do, which I think is a much more
diYcult thing to do but we have to do that, as you
quite rightly indicated, is make sure that people
understand what lies behind it so that people can feel
more reassured by this. The end game to this is I
want to make sure that consumers buy my product
because I have done a little bit more than my
competitors and that is what we are trying to do—
to reassure and make people feel confident in buying
that product. It is not straightforward to inform the
consumer and they will know all about it; it is quite
a lengthy process.
Q274 Joan Ruddock: I think you oVered no evidence
at all that it makes the slightest diVerence to the
consumer at the point of purchase doing the family
shopping. They may be randomly buying red tractor
meat or non-red tractor meat from everything we
have heard at this Committee. I can accept the point
of sale to the retailer from the farmer of course, but
at the other end there is no evidence from what you
have said.
Mr Tapper: The only thing I would say is that the
major retailers, if they are buying British meat, to
take your example, would only be selling red tractor
British meat so from that point of view—
Q275 Joan Ruddock: The consumer does not have
a choice.
Mr Tapper: The consumer does not have a choice
but is that not the right answer in that the
supermarkets are acting responsibly by supporting
their own tractor which in itself is a responsible
action about food safety, provenance and all the
various agricultural—
Q276 Joan Ruddock: I think that is a huge
philosophical debate and we have not got time to get
into that.
Mr Bennett: Can I come back to that. They do have a
choice because on that shelf there are products from
other countries that have not got a red tractor on
them, so they have that choice. If the legislators pass
legislation and if we can make sure that that
legislation is being enacted and it is being
independently verified and marked up as a logo,
surely, ultimately, that is for the benefit of the
consumer otherwise why pass the legislation?
Q277 Joan Ruddock: We are going to vote in two
minutes but just to take you on to something which
I know is dear to your hearts and that is country of
origin; you believe, I understand, that country of
original labels can be misleading. Just give us a word
on that and what you think should be done?
Mr Bennett: I actually think labelling is very
important. It is obviously important to us as an
industry if we can get the consumer to want to buy
our product, and if the labelling is misleading then it
is obviously damaging to ourselves, but I do not
think anyone has an interest in misleading the
consumer. To give you an example of country of
origin, we saw one last week and we have probably
still got it in our building which we can show you (it
happened to be rib eye steak) where it had “product
of the EU” stamped all over it but then if you really
looked in the small print it said “reared and
slaughtered in Brazil”. I do not think that is honest
and accurate labelling. If I may say so, recently in the
United States their labelling, both nutrition wise and
on these other things, seems to be slightly better than
ours, which rather surprised me.
Q278 Joan Ruddock: That is a very good example. If
it is reared and slaughtered in Brazil, there is no
processing process, is there? A piece of meat reared
and slaughtered in Brazil.
Mr Bennett: The law allows you to put “product of
EU” on it if it is processed. I guess what happened
there is that it was reared and slaughtered in Brazil
and then was cut up and processed in the UK.
Joan Ruddock: Cut up is “processed” by the
definition of the EU? We have a few more questions
but I think the Chairman would like us to stop.
Q279 Chairman: If you want to briefly follow up on
the last point, we have one minute left before we
finish the meeting.
Mr Tapper: What we would like is a very simple label
that just says “product of . . . packed in . . .” If it does
not say “packed in” one assumes that the products
are packed in the same country. That would be a
very simple one to get across. It would certainly fulfil
our requirements and I think it would be very easy
for the customer. Some companies already do it and
I think it should be standard.
Q280 Chairman: But for the food that is being
processed do you think there is a need to label
ingredients by country of origin?
Mr Tapper: Yes for the major ingredients so if you
are selling chicken tikka you can say “chicken
tikka—produced in the UK, made from chicken
from wherever” because it is chicken that you are
actually selling there, and that is the ingredient that
the customers, I would assume, are most
concerned about.
Chairman: I think that division bell brings us
naturally to the end of our questions in any event. I
would like to thank you for coming along this
afternoon, it has been very helpful. If there is any
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written evidence you wish to submit further to your
comments today we are certainly very happy to
receive it and again we await with interest receiving
the information on farm assurance schemes which
you were kind enough to say you would provide.
Thank you very much for coming along.
Supplementary memorandum submitted by the National Farmers’ Union
Farm Assurance Organisations
As requested, please find attached a summary of farm assurance organisations. This should not be viewed
as exhaustive but does demonstrate the number and complexity of schemes which exist.
Understanding of Red Tractor Logo
The Government agreed with the recommendation of the Curry Commission that the Red Tractor should
be a baseline standard that all food should attain and that the standards underpinning it need to be owned
by the whole food chain and managed by Assured Food Standards on their behalf.
The incorporation of all existing sector standards setting bodies into an independent Assured Food
Standards (AFS II) under the Red Tractor logo has now been completed. As debated at the Efra Select
Committee, the next urgent priority is to communicate the meaning and benefits represented by the Red
Tractor logo to the consumer.
As a major stakeholder in the new AFS II, the NFU is committed to supporting the Red Tractor scheme.
We believe that as we move towards a decoupled, market focussed industry, the Red Tractor will provide
the customer and the ultimate consumer at all stages in the chain with the necessary confidence that all
products bearing the logo have been produced to independently accredited production standards and that
the integrity of the product is assured.
Labelling
The NFU strongly supports the need for clear unambiguous labelling. In the important areas of health
and nutrition, labelling must be easy to understand but not over simplistic such as the proposed “traYc
light” approach which the NFU does not support. The NFU favours a form of nutritional information
which provides, for example, the amounts of fat, salt and sugar in a product as a percentage of the
recommended daily amounts (RDA).
We should also like to reiterate the point made in our evidence concerning the importance of clear country
of origin labelling of food. Consumers have a clear interest in where food was primarily produced and
processed. We are concerned that under current regulation and practice, labels can be highly misleading.
The NFU recommends the adoption of product of . . ., packed/processed in . . .. For composite products,
the country of origin should relate to the key ingredients eg for a chicken curry the information should relate
to the primary source of the chicken. In this instance, product of the UK made with chicken produced in . . ..
We have also taken the opportunity to provide the Committee with what we believe to be a grossly
misleading example of labelling even though legal [not printed]. Most customers could be forgiven for
believing that this label refers to product produced in the UK or at the very least, the EU. On closer
examination, a customer might believe it to have been sourced in Northern Ireland. Only when the label is
magnified can it be discovered with diYculty that this is in fact Brazilian beef packed in Northern Ireland.
This example was purchased in a major supermarket in Shrewsbury on 6 June 2004.
July 2004
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Members present:
Mr Michael Jack
Mr Austin Mitchell
Joan Ruddock
Memorandum submitted by the Co-operative Group
The Co-operative Movement comprises 45 retail Co-operative Societies across the UK operating some
4,000 retail outlets. The Co-operative Group is the largest Co-operative Society, operating as a consumer
owned co-operative, and comprises of a family of businesses whose activities range from food to finance
and from farms to funerals. Food retailing is core to our activities, providing almost half of the Group’s
turnover.
The Co-operative Group provides the Movement’s own label, Co-op Brand, comprising some 4,000
lines. Through the Co-operative Retail Trading Group, an organisation of Co-operative societies, it
provides the buying and marketing function for all these UK consumer-owned Co-operatives.
Background
The Co-op’s Right to Know policy is a commitment to provide the facts people need to make informed
purchasing decisions. Facts about products are supplied to consumers on labels, at point of sale, in leaflets,
on our website (www.co-op.co.uk) and in response to individual letters, e-mails or phone calls to our
freephone customer careline.
Clear labelling plays a vital role in helping people know exactly what they are buying. The Co-op prides
itself on its clear, comprehensive and well presented labelling where it sets the standard for the retail
industry. In 1997 the Co-op produced a code of practice for labelling and called on industry to adhere to it.
Many of the ground-breaking initiatives in the code are now either legal requirements (QUID labelling) or
subject to FSA labelling guidelines (origin labelling, marketing terms such as fresh, traditional, etc).
The FSA Labelling Action Plan has built on the Co-op Code of Practice, taking it forward. We welcome
their initiatives in this field. We believe they get to the heart of what consumers need to select appropriate
products. They are constrained by EU Labelling regulations which preclude the introduction of mandatory
approaches, leaving them to rely on industry’s goodwill to adopt guidelines.
The Nutrition Content of Foods
The Co-op has voluntarily provided nutrition information on pre-packed foods since 1986 which, since
1993, has had to comply with legally prescribed formats of the EU Nutrition Labelling directive (90/496/
EEC). Having a standard format is good from the point of view of consumers, ensuring they can compare
products from diVerent brands. However, this puts the labelling into a straightjacket which does not allow
innovation and adaptation to meet consumer needs. Based on textbook nutrition, it has familiarised
consumers with the names of nutrients but does not relate well to the health messages and advice given to
consumers, nor does it put the information into context to help consumers make use of it. Allowing a short
and a long form and making the 100 gram portion the basic information has, over time, resulted in denying
consumers key information to make healthy eating choices. Information on the key nutrients of health
messages; sugar, salt (sodium) and saturated fats are excluded from the short format. Our research has
shown that branded products high in sugar and salt are the very ones to adopt the short format and use only
a 100 gram serving.1 The latter does not help consumers to readily relate what they consume in a serving;
two biscuits or ° pack, with the detailed information given.
To address these and other issues, the Co-op has introduced the following adaptations into its nutrition
labelling policy:
— Full nutrition labelling (seven nutrients and energy) on all Co-op Brands.
— Declarations on both 100 grams and a serving on all products.
1
NOP Consumer Research conducted 1,061 face-to-face interviews with a representative sample of the UK population.
Completed July 2002.
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— Declarations per serving preceding those per 100 grams in line with IGD research findings.2
— HIGH, MEDIUM and LOW descriptors, based on a system developed by the Coronary
Prevention Group3 accompanying each nutrient. This approach, unique to the Co-op, puts the
information in context for consumers. It has also been shown in several consumer studies,4 most
recently by the FSA,5 to be both preferred and to perform best.
— Salt declared as well as sodium. Research, including our own,6 consistently shows that consumers
are confused about the relationship between salt and sodium. Provision of information on labels
about sodium is unhelpful since all health messages relate to salt.
— Flashes on front-of-pack show Calories, fat and salt per serving. Other retailers have introduced
this on their healthy eating ranges. The Co-op applies it across the Co-op Brand range.
— Guideline Daily Amounts (GDAs) for Calories, fat and salt for the average man or woman to put
nutrition information in context in line with IGD research.7
— Rounding of decimal points to facilitate calculation.
— “Eat More” roundel on front-of-pack to encourage consumption of certain categories of food;
starchy carbohydrates (bread, pasta and potatoes) and oily fish.
— “5-a-day” logo on front-of-pack to encourage consumption of fruit and vegetables. Although
using DoH criteria, the logo was developed by the Co-op to be more impactful and universally
applicable than that developed by DoH.
— Healthy Living range—a range of products which meet healthy living criteria, identified by special
logo and livery as a signpost to consumers seeking the healthy option.
In addition, we would like to implement other measures which our consumer research shows us improves
consumer understanding of nutrition information.8 Although we have trialled these on-pack, they
contravene current legal requirements, so had to be abandoned.
— Re-ordering of the nutrients to give priority to key, healthy eating information; Calories, fat,
saturates and salt.
— Putting salt not sodium content.
— Adding portions of fruit and vegetables.
— Abandoning Joules as a measure of energy to allow space for more useful information. Research
shows consumers do not understand Joules.9
— Omitting protein from all labels and declaring fibre only where relevant, so providing more space
to improve presentation and avoid confusion by overly complex information.
Our research and proposals are described in the attached booklet “The Lie of the Label II”10 [not printed].
On certain products we go further. In particular, on alcoholic drinks, where labelling is very prescriptive,
we go beyond the law, providing:
— Ingredient lists including information on processing aids on the advice of our Consumer Jury. This
is not mandatory on these products. The Co-op is the only brand to include this information.
— Sensible drinking guides, repeating the current DoH advice on sensible drinking.
2
Voluntary Nutrition Labelling Guidelines to Benefit the Consumer—Voluntary Nutrition Research Findings, IGD,
February 1988.
3 “Just Read the Label: Understanding nutrition information in numeric, verbal and graphical formats”. The Coronary
Prevention Group, Alison Black and Michael Rayner, 1992, London, HMSO.
4 “Just Read the Label: Understanding nutrition information in numeric, verbal and graphical formats”. The Coronary
Prevention Group, Alison Black and Michael Rayner, 1992, London, HMSO; The Consumers’ Association, The Ministry
of Agriculture, Fisheries and Food, National Consumer Council “Consumer Attitudes to and Understanding of Nutrition
Labelling”, British Market Research Bureau, 1985.
5 Nutrition Label Testing, Food Standards Agency, November 2003.
6 NOP Consumer Research conducted 1,061 face-to-face interviews with a representative sample of the UK population.
7 Voluntary Nutrition Labelling Guidelines to Benefit the Consumer—Voluntary Nutrition Research Findings, IGD,
February 1988.
10 Lie of the Label II, the Co-operative Group, August 2002.
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— Alcohol units; units per glass and number of glasses per bottle on spirits, units per bottle and
number of glasses per bottle on wines and units per can/bottle on beer, as agreed with our
Consumer Jury.
— Calories per standard glass/can/bottle as appropriate.
Safety of Foods
The safety of foods can be prejudiced if they are stored too long, at the wrong temperatures or cooked
inappropriately. It is a legal requirement to label foods with a “use by” date, if they are highly perishable,
or with a “best before” date where prolonged storage leads to deterioration of quality rather than microbial
deterioration. To guide consumers we include with the date mark, on all chilled food, the advice to keep the
product in a fridge at 2 to 5)C and for frozen foods, in a freezer at "18)C. This reminds consumers of the
recommended temperatures for fridges and freezers.
The majority of products carry cooking guidelines. In the case of meat and poultry, under a Food Safety
header, consumers are reminded of the need to cook the food thoroughly with an indication of how this can
be judged, accompanied by other statements on hygiene and handling, where space permits.
FOOD SAFETY
Ensure food is piping hot, an even colour throughout, and no pink
bits can be seen. Always wash work surfaces, cutting boards, utensils
and hands before and after preparing food.
Some consumers need special advice. To help consumers allergic to particular ingredients avoid foods
containing them, the Co-op not only labels all ingredients, but highlights the presence of nuts and eight other
most common, serious allergens (Eggs, Fish, Shellfish, Milk, Soya, Gluten, Sesame and Sulphites) as
follows:
ALLERGY ADVICE
Contains Peanuts, Fish, Milk
Because of the very serious risk of anaphylactic shock from traces of nuts or sesame seeds, where there is
the potential for cross contamination, the allergy advice also indicates that the product is made in a factory
handling nuts and/or sesame seeds.
The Co-op also uses labels to remind consumers of Government advice, for example, advice to pregnant
women about the risks from consuming raw milk cheeses or from excess vitamin A in liver, or from caVeine
in coVee, tea, chocolate, medicines and certain soft drinks.
In-store point of sale is used to highlight similar, key messages on chilled food safety, allergy advice and
risks from consumption of pâté, cheese and raw eggs.
The Means of Production of Foods
Like other retailers, the Co-op has a range of organic foods which are easily identified in-store by a
distinctive logo.
All eggs are labelled to indicate whether they are free-range or from caged hens. Indeed, it was the
Co-op who provoked the EU to introduce the term from caged hens to identify battery hens’ eggs by
labelling eggs intensively produced, despite this being illegal at the time. Eggs used in recipe products are
similarly labelled to indicate their source.
The Co-op supported the development of the RSPCA Freedom Food scheme to improve welfare standards
for animals at all stages of the food chain. We stock poultry, meat and eggs meeting the standards. These
can be distinguished by the Freedom Foods logo.
The little red tractor logo is carried on a majority of fresh meat and produce, indicating it has been grown
to Farm Assurance standards. Sadly, the logo is restricted to British produce, so although we require the
same standards from overseas suppliers, we cannot use the logo.
The Co-op recognises that consumers are concerned about the use of pesticides. It has introduced its own
code of practice, banning some pesticides and restricting others. Such produce is nevertheless conventionally
grown. To make this clear to consumers, packs carry the following message:
“Conventionally Grown—reducing, banning and controlling pesticide use”
The back of pack (where room permits) will carry the following explanation, under a Conventionally
Grown header:
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CONVENTIONALLY GROWN
Most produce, including that sold by the Co-op, is grown using
pesticides to help control crop damage. However, for Co-op Brand, we
ban some chemicals, control and reduce reliance on others and
encourage alternative methods.
For further
Department.
information,
contact
our
Customer
Relations
Genetic modification (GM) is a concern for many consumers who wish to avoid GM foods and
ingredients. For some, this extends to any product touched by the technology. The Co-op’s policy on GM
took a lead by committing to label foods produced using GM. We are the only retailer to label cheese when
it has been made with the enzyme chymosin produced by GM, making it suitable for vegetarians. Such
cheeses are clearly labelled:
“Made using genetic modification and so free from animal rennet”.
Similarly, we are endeavouring to respect consumers’ wishes by eliminating GM from the feed of food
producing animals; meat, fish, milk and eggs. Where we are successful, this is clearly stated on-pack with
reference to non-GM feed.
In the case of eggs we have also removed the colourant added to feed to enhance the colour of the yolk.
Both issues are communicated by the roundel shown on the packet.
The Co-op believes it is wrong for the majority of the world’s citizens to be condemned to a life of poverty
and firmly advocates the protection of human rights for workers in all countries. The two main ways of
tackling the issues are Ethical Trading (also known as sound sourcing) and Fair Trade. The two approaches
are complementary.
Ethical Trading is primarily aimed at ensuring basic human rights and a safe and decent working
environment for employees of supplying producers and manufacturers. The approach therefore covers the
vast majority of our suppliers and, as such, does not require special labelling.
Fairtrade seeks to guarantee a better deal for the world’s disadvantaged growers and small-scale
producers. Aimed primarily at marginalized independent growers and producers in the world’s poorest
countries, fairtrade ensures they receive payment that exceeds the market place norm and includes an
additional premium to support producer programmes.
The Co-op has pioneered the development of fairtrade in the supermarket sector, being the first retailer
to develop and launch an own brand fairtrade product. Our ultimate objective is to bring Fairtrade into the
mainstream. We have fairtrade products in more stores than any other retailer, improving consumer access.
A distinctive livery, together with the Co-op Fair Trade logo and the FAIRTRADE Mark, readily
identify products in the Co-op Brand range which meet the criteria of the Fairtrade Foundation.
We have also pledged to include Fairtrade ingredients in products wherever we can. In order to qualify
for the Fair Trade branding at least 20% of the total must comprise Fairtrade or Fairly Traded ingredients.
Such products carry the FAIRTRADE mark but not the Co-op Fair Trade logo. Each Fairtrade or Fairly
Traded ingredient is identified in the ingredient list. A line below will identify the percentage of Fairtrade
or Fairly Traded ingredients.
INGREDIENTS
(greatest first): Sugar, Fairtrade Cocoa Butter, Skimmed Milk
Powder, Milk Powder, Fairtrade Cocoa Mass, Crisped Rice (70%),
Butterfat, Emulsifier (Lecithins—Soya), Flavouring.
MILK CHOCOLATE CONTAINS COCOA SOLIDS 32%
MINIMUM AND MILK SOLIDS 27% MINIMUM
32% FAIRTRADE INGREDIENTS
Where there are some ingredients that are not Fairtrade or Fairly Traded, the amount is always repeated
under the product name, eg:
Fairtrade Cranberry Sauce
Contains 20% Fairtrade Sugar
Uniquely among supermarkets the Co-op has run a national TV campaign dedicated to the support of
fair trade, in addition to awareness building adverts in national press and magazines.
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Summary
The examples above provide a flavour of the way the Co-op uses labelling, in particular, to make
consumers better informed about the nutritional content of foods, how to handle and consume foods safely,
how foods have been produced and where good labour practices are used. Further examples are provided
in the attached leaflets [not printed] and can be found on our website; www.co-op.co.uk
19 April 2004
Witnesses: Mr David Croft, Head of Co-op Brand and Technical, and Mr Adrian Hill, Policy and Standards
Manger of Co-op Brand, examined.
Chairman: Welcome to the meeting of the SubCommittee on Food Information. My apologies for
keeping you waiting a little. Our first witnesses are
from the Co-op Group: David Croft, who is the
Head of Co-op Brand and Technical, and Adrian
Hill, the Policy and Standards Manager of the Coop brand. Welcome to the Committee and thank you
for sending your written evidence. We look forward
to your oral evidence this afternoon.
Q281 Mr Mitchell: The Co-op has always taken an
enlightened position on labelling and quality
improvement, and I say that despite not being a Coop MP; but when the Health Committee report
recommended voluntary action by the industry, the
Co-op expressed doubts as to whether voluntary
action would work. What could voluntary action by
the industry achieve, do you think?
Mr Croft: From my own perspective, voluntary
action has obviously allowed us to implement a
whole range of customer information, whether it is
related to nutrition labelling or supportive labelling
in terms of the nature of the products, the history of
the products and their pedigree. One of the
diYculties of voluntary labelling going forward,
particularly when you start to get into the complex
areas of nutrition, is the question of consistency and
whether that leads to more confusion for consumers
rather than the aim we all have of providing clear
information that they can readily understand.
Q282 Mr Mitchell: You mean consistency across the
industry?
Mr Croft: Yes.
Q283 Mr Mitchell: So we are all measuring from the
same stick, as it were. Is that not attainable?
Mr Croft: It is diYcult to see how it would be
attainable from a voluntary basis. Whilst we have
been supporting, on nutrition labelling in particular,
a number of steps over the past decade or so, we have
singularly failed to see widespread adoption of that.
It is reassuring that in the last few weeks we have
seen one of our competitors making similar steps
forward. As we look at the totality of nutrition
labelling, there are areas of inconsistency and areas
where guidance perhaps is not addressed in the same
way, so there are inconsistencies between the way the
guidance is interpreted and what the legislation
states. We think that there is definitely a need for a
degree of consistency and application of those things
in order to make certain that consumers receive clear
information that they can use to have a balanced
diet, or indeed in terms of any of the product areas
that we could talk about.
Q284 Mr Mitchell: You have been campaigning for
a “high, medium, low” system of marking, denoting
the nutritional quality of products, and you have
been arguing for that for a long time. What success
have you had in achieving it?
Mr Hill: “High, medium, low” is on every product
we can get a nutrition panel, which are the vast
majority. Research is ongoing. We have dipped into
it every now and then, and our market research
shows that consumers like that, in preference to pie
charts, bar charts or other graphical indications. It
is based on a sound scientific basis, although it
would be fair to say that our research shows that the
public are not necessarily bothered about the science
behind something, as long as it delivers what they
can use. Since we have been doing it, it has been well
received by the public and opinion formers, but we
are constrained by legislation at the moment.
Q285 Mr Mitchell: Has anybody else taken it up?
That is just your own customers and your own
products.
Mr Hill: Recently, there has been a high-profile
instance: Tesco have adopted that as well.
Mr Croft: Or will be at least taking a trial out later
on this year.
Q286 Mr Mitchell: What kind of areas would you
advocate legislation or compulsion on?
Mr Croft: There are areas where the legislation
currently creates some anomalies, for example if we
were to look at nutrition labelling. One of those is on
the nutrition declaration and the use of “sodium”
rather than “salt”. One of the things we have
researched and have been advocating for some time
is that consumers readily understand “salt” and are
actually told by GPs to regulate the amount of salt
in their diet; and yet the full nutrition panel requires
you to put “sodium” on, and less than about 25% of
consumers, when we researched it, know the
connection between salt and sodium. We think that
is the sort of area where legislation needs to be clear.
Another example is where we talk about claims,
typically claims on products that are 90% fat-free.
That still leaves, obviously, 10% of the product that
could be fat, which could be a very high amount of
fat. That is something that the Government
guidance already recognises as being inappropriate
and confusing, and yet it is still not enshrined in
legislation, to clarify it for the consumer. There are
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29 June 2004 Mr David Croft and Mr Adrian Hill
a number of anomalies like that where a greater
degree of consistency would be valuable for
consumers, in terms of getting the information that
makes the content of products much clearer for
them.
Q287 Chairman: Why do you think there has been,
as it would appear there has, such resistance from
the industry for the traYc-light type of system that
you have been operating for some time? You have
said in your evidence that you have been
campaigning since 1986 for that type of system to be
introduced, and yet it has not exactly been taken up
with alacrity by industry, so it would appear.
Mr Hill: Can we just clarify that? We do not operate
a traYc-light system, we use “high, medium, low”.
We have discussed and looked at traYc-light
systems, but we have not adopted them. We think
there is a diVerence.
Mr Croft: It is diYcult to comment on the
motivations of other parts of the industry, but from
our perspective, being consumer-owned, we have
endeavoured to look at the spirit of the legislation,
and trust that the spirit of the legislation was always
in protecting consumers or giving a stronger set of
advice for consumers. When we develop new
approaches, be it in terms of labelling or product
authentification, then we have done it with the
interests of the consumer at heart. We have done a
lot of lengthy research with consumers, which you
would expect any retailer to do, but we have also
hosted consumer juries to give clear advice on how
our policy might develop, and particularly in the
case of labelling, where there were some question
marks over the position a typical industry might take
and the position that we wish to take. We would
consult our consumer jury over the issue and see
what their perception of the whole issue was, and try
and bring it down to a practical level, so that at the
end of the day you have information that is
meaningful to people. That is what we thought the
spirit of the legislation was designed to generate.
Q288 Mr Mitchell: When it comes down to the cold
cash test, do you find that more information pays?
You say consumers like it, which presumably you
find out from surveys, but does it lead to an increase
in sales?
Mr Hill: It does not lead to a decrease.
Mr Croft: Most importantly, it exemplifies our
brand as a brand that you can trust. If we are
prepared to be open and honest about what we put
on our labels, far beyond what the legislation might
require or what the rest of industry might say, to me
it is about people being able to have trust in what the
Co-op does, and fundamentally that is where we
would position ourselves as being a consumerowned organisation.
Q289 Mr Jack: Mr Croft, can you refresh my
memory: what is the recommended average daily
intake of salt, and then sugar?
Mr Croft: Six grammes of salt. I will let you answer
the one for sugar!1
Mr Hill: Sugar, I am not too sure of.
Q290 Mr Jack: Right, so you two are in charge of
labelling and you are giving all this information to
the customers, but we have a 50% score on the
average daily intake. In your evidence to us, you
have flashes on page 2, on the front and the back,
showing calories, fat and salt. The reason I asked
that question was that I am interested to know how
consumers ought to be able to acquire a benchmark
to know how they are doing, in terms of their intake
of these substances. Do you contribute to educating
your customers in this respect?
Mr Croft: I think we do in a number of ways. As the
starting point, the roundel on the front of the pack
leads you to look in more detail at the information
that is there; so our “high, medium, low” will express
the amount of each nutrient, in terms of high,
medium, or low, on the back of the pack. Wherever
possible, where space allows on the pack, we also put
guideline daily amounts. With that information, you
can compare that product.
Q291 Mr Jack: On some of your pack products you
do have it! When we had the Consumers’
Association as a witness, they very kindly brought
along one of your packs of jam tarts, and it was
packed full of information as well as jam; but are you
saying that somewhere on your products there is an
average daily intake box as well?
Mr Croft: Not on all of them. We endeavour to do
as much as we can where space permits. I have an
example here. Unfortunately, this is one for sponge
cakes, but we have a lot of information that is legally
required in terms of the ingredients that are present.
For each of the diVerent cakes the nutrition
declaration is using our “high, medium, low”, but
because of the amount of information we have to put
on that, it is very diYcult to put the guideline daily
amounts on as well.
Q292 Mr Jack: You mentioned a moment ago your
customer panels and the work that you do to assess
how your customers use the “high, medium, low”.
How aware are the customers on the panel of the
simple question I asked at the beginning: what is the
recommended daily intake? If they are not, they do
not have anything to relate all this information to,
do they?
Mr Croft: No, and that is where I think “high,
medium, low” starts to give them clearer guidance. I
suspect that until very recently not that many people
knew about the amount of salt that was in food,
whether added salt or salt that was naturally
occurring. There has been much debate about
whether the limit should be set at six or whether it
should be diVerent from that. There is a growing
awareness amongst consumers about what a healthy
diet should comprise of, but whether they know
specifically what individual nutrition criteria they
have to achieve is still debatable. That is where clear
1
There is no oYcially agreed recommended guideline daily
amount for sugar.
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signposting is probably most important, to try and
give an indication of the overall trend within a
product or series of products, as to being high,
medium or low in certain criteria.
Q293 Mr Jack: Whose role is, do you think, to make
certain that consumers know what the benchmark is
on these daily intakes?
Mr Croft: It is a combination of people’s roles. We
have a role to play, and that is where labelling comes
into it. That is why things like “high, medium, low”
and guideline daily amounts are very important.
However, clearly there is also a role in terms of
broader education—and whether that is through the
health service, or through standard education
practice, is diYcult to say. We have worked closely
with community nutritionists in various parts of the
country to try and generate wider awareness of what
a healthy diet means, so that people can actively
select products to support that with a bit more
understanding. The label on its own is one part of
that equation, but it does still need a broader
awareness of what constitutes a healthy diet.
Q294 Mr Jack: In terms of the categories that you
sell, how do you decide within a category what gets
the “high, medium, low” indicators?
Mr Hill: Where possible and where space permits,
we try and get the full nutrition panel on all
products. Clearly, a salmon paste and a ready meal
or a pizza, are two diVerent sizes of labels; so we do
not diVerentiate category to category. We try and
get a full nutrition label on every product we can.
Q295 Mr Jack: How do you deal with a product like
cheese, which may have quite a lot of salt in it but
some good calcium, and some people will say it is
potentially dangerous and others will say it is an
absolute “must have” in the diet? How does your
system deal with cheese?
Mr Hill: The labels for cheese generally preclude
having a nutrition panel; so where possible we put
linear nutrition.
Q296 Mr Jack: In other words, you are saying that
the European Union labelling requirements do not
allow you to do what you want to do on that.
Mr Hill: No; it is just that the label physically is not
big enough to accommodate a legal nutrition panel.
If that was cut down, which is something we have
been campaigning for, then possibly the space may
be there. In that case, we would revert to linear
nutrition, which gives it in a line.
Q297 Mr Jack: What about shelf markers; do you
use those to substitute the labelling or to make up for
the fact that you cannot put it on the product, but
the customer might like the information?
Mr Croft: We do not at the moment. It is something
we are going to trial later on this year as a means of
providing more information on the front of the
pack, on the front selling face of the product. At the
moment, we do have a roundel, and we are looking
at how we can expand that, but we feel there is an
opportunity to look at shelf-edge labelling as
another way of providing more information.
Q298 Mr Jack: I ask because if you go across the
catalogue of foods, we have a very detailed amount
of information on certain packaged items, and the
nearer we move away to the naturally occurring
item, the less of the information we have just been
talking about is available. How, given that there is
not a uniformity of information, does the consumer
make up their mind, if they are doing a one-stop
shop at the Co-op, that they are buying balance in
their diet?
Mr Croft: In terms of loose products, things such as
bread from an in-store bakery, or products from a
delicatessen, then we also provide a manual of
information that is available on display so that
people can look at the product. It gives the full
nutrition breakdown, in the same way as you would
see it on a pre-packed product. It is just a manual
that is available next to the display stand so that
people can select from that and have a reasonable
understanding of what those products are as well.
Q299 Mr Jack: Is there a danger that the “high,
medium, low” approach ignores some of the
complexities, for example, of micronutrient
arguments, because some of those things can be
absolutely vital to some people’s health and wellbeing, and making judgment calls, for example, on
vitamins, as to whether people are getting the
required dosage of those, is quite diYcult to find out.
How do you resolve what could be an apparent
paradox in a very important area in enabling people
to decide in total whether they are giving themselves
what we all might like to call a “healthy” diet?
Mr Croft: You have to be wary about
micronutrients, particularly the addition of
vitamins. From our perspective, we make it clear
about the presence of added vitamins, but the “high,
medium, low” also looks at the broader nutrition.
What we would be wary of are situations whereby
products are perhaps marketed on the basis of
having added vitamins, and yet still are very high in
fat, for example, or sugar, as is the case for certain
chocolate spreads for example. We are certainly not
against added nutrients and particularly added
vitamins, but it is important to look at the overall
product context and make certain that by suggesting
that something has added vitamins it is
automatically more healthy for you. It might be
more healthy for you than the direct comparison,
but in the case of a chocolate spread there is still a lot
of fat and sugar in there, and to eat it every day,
almost regardless of the amount of extra vitamins it
gives you, might still not be very good for a
balanced diet.
Q300 Mr Jack: You mentioned your consumer
panel, and it is clear that you listen to your
customers a lot. What evidence, since you went into
“high, medium, low”, have you found that people
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have altered their purchasing behaviour to take into
account the additional information that you are
making available?
Mr Croft: As I said before, “high, medium, low” is
part of a broad section of information in terms of
healthier diet options and giving people more
information about their diet. We have seen a quite
considerable increase in fresh fruit and vegetable
sales quite considerably over the last few years. That
partly reflects a change in the style of our stores, but
it also reflects the fact that consumers are more
aware of what they are consuming and want to have
more fresh fruit and vegetables within their diet.
Q301 Mr Jack: Given that the spend on food
remains slightly declining, if anything, as a
proportion of income, is there a corollary that you
have noticed that other areas, perhaps “less
obviously healthy parts” of the shopping basket are
going down? Are they buying more fruit and
vegetables to compensate that they are having a
whizzo time on other things, but they think they had
better have a bit of fruit and veg as well because
people are saying that is good?
Mr Croft: I could not say. There is certainly a
broader awareness of what a healthy diet
constitutes. I think that probably accounts for some
of the increases in sales of healthier products, or
perhaps lower fat alternatives of standard products;
but it is true to say that consumers still like a bar of
chocolate every now and again.
Q302 Mr Mitchell: You also provide advice on
allergy and food intolerance stuV on the labels. To
what extent does the information you provide there
on allergens go beyond what you need to do legally?
Mr Hill: For many years we have split out the
allergens that we have thought were the top six or
seven, which have now been almost adopted by the
EC—for example peanuts and cow’s milk, fish, soya.
We have split those out into a separate clear box,
always associated with the ingredients panel
underneath it.
Q303 Mr Mitchell: By providing more detail then,
you have gone beyond the law.
Mr Hill: We have just picked out when the allergens
are present in the food. There is a clear header
“allergy advice” and then we say whether it contains
fish or shellfish or cow’s milk or what-have-you. It is
a shortcut for people who have concerns about
allergens, to look there rather than having to look
through the full ingredients panel.
Q304 Mr Mitchell: You identify trans-fatty acids on
some types of food labels. You had better tell me
what they are first of all, because I am not quite sure.
What are they, and if they are dangerous why do you
not identify them on all food labels?
Mr Hill: It was some time ago that there was a
widespread concern about trans-fatty acids in the
diet.
Q305 Mr Mitchell: What are they?
Mr Hill: It is a type of vegetable oil—a type of fatty
acid, a bit like saturated fat or mono-unsaturated
fat. They are just one particular type. The chemistry
is beyond me, but there was concern about them in
that they contributed to some heart diseases. We
researched it and found that certain products were
prone to have high levels of trans-fatty acids, so in
certain products such as digestive biscuits and
similar things we picked that out and highlighted
whether those were contained in high amounts or
not.
Q306 Mr Mitchell: It tells you here, “on fats, biscuits
and meat products”, so it is just specific products?
Mr Hill: Those were the only ones that we identified
would readily have a large amount of it in, purely
because of the fats they used in their industrial
processing.
Mr Croft: Part of the issue there is whether we can
then re-formulate it to avoid that type of fat in the
product, which is something that we are looking at
now. The other point that I should add about
allergies is that we also provide information for
consumers who may be concerned about the
potential food intolerance eVects of things like
artificial colours. We highlight where those colours
are used, and indicate again, as Adrian said before,
that they may be associated with food intolerance—
colours like Tartrazine, for example, which are
perfectly legal to use, and yet there is a growing body
of concern that they may be associated with some
form of food intolerance.
Q307 Mr Mitchell: You also provide information in
Braille on some products. How widespread is that?
Mr Hill: Currently, we have got that on 350
products. The example that was given had Braille
on, and I have another couple of products with
Braille on. Admittedly, it is fairly basic because of
the space constraints. We give the name and, where
possible, the cooking instructions. We have found
that most blind people tend to shop with a sighted
shopper. It is in the house that they have issues in
telling one product from another; so we indicate the
name and possibly cooking guidelines.
Q308 Mr Mitchell: That is 350 out of how many?
Mr Hill: We have 4,500 at the moment. We started
oV—every journey starts with a single step! We
started oV with all medicines, for I would hope
obvious reasons, and we are now looking to get it on
as many products as possible. It is put into the design
brief wherever possible. Constraints are that
sometimes the print process does not allow it, and
the substrates, the varnishes and that sort of thing,
do mean that we cannot get Braille on, but where
possible we do. It is an increasing number.
Mr Mitchell: How long has the Co-op been this
virtuous? I cannot remember that it was that
concerned—or indeed anybody was—when I
worked at the Co-op biscuit factory in Crumpsall in
Manchester. That, mark you, was a long time ago.
Mr Jack: The quality of biscuits has definitely
improved since then!
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Q309 Mr Mitchell: I was very unskilled labour! At
what point did you begin this process of provision of
full information? Was that in a public-spirited way,
or did you consider that virtue would pay?
Mr Croft: The Co-op movement was obviously
founded in the interests of consumers. How we are
looking at products now is very much about
bringing co-operative values and principles into how
we look at our product formulation. The
information that we provide about being open and
honest fully delivers two of the key Co-op values.
What we are doing in terms of our product
development and information provision to
consumers, in terms of how we source products,
through for example initiatives such as Fair Trade,
is delivering what increasingly consumers are
turning to us and saying that is what they expect
large organisations, be it retailers or manufacturers,
to deliver as part of the broader social responsibility
they expect from large organisations. Ever
increasingly, the research we do tells us that people
want to see more of that sort of activity from large
organisations. It certainly fits with our
organisational values, and if it delivers a commercial
benefit to us by demonstrating the trustworthiness of
the co-operative brand, that is not something we are
going to shy away from either.
Q310 Mr Mitchell: Over how long a period?
Mr Croft: The labelling policy has really been
developed with most strength over the last 20 years
or so, which reflects the increased consumer
awareness of all matters relating to food, and indeed
supermarket activity, which has probably
culminated in the last five to ten years in a lot of close
scrutiny of how major organisations in the food
industry operate.
Q311 Mr Jack: What does your questioning of
consumers tell you about which source of
information on food consumers put their most trust
in? Who do they believe?
Mr Croft: They have limited trust in a number of
people. Some of the research that we have done
suggested that on certain issues government advice
was preferred, and in certain issues government
advice was not considered in the same way. That
reflects the way that some of the food scares over the
early and mid-nineties were handled, both by
industry and regulators. Consumer groups are
usually seen in a very positive light because with a
consumer perspective they clearly have no axe to
grind that is commercially driven. They do see
information from major organisations as something
to be questioned in the first instance, until they can
be confident that it is stated with the right sentiment.
Q312 Mr Jack: It would be very helpful to us if you
could develop that point. There are lot of people in
the food information business. Some, like the Food
Standards Agency, try to be even-handed, balanced,
very careful and very scientific. There are others that
come from a biased point of view, in whatever views
they put across. There is an ocean of information out
there. I am personally interested to know what it is
that triggers a reaction from the public. You have
given us some indication of that. You did not
mention the newspapers as a source of information,
but when they carry stories that eVectively say there
is another food scare, do those show up fairly
quickly in what happens on the sales floor, or are
they generally ignored?
Mr Croft: I think it depends on the nature of the
issue. Generally speaking, media coverage of food
scares leads to a relatively quick reaction from
consumers, in terms of changes in their purchasing
patterns. We certainly saw that with issues such as
BSE. Conversely, however, media coverage in terms
of healthier diets has a slower build, although
everybody in the food industry is seeing a rise in
interest in low-carbohydrate diets; and that is driven
by media coverage of, for example, the Atkins Diet.
My personal opinion is that it takes a little bit longer
for those positive indicators to be picked up by
consumers, but a food scare has an immediate
reaction, and I think that is because it is more
emotive as far as members of the public are
concerned, and it is understandable that they would
react to it fairly quickly.
Q313 Chairman: You said that you felt consumers
wanted more information about the products that
they were buying and consuming, but at the same
time you pointed out that there is a need to simplify
the information on packaging. How do you
reconcile these two tensions, on the one hand a
requirement to have more information and on the
other hand a requirement to try and keep it as simple
as possible? Has there not got to be a choice made
about what are the priorities for the information that
is provided?
Mr Croft: Increasingly, I think there has to be a
choice that prioritises the information. From the
work that we did about three years ago now on
labelling, within which we suggested an alternative
nutrition panel, which helped to prioritise the order
of the nutrients, for example, and the way the
information was portrayed, it was clear to us that
consumers were seeing a lot of information and not
necessarily taking as much out of it as we had hoped.
I am certain that the legislators who generated the
need for that nutrition format would have felt that
as well. There is an argument, which needs further
debate, that suggests the amount of information on
packs does start to become meaningless to
consumers in certain areas. We tried to address that
and begin that debate in our campaign some two
years ago now.
Q314 Chairman: How clear is it to you, as a retailer,
are the messages coming from Government about
the type of food information they would expect you
to provide in food information?
Mr Croft: It is fair to say that we do from time to
time see conflicting indicators. On the one hand,
there are messages about what healthy eating should
include, or what diet considerations people should
take from the Department of Health; and yet from
the regulatory point of view those issues might be
contrary to the current legislation. For example,
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some time ago we were in discussion over the
inclusion of folic acid, and there was a clear
indication from the Department of Health that folic
acid was a dietary supplement that people should
support; and yet putting information about it on
pack was fraught with diYculties because it could be
construed as a health claim. We are not advocating a
free-for-all in terms of health claims associated with
food products, but there seems to be a need for
consideration of the diVerent messages that diVerent
arms of government might suggest in relation to
food.
Q315 Mr Jack: Who decides the boundaries
between low, medium and high?
Mr Hill: They are based on the contribution of each
nutrient towards the overall energy in the product—
the calories in the actual product itself. They are
based on the Coronary Prevention Group bandings
of what consists of a balanced diet. For instance,
they said that 33% of the diet should be fat, so the
band fat to be medium is 49.5% down to about 15%,
and that would be medium. Anything under that
would be low, and anything above 49.5% would be
high. That is the fat contribution towards the
calories of the product, rather than as an absolute.
Mr Croft: That was the process we developed with
the Coronary Prevention Group, as a means of
involving their expertise in how these nutritional
signpostings should be developed. It is fair to say
that in the light of the Select Committee on Health,
more scrutiny is being given as to how the
signposting should work. We recognise in certain
products, particularly where the energy level is very
low, that even our system has some issues that we
need to address. We think there is scope for further
discussion and development on that front now.
Q316 Mr Jack: I suppose, if you really were a
glutton, you could get yourself into the danger zone
if you consumed too many things that might get on
the low scale of something, in a theoretical sense.
Mr Croft: I would not have thought so, if it were
all low.
Mr Hill: But for medium and high you might.
Mr Croft: If you are always eating medium and
high—well, we would always advocate a balanced
diet, which balances some products with high and
some with medium and low, obviously.
Q317 Chairman: Can I ask you about the willingness
of consumers to carry out in their purchasing
patterns the conclusion that we should draw from
the information that is provided. You said in your
research that up to 84% of consumers were prepared
to pay more for products of higher ethical standards.
Have you evidence from your own sales that
customers are indeed prepared to pay a little extra
for higher ethical standards?
Mr Croft: Very much so. At that level the definition
of an ethical product can be quite broad, but if, for
example, we were to look at Fair Trade, what we
have seen on Fair Trade products is a growth in sales
as people compare our own Fair Trade products like
coVee, for example, with major brands; and they
recognise a degree of additional value that the Fair
Trade accreditation brings. Of course, those
products remain competitively priced with the
brands, and we have seen sales growth in all areas
where we have introduced a Fair Trade product, as
consumers move towards those ranges.
Q318 Chairman: Is that a substantial increase?
Mr Croft: For example, in the case of chocolate—if
I can mention chocolate whilst we have been talking
about nutrition characteristics—we have seen an
increase such that in certain product areas, our dark
chocolate for example outsells the major brand. This
is a very competitive product category and there is a
lot of advertising spend from major brands in terms
of things like coVee and chocolate; and we are seeing
more consumers buying in to Fair Trade because
they perceive a strong value with it.
Chairman: Thank you very much indeed for your
evidence this afternoon, which has been extremely
helpful.
Q319 Mr Jack: Your Fair Trade chocolate cake is
seriously dangerous because it is rather good, and I
am always tempted to buy another one, I am afraid!
Mr Croft: Much as I would like to, I cannot
advocate eating it at every meal!
Q320 Chairman: If you want to write with any
additional information to the Committee to expand
upon your evidence this afternoon, please feel free to
do so, but do not feel under any compulsion to
provide any more information. Thank you very
much for your evidence this afternoon.
Mr Croft: I will certainly trace the research that we
had in terms of consumer trust in diVerent bodies.
Supplementary memorandum submitted by the Co-operative Group
Following the evidence session on Tuesday 29 June, the Cooperative Group would like to submit the
following, supplementary evidence.
Voluntary versus Mandatory Nutrition Information
The Co-op would like to reiterate its support for mandatory nutrition labelling. With minor exceptions,
the provision of nutrition labelling has to date been voluntary. For those providing this information
voluntarily, there has been the option to choose either a short (three nutrients and energy) or a long (seven
nutrients and energy) format. Although uptake amongst UK brands is high, there are exceptions and many
imported brands fail to provide nutrition information. Secondly, many brands choose to give only the short
format, denying consumers information on those nutrients at the heart of health messages; saturated fats,
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sugars and sodium, the legally prescribed way for providing an indication of salt. Our research shows that
those brands which choose to give only this limited information are those which are high in sugars, fats and
salts where such information would be of particular interest to consumers. Only if nutrition information
were made mandatory could consumers be guaranteed the information to make comparisons across all
products.
Preferred Format
Reducing the number of nutrients and selecting only the most useful to consumers is important. Too much
information only confuses and complicates their task. It is also more diYcult to display the information in
a clear and accessible way on packs, especially small or awkwardly shaped packs where there is competition
for space from other important and legally required information such as Use By dates and ingredient lists.
Our research would suggest that the following would be optimum to meet the needs of the majority of
consumers whilst supporting the Government’s key messages.
Typical Values
Calories
Per Pack
(57g)
Per 100g
140 kcal
245 kcal
Fat
(of which saturates)
11g
5g
19g
9g
High
High
Salt
0.6g
1g
High
1g
Trace
2g
Trace
Low
Low
1 Portion
2 Portions
Carbohydrate
(of which sugars)
Fruit and Vegetables
Signposting
We would like to express our support for Government-led standards for signposting of foods. We
disagree with industry colleagues who believe this can be agreed voluntarily by industry bodies. Whilst
industry has a lot of experience to bring to the table, we believe an impartial arbiter is needed to facilitate
the negotiations. We are therefore pleased to see that the FSA board has agreed to the FSA’s action plan
on food promotion and children’s diets which includes a commitment to publish best practice advice on
signposting and guidance on “high”, “medium” and “low” nutrition labelling with a target date of June
2005.
The Role of Labelling in Healthy Eating
Labelling alone cannot educate consumers but it can provide a very useful tool to support educational
campaigns. To be able to do so there needs to be clear and consistent messages from Government which
need to reflect what is legally permitted on labels. We have a classic dilemma at the moment where the
Government tells consumers to eat less salt but all that consumers see on labels is the sodium content—
because that is the legally prescribed nutrient.
There is a need for a “joined-up” approach by the Government and its Agencies, to provide simple,
consistent messages about food (perhaps limited to three key statements—Less Salt, Less Fat, five a day),
and to include these in a larger public health strategy, which includes health education in schools, sports in
schools, exercise for the population as a whole, etc.
Guideline Daily Amounts (GDAs)
The Committee asked us about Guideline Daily Amounts for salt and sugars. Our witnesses were unable
to provide a figure for sugars. The reason is quite simply that no “oYcial” GDA has been agreed for sugars.
At the present time oYcially agreed GDAs cover Calories, fat, saturated fat and salt. If the GDA approach
were to be adopted as the way ahead, it would be necessary to agree additional GDAs.
21 July 2004
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Memorandum submitted by ASDA Stores Ltd
1. Who We Are
1.1 We operate 265 stores in England, Scotland and Wales and have 22 distribution depots. We are proud
to serve over 11 million customers each week.
1.2 Our mission is to be Britain’s best value retailer exceeding customer’s needs with a key purpose of
making goods and services more aVordable for everyone. We are able to achieve this objective by operating
from an Every Day Low Price and Every Day Low Cost strategy.
1.3 ASDA has repeatedly been shown to be Britain’s “best value supermarket” by industry journal the
Grocer. ASDA has reduced its average full basket price from £38.57 to £36.45 this year.
1.4 This year AC Neilson’s consumer panel (7,133 households) voted ASDA as Britain’s best value
supermarket for the third year running as well as top supermarket for service to its customers.
1.5 ASDA has ranked in the top three in the Financial Times “Best Workplaces Survey” in 2003 and
2004. In 2002, ASDA was presented with the Castle Award. The judges praised: “. . . the progressive culture
relating to rethinking the nature and structure of management jobs for women.” We pride ourselves on our
people friendly working policies.
1.6 Our customers those defining themselves as ASDA main shoppers—have also rated us as best for:
— Supporting healthy eating through own brand ranges of brand food and drink.
— Promoting healthy eating through store activities and events.
— Clearly communicating the nutritional content of own brand products.
This information has been drawn from a monthly tracker survey—independently conducted of 900
shoppers—450 of whom are main ASDA shoppers
2. Overview
2.1 Own label retailers have been very active over the years in promoting diet and health information
enabling choice for their customers.
2.2 There needs to be very careful analysis of the diet and health needs of our society and what they
priorities for communication are. Is the priority salt and hypertension, fat consumption and obesity, sugar
consumption and children’s teeth, fibre consumption and reduction of cancer?
2.3 Solutions must be customer-centered—they must help consumers to make well-informed choices
about their own diet and health. This is particularly important for parents.
2.4 We believe that a plethora of priorities and approaches can only add to customer confusion.
3. On-Pack Labelling
3.1 Customers have relatively little time in practice to make product selections at the shelf edge (research
has shown an average of 14 seconds in the case of sausages to consider all aspects of selection including brand
variety, size, price and quality). It is therefore clear that any information we provide on nutrition and health
must be both simple and readily available to the consumer.
3.2 It is ASDA policy to declare the “full 8” nutrition information in the form of a table wherever space
permits, with information per 100g and per serving. An additional highlighted box provides fat, calories and
salt values per serving—this has been on packs for over five years.
3.3 We provide GDAs (Guideline Daily Amounts for energy intake) on selected packs, on our website
and in literature for calories, fat, saturated fat and salt.
3.5 ASDA “Good for you!”, our healthy eating brand and our latest brand to be re-launched, carries
front of pack messaging showing “at a glance” values for calories, fat and saturated fat per serving also the
% fat content. These have proved very popular with customers and we are looking at whether we should
roll out this approach to other ASDA packs.
3.6 We also communicate health messages on the front of pack through a range of icons such as low fat
(for naturally low fat foods) and high in vitamin C. We are assessing the consumer demand for health
improvement icons for example, “now 10% less fat”, or “20% less salt”. This supports our extensive Food
Pledge programme to reduce fat, salt and sugar in our foods.
3.8 The ASDA Food Pledge programme started in 1998 with a focus purely on salt. In 2002, we increased
the focus to reducing fat, sugar, additives and allergens. In May 2004 we launched a new fat, salt and sugar
policy with maximum values and lower target values for all ASDA brand product categories. Priorities for
delivery in early 2005 include sandwiches, soups, all products in our “Smart Price” value and “Good for
you!” healthy brand ranges plus any planned category re-launches.
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3.9 We believe that reductions in the levels of fat, sugar and salt will only be a success if:
— they are gradual so that they are accepted by consumers as their palates change; and
— the food industry moves together. The retail industry, a number of key manufacturers and food
service operations are making large scale product changes. We question whether smaller
manufacturers, independent restaurants and local “take-away” shops are adapting their recipes in
a similar manner.
3.10 Asda was the first retailer to work with the Department of Health and to introduce their five-a-day
logo on our fruit and vegetable packs. We are currently rolling out the logo to more areas (initially frozen
and some fresh fruit and vegetables). We also worked with the DOH to trial shelf edge labels in our stores
with their branding.
3.11 We have for a number of years sought to avoid the presence of unnecessary allergens in our ownlabel products. We have highlighted for our customers the presence of these key allergens—wheat, gluten,
shellfish, nuts, milk, Soya—by means of a separate “contains” box. We are extending this to include the
latest revision to the food labelling directive by including thirteen major serious allergens on pack.
3.12 In addition to allergen declaration in ingredients listings, all own-label packaging will carry an
“allergy advice” box for additional emphasis. During the transition period to extending the list of allergens,
we will indicate in the allergy advice box the number of major serious allergens the product has been
assessed for.
3.13 To optimize consistency for UK consumers we were also the first retailer to use the Coeliac UK
Gluten-free symbol on relevant ASDA brand foods and it is now widely used on our packs.
3.14 We have a stringent auditing policy to ensure that any “free-from” claims on packs are correct. We
do not want “may contain” or equivalent labelling on more products than necessary because this limits the
choice for allergy suVers but at the same time we are, of course, acutely aware that customer safety must be
our absolute priority.
4. Other ASDA Nutrition Information
4.1 We have provided customers with supporting nutrition advice and information for many years and
some elements are described in this section. Here are our main initiatives.
4.2 Our “Big” school curriculum education programme, which is now in its seventh year and its fourth
year focusing on health. The Big Healthy Eat 2004–06 will focus on healthy eating especially five-a-day and
will reach one million school children through in store walking trails, educational visits to our stores,
teachers notes, parents notes to support the health messages for children and a dedicated ASDA web micro
site. Healthy Eating is the topic most popular with our stores, due to school demand for materials—this
shows the real need for a greater formalised school curriculum health, nutrition and cooking programme.
4.3 We have a range of ASDA healthy eating leaflets (Healthy Living, Diabetes, five-a-day and Allergies
and Intolerances). These are displayed in stores and requested by nurses, dieticians, GP surgeries and
schools for wide scale education.
4.4 ASDA “Healthy Living for Everyone” website, provides:
— fact sheets on topics including fat, salt and sugar, diabetes, heart disease, five-a-day;
— diets for children, healthy eating, allergies and more, with many additions planned;
— diet plans especially “Good for you!” and “Smart Price” (healthy eating on a budget);
— store tour guides for use by the public and health professionals; we have a database of around 200
health professionals working with us locally and are rapidly expanding this;
— 30 new monthly healthy recipes with fat and calorie values;
— hyper link to NHS Direct and links to/ information from health related charities; and
— an ASDA Health Exhibition Stand taken out to events for health professionals and the general
public,
4.5 Articles in ASDA Magazine and other magazines on ASDA’s health activity, our healthy ranges
especially “Good for you!” and articles in health professionals’ publications including NHS directories.
4.6 ASDA Pharmacy health checks in store supported with basic health advice including blood pressure
and diabetes testing.
4.7 We have nutrition education incorporated into our store colleague training programme, so that by
end 2005, 50,000 colleagues will have basic nutrition and allergy knowledge.
4.8 We are investigating other health promotion and education opportunities to be launched in 2005.
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5. Future Labelling Formats
5.1 We believe there must be common criteria for any potential energy density, traYc light or high/
medium/ low labelling approach. Stakeholders need to act quickly and work together to develop them before
various labelling regimes and criteria are in place, potentially causing even greater confusion to the
customer. Otherwise the same product could be rated red/high in one store or for one brand but amber/
medium in another.
5.2 Any labelling proposal must be properly researched both from an expert nutritional and consumer
perspective so that it does not have negative impact on the UK nutrient intake, especially from main food
groups such as meat, dairy and fruit and vegetables. Labelling dried fruit as being high sugar and cheese as
being high fat, calorie, saturated fat and salt (just for two examples) would not be in consumers’ interest
because of five-a-day or calcium intakes. Twenty per cent of children do not eat fruit during the week (source:
Department of Health survey) and one in 12 women have osteoporosis.
5.3 Labelling must take into account the diVerent nutritional needs of groups within our society, for
example children, older people, pregnant women. We believe it is important to have agreement on what
labelling information is also applicable for children’s products for example.
5.4 The Department of Health must work closely with our sector in determining the five-a-day criteria
for composite products to support the overall objective of increasing awareness of what counts as a “fivea-day serving”. These must be relevant for all consumers not just those who are already “healthy eaters”.
6. Legal Constraints
6.1 We are faced with a number of labelling and product development constraints which restrict our
ability to provide information and choice for our customers.
6.2 We cannot legally provide a salt value where space prevents sodium values being declared in the
nutritional table. Given the national focus on salt (which is much more widely understood than sodium) we
need to be able to provide these values.
6.3 Regulations dictate or determine minimum fat contents for traditional cheeses, cream, evaporated
milk, butter, spreads and chocolate. We are legally prevented from reducing the fat content by 10%!
6.4 Regulations also prevent a simple 10% sugar reduction in standard jams and marmalade. We can
make 25% less fat/sugar versions but these are diVerent, additional products with altered qualities and
sometimes prices. Reduced sugar jam, for example, will always cost more to produce because as the sugar
content goes down the fruit content goes up and not all consumers are able or willing to pay the higher prices.
6.5 EU rules currently prevent the making of any claim that a food is capable of treating, curing or
preventing any disease on medical condition. This coupled with incidents of unreasonable enforcement
make it more diYcult for retailer to support key Government campaigns. An example would be the potential
illegality of promoting the Department of Health’s message that eating five-a-day can help to reduce the risk
of cancer and heart disease initiatives.
6.6 Only use of adult RDAs for vitamins and minerals is permitted on pack by EU requirements. Adult
RDAs are not relevant to children but are the only legally permitted measure for indicating the % of the
daily vitamin or mineral requirement a serving of a food or drink provides. 20mg of Vitamin C is a third of
the adult RDA but actually two thirds of the Reference Nutrient Intake (RNI) for 7–10 year olds. So a pack
can only declare that the product contains one-third of the child’s requirement when actually it is two-thirds
the daily requirement. This labelling could lead to the over-consumption of certain vitamins and shows the
inflexibility if the current regime.
6.7 We are concerned at EU nutrition and health claims proposals that might remove our ability to
use healthy brand range descriptors, such as “Good for You!” which is our primary means of enabling
customers to identify and choose healthy options in their weekly shop. We are also concerned that having
a closed list of potential claims will be too inflexible to meet changing customer needs for example low calorie
claims are excluded.
7. Country of Origin
7.1 Our policy is to label country of origin, production and packing.
7.2 Whilst there is no legal requirement to declare country of origin on processed foods (as opposed to
meat, fruit and vegetables) to enable customer choice we have always done so. This used to be on the basis
of where the final product was produced but now reflects also the origin of key value ingredients where this
might diVer.
7.3 In providing country of origin information, we need to be careful that this does not increase
packaging costs where origin of ingredients may change at short notice.
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8. The Means of Production of Food
8.1 Methods of production messages are diYcult to distil into easy to understand customer
communication.
8.2 Organic—There are over 10 organic certification bodies, several of which have diVering production
requirements (over the base UK legal minimum) yet the products are all sold as organic. Each certification
body has its own on-pack logo—again, potentially adding to customer confusion.
8.3 “Organic” is the clearest message at present oVered to customers. “Free range” is a term widely used
and some groups, particularly Compassion in World Farming, actively encourage consumers to purchase
free range products.
8.4 Free Range—Only poultry has defined standards for free range production (and there are two
standards; free range and traditional free range related to the age of the birds).
8.5 There is no definition of free range beef and lamb yet consumers are being exalted to buy these
products. We would be happy to stock them if we knew what they were—we are criticised for not stocking
a product that doesn’t exist!
8.6 Little Red Tractor—The Little Red Tractor has been widely supported by British retailing but there
appears to be some customer confusion about what the mark actually means. This is not helped by the fact
that it does not apply to all production, for example, the pig industry has a Quality Standard mark and the
egg sector uses the red lion—not a single coherent message.
9. Food Safety
9.1 Assisting customers to store and prepare food safely is a key priority.
9.2 All packs carry “use by” or “best before” and appropriate storage instructions. Products also carry
cooking instruction and these are carefully checked.
9.3 Products also carry voluntary storage and use instructions for after purchase for example “eat within
three days of opening”.
9.4 Instructions are also given on outdoor and barbeque products to assist the customer to store and
cook safely.
9.5 Key messages of the meaning on date codes appear in leaflets on our in-house magazine on a
regular basis.
9.6 All packs carry supplier identification and traceability information for internal control purposes. This
allows us to respond quickly when customer concerns are raised or we identify issues regarding a
particular product.
10.1 We have been a member of the Ethical Trading Initiative (ETI) since 1998 and we have a strong
relationship with them.
10.2 We have adopted ETI Base Code in its entirety, stating suppliers must not use child labour, forced
labour and discrimination.
10.3 Our code is enforced through third party audits. Our audit programme for this year focuses on high
risk suppliers by country and by product.
10.4 We are a member of tripartite working groups which includes retailers, NGOs and trade unions,
designed to address gangmasters in the UK, health and safety issues in China, home workers around the
world and smallholders.
25 June 2004
Witnesses: Mr David North, CSR and Government AVairs Director, Ms Liz Kynoch, Technical and Trading
Law Director, Tesco, and Ms Penny Coates, Brand Manager, Asda, examined.
Q321 Chairman: Good afternoon. Welcome to the
Committee. We have as witnesses Mr David North
and Ms Liz Kynoch from Tesco, and Ms Penny
Coates from Asda. Thank you for the written
evidence provided to us earlier by Asda. We look
forward to hearing what you have to say to us in
answer to our questions. I will begin with a question
that is addressed to both Tesco and Asda. Tesco, in
its evidence to the Health Committee of the House
of Commons a few months ago said that consumers
were uncertain about whom to trust. They felt they
lacked knowledge on food safety and nutrition and
were not confident about who to turn to for reliable
information and advice. Where do you think the
most suitable means of providing information
should be placed? Who do you think should take the
lead in providing information to consumers of that
type?
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29 June 2004 Mr David North, Ms Liz Kynoch and Ms Penny Coates
Mr North: Our view is, rather as the representatives
from the Co-op said, that responsibility or the role
of providing information rests with a number of
diVerent organisations or sectors. What our
customers tell us, again as the Co-op is saying, is that
they trust diVerent sources on diVerent pieces of
information. On specific information, for example,
they might trust brands like Tesco; on food safety
messages, they are increasingly likely to trust
agencies like the Food Standards Agency or
whatever. It will rather depend on the issue or on
the product.
Ms Coates: As David says, in terms of trust there are
a number of diVerent sources of information to
customers, and they include the press and the
Government. A lot of customers say that they are
heavily influenced, particularly women when they
become influenced, by the advice that they get from
clinics and so on. Schools have a big part to play in
the education of customers, as do we, and food
manufacturers. It is very much a joint eVort, and we
all need to work together to one agenda to achieve
that.
sponsorship and repeat promotions should only be
used for healthier foods. Is that not a fair approach
to take?
Mr North: In terms of promoting healthier diets for
children, again there is a range of techniques that can
be taken, and a range that are successful. To take
one example of our fruit and vegetable products, last
year we took the phrase “reverse pester power” with
our fruit products, and managed significantly to
increase our sales of apples by linking it to a Barbie
Doll campaign, and they were our best-selling apples
for a while. There are other factors obviously that
will influence low income diets, including low
income diets among children. One of those is the
location of stores and the price of food as well. An
interesting piece of research was carried out in one
of our stores in Seacroft in Leeds where the
University of Southampton did some research and
found that by putting a new store in that area where
retail and food retail provision previously had been
poor, the period following our opening of the store
showed an increase of one-third in fresh fruit and
vegetable consumption amongst the lowest income
consumers. There are ranges of approaches.
Q322 Chairman: Do you not think there could be a
greater role played by in-store placement, in-store
advertising, for example? You will see
advertisements in supermarkets, and products being
pushed by the retailer that you do not see in the same
way with encouragement of fruit for example.
Ms Coates: We do try and balance the advertising
and their promotions, and the placement of
products in-store. For instance, in almost all of our
stores the first products that you come across when
you go in are fruit and vegetables. The healthyeating ranges are clearly marked. We do not tend to
promote products anyway within Asda. The sort of
levels of promotion we have, or multi-buys and
things, would apply equally to less healthy items as
healthy items. We do provide choice in that. If you
are asking if we could put more focus on promoting
healthy foods, then I am sure we could, and we can
work towards that.
Mr North: I very much agree with what Penny has
said. When we counted up, on an average basis,
weekly promotions across our fruit, vegetables and
salad ranges, we counted up typically to around 80
or so per week. That compares with, for example,
confectionery, around 15 promotions in an average
week, albeit rising to around 50 or so at key times of
the year such as Christmas and Easter. The other
relevant point is that when one looks at the total
amount we spend on promoting produce, that is
fruit, vegetables and salads, and express that as a
percentage of our total promotional spend, then that
amount spent on produce will exceed the proportion
of the total sales of those products.
Q324 Joan Ruddock: I apologise if anyone has asked
this before but I was at a ministerial meeting and that
is why I was late. You mention pester power. I just
wondered if you, in using that term, were trying to
encourage a certain form of behaviour from children
towards their parents. Is that right?
Mr North: No. I think it is a term that is sometimes
used as a critical term for an allegation of behaviour.
The point that I was making was simply that one can
use promotional techniques in relation to fresh fruit
and vegetables, just as one might in relation to other
products.
Q323 Chairman: I came across a document that I
think was circulated to all MPs from the charity
NCH recently about issues of healthy diets,
particularly for children and families on lower
incomes. One of their suggestions was that
Q325 Joan Ruddock: Does that not mean that you
are suggesting to a child that the child should pester
the parent to buy a product in your store?
Mr North: No, as I say, I was using a term that is
commonly used as a criticism of techniques and
saying that one might make that criticism of
something that was used to promote fruit and
vegetables.
Q326 Joan Ruddock: Did you use it or did you not?
That is what I am trying to get at?
Mr North: I referred to it as being an allegation that
was made and said that we were promoting fruit and
vegetables.
Q327 Joan Ruddock: Did you use pester power in
some way to promote fruit and vegetables?
Mr North: No. What I said was that this was a
phrase that was used, but that, if one looked at what
we were doing in respect of fruit and vegetables, that
was linking fruit and vegetables to a Barbie doll
promotion that had been very successful in selling
fresh produce.
Ms Coates: We are actually running a programme
called “The Big Healthy Eat”, which is aimed at
children and taking children round a nutritional
trail. There is a trail for diVerent ages. We are
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actually running that across the country. One
million children will go through this across a fouryear period. We have been running “big healthy”
campaigns for schools a total of seven years. We
believe that encouraging children to try diVerent
healthy options through groups like this, and
enjoying them and then coming back and wanting
more, is a good way to encourage them to eat
healthily. That is one of the techniques that is
working for us at the moment.
Q328 Mr Mitchell: It is a long time ago since I was
a kid but I remember that towns in the north were
dominated by a kind of religious competition
between the Methodists, Congregationalists,
Catholics and Anglicans. Now the titanic struggle
which dominates their lives is Asda versus Tesco.
You belong to one denomination or the other. I am
just wondering how far the concern with virtual food
standards is really a result of that competitive
pressure. Is being virtuous on healthy eating and
eYcient labelling an essential part of competition
these days?
Ms Coates: I think it is an essential part of
conscience and responsibility.
Q329 Mr Mitchell: Yes, but it is conscience only
recently discovered.
Ms Coates: It has probably been highlighted more
recently but I think nutrition has always been at least
considered. I think that would be true for all of the
grocers.
Q330 Mr Mitchell: Are you doing it because they are
doing it and vice versa?
Ms Coates: No. We are doing it because customers
want it.
Q331 Mr Mitchell: Is it an aid to sales?
Ms Coates: I guess that depends on the individual
customer and what it is that they are looking for. It
may be for some customers that having more
information about health and healthy campaigns is
an aid to sales but, at the end of the day, it is a
combination of a social responsibility, and hopefully
everything we do is that.
Q332 Mr Mitchell: You must have done surveys to
show what the customer wants and whether it pays
or not?
Ms Coates: Yes.
Q333 Mr Mitchell: What do the surveys say?
Ms Coates: What customers want in terms of
information on nutrition and things varies an awful
lot customer to customer. Often women, once they
become pregnant, become a lot more interested in
nutrition and healthy eating. That is one of the
points in their life that seems to turn them more
towards taking more notice of information. The
counter to that is that we do get an awful lot of
feedback that says, “I just do not have time to look
at this. I have three children and a trolley going
around a busy store and I have a few seconds to
make a decision on what I purchase. You have too
much information on there.” I think it varies
enormously between individual customers and their
requirements. I suppose what we are trying to do is
find a way through this that satisfies most customers.
Q334 Mr Mitchell: Have you anything to add to
that? Am I being unduly cynical?
Ms Kynoch: You ask if this is a recent thing, but
most of the retailers have had a healthy range for a
number of years. I think ours is 25 years old.
Providing healthier products is not something that is
desperately new. I think I would agree with what
Penny Coates has said: we are very driven by what
our customers want and if they tell us that they want
more healthy products, or they tell us they want
clearer labelling, then that is exactly what we do. We
do that based on customer research. Healthy
products per se are not particularly new.
Q335 Mr Mitchell: When it comes to government
responsibility, everything seems to split up. It is not
only British responsibility; it is European
responsibility and you have the split between Defra
and the Food Standards Authority. How clear is it
to you as retailers who is responsible in government
for agreeing and communicating full information?
Ms Coates: I think it would be really helpful if we
could have a completely joined-up agenda. I think
there are lots of diVerent parties. It is a very complex
issue. From my point of view, a single agenda with a
clear list of priorities that we all work towards would
be the most helpful, from one source.
Q336 Mr Mitchell: Does this division of authority
cause you real problems?
Ms Coates: It does sometimes, yes.
Q337 Mr Mitchell: How about Tesco?
Ms Kynoch: I would echo that to a certain extent.
Clearly there is a Health Protection Agency now and
a Food Standards Agency. Some points and agendas
which are similar would be very helpful to all of us.
Q338 Mr Mitchell: What is your experience of
working with government agencies and government
organisations on issues like this?
Ms Coates: Perhaps this is limited and my colleagues
may add to it. I think that whatever is the most
topical point of the day is pushed very hard by the
Food Standards Agency to retailers in particular,
but the food industry, of course, is larger than just
retailers. Whilst I think we all accept we have a very
huge part to play, the industry is very wide and a
great number of products are now consumed outside
the home and not purchased from retailers. There
must be a holistic approach from the Food
Standards Agency or the Health Protection Agency
to the industry as a whole. I believe they do talk to
diVerent sectors of the industry. I would say that,
yes, they are challenging and we hope we can step up
to the mark and do the art of the possible.
Q339 Mr Mitchell: How frequently do you have
contact with Government on these issues?
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Mr North: I think contact of one sort or another
would be almost daily, whether it is on an individual
issue or on wider ranging issues like obesity. Contact
with Government is frequent.
Q340 Mr Mitchell: Would you welcome
Government laying down standards which you then
put on the labelling, or is this best left to industry cooperation?
Mr North: I think it must depend on the issue.
Q341 Mr Mitchell: That is a good political answer.
Take the nutritional value of salt. Would you prefer
a clear government message that you label it this way
or that way?
Mr North: On labelling or on nutritional content?
Q342 Mr Mitchell: On labelling?
Mr North: It would depend on the evidence base as
to the issue. There clearly are areas where labelling
has been set down by government action. Whether
one would want to go further than that at this stage,
I do not know. I think it would be diYcult. It is
diYcult to answer that question as an absolute
without having a specific proposal in mind, I fear.
Ms Kynoch: May I add to that and say that there are
obviously clear guidelines from the Government
now about labelling and that is what retailers do; we
comply with legislation and nutrition as well.
Colleagues from the Co-op mentioned that the
reason sodium is on there and not salt is that that is
a government requirement and additionally adding
salt is what some retailers have done voluntarily. To
make changes to that legislation, perhaps one of the
questions is: “Does this go back to the EU because
they are the ones who actually set it in the first
place?” You first asked us whether it would be a
good idea to co-operate with industry. Yes, I do
think it is a good idea to co-operate with industry
because, frankly, that is where a lot of the knowledge
actually is.
Q343 Mr Mitchell: Would you welcome government
direction?
Ms Coates: I agree with your comments. I am not
sure that it is necessary to introduce legislation but I
do think that a united approach between industry
and Government would be the right way to do it. I
think we need to be in agreement. It does not
necessarily have to be legislated for because I do not
think there is anybody that does not want to do it.
Q344 Joan Ruddock: From what I have heard, I
would like to ask you all really: why should not all
our foods be healthy foods? You say you do healthy
options, you do healthy eats, healthy promotions.
Why should not all our food be healthy?
Ms Coates: I think to some extent the definition of
“healthy” depends on who you are, how much
exercise you take, whether you are a growing child
or whereabouts you are in your life stage. A balance
of food and calories/in calories/out is really what
matters. A packet of crisps, for instance, may be
considered unhealthy to an obese person who is not
taking exercise, but for a child who is going to go and
play a game of football afterwards, there are certain
nutrients, potassium and things in potatoes that are
quite good for them. I think it is all about balance.
It is limiting things with may be high fat, sugar and
salt, all things that do not actually fit with that
individual’s requirements for their healthy body,
which obviously, with lots of allergies and things
around, do vary enormously by individual.
Q345 Joan Ruddock: Does that imply that you think
that there is nothing supermarkets should do about
their current products to make them healthier?
Ms Coates: We are doing an awful lot, and so that is
not the case. We are all trying to make reductions at
the moment in things like salt, fat and sugar. We are
trying to do it with the very best intentions,
recognising that one of the overriding issues in
society at the moment is obesity.
Q346 Joan Ruddock: Asda, I believe, has said that
over the past three years you have taken one
thousand tonnes of salt out of your products.
Ms Coates: Yes, and we are taking more. We are
reducing salt in 1,000 products this year. I am not
sure that was the number that I had in my mind. I do
not know what the number is. I know we are
reducing salt in 1,000 products this year, and we
have been removing slat for the past five years from
products.
Q347 Joan Ruddock: You acknowledge that there is
great scope for removing salt from processed foods
in supermarkets?
Ms Coates: I think there is scope for gradually
reducing salt, fat and sugar. One thing that we have
to be aware of is that if we do suddenly take a lot of
salt out of a product, then it does make a big
diVerence to the taste. It is about gradually weaning
people oV things and I think again that will be a
united approach to gradually lessening thing like salt
content in products. I was thinking about this on my
very long train journey down here, and I apologise
that it was delayed by two and a half hours. I was
forced to stand in a smoking carriage because there
was nowhere else to go. I personally do not smoke
and never have but I was exposed to quite a lot of
smoke as a child. I used to be able to tolerate it and
it was fine. Gradually I have moved myself into an
environment where there is no smoke at all. There
was a diVerence going back to being forced into that
environment; it was exceptionally claustrophobic. I
think there is quite a similarity in some ways with
salt because gradually you eat less and less. I
personally have been trying to eat less and less, but
if I eat very salty products now, I really notice. I
think it is about gradually educating and gradually
removing to get to a sensible point for everybody.
Q348 Joan Ruddock: How helpful do you think the
intervention recently by the Minister of Health has
been in highlighting the failure of so many
manufacturers to take salt out of their processed
products, or not to take it out, as you rightly say, but
to reduce it?
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Ms Coates: I think it is absolutely the right intention
to reduce salt.
Q349 Joan Ruddock: Do you think naming and
shaming is not appropriate?
Ms Coates: It is certainly not very motivating when
you have done a lot of hard work.
Q350 Joan Ruddock: But not enough?
Ms Coates: That is debatable, I guess.
Q351 Joan Ruddock: How do we arrive at a position
where we know what is enough? Who is going to
decide that if each supermarket chooses to go down
its own path when we all know that an enormous
amount could be done?
Ms Coates: Again, I think there are a number of
things that we could do and various aspects for
reducing things like salt, fat and sugar. I think that
is where we could have a united approach, and you
mentioned the Minister’s initiatives on salt, which in
its own right is good. There are other things like fat
and sugar that we need to look at altogether. If we
could get to a point of having a single agenda that is
prioritised with timescales and follow-up, then I
think that would be a great place for everybody to
be. Certainly, I think I speak for all of us in being
very happy to be involved in something like that.
Joan Ruddock: Does that go for Tesco’s?
Q352 Chairman: From Tesco’s point of view, do you
endorse what has been said?
Mr North: We do endorse what has been said. On
salt, it is an area where the industry can work
together, where for example we are working with our
competitors through the British Retail Consortium.
Obviously we have heard what the Minister has had
to say. We will continue to work with our colleagues
in the British Retail Consortium to achieve progress
on salt.
Ms Kynoch: There are obviously a few products
which have to have salt in them because it is a form
of preservative. It is not as if you can remove salt
from absolutely everything. The bread industry did
do just that. They took salt levels down over time so
that palatability is not adversely aVected and
eVectively people stop wanting to buy great product
ranges. Certainly as far as Tesco is concerned, in
terms of NPD it is now on the agenda and we are
saying that as we are developing a product, then we
will look to minimise the salt, which means that you
have to work harder to make the other ingredients
perform in terms of flavour.
Q353 Joan Ruddock: Accepting all of that, what I
am trying to find is how we are going to arrive at
some agreed position because the evidence so far is
that you are not getting to a point where you have a
common agreement across the industry, a common
time frame. You have had years and years and years
in which to do it. How is it going to happen?
Otherwise we would have to say to Government that
Government should legislate.
Ms Coates: I am not sure that they have actually
tried yet doing something united between something
like the BRC and a single government group to set a
policy and a single plan to prioritise and into which
everybody has input, a single plan on which we all
work together. If we set up such a group in
government, it may be a separate nutritional board
or it may be one of the existing bodies, together with
the BRC, that could work. I think it would help in
terms of clarity as to what the priorities are because
obviously there is a limited number of things we can
work on at one time. Having that clarity of priorities
and a single set of priorities would be really helpful.
Ms Kynoch: I think we are moving towards that
through the BRC. That is where obviously you do
get all the retailers coming together. We have agreed
a common point from the British Retail Consortium
point of view. I believe that is with the Food
Standards Agency.
Q354 Joan Ruddock: If we re-visit this inquiry in a
year’s time, will you have cracked it?
Ms Kynoch: We will certainly have done what we
said we would do in that paper the BRC presented
because the intention is to do that and do more
over time.
Q355 Chairman: Is there not really a problem here
though about the reliance upon the industry cooperating amongst the major players at least? I think
in the evidence from Asda, you yourself said that
although the retail industry, a number of key
manufacturers and food service operations, are
making large-scale product changes in respect of
levels of fat, sugar and salt, you were questioning
whether smaller manufacturers, independent
restaurants and local take-away shops were
adapting recipes in a similar manner. Is there not a
big problem here that for information to have a real
impact on the consumer there has got to be some
standardisation across all the various outlets? If
people are moving forward at their own pace to a
faster or slower extent, you are not going to get the
full benefits that you could have from a standardised
approach, which I think must surely require some
government intervention? How would you respond
to that?
Ms Coates: I would agree that we do need a single
approach. I think we need to have some sort of time
lines. We just need to involve a number of people in
what their approach is and make sure that it is
practical for all parties to achieve time lines. I
absolute agree: I think a common approach is right.
Q356 Chairman: That would require government
regulation. Would you accept that?
Ms Coates: If parties are not prepared to comply
anyway, and I think most parties would be, it is
probably lack of information and understanding or
resources that is generally the problem rather than
willingness to produce the right food and serve the
right food to customers.
Mr North: I would agree with Penny Coates that the
more various parts of industry can work together on
this, the better. On your second question about
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whether that requires the Government to regulate, I
would wonder about the practicality of doing that,
particularly given the point that you made about
Asda’s evidence in relation to the catering and other
sectors and whether one could really legislate in a
way for limited salt across the board in products.
Q357 Chairman: There is one specific point which
arises from these questions. Can I ask you in each of
your cases: how do you convey nutritional
information to your customers about food that is
sold loose rather than packaged foods: for example,
the fish counter, the delicatessen counter or
whatever?
Ms Coates: From Asda’s point of view, we certainly
have nutrition information leaflets and we have
information on websites. When you see products on
counters and things, you will see what we call a little
(pentics) stuck in the product, a little plastic label.
On the back of that label is the nutritional
information. It is there on request. Obviously things
vary by weight; it is not automatically provided on
the label for the customer at this stage but the
information is there so that any requests can be
answered at the counter because the information is
on the back of the price label, which is what the
customer sees.
Q358 Chairman: This would require the customer to
ask for the information. It is not obvious at first
sight?
Ms Coates: It would require him either to ask for the
information or to look it up on the website or in one
of our nutritional or healthy eating leaflets.
Q359 Chairman: In your experience, do many
customers ask for that information when they buy
their cheese or whatever?
Ms Coates: Not a lot of customers do that, no.
Ms Kynoch: It would be exactly the same for Tesco,
including not many customers actually asking us for
that information but it is available at the point at
which you buy it and on the website and in leaflets,
pretty much as Asda have said.
Q360 Mr Mitchell: Tesco’s recently got a traYc
lights system, which is going to start in September. I
think it is the kind of thing that the Consumers’
Association has been urging. Why did you decide
that the time was right to do this?
Ms Kynoch: We are constantly doing customer
research and asking customers what they want. One
of the things they are telling us is that nutritional
information and information in general on the pack
is very confusing. I know that you have just had a
long conversation with the Co-op about that very
point. They are saying it is confusing. One of the
things we look to do is see what information we
could possibly provide that is as meaningful as
possible and that would be simpler for consumers.
That is why we have come up with the traYc lights
system. We have gone through various stages of
mock-ups and looked at it with consumers. They
have said that they feel this would be good for them;
it is quick and easy to recognise. It will be on the
front of the pack; there will be green, amber and red.
There is an acknowledgment from them that they
understand that, that they understand that the
products in the green zone are the products which of
course are going to be good for you. That does not
preclude them wishing to buy products which in
some cases may be labelled red for perhaps fat
because they know that they should not have too
much of that. Really it was down to customers
telling us what they wanted. Of course, we provided
various ideas, but this is the science behind it. The
customers are the ones to listen to in this instance.
That is why we have chosen to go with a traYc
lighting system on the front of our packs.
Q361 Mr Mitchell: I understand that. You are going
to have traYc lights for fat, concentrated fat, sugar
and salt. If you take marmalade, I like marmalade,
so it is going to be green—green for guzzle in my
case—on everything except sugar, where it is going
to be red. That is a bit confusing, is it not?
Ms Kynoch: You have chosen something that you
only need a little drop of each day, I suppose, so it
would be quite diYcult to overdose fully on
marmalade. To be fair, nutrition is a very complex
subject and trying to explain even what we deem as
scientists as a relatively simple calorific fat content is
hugely diYcult. What we are doing is
oversimplifying it by going for the traYc light
system. You do not just eat marmalade all day, so
that is only going to be little bit of your diet. Clearly
I am sure you will then balance what you have for
your breakfast, your marmalade, by choosing some
other products which are green, so you will be
choosing a good quality breakfast cereal with
skimmed or reduced fat milk in order to balance
that. People did not see products labelled red as evil
and that they must not eat them; they accept that life
is a balance. I think no customer would expect a nice
cream bun is going to be pretty green but they will
probably balance that by making sure that they have
the healthier options as part of that meal or as part
of another meal during the day.
Q362 Mr Mitchell: I am not sure I have got the
willpower to do that.
Ms Kynoch: We have not started selling willpower
tablets yet but I suppose it is a possibility.
Q363 Mr Mitchell: As a follow-up to that, I get very
confused by the conflicting warnings given by
various health people. I am not quite sure really
whether we have a scientific basis for the
information about the eVect of salt, the eVect of
sugar, the eVect of fat, and so on. Are all these cases
suYciently proven to simplify them into a traYc
light system?
Ms Kynoch: If they are not suYciently proven, there
is some extremely strong evidence to suggest that
sodium disrupts the sodium pump in your body that
leads to coronary heart disease, much the same as
with smoking and, yes, you can get lung cancer and
all sorts of other things. If you like, it is beyond
circumstantial evidence, so it is enough to be taking
heed of. You are right that food is made up of a
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number of diVerent components. Fat could be one of
them; sugar could be another. There is salt to
consider and then there is the overall calorific
content. There are negative messages about too
much of each of those. It is not that the messages are
conflicting. It just so happens that food is a mixture
of all of those things, which is why it makes it very
diYcult.
Q364 Chairman: Will Asda introduce a traYc
lights system?
Ms Coates: We have clearly discussed the traYc light
system. I think you are probably aware of some of
the packaging we have at the moment. Customers
say that things like the medals on this box work very
well for them because these are quite clear and they
can spot them. The opportunity to turn those into
traYc lights is obviously there. We were really
waiting to see whether we decided as an industry to
go with the common approach, because I think it is
a very positive approach to take, provided we decide
what we are traYc lighting and we do it consistently.
Otherwise if, heaven forbid, some of Asda’s
shoppers were to shop in Tesco one day, we would
want to make sure that red and amber and green
were consistent in all of the supermarkets. I guess.
Q365 Mr Jack: How much work do you do in
deciding what the base knowledge is of your
customers about the various sorts of average daily
intakes that they are supposed to have? If you do not
do this, all of this discussion about all this
information is a bit meaningless because there is no
benchmark against which to compare it. Do you feel
(a) any obligation to help your customers know that
information and (b) do you provide it?
Ms Coates: We provide recommended daily
allowances on packs according to the current
recommendations. I think again the data is that the
recommended daily intakes would vary according to
age, size and whether you want to reduce weight.
Q366 Mr Jack: The question I asked is not so much
what you are doing but do your customers know
this? In terms of your service, both companies spend
a lot of time talking to customers. What is the level
of customer awareness about what they ought to be
taking in?
Ms Kynoch: I think it is very low indeed. People are
very influenced by the media. If there is talk of fat
being very bad for you, saturated fat, then that is
what they pick upon. If the latest media topic is salt,
then that will also be picked up on. At best, the
guideline daily amount, the 2,000 calories for
women and 2,500 calories for men, is probably a
more recognizable phrase. I think people see that
amount and can in some cases decided to add up and
make sure that they do not have more than that
intake a day. In general terms, unless you happen to
be a scientist or a nutritionist, I would say that the
consumers’ understanding and knowledge is quite
poor.
Q367 Mr Jack: We have on the one hand a lot of
information but poor benchmarking. Do both of
you run what might be described as healthy eating
ranges?
Ms Coates: Yes.
Q368 Mr Jack: You label these accordingly so that
people can diVerentiate between the unhealthy stuV
and the healthy stuV.
Ms Kynoch: It is very clear; in Tesco’s case it is a
brand all of its own that we have been running for 25
years, so it is easily recognizable, yes.
Q369 Mr Jack: How do you decide what goes into
the brand?
Ms Kynoch: I suppose it is like any product
development: in some cases you are following food
trends, and that is why you launch ranges of sushi if
that was in vogue. At the time when you are
launching a product, you may well consider whether
it should be a healthy living product, whether it
should be a Finest product or whether there is room
for a Value line. I think it really just depends. It is
driven by what consumers want to buy essentially.
Q370 Mr Jack: It is driven by what consumers want
to buy and yet in your previous answer you told me
that, in terms of awareness of what they ought to be
buying, there was a low awareness.
Ms Kynoch: It is the NPD [New Product
Development] of products; if it is in vogue to eat
sushi, then we will launch a range of sushi. The
question I answered was separated somewhat from
their ability to understand a nutritional label on a
pack. You extend product ranges because that is
what people want to buy, not necessarily because
they need to buy a reduced fat product. In many
cases it is not possible to make a product fit into the
tight criteria we have for healthy living, and so you
add to the ranges those products that it is physically
possible to make with low fat and lower sugar and
lower salt.
Q371 Mr Jack: I am wondering how meaningful you
actually feel putting labels like “healthy eating” on a
product actually is?
Mr North: On that point, there is a question of trust
on the part of the customer. As Liz Kynoch was
saying, our Healthy Living range was launched in
the mid-1980s. We also have a Healthy Living Club,
for which I think we have 175,000 members, and so
we communicate through our Healthy Living Club
messages about healthy living and healthy eating.
Our customers do not generally come in and say,
“What is the specification for a product to enter the
Healthy Living brand?” although if they did, we
would be able to tell them, for example, that it must
contain 10% less sodium or 3% less fat, or whatever,
than a standard product. They trust the brand if they
want to eat a product that, combined with other
things they do in their lives, will on balance give
them healthier living and our Healthy Living brand
will do that for them, or will help them to do it.
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Q372 Mr Jack: You do not think it is a conscience
thing, do you? They have one of your healthy meals
a week and then think, “Right, I have done that. I
can go back and indulge now”?
Ms Coates: We do not want customers who say they
eat the Health Eating range during the week and
then they will have other ranges at the weekend or go
out to eat at the weekend. Some customers
consciously do that if they are watching weight.
Q373 Mr Jack: Is that what we would call a
balanced diet?
Ms Coates: We do not encourage them to do that.
They choose to do so.
Q374 Mr Jack: What I am trying to get at is whether,
with all this information, people say, “Yes, I
understand it, yes I believe it, yes, I will react to it”?
I am interested in terms of the feedback you get from
customers. You said, Mr North, a minute ago that
you had 175,000 people in your Healthy Living Club
“and we send them messages”. What questions do
they come back and ask you? I presume this club is
interactive, is it?
Mr North: It is and customers will come back with
questions. It is precisely those sorts of questions that
have led us to develop our traYc lights system. When
we ask customers or when customers speak to us
spontaneously, one can see an increasing trend of
customers saying, “We are more concerned about
healthy living. We are more concerned about issues
like obesity”, partly because of what they read and
partly because of what they see and experience.
What they will then say is, “We understand that
retailers, manufacturers, or whatever, provide lots
of information”. Nonetheless, again as I think we
heard during the evidence that you took from the
Co-op, they will say on the one hand that there is
already a plethora of information but that, perhaps
because of the amount of information, some of it is
hard to understand and hard to interpret. That was
why we then devised, for example, the traYc lights
system and customers responded by saying, “If you
were to do that, then we would, on balance, find that
helpful”. As Liz Kynoch said earlier, they did not
respond by saying, “If we saw red, we would not eat
it or would not buy it. We would act with
moderation in choosing between products and in
choosing an overall balance of products”.
Q375 Mr Jack: Let us move on to Europe because a
lot of the labelling requirements come out of
Europe. I gather that Asda have expressed concern
about the review that is to take place on nutrition
labelling. Would you like to tell us why?
Ms Coates: I think at the time we raised concern
about the review into nutrition labelling it was about
having individual traYc lights for salt, fat and sugar,
or having a traYc light that represented salt, fat and
sugar. It may be that one is very high and one is very
low. I think we just wanted to make sure that a
balanced diet was introduced. If we were going to
support something like a traYc light labelling
system, then doing something on energy density or
something that is most important to the majority of
customers was what we were concerned about.
Q376 Mr Jack: Can you tell me what energy
density is?
Ms Coates: Calories per 100 grams.
Q377 Mr Jack: What contact do you have with
other supermarkets in other parts of the Community
about how they react to all this? Are people in Italy,
France and Germany as obsessed about all of this as
we appear to becoming here?
Ms Coates: I do not know the answer to that.
Q378 Mr Jack: You have the European Union busy
reviewing this nutritional labelling for a universal
application throughout 25 countries in the
European Union and you have not talked to another
retailer about it?
Ms Coates: We talk as part of the BRC. We are
obviously not in contact with other retailers on a
regular basis for competition reasons. We would
talk through the BRC generally on topics like this.
We have been doing that on a UK basis rather than
a European basis.
Q379 Mr Jack: From evidence that we have heard
before, there are some serious questions about
labelling, full stop: purpose, content and all the rest
of it. This is universal labelling across Europe. I am
just surprised that there has not been any dialogue
store chain to store chain. Maybe that is the way that
you are approaching these matters. What about
Tesco, because you have a presence in other
Community countries, in Hungary and in Poland?
Mr North: We do have a presence in some other
Member States. There is dialogue through bodies
like EuroCommerce. Although the response will
diVer Member State to Member State and an issue
like obesity will have a higher profile in some
countries than in others, the concerns that Penny
Coates has expressed about the proposed Directive
I think were pretty widely shared. That is why the
Commission has said that it will look again. It is
important sometimes to diVerentiate between the
objectives behind the proposed legislation, some of
which were perfectly laudable, and sometimes what
one fears might be perverse eVects. For example, we
were concerned that our Healthy Living products
would be threatened by that Directive, which we
thought was a perverse eVect. It is similar to the
perverse eVects of some other legislation, for
example the reason why both ourselves and Penny
Coates’s company are being prosecuted by Trading
Standards departments for promoting the
Government “five a day” message.
Q380 Mr Jack: You are being prosecuted. Why?
Mr North: The claim or the allegation is that, at least
in our case, repeating the Government’s message
that eating five portions of fruit and vegetables a day
helps prevent cancer is a health claim that is
technically prohibited by existing legislation.
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Q381 Mr Jack: Just out of idle curiosity, why have
they picked on you because other people seem to
dwell on this? The Government themselves
promote this?
Mr North: It is probably a question that we
sometimes wonder about ourselves. It depends on
the specific wording that is used. In our case, we did
for a time use the wording that we took from the
NHS, and in fact developed with our partners on
this, Cancer Research UK, which was that eating
five a day helps prevent cancer. It was that specific
wording that they objected to, notwithstanding the
fact that it was precisely the same wording that the
Government was using. I think Asda have had a
similar experience.
Ms Coates: Yes.
Q382 Mr Jack: Do you think that sends out a
confusing stream of information to the customer,
that the simple message “five a day” and all that goes
with it ends up with their favourite purveyor of food
being taken to court?
Mr North: Customers will have noticed, if they look
at our “five a day” ranges, that our message has
changed from one that we thought was perfectly
objectively justified, which was that it helps prevent
cancer, to one that is something along the lines of
“for a healthier lifestyle” and they will wonder why
that message has been diluted. I think their
wondering why it has been diluted is probably not
helpful in promoting the “five a day” message.
Q383 Joan Ruddock: I was just wondering if they
really did notice. I must say, when I am in a
supermarket, I notice nothing except where the
product is that I want to buy. You have research on
this. I wanted to ask about prosecutions, but from a
slightly diVerent angle. To what extent do you feel
yourselves responsible to see that the labels as
applied by manufacturers, other than your own
brands, actually comply with labelling law? Do you
have a checking process or do you just depend on the
manufacturer doing the right thing?
Ms Coates: We have an independent check so that
manufacturers check depending on whether the
products are assessed as being high, medium or low
risk. The frequency of the checking by the
manufacturers is determined by which category they
fall into, but every product is checked both at the
time that it is actually launched and annually by an
independent body as well, or at least annually.
Q384 Joan Ruddock: When you say “an independent
body”, you mean a body independent of what?
Ms Coates: It is independent of the supplier and of
us.
Q385 Joan Ruddock: That is of both?
Ms Coates: Yes.
Q386 Joan Ruddock: What is that body?
Ms Coates: We actually use Law Labs, a company
in Birmingham.
Q387 Joan Ruddock: It is just a private company.
What happens with Tesco?
Ms Kynoch: The process for Tesco own label
products is very much as Penny Coates has
described, and the independent product test are
done by Law Labs. I think they are getting a lot of
business because we use them as well. I think you
actually mentioned the brands. Did you ask us a
question about whether we checked that branded
products were actually legally compliant?
Q388 Joan Ruddock: I was making a distinction
between your own brand, and I assume you control
the labelling of your own brands, and those brands
which are not your own but are coming from other
manufacturers. I wondered if you saw yourselves as
being responsible for checking that the labels from
those other manufacturers complied with labelling
law.
Ms Kynoch: That is only if we actually had a concern
about the technical competency of that supplier.
Clearly when it is Mars or a worldwide company or
Heinz baked beans, I think they have plenty of
technical resources to ensure that their products
comply with all legislation, including labelling. We
do risk assessment depending on the supplier, but
that would extend beyond foods to electrical goods
as well.
Q389 Joan Ruddock: When we were visiting as a
select committee the accession countries, Tesco’s
was already taking quite a lot of local product and
manufactured goods presumably from those
countries. They had very little in place for regulating
anything as far as we could tell. Would you assess
that new supplier as a high risk and make certain
that you got the right labelling and compliance? Is
that what you are saying?
Ms Kynoch: In those counties that we deal with in
what was the old eastern bloc we have a very small
proportion of Tesco own brand product but,
whichever country we are in, Tesco brand products
are taken care of 100% by the technical team within
our company, whether it is in Poland or back in head
oYce in the UK. To the extent to which our
operations in those countries are able to screen the
labels of every brand manufacturer, we are not able
to do that.
Q390 Joan Ruddock: So there could be products
being sold by your company, certainly in other
countries where the labelling might not be
compliant. What about in the UK? Have you had
examples where you have sold products that are not
compliant?
Ms Kynoch: I am not aware of any.
Q391 Joan Ruddock: Have you any knowledge of
prosecutions ever having happened?
Ms Coates: No.
Q392 Joan Ruddock: We have been given evidence
that suggests there are very few prosecutions in this
field but not necessarily that there is 100%
compliance.
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Ms Kynoch: I think that is probably true because
there are an awful lot of products with an awful lot
of labels and Trading Standards’ ability to screen all
of those would be limited, I suppose.
Q393 Chairman: Turning away from the question of
making sure that manufacturers of products meet
the legal requirements for labelling, can I ask you
how much pressure you put on those manufacturers
from whom you purchase products for sale to meet
some of the wider objectives of nutrition
information, information for the consumer, and so
on? We heard about the information that you are
putting in place on your own brand products. That,
of course, is only a relatively small proportion of
what you are selling. How do you try to ensure that
these other external producers aim to reach the
standards that you yourselves are trying to set?
Ms Coates: I think that is where the joined-up
approach comes in. Actually, the own-branded
items are over half of Asda’s sales certainly, so it is
quite a large proportion of our sales. In terms of
influence on branded suppliers, I think we can talk
with branded suppliers. Obviously we have no
power to tell them what to do. We can make
suggestions, as Government and everybody else can,
and I think probably the influence of the current
focus on obesity in the media, et cetera, will influence
the branded manufacturers more than we would be
able to do.
Q394 Chairman: Surely you do a have a lot of
power? You are major players in the market. You
can influence them, surely, by your purchasing
decisions. To give an example which I put to the
Committee last week, on the rare occasions I go
unwisely with my children to the supermarket and
we go to the breakfast cereal counter, inevitably I am
dragged towards the highest priced goods, the ones
which have the most chocolate and sugar in them.
Not surprisingly perhaps, given the advertising and
the nature of the packaging, those are the ones that
are attractive. I think that is an example of pester
power, which we discussed earlier. How is all your
good work in terms of traYc lights or other
information going to counterbalance that kind of
eVect of advertising on packaging from external
producers? Have you not got some responsibility to
influence the kind of way in which these products are
advertised, packaged and sold to the consumer?
Ms Coates: It is quite an interesting debate, is it not?
It is about whether we are there to sieve what we sell
for customers or we are there to provide the choice
and the information for customers. That is a
diVerent debate really because we cannot force
branded manufacturers to do things. We can make
suggestions, as can Government and other parties,
but we cannot force them.
Q395 Chairman: What is the response of Tesco to
this area?
Mr North: I would agree with much of what Penny
Coates has said. Another interesting point is that, in
a competitive market, good ideas can spread quite
quickly. If you take the example of our traYc light
system, we are pretty confident that if it proves
helpful to customers, then pretty rapidly others will
take it on. To look at a historical example, I think we
were either the first major retailer or very close to the
first major retailer, to introduce the nutrition panel
on products, long before it became compulsory.
That very quickly became a non-Tesco exclusive
idea because the manufacturers realised that it was
something that consumers found helpful.
Q396 Chairman: If your traYc light system is a
success, then surely you can say to the external
producers who supply you, “We want you to have
that information on the products that we are selling
our stores and, if you do not provide it, we will not
buy from you”. Surely you are in a position to be
able to exercise that kind of power over the
producers?
Mr North: As Penny Coates has said, one can have
a debate about whether retailers really do have that
power. If one individual retailer were to say that,
then the large manufacturers would reply by saying,
“Actually, whatever size you think you are, we are in
fact supplying a whole number of other retailers,
both large and small, and introducing that sort of
change just for you is very diYcult”.
Q397 Mr Jack: Is it really true to say then that the
massive Asda Wal-Mart is at the mercy of its
suppliers when it comes to what is printed on labels?
This is a revelation to me.
Ms Coates: The size of companies like P&G and
Mars, et cetera, and remember we are buying as
Asda in the UK and we do not buy as part of a global
purchase—
Q398 Mr Jack: I cannot help but think a little transAtlantic nudge and a wink might get you down the
line to where you want to be. Certainly, as we come
down the supply side, you do have a profound
influence on what people do.
Ms Coates: I think Tesco might have an issue if we
tried to dictate what manufacturers did in the UK.
Q399 Mr Jack: I suppose it is a question of whether
collectively, in conversations with the supply side
through organisations like the British Retail
Consortium, there is any feeling of a need to
promote jointly on behalf of retailers food
information messages of the type we have been
discussing on a broad band as far as the supply side
is concerned. The message I am getting from you is
that if somebody has a big, successful brand, it will
be they who dictate the food messages that we all
stare at on our breakfast tables, not you as the
retailer.
Ms Coates: I think there is a joint responsibility
again. This is where we could have a single agenda
with the food manufacturers involved in that.
Obviously in terms of expertise, nutrition and
things, a lot of the large food manufacturers are
bigger than any of the individual manufacturers that
would supply us as private label suppliers. The
expertise is there.
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Q400 Mr Jack: Will you turn the question around
the other way? Given that you are very aware of this,
are you happy with the situation? If I said to you,
“Give me an example of good practice in messages
about health, food, nutrition, salt, et cetera, from a
major manufacturer whose brand you accept”, what
would that be? Have you got a corresponding
example of bad practice that does not, in your
judgment, communicate those important messages?
For example, if you take breakfast cereals, they tend
to be within the framework of people thinking that
these are healthy things to eat, and yet, as the
Chairman has indicated, sometimes there are
breakfast products which in his judgment, not his
children’s, may have the adverse eVect. Do you look
at labels and say, “That is good”, “that is bad” and,
if so, do you feed any of that information back to
major branding manufacturers?
Ms Coates: In thinking about the number of
products that are supplied to us, the expertise within
the individual manufacturers and their level of
awareness and activities in food and nutrition, I
think they are well aware of anything that we would
be able to tell them.
Q401 Mr Jack: I am intrigued that there is so little
analysis of this. You are more or less saying that the
manufacturers will always get it right.
Ms Coates: I am not sure that is what I am saying. I
think I am saying that Kellogg’s, who probably
provide at both ends of the spectrum that you
discussed, are providing a choice for a variety of
diVerent needs and a variety of diVerent customers.
They are obviously researching the customer base to
determine what they think is most appropriate to
sell. Similarly, we would do the same. I think it
comes back to this debate as to whether you are
asking us actually to sieve and filter products and
just sell what we believe is the right thing to sell, or
whether we should be selling across the whole
customer base what the customers want. At the
moment, we are at the latter of those two. That is the
position we are in.
Q402 Mr Jack: I want to ask one question of Tesco,
if I may. In my local Tesco in Kennington, I went in
to have a look to see what information was available.
My eyes lit up when I saw this great big thing on the
back wall that said, “Food Information”. What
should I have expected to have found in the blue
display with the transparent plastic inserts in it
where it said “Food Information”? What would I
have found there, do you think?
Mr North: I do sense that what we might have
expected you to find and what you actually found
might be two diVerent things! Were it to have been
stocked properly, then I think you should have
found quite a range of pieces of information. For
example, this is one of our latest leaflets on our
glycaemic index initiative, “Feel fuller for longer and
help control your weight” or, for example,
information on food additives, organic foods or a
whole range of issues. I suspect we do not make sure
that these are always 100% stocked, although we do
try our best.
Q403 Mr Jack: You have answered the question
very astutely. I will not tell you what I did find. You
can always go up to Kennington and find it yourself.
In fairness, there are some Tesco stores which I have
been into which have had the range and style of
leaflets that you have talked about, but in terms of
actually how high the priority is in ensuring that
your materials produced centrally to communicate
these messages are always available to customers,
that may be lower down on the priority in terms of
store management than other functions about
selling products.
Mr North: It is also not the only method by which we
communicate to customers; for example, our Club
Card Magazine or, as I mentioned early, our Healthy
Living Club, our Baby and Toddler Club or our
Organic Club. There is a range of ways of
communicating with customers, and obviously some
work better than others.
Chairman: The next time Mr Jack visits the
Kennington Tesco, it will be bulging with food
information leaflets. Thank you very much indeed
for your evidence this afternoon. That has been
genuinely helpful. There are a couple of issues which
we have not been able to cover in the time this
afternoon. If you do not mind, we will ask you to
answer those in writing. We will let you know what
those questions are. If there are any additional
points which you feel it would be helpful for us to
have as a result of today’s session, please do let us
have that. Once again, thank you very much indeed.
Memorandum submitted by Whitbread
1. In this paper we set out to provide background to Whitbread and our food businesses, look at the eating
out market and the attitudes and behaviours of our customers, explain our oVering to customers and
consider the food information we provide to our customers.
2.1 The Whitbread Business
Whitbread is the leisure business.
Having ended our 258-year association with brewing in May 2000, the Company has focused on value
creation for shareholders through the management of the UK’s most popular branded leisure businesses.
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The Company’s aim is underpinned by a strategy of organic growth for leading businesses in expanding
sectors of the leisure markets. Whitbread owns and operates leading brands in hotels, restaurants and sports,
health and fitness clubs.
The Company was founded in 1742 and has been listed on the London Stock Exchange since 1948 and
is a member of the FTSE 100 and FTSE4Good indices.
2.2 Key facts
Whitbread:
— Employs over 65,000 people and has a turnover of over £1.8 billion and net assets of around £2.9
billion (2002–03).
— Owns and operates a number of leading brands, including:
— High Street Restaurants:
— Costa, TGI Friday’s, Pizza Hut, Maredo (Germany).
— Pub Restaurants:
— Brewsters, Brewers Fayre, Beefeater, Out & Out.
— Hotels:
— Marriott, Travel Inn.
— Health and Fitness Clubs:
— David Lloyd Leisure.
With 1,477 branded restaurant outlets, 364 hotels and 56 tennis health and fitness clubs, Whitbread is one
of the largest operators in the UK eating out market.
Our pub restaurant brands—Brewers Fayre, Brewsters, Beefeater— account for over 40% of the UK’s
branded pub restaurant sector. These pub restaurants serve more than 32 million meals each year.
3. The Catering Industry
Catering and Leisure (Hospitality), which is defined as “the serviced provision of food, beverages,
accommodation, leisure and other facilities purchased outside the home” is one of the UK’s largest
industries.
— Cafes, clubs, hotels, public houses, restaurants, etc, in the UK number over 300,000 approximately
80% of which are independently owned and operated by SMEs.
— The industry employs over 2.5 million people (about 10% of the total UK workforce) and
generates revenue of around £50 billion per annum.
— The SME nature of the industry is demonstrated by the simple average that less than nine staV are
employed per outlet.
— Currently some one in five of all new jobs are created in the hospitality sector.
4. The Eating-Out Market
4.1 The eating out market as a whole is valued at £28.2 billion and accounts for some 4.4 billion eating
occasions. The market comprises a variety of diVerent oVerings.
4.2 Going forward the markets in which we operate we believe will grow by around two points of volume
per annum. We note that penetration (those who have eaten out in the last week) continues to grow. The
drivers of this growth are:
— increased economic wealth in the middle market;
— increase in “casual” eating out;
— time famine (dual income families etc.);
— improved quality and choice available locally; and
— branded supply showing highest growth.
4.3 The High Street restaurant sector is valued at c £19 billion and accounts for some 3.2 billion eating
out occasions. Research shows that consumers visit these restaurants for two key activities; for sustenance
or as a treat (often as an adjunct to another activity eg shopping or entertainment).
4.4. The Pub Restaurant sector has a market value of c £5.5 billion accounting for some 0.7 billion eating
occasions. The average spend per occasion is £7.85. In this sector socialising or treating is the key reason
for customer visits where food is the primary focus.
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5. Overview
5.1 Food information
There are three significant factors that influence Whitbread’s approach towards providing information
to consumers:
— What the consumer needs or wants to know.
— How best to inform them.
— The mechanics of accurate information provision against the background of providing a dish or
meal as a social occasion rather than food as a packaged product.
5.2 Consumer attitudes when eating out
The profit sector of the catering industry is highly competitive. The need for Whitbread’s restaurant
brands to anticipate and respond to the views of its customers is paramount. We therefore undertake a
considerable amount of consumer research to inform our decisions and react to feedback from our guests.
This feedback and our research and that undertaken by others, including the Food Standards Agency,
has consistently identified some fundamental diVerences in consumer attitudes towards consumer
information when eating out and when shopping.
The evidence suggests a key distinction in that restaurant dining is very clearly seen as a treat or social
occasion, often a celebration. By comparison there is a functionality associated with shopping for food.
In restaurants people are more interested in those emotional aspects that influence their level of
enjoyment, such as atmosphere, service, choice and value for money. Research to date has indicated that
they are less interested in food production issues, nutritional content and animal welfare and country of
origin issues when compared to shopping for domestic use.
We believe that a very important exception to this relates to information required for those with food
allergies. [See paragraph 7 below]
Whitbread has recently also researched parental attitudes in relation to making choices on behalf of their
children when eating out and a similar picture emerges. For this group healthy eating, when eating out, was
low down the hierarchy of parental concerns behind road safety, bullying, accidents, health scares, eg
MMR, “stranger danger” and general health. This is because restaurant dining is focused on enjoyment
rather than healthy eating. Parents consider that one night oV will not do harm and be countered by careful
buying and cooking at home the remainder of the time.
5.3 Practical issues
In addition, restaurants serve dishes comprising a number of ingredients. Choice is a key element of
restaurant dining which means that a typical table of diners will all choose diVerent dishes or combinations
of dishes from the same menu. Many of our restaurants will also oVer “oV-menu” choices or “specials” only
available on that particular day. The menus will change with diVerent regularity depending on the brand.
Whitbread’s food and drink spend is c. £335 million per year of which over 90% is purchased through
our central procurement team and then dispersed into our brands’ restaurants. Because of the range and
scope of our operations, Whitbread currently has 186 food suppliers providing a range of 4,900 products.
In addition, we have 97 drinks suppliers supplying some 1,300 products.
6. The Nutritional Content of Food
6.1 Communication of the nutritional content of foods
Currently our brands do not as a matter of course provide nutritional information.
The primary reason for this is because of our experience that our customers do not ask for this type of
information. To date this has also been confirmed by our consumer research. However, consumer attitudes
may well change over time particularly in light of government and media interest in the issue.
Notwithstanding this, Whitbread has been addressing the issue of healthier options following challenges
laid down by the FSA and DoH Ministers about salt content. We extended this to include sugar and fat
content.
The results of this activity include:
— All Whitbread suppliers have been briefed on the Company’s “healthier eating” initiative and
challenged to reduce salt, fat and sugar levels wherever possible without compromising taste.
— We tackled high volume lines and children’s menus first.
— Product and ingredient brief forms now include a requirement to record salt, sugar and fat content.
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— All new product development must meet the new requirements for lowest possible levels of salt,
sugar and fat.
— All reformulations include details of salt, sugar and fat content in order to provide a trackable
record of reductions made.
— Actions have been taken to change the mindset of marketers when developing menus to encourage
the inclusion of “healthier eating” choices eg pasta/rice, salad, fresh fruit, water.
— Explicit demonstrations of the Company’s commitment to “healthier eating” to our supply base
(eg Supplier Conference stands and presentations) restaurant managers (eg Brewers Fayre
Showcase House Manager handout) and head oYce staV.
We also use the same suppliers as some of the leading food retailers (eg bread and breakfast cereals) and
benefit from the salt reductions they have already introduced.
We have briefed the FSA on this initiative and on progress to date and will keep them updated on
developments.
7. Food Safety—Allergies
Notwithstanding the importance of ensuring that all of our outlets take full account of food safety and
hygiene issues, we believe it is vital that accurate information is provided to food allergy suVerers for those
dishes which contain ingredients of special interest to them. This is the principal food safety issue we believe
it is important that we communicate clearly to all of our customers.
The drivers for food allergy information include:
— Severe food allergies can kill.
— Eating out can place allergy suVerers in a vulnerable/hazardous situation.
— All food businesses have a duty of care to their customers.
— Businesses need to protect and enhance their (brand) reputations.
— More people are suVering from severe food allergies.
— Allergy suVerers show loyalty to businesses that allow them to choose their meals with confidence.
Whitbread has worked closely with the FSA and other interested bodies including The Anaphylaxis
Campaign to develop what has become known as the Four-Strand Approach:
1. Accurate and consistent labelling/provision of information by suppliers.
2. Training and awareness of designated employees.
3. Standard operating procedures.
4. Guest information available on request.
Whitbread menus include the printed statement:
“Customers concerned about the presence of nuts, seeds or other allergens in our food are welcome
to ask a member of staV for assistance when choosing their meal”.
A detailed data sheet showing the allergy status of ingredients contained in each dish is retained back of
house and is available to staV. On request, this information is shared with the customer to help ensure that
he/she makes an appropriate choice.
The data sheet is updated centrally eg at menu change, and communicated electronically to outlets via
the brand’s individual intranet sites.
8. The Means of Production of Foods (eg Organic, Battery, or Free Range) and Ethical
Considerations (Such as Whether Good Labour Practices were Used)
As has already been stated, in our experience there is currently little demand from our customers for this
type of information when eating out.
However, in our competitive market place we aim to anticipate changes in the wants and needs of our
customers. Were we to detect a shift in consumer attitudes towards the provision of information on these
subjects we would want to respond positively.
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9. Role of Labelling
9.1 Consumer Information
The provision of consumer information in full service restaurants needs to reflect both the practicalities
of the restaurant environment, including sourcing and procurement policies, and the attitudes of customers
when eating out.
As has already been stated, consumer attitudes when eating in restaurants are diVerent and suggest a
significantly reduced demand for information reflecting the social nature of the restaurant experience. This
may or may not be the case in other out of home eating environments eg fast food restaurants and workplace
restaurants.
This is a fundamental issue. Given current consumer attitudes, we would question whether restaurants
are the most appropriate environment to start to promote the public education process on healthier eating.
That said, it is likely that consumers will respond positively to healthier eating education campaigns and
more relevant labelling information on packaged products in other environments. Once that has happened
it may lead to an increase in consumer demand for similar information when eating out in restaurants.
At that point we will want to be able to respond to any increase in requests for information from our
customers in the appropriate way.
9.2 Communication methods
In our full service restaurants the menu fulfils the role of the primary consumer communication tool. This
is supported by additional information provided on request by our waiting staV. We also make use of brand
web sites for restaurant location details, menus and restaurant facilities.
We believe there would be significant practical problems in providing a comprehensive breakdown of
nutritional and other information in the form given on packaged products. If this were to become a legal
requirement the risk is that the menu would become an unwieldy and incomprehensible tome.
The idea of a “traYc light” system has been suggested and this simpler and more readily understood
mechanism could have some superficial appeal.
However, given the current attitude of consumers when eating in our restaurants it is a matter of debate
how much influence this additional information would have on the menu choices customers make.
There would also be significant practical diYculties. Significantly the introduction of such a system would
require a standard approach to be agreed and adopted to establish the statistical basis for each of the three
“traYc lights”.
For restaurants this would need to reflect the dish as served, including accompaniments and side orders
etc. It is diYcult to see how it could be applied in practice with both accuracy and consistency for the
following reasons:
— A very wide ranging portfolio of meals, including many ingredients.
— Individual ingredients within a dish may change during the life of a menu due to eg nonavailability/seasonality.
— Ingredients may be sourced locally.
— Particular diYculty in accommodating daily “specials” or additions to the menu.
— Nutrition content may vary according to nature of cooking method/equipment used. potential for
a wide range of “typical values”.
— Complex messages to be communicated simply.
— Don’t want to lose or devalue the lifesaving information regarding allergies.
These challenges are significant even for a company the size of Whitbread with branded, companymanaged restaurants, a centrally controlled supply chain and business relationships with a number of key
suppliers. They would be even more diYcult for SMEs in the restaurant sector to introduce.
9.3 Education programmes
We understand that all parts of the food industry have a responsibility to encourage our customers to
follow a healthier diet. The evidence of increased health risks associated with obesity is very worrying for
society as a whole.
However, we believe that the restaurant environment, with its focus on sociability and “treat”, should
take the lead from its customers in providing additional information about the food it serves.
In the meantime the key priority for us is the food safety issue associated with allergy information. In
addition Whitbread is responding to the healthier eating debate by working with suppliers to develop
healthier dishes with lower salt, sugar and fat content.
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Increasing public awareness of healthier eating requires a comprehensive communication strategy similar
to that associated with drink driving, car seatbelts and smoking. Schools also have an important role to play
in educating the young.
8. Conclusion
Restaurant customers are enjoying a sociable event and, as a consequence, have a diVerent attitude
towards their information needs than when shopping in a supermarket.
For this reason we would question whether the restaurant environment is the most appropriate to launch
a “healthier eating” initiative.
However, as consumers respond to the “healthier eating” message promulgated elsewhere we would want
to respond positively to requests for more information on those issues of most concern.
24 June 2004
Witnesses: Mr Neil Riding, Managing Director, Beefeater; Ms Paula Vennells, Marketing and Strategy
Director, Whitbread Restaurants, Mr Paul Farrow, Director of Food and Drink Procurement, and Mr
Mark Kerr, Public AVairs Director, Whitbread Restaurants, examined.
Q404 Chairman: Good afternoon and welcome to
this session of the Food Information SubCommittee. I understand that you want to make a
very short statement before we asked you our
questions. We are happy to take that if it is short
because, as you will appreciate, we are running a
little behind time. I would invite you to make that
statement and perhaps introduce your fellow
witnesses.
Mr Riding: Firstly, thank you for inviting us and
including us. Secondly, if I can introduce my
colleagues and what we do. My name is Neil Riding
and I am the Managing Director of Beefeater
Restaurants. My colleague Mark is the Corporate
AVairs Director for Whitbread, Paula is the
Marketing Director for Whitbread Restaurants and
Paul is the Procurement Director for Whitbread
Restaurants. We are here to represent Whitbread
and as such our views should not be taken as
representing the hospitality industry as a whole. I
have three points to make which might be helpful
before we do start. As you will see from our
submission, we operate a number of diVerent
brands, restaurants, cafés and health and fitness
operations. All of our outlets serve food and drink
and all our pub and High Street restaurants are table
service; that means that food is ordered from a menu
and then delivered to table.
those helpful and short introductory comments.
From the evidence that you have submitted in
writing, it would seem your view is that there is not
a need for the restaurant/pub/café sector to be
required to provide food information but you said
that you would question whether restaurants were
the most appropriate environment to start to
promote a public education process of healthier
eating. Is it not somewhat irresponsible to suggest
that your sector does not have a duty to its
customers in this way? With people spending more
and more money eating out, drinking out and
whatever, is there not a strong case for the
requirements for food information being much
stronger in your sector? People are trying to eat
healthily and in what they buy from the
supermarkets, so is that message not going to then
be negative if they are not getting information from
people like yourselves?
Mr Riding: We have a role to play and there are a
number of bodies here that have a role to play in this.
The point that we were highlighting here is the
nature of our business and that people tend to treat
it as a bit more of an indulgence, a bit more treat and
it is a lot less regular than a meal occasion at home,
for example. Research would tell us that people tend
to not perhaps take into account health issues in the
same way as they would in a supermarket, for
example.
Q406 Chairman: Is it not up to consumers to make
their own decision about how far they want to treat
themselves in spite of what is necessarily the most
healthiest option? Surely, there should be the
information available in order that they can make
the choice. For example, would it not make sense to
provide information about alcohol units in drinks?
Mr Riding: We do provide alcohol information.
Outside a very discrete area of food allergies and
intolerances, we do not get asked for that type of
information. Again, it is the nature of our business.
If people come out, it tends to be with family or with
friends, it is a weekend and they may not have been
out for three or four weeks or whatever and people
tend to suspend their judgment as to what might be
healthy or not. The other thing that we would point
to is that people tend to select from a wide range of
items on a menu and that could be anything from the
full steak with chips through to salads.
Q407 Chairman: If I went into your restaurants,
would I find information about the alcohol units and
the drinks on the menu or would I find information
about the calorie content or other food information
on the menu?
Mr Riding: On the menu, you would find a brief
description of what the meal comprises. It is a legal
requirement to actually tell people what the alcohol
content is and that is made available to people. What
you would find is a message on the menu which
suggests that if you are worried about content
because of allergy or intolerance, you should ask a
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Mr Neil Riding, Ms Paula Vennells, Mr Paul Farrow and Mr Mark Kerr
member of staV and then what we do is supply—if I
can wave this before you—that, which is allergy and
intolerance information for one menu in one brand
and one of the things that we have to face is that,
when people come out and they want to get the
information they need from a menu, if we tried to
put all that on to a menu, what would that look like?
We clearly have a role to play in here somewhere and
it was fascinating to listen to our colleagues from
supermarkets as to what traYc lights may look like
because we would be extremely interested in taking
some of that learning and applying it to some of
our menus.
Chairman: It would be helpful if you could provide
the Committee with the document which you have
just been indicating, if you are able to do that.
Q408 Joan Ruddock: How often are you asked for
anything at all?
Mr Riding: In terms of allergies and intolerances?
Q409 Joan Ruddock: Yes. You have a notice saying,
“If want more information, ask us.” How often do
people actually ask you about anything?
Mr Riding: In an average restaurant, probably two
or three times in the evening and that would be
specific to allergies. I personally have an allergy to
dairy products. We had lunch in the Marriot Hotel
across the way and I asked if they could give me
some advice and they were able to give me advice
and actually cook me something to order that did
not include dairy. What we do not get asked for is
anything to do with nutritional content. Again, we
have a role to play in this but we see that this is a
going to be a start of a big educational journey and
clearly our role is going to grow. Where our role lies
alongside skills, some of the big supermarkets etc, we
are not quite so sure yet but one thing we are
absolutely sure on is that this is a big issue and it is
going to stay and get bigger for us.
Q410 Mr Jack: In paragraph six of your evidence to
the Committee, you say, “Currently our brands do
not as a matter of course provide nutritional
information” and you say that the primary reason
for that is that people do not ask for it. What do you
feel obliged to oVer people by way of information?
Mr Riding: At the moment, we oVer the information
that you see in front of you there which is what we do
get asked for, so that is specific to people’s identified
allergies and intolerances.
Q411 Mr Jack: In the same paragraph, you go on to
regale us with the information about, “All
Whitbread suppliers have been briefed on the
Company’s ‘healthier eating’ initiative.” That is
wonderful. Then you talk about “Product and
ingredient brief forms now include a requirement to
record salt, sugar and fat”, so you are building up
the awareness of all this stuV. Do you not think that
a simple message to customers, “In formulating our
menus, we have taken into account the need to
minimise blah-blah-blah” and give a message of
reassurance?
Mr Kerr: I think it is fair to say that the catering
industry has been slower into this debate than the
supermarkets. Our research consistently shows, as
Neil said, that the majority of people are not
interested. Indeed, there is quite a chunk of people
who actively do not want to know because of the
nature of the experience they are going to have in a
restaurant. However, it would be naı̈ve of us and
stupid to not assume that customer reaction might
change over time, partly because of initiatives that
the supermarkets and others have taken. As a
consequence, we have started from perhaps a
standing start with our suppliers to look at the issue
of salt because that was one that the Government
particularly wanted us to look to and, at the same
time, we took fat and sugar on board as well because
it seemed fairly self evident to us that they were going
to be the next targets. So, this is the beginning of the
piece of work which has been going now for around
12 to 18 months. It is exceptionally complex for us
to do it for a lot of the reasons that were described
earlier by the supermarkets multiplied by the fact
that we are serving dishes not packaged products, so
it does become more diYcult. What this was meant
to identify is that we are not doing nothing. What we
are doing is getting our information in the right place
and, when the customer identifies the fact that they
would like that information, we will then be able to
react with accurate information in the right form but
we do not know what form that would be and we do
not quite know when the customer is going to make
that request in our environment.
Q412 Mr Jack: One of the things that forms part of
the Whitbread oVer are David Lloyd leisure centres.
Bearing in mind that people who go to enjoy those
facilities are pretty clued up about exercise, fitness
and diet, do you oVer any special information to
your customers in those environments?
Ms Vennells: Yes, we do. On the menus in David
Lloyd, we make healthy suggestions/observations
on the menu pages and the menus are designed more
from a healthy eating point of view and the simple
reason for that is that that is actually what those
customers have asked for.
Q413 Mr Jack: Do I deduce from that that those
who are the self-selecting segment of the market who
have decided that healthy living is what they want
are happy to have their knowledge base advanced
but the rest of your customers who do not appear to
be in that category do not get any help at all?
Ms Vennells: They are not in the same category at
all. David Lloyd customers are in David Lloyd
leisure centres because they are expending calories
and they snack occasionally when they are there. It
is not a big part of David Lloyd at all. The customers
who come into Whitbread’s other restaurant brands
are there for a family treat in the vast majority of
cases which are very, very diVerent usage occasions
altogether. As Mark said, if the customers coming
into our restaurants want that information, we will,
over a period of time, be able to give it to them. The
challenge for us that we are really struggling with
and it was, in a sense from my point of view, not
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helpful in hearing the supermarkets because, if they
have problems with labelling, then for me to think
how I get nutritional information on to a menu is
very diYcult. We are having conversations and we
met recently with the FSA and shared with them the
work that we are doing. We are coming here to say
that we are very aware of this, we realise it is
important, but Whitbread has for hundreds of years
been a very responsible company and we are
continuing with that approach. However, we do not
actually know what the answer is just yet.
Q414 Joan Ruddock: There is a huge diVerence if
you are oVering a fatty mixed grill with big chips and
loads of salt and it is delicious—I can hear Michael
salivating away there!—and a huge great sugary pie
with masses of cream and chocolate droppings on
the top swilled down with a few lagers and having the
pasta with some fish, salad and a glass of red wine.
You know that there are extremes and you
presumably are able to oVer the various dishes
within that spectrum. So, something could be done
but what you seem to be saying is that because the
customers are not asking for it, you do not feel the
need to lead them and, to me, that is where the
challenge seems to lie for your industry and I would
say that your responsibility lies there. Of course, you
cannot have pages of labelling but there are ways of
demonstrating that some things are more healthier
than others and there are ways, I would suggest, in
terms of pricing policy, where it is possible to oVer a
dish with a cream topping or without a cream
topping and various moves could be made which
you could lead on and it seems to me that you are
saying, “We don’t have to do this because nobody is
pushing us.”
Mr Riding: I am sorry if we gave that impression. I
will give you an example. If you eat in a Beefeater
Restaurant now and you order the big steak, then
you will be oVered a choice of salad, jacket potato,
wild rice or chips. So, we are trying to give people
that option and it is within people’s comprehension
that rice is going to be better for them than perhaps
the chips.
Q415 Joan Ruddock: Not if they do not want to
know, which is what you have said. If we are to help
people, if we are to have labelling which is perhaps
going to prompt people to think before they actually
make the order, then usually people have to see it
with their own eyes, so some labelling would, I
suggest, make some diVerence to some people.
Mr Kerr: From our perspective, the diYculty you
have identified is clearly, on every menu, you could
choose, as distinct from your choice, an obviously
healthy starter and a fruit salad pudding. The choice
is obviously there. If you are suggesting the traYc
light kind of notion, then, as we have said, as the
ideas of how that might be introduced are
developed, we would be very interested to look at
that in a positive way despite the fact that a dish is
diVerent from a packaged product and we are going
to have to be careful about how that would be done
on a menu. There are other ways, for example
websites that can be used for that kind of
information but that is not terribly helpful when you
are sitting at the table making your choice. I think
that the choice is there; we will increase the oVer of
food on the menu that will reflect what customers
want because it is commercial business and, as I said
before, the depth with which the other food
suppliers, supermarkets and others, get their
education into the psyche will determine how people
make the choices on restaurant menus.
Mr Mitchell: What a terrible puritan you are! I do
not go into a restaurant to have sermons preached at
me about what is good for me or to have a label on
the huge chocolate cake saying, “This will make you
fat.” I go in to eat it
Joan Ruddock: We have it in the House of
Commons.
Q416 Mr Mitchell: We have a diVerence in the
House of Commons in that the restaurant actually
does provide small portions of healthy food. Surely,
all these comments could be catered for by having a
kind of healthy option menu as well as the gorge
your guts menu?
Mr Riding: It takes us a long way there. The point I
was going to make about the chips or rice etc is that
most people still plump for chips. We have had fresh
fruit salad on the menu and you would be amazed at
how little we actually sell of it. Until we get to a stage
where, out there, the public maybe has a deeper
understanding of this and is prepared to have the
weekly/fortnightly indulgence as part of the
balanced diet as opposed to a complete step aside
from it, I think we are still going to have a deafening
silence. And w have asked people what nutritional
information they want. What we are saying is that
we are trying to move where we can and we would
need to find something that was publicly
recognisable like a traYc light that could be
transferred into a menu that did not make it look like
war and peace and would deter people.
Q417 Mr Mitchell: Do you have a healthy options
menu?
Mr Riding: We have items on menus which are—
Q418 Mr Mitchell: Starred or asterisked?
Mr Riding: No.
Q419 Mr Mitchell: Would it not be better to do that?
Not to turn it into War and Peace but you just have
to oVer a couple of dishes for people like Joan, not
like me!
Ms Vennells: I do not think we are saying that we
would not do it, I think we are saying that,
genuinely, we would be very interested in finding a
solution because, responsibly, we think it is a good
thing to do. You heard earlier of the diYculties if
you start having traYc lights on fat and salt and
sugar and it is quite how you make that work on a
menu. We had, just a couple of years ago, an
arrangement with Weight Watchers, so we had
Weight Watchers points on one of our brand menus
and, actually, it was singularly unhelpful.
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Q420 Mr Mitchell: Why?
Ms Vennells: Because the research back from the
majority of customers was that, when they come out
for a treat, they do not want to be told that they are
having their total calories in one particular dessert!
There is a very fine balance that we have to strike
on it.
Q421 Chairman: What if your customer wanted to
have information not just about issues relating to
nutrition but, for example, issues such as animal
welfare considerations and the way food was
produced and whether or not they were concerned—
and this is back to a nutritional issue—about a
product having GM ingredients? Would they be able
to get any of that information either on the menu or
from the outlet or in some way easily from your
business?
Mr Kerr: Certainly we have traceability across our
supplier base in terms of animal welfare and whether
our products and the specifications—
Q422 Chairman: I was not so interested in
traceability, I was asking whether the customer
would be able to get the information relatively easily
either at the point of sale or by some other means.
Mr Kerr: Yes, we have the ability to get the
information to the outlet and then we are reliant on
the staV in the outlet answering any questions that
are fired at them from the consumer. One of the big
challenges we have is that we are trying to operate a
menu perhaps over the duration of six to 12 months
and therefore, to ensure continuity of supply, we
might be ordering from up to three or four diVerent
countries. So, it again provides another challenge to
us to get consistent information through to the
outlet staV.
Q423 Mr Jack: What training do the staV get to
answer all these questions?
Mr Riding: We do not want to mislead anybody. If a
customer came in and said, “Where did that Brussels
sprout come from?” our people would not know
that. The information exists within the supply chain
but it does not get put on a menu in any way that
people would recognise that if they walked into a
Brewer’s Fayre on a Saturday Night. The specific
training that we give people is particularly around
allergens and intolerances because that is the bit that
people really do want to know there and then. If I am
on a gluten-free diet, what can I and what can I not
eat? That is what we get asked for a lot. Also, a more
very, very friendly attitude in that, if people do want
the dessert without the extra cream, let us take the
cream oV and let us not charge them for taking the
cream oV. Let us be very flexible around the
foodstuVs that we oVer. So, we are clear, if
somebody came in and asked where a particular
piece of protein came from, they would not know.
Q424 Chairman: I can see how there are diYculties
in the catering industry in providing the kind of
information we are asking about and there are the
diYculties also in the kind of messages that the
consumer wants to read, but could I suggest to you
that this is an area which perhaps you should be
paying more attention to and looking at ways in
which the customer can have that choice made
available to them. I notice that one of your outlets
is the Costa CoVee chain and, if you go into most of
those, you will see a wide range of croissants, cakes,
biscuits and other material for sale and I am not
aware of information being provided at the point of
sale about calorie content, sugar content and
information of that nature. Is that not something
that is quite easy to provide, for example?
Ms Vennells: That would be almost more diYcult
than providing it on a menu. We could certainly
make the information available if the customers
asked about it. I have never ever heard and never
come across in any research anybody in a coVee shop
asking for that because it does not even register on
their Richter scale of what they are doing in terms of
the snack or croissant they have. To make it
available for them at point of sale physically would
be diYcult because you are dealing with a smaller
space than the labels we were talking about before at
the supermarkets. I think, in terms of the priority we
have been putting on the work we have been doing,
it is about understanding whether we can apply a
traYc light system, once one has become available
that is user friendly within our restaurants, and we
could conceivably extend that to Costa CoVee shops
quite easily, but it would have to be information held
somewhere near the till and, in terms of the priorities
and the number of customers, I think we would be
better oV concentrating where we are currently
which is on our restaurants, but it would not be a
problem to extend whatever system we developed
for Costa.
Q425 Chairman: Is there not a duty—and I was not
wanting to pick out Costa to any great degree but
just as one example—on people like yourselves if
you are going to support the healthy-eating message
and support the eVorts against obesity to actually
provide that information in order that people can
know what they are purchasing and can then make
the choice themselves?
Ms Vennells: I think we would agree there is, yes,
and that is why the work we are doing is in place. We
do not have all that information available currently
but our biggest challenge is, when we do, the format
of how we make that available, which is why we
would be interested, very much, in getting involved
in debates around a traYc light system and why we
involve the FSA in the work we have been doing.
Q426 Joan Ruddock: Do you intend to import
genetically modified sweet corn now that it is legal in
the European Union?
Mr Kerr: We have a policy on GM food—the Soya
and maize issue came up some years ago where
labelling was required—to not have GM in any of
our products.
Q427 Joan Ruddock: So, you do not knowingly
have any?
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Mr Kerr: That is correct.
Q428 Joan Ruddock: That is held during the
moratorium but there is now a change clearly and we
are beginning to see marketing consents given for
importation into the UK; is the policy likely to
remain the same?
Mr Kerr: There has been no suggestion that it will be
changed.
Q429 Chairman: We have been asking questions of
yourselves and of the industry’s role in this area but,
turning now to the role of Government, can I ask
you whether you think you are getting a clear
message from Government on the issue of food
information? Do you find any diVerences in
approaches from diVerent arms of Government and
do you find that this causes confusion for the food
services industry?
Mr Kerr: I think I would agree with what has been
said earlier about that particular topic in that a more
joined-up approach would be helpful but, from our
perspective, there is a more fundamental issue in that
there is not suYcient understanding of the diVerence
between the food service sector and the other parts
of the food chain: the producers and the retailers. So,
a better start point for us—and we spend some time
trying to achieve this—is to educate anybody
frankly but Government departments, FSA and
others about what our industry is. Everybody
experiences it but they do not understand it. So,
some of the issues and some of the early discussions
around labelling, for example, were diYcult because,
from our perspective, it is not labelling anyway, it is
consumer information and there was not an
appreciation of that relatively simply diVerence. So,
I think that, yes, a more joined-up approach would
be helpful. I would not lay criticism in any particular
direction, I am sure it is something that we are all
trying to achieve but it does not look as if we are
getting there quite yet. More fundamentally, a better
understanding of our sector would be the most
important factor.
Chairman: Thank you very much indeed for your
answers to our questions this afternoon and that
concludes the Committee’s questions to yourselves.
We are very grateful to you for coming along and, if
there are any points of further elucidation which you
would find it helpful to provide to us in writing
following your evidence this afternoon, we would be
very happy to hear from you. Once again, thank you
very much for coming along.
Memorandum submitted by McDonald’s Restaurants Limited
1. Introduction
1.1 McDonald’s Restaurants Limited welcomes the opportunity to contribute to the House of Commons
Environment, Food and Rural AVairs Select Committee’s Inquiry into Food Information. We are proud
of the food that we serve in our restaurants and we aim to deliver the UK’s best quick service restaurant
experience. We are committed to serving hot, fresh, great tasting, good value food to all our customers and
providing them with the information they need to make an informed choice from our menu.
1.2 We are conscious that eating habits and lifestyles are changing, and that food choice and nutritional
issues are of increasing importance to our customers. We believe that we have an important role to play in
informing the two and a half million customers whom we serve every day in a number of key areas:
— The nutritional content of our food and drinks.
— Balanced diet and healthy lifestyle.
— Food safety.
— Food origin and means of production (including ethical considerations).
1.3 In the pages that follow, we provide further details about what we have done in the UK in each of
these important areas and what we currently have planned for the future.
2. About McDonald’s Restaurants Limited
2.1 McDonald’s opened its first restaurant in the UK in October 1974. We now have 1,235 restaurants
in the UK, representing a total investment in property and equipment of over £1.6 billion. The Company
employs over 45,000 people, with over 25,000 more employed by McDonald’s franchisees. We serve food
and drinks to around two and a half million customers in the UK every day.
3. The Nutritional Content of our Food and Drinks—General
3.1 The McDonald’s menu oVers a choice of food and drink made from basic ingredients including red
and white meat, fish, eggs, milk, grain and vegetables, all of which are produced to the highest standards of
quality and safety.
3.2 We are constantly looking at ways to improve the nutritional value of our food and drink, whilst
maintaining the great taste that our customers enjoy. Our menu evolves over time, reflecting the changing
tastes of our customers. Fifteen years ago, we did not have the choice of main meal and side salads, grilled
chicken, fish, mineral water, non-meat meals, diet drinks, semi-skimmed organic milk, yoghurt and fruit that
we now oVer.
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3.3 In recent years, we have made a number of nutritional changes to our menu in response to customers’
changing needs, including the following:
— Lard has been replaced in buns with a smaller quantity of vegetable oil.
— Mineral water, pure orange juice, diet Coke and cartons of organic semi-skimmed milk are
available in all restaurants.
— A low calorie sweetener is available as an alternative to sugar.
— The formulation of sauces has been improved to reduce oil levels.
— Cooking oil has been changed to reduce the saturated and trans-fatty acid content.
— Free-range eggs are used in all our breakfast oVers.
3.4 This has continued with further innovations over the past 12 months including:
— Introducing our new “Salads Plus” range, which will ensure that convenient and aVordable main
meal and side salads (including a choice of two warm grilled chicken salads) will be available to
more British people than ever before. The range also includes a new grilled chicken sandwich,
Quorn sandwich, fruit and yoghurt dessert and apples.
— Introducing organic semi-skimmed milk that can be included as a part of a Happy Meal.
— Introducing fruit bags in April 2003. The 80g Happy Meal Fruit Bag is equivalent to one of the
Department of Health’s five-a-day recommended daily intake of fruit and vegetables and can be
eaten as a dessert or swapped for French Fries in our Happy Meal. Since their introduction we
have become the largest single retailer of pre-prepared fresh fruit in the UK and have delivered
more than 10 million portions of fruit to British customers.
— Introducing other new choices within the Happy Meals range such as Robinson’s Fruit Shoot (a
high juice, no added sugar drink).
3.5 These changes stem from the on-going dialogue we have with our customers and ensure that
McDonald’s continues to provide them with what they want—more choice and variety.
4. Providing Clear Nutritional and Other Information to our Customers
4.1 McDonald’s supports the principle of providing clear information to customers about our food and
drinks. We believe that many customers want to make informed individual choices about the food and
drinks that they consume in the context of their whole diet and exercise regime.
4.2 The labels on all of our pre-packaged foods of course contain nutritional information. However, our
eVorts in relation to most menu items have been concentrated on providing information to customers before
they make their purchase. Unlike supermarkets, for example, where food items can be picked up and labels
read before purchase, in the case of restaurants serving hot, fresh food, at times made to individual
preferences, labels will not be seen until after the food has been served.
4.3 In 1984, we were the first UK quick service restaurant company to provide customers with nutritional
guidance and ingredient information on all our food and drink. The current version of this “Our Food”
leaflet, which is available in our restaurants. As well as nutritional information, the leaflet contains full
country of origin information wherever possible, and full allergen information, in addition to our policies
on key food issues such as Genetic Modification.
4.4 This nutritional information is also available on the McDonald’s UK website
(www.mcdonalds.co.uk), alongside an interactive menu planner, via our Customer Services Helpline and
on the back of our trayliners for customers to take away with them if they wish.
4.5 Also available in our restaurants is our “five-a-day” leaflet, written by nutritionist Anita Bean BSc,
R.Nutr, which provides parents with easy-to-use guidance in the form of facts and tips on ensuring that
children eat five portions of fruit and vegetables a day.
4.6 We are also in the process of introducing nutritional training for our staV. We want to make sure that
our employees have all the information they need to make the right choices for their lifestyle. Our ongoing
Eat Smart, Be Active campaign, aimed at customers and staV, gives guidance on healthy eating, nutrition
and physical exercise and will be incorporated into our employee training programmes over the coming
months (see www.goactive.com).
4.7 We also understand the desire for, so far as practicable, a consistency of labelling applied across the
European Union, and McDonald’s, as a representative of the European Modern Restaurants Association
(known as “EMRA”), is an active participant in the food labelling issue, working as part of the EU Food
Labelling Steering Committee. The Committee, made up of representatives from consumer organisations,
industry and euro-commerce, acts as an advisory group to the Commission, looking at new approaches to
food labelling.
4.8 We recognise the growing desire for more information on the food we eat and we will continue to
look for new and innovative ways to communicate information to our customers so as to improve its scope,
clarity and accessibility. We are currently testing a number of diVerent approaches in diVerent markets
across the world, and will closely monitor the response of our customers. For example, our colleagues in
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the United States are testing the provision of nutritional information on Happy Meals in parent-approved
and child-friendly ways, with the objective of helping families make informed choices and learn ways to
achieve a good food/energy balance.
5. Food Safety
5.1 Food safety is of the utmost importance to McDonald’s. We serve two and a half million customers
in the UK every day and they trust and expect us to serve safe food. We pride ourselves on core values such
as quality, service and cleanliness and have developed leading hygiene and food safety systems over many
years.
5.2 Our commitment to food safety encompasses the entire supply chain from raw material production
through to our restaurants. As customers in our own right we demand high standards of our suppliers. Our
food and drinks are made to exacting specifications and we work closely with our suppliers to ensure that
both the highest food quality and food safety procedures are in place throughout the sourcing and
production process (please see further comments in paragraphs 6 & 7 below).
5.3 At restaurant level, our comprehensive Crew Development Programme (CDP) trains our staV in food
handling and hygiene procedures. Observation checklists and regular audits are used to ensure that correct
procedures are followed and to verify the eVectiveness of the hygiene and safety training. Many of our
standards with regards to food safety exceed or significantly exceed legal requirements.
5.4 The Company has a Hygiene and Safety Department under the leadership of a Department Head
with many years experience in this area. We also utilise the services of leading external consultants when
required.
5.5 Lack of consumer understanding of the supply chain can result in uninformed and specious criticism
of the food industry as well as confusion in the minds of the consumer over food issues. It is therefore
important that we inform our customers about the safety and quality of our food in an accessible and
eVective manner. We believe that such communications not only promote our own standards, they also
reinforce the general importance of matters such as hygiene in food preparation.
5.6 In the autumn of 2003, we ran a programme called “Open Doors”, which allowed members of the
public to have a behind the scenes tour of McDonald’s restaurants. One hundred and twenty restaurants
opened their doors to the public to tell them more about our food, our people and to show them how their
meals are prepared within our restaurants. We will be undertaking a larger “Open Doors” programme this
year, to coincide with National Food Safety Week between the 14 and 20 June, and will include visits to
suppliers as part of the programme.
5.7 We also ran an advertisement in the first part of 2004, featuring Chris Eubank, and focussing on the
hygiene and safety procedures that exist within our restaurants. Most McDonald’s advertising is about our
food, but we know that the public is also interested in clean restaurants and safe food. We plan to run similar
advertisements later in the year.
6. Food Origin & Means of Production
6.1 Consumers expect the food chain to provide diversity, choice and quality products at a reasonable
price. McDonald’s serves as a conduit for the views of consumers at the retail end of the food chain through
regular consumer research and focus groups. Those views are then channelled back so that they are taken
into consideration and addressed further up the chain. Ours is, we believe, an enlightened, consumer-led
approach to the management of the supply chain.
6.2 The demands we place on our supply chain are considerable. Our expectations are that the supply
chain should deliver quality, safe products that meet our standards, that these are delivered reliably,
eYciently and competitively priced, and in the quantities that our customers require. The need for
traceability and product integrity has brought about a much closer relationship between suppliers
throughout the supply chain, particularly producers.
6.3 In 2002, we launched the McDonald’s Agricultural Assurance Programme (know as “MAAP”), a pan
European programme that defines the standards we expect of suppliers operating throughout our supply
chain, that demands high standards and best practice from farms and suppliers. Our seven general policies
determine the present and future development of our primary supply chain with regards to:
— environment;
— agricultural practices;
— animal welfare;
— animal nutrition;
— animal medication;
— traceability; and
— genetics.
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6.4 For each product, a number of standards define details for production throughout the food chain,
from pre-planting via cultivation methods, to harvest for arable crops, and from feed mill and breeder
animals, via husbandry including all transport for food animals. These standards often exceed or
significantly legal requirements.
6.5 In our submission to the Curry Commission in November 2001, we pointed out that one of the
diYculties which besets the food industry, at all levels of the supply chain, is a lack of consumer
understanding of how food makes the journey from farm to fork, and the quality of much of the food that
they consume on a daily basis.
6.6 For this reason (and the reasons stated in paragraph 5.5 above), through a number of campaigns
McDonald’s has sought to inform consumers of the quality of the ingredients used in our food and drinks,
and to re-connect them with the supply chain. Our quality campaign, which has been running since 2003
across various forms of media, has focused on our main ingredients, including beef, eggs, potatoes and
chicken.
6.7 In addition, our organic milk and and free-range egg campaigns, which also ran throughout 2003, have
focused upon the means of production and in April 2003 we won the Good Egg Award for our use of freerange eggs. Our switch to organic semi-skimmed milk, and re-design of the packaging, have seen our milk
sales increase by 26% reflecting the general public’s growing interest in organic produce.
7.1 An ethical and sustainable supply chain is of utmost importance to McDonald’s. A great deal of work
is already being undertaken by the industry with a view to identifying alternative, sustainable and
commercially viable farming methods. Part of our approach in this area is through MAAP since the
enforcement of high standards and best practice from the farm to the point of final sale by large players in
the food industry, such as McDonald’s, is key to the maintenance of an ethical and sustainable supply chain.
7.2 Each of our direct suppliers, wherever they are located, is required to comply with McDonald’s strict
code of conduct for suppliers that covers matters such as employment practices. Deviations from this code
are not permitted.
7.3 We use our “Our Food” leaflet to inform customers about some of our sourcing policies, including
those on animal welfare and Genetically Modified produce, and we are currently working with our suppliers
on a supply chain charter.
7.4 We are founder partners of the Food Animal Initiative, a project founded to bring together top
quality scientists with farmers and the food industry to find solutions to the issues and matters of social
concern now facing the farming industry. It aims to develop and promote practical and sustainable
agricultural practices, which will be good for animal welfare, the environment and the public.
7.5 FAI operates on several sites across the United Kingdom, but primarily from a farm close to Oxford.
FAI holds a number of open days and courses for the general public, looking at how everyday foods are
produced and incorporating a tour of the working farm. In addition, there is an education service running
introductory courses on agriculture for children and providing teachers that explain production systems and
the issues relating to the supply chain.
8. Conclusions
8.1 With food and nutrition issues taking on a greater importance than ever before, it is important that
the consumer is able to make informed choices on all elements of their diet and that they understand how
these choices fit within the context of their own lifestyle.
8.2 McDonald’s has for many years provided clear and relevant information about its food and drinks
to customers and is committed to seeking ways of improving the scope, clarity and accessibility of this
information.
8.3 McDonald’s, with its considerable customer base, can, and seeks to, play an important role in
reconnecting the consumer with all aspects of the supply chain and in educating the consumer on issues
related to food production and food preparation.
8.4 Programmes such as Open Doors and the Food Animal Initiative have provided customers with firsthand insights into our food practices and we have an ongoing programme of communication through
literature available in our restaurants, advertising and promotions to ensure they are kept informed.
8.5 We are committed to working with Government to promote better understanding of food issues
amongst our customers and the wider public.
19 April 2004
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Witnesses: Mr Julian Hilton-Johnson, Vice President with responsibility for Corporate AVairs, and Mr Keith
Kenny, Head of Quality Assurance and Supply Chain, McDonald’s, examined.
Q430 Chairman: Good afternoon and welcome to
the Committee. We understand that we have Julian
Hilton-Johnson who is the Vice-President with
responsibility for Corporate AVairs, and Keith
Kenny, Head of Quality Assurance and Supply
Chain. Thank you for first of all submitting written
evidence to us and for coming along this afternoon
to answer our questions. Could I begin by asking
you what, in your experience, is the way consumer
attitudes towards nutrition have changed in recent
years and what research you are carrying out to
monitor these changes?
Mr Hilton-Johnson: I suppose that could break
down into two diVerent areas: firstly, the actual
information side and, secondly, the actual product
side, and obviously they are very closely linked.
There clearly is a change in consumers’ attitude to
food. There could hardly not be particularly over the
last couple of years with everything that has gone on
in the media, Government and elsewhere and that is
why, for example, we made the biggest change to our
menu in the 30 years we have been in the UK by
introducing what we call the Salads Plus range which
includes salad and also a number of other items such
as that. We do have quite a lot of research—and I
cannot think of any one particular example because
there are many—which does suggest that there is a
much greater interest in food and in food being
freshly prepared and so on. It is a much more
diYcult answer in relation to nutritional
information because whereas, particularly with
what is happening in the media and elsewhere,
people are much more interested in not only the
ingredients of their food but also the nutritional side
of it, there still is not a huge take-up of that interest.
We, for example, produce a number of diVerent
booklets—I will not go through all of them—and
this is the principal one and we have produced this
since 1984 in one shape or form and made
information available on our customer service help
line, through the Internet and so on and so forth.
There is a greater take-up but it is still not a huge
take-up.
Q431 Chairman: On the question of take-up, that
leads me quite nicely to my next question which is,
in preparation for this Committee this afternoon, I
did some customer research in my local McDonald’s
in Edinburgh at the weekend and indeed the Salads
Plus range was very prominently advertised
throughout the store and there is certainly no
criticism of yourselves for that, but it did not seem
that many of the consumers were partaking of the
Salads Plus range. I would be interested in knowing
what is the actual take-up of sales of the newer
ranges that you have brought on to the market.
Mr Hilton-Johnson: Our customers told us what that
they like our hamburgers but that they want more
choice and more variety, so that they would come in
and visit us more often or perhaps they would come
in and visit us the same amount but have something
completely diVerent. We have sold 3.5 million salads
to date since they were introduced at the end of
March and those are main meal salads, and we have
also sold about 410,000 side salads. I think that
makes us the third biggest seller of salad in the UK—
I think that is right—after Tesco and Sainsbury and
we went into that position overnight. Clearly, there
is a perception that McDonald’s is about
hamburgers. We have changed our menu very
significantly over the 30 years that we have been in
this country—at one time we did not have chicken
nuggets—and we have made all kinds of changes but
there is still a perception that McDonald’s is about
hamburgers for some people. My own personal
belief is that that number will continue to rise quite
significantly.
Q432 Chairman: With those millions, how much is
that in terms of a percentage of the overall sales
during that period? Is it significant?
Mr Hilton-Johnson: It is about 200 salads per
restaurant per week and, in terms of percentages, I
do not have an exact number but it is something, I
would think, probably round about the 10% mark
but I can find out exactly.
Mr Kenny: For the total Salads Plus programme, it
is round about 10% on sales.
Mr Hilton-Johnson: We have a slightly unusual way
of calculating percentages which I think is
misleading, but I would imagine that somewhere
round 10% of meals have a salad with them.
Mr Jack: I am rejoicing in the new McDonald’s
maths that you have disclosed—new percentages!
Q433 Chairman: It would be helpful if you could
provide information in writing afterwards.
Mr Hilton-Johnson: Certainly.
Q434 Mr Mitchell: There was an article in The
Guardian which I read and I see that it is quoted in
our research notes that McDonald’s was down in the
dumps a year ago, it was in deep trouble, share prices
had dropped steadily and its decades of remarkable
growth seemed over forever yet, 16 months later, the
company registered 12 continuous months of
growth and an astonishing 22% increase in February
and share prices doubled. Does this have anything to
do with your attempts to change the menus and
provide healthy eating options?
Mr Hilton-Johnson: Yes, absolutely it has, but it is
not just that. I think what we have done across the
world, including in the United States which is still
where half of our restaurants are located, is that we
have looked very carefully at what it is our
customers want and they have told us that they want
better restaurant facilities, they want our premises to
be spick and span and more up to date and more
contemporary, they want us to concentrate on
serving food that is hot and fresh but they also said
that they wanted better variety in the food and that
is why this Salads Plus range was introduced. So, it
is part of the answer but by no means all of the
answer. The other thing I would add to that is that
obviously if you introduce a range such as Salads
Plus—and we have had salads in the UK on and oV
over the years but the honest truth is that they have
not always been successful—the key for us is to get
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Mr Julian Hilton-Johnson and Mr Keith Kenny
the right salads, which we believe we have done, but
then to market them in the right kind of way and we
have put in a very significant proportion of our
marketing budget this year behind our Salads Plus
range, I think somewhere in the region of £15
million.
Q435 Mr Mitchell: Do you carry out research as to
what customers want here or do you just take the
findings from the American research?
Mr Hilton-Johnson: We obviously look at the
American research and we look at the Australian
research and we look at research from other
European countries because it was a range that was
introduced across 16 diVerent European countries at
more or less the same time. So, it is partly the UK
and partly wider afield.
Q436 Mr Mitchell: I am all in favour of healthy
options but, on the other hand, it must make the
running of a very highly programmed organisation
like McDonald’s—I think you have eYciency down
to a fine art with suppliers and the way it comes in,
the menu and the serving—far more complicated.
Mr Hilton-Johnson: Yes, it does, absolutely. We run
essentially the same food across a number of
diVerent countries and it can be a challenge of course
providing people in diVerent countries with what
they want because that does vary. So, there are some
local variations.
Q437 Mr Mitchell: Is it more expensive to run it with
more options?
Mr Hilton-Johnson: Obviously, the more options
you have in a particular restaurant, it is more
expensive and it gets more complicated but, if we are
in a wider and much bigger supply chain, there are
eYciencies that can be achieved there and there can
be eYciencies in marketing and other things as well.
Mr Kenny: There are obviously only a limited
number of menu items that we can sell through our
restaurants and adding the Salads Plus programme
has complicated quite significantly the amount of
products that are coming into the back door. We
have also had to invest in equipment to prepare
those salads in the restaurant. So, it has significantly
complicated the operation.
Q438 Mr Jack: This inquiry, amongst other things,
is looking at the messages that people receive and
believe in the context of the food they eat. Let me just
ask first of all for a piece of information: on
average—and this is the normal average, not the
McDonald’s average!—how many customers do
you get through your restaurants a week?
Mr Kenny: We serve about 2.5 million customers a
day in the UK.
Q439 Mr Jack: The reason why I ask that question
is that McDonald’s as a company has, ever since it
has been in the United Kingdom, prided itself on the
quality of the ingredients that it has used but it is part
of an industry that has acquired the label “junk
food”. You have prospered against a background of
“junk food”. What message have you given to your
2.5 million customers that enable them to have
confidence that they are not buying junk from
McDonald’s but that they are buying something
which I presume they would see as nutritious,
healthy, wholesome, good to eat, etc and not junk
which, by implication, means doing harm to them?
Mr Hilton-Johnson: I think we do that in a number
of diVerent ways. I have referred to leaflets that
provide information about our food—
Q440 Mr Jack: If I can be rude and interrupt for a
second, you said in your introduction that you did
not have an enormous uptake of that. Out of the 2.5
million that go in a day, how many go away with a
leaflet?
Mr Hilton-Johnson: Not many and that is why we
supplement it, for example, with quality campaigns
that run in magazines and on the television: we ran
those earlier this year and they related, for example,
to beef quality—some people question what goes
into our hamburgers and we say it is 100% beef. We
focus on other things as well such as cleanliness. You
can take the way in which we have reacted as well to
various food scares into consideration in
considering how our customers react to us. I think
we were able to secure a fairly significant amount of
trust amongst our customer base, for example, at the
time of the BSE crisis in 1996 where we very
regrettably took British beef oV our menu but it was
because our customers told us that they had no
confidence in it. We polled them pretty much on a
daily basis on occasions and put British beef back on
to the menu just as soon as we were able to do so.
Q441 Mr Jack: You say that you poll your
customers and that you give a lot of information.
What is it that the customers perceive is okay in
quality terms, in recipe terms and in everything?
They obviously put a lot of trust into McDonald’s
that the basic hamburger product, notwithstanding
what you have been saying about salads, is good
food to eat as I say against this background of a very
powerful message that you are part of the junk food
industry. Perhaps you do not accept that and
challenge me if I am wrong.
Mr Hilton-Johnson: I disagree with the fundamental
premise of junk food because I think it is misleading.
I think that most of our customers would
understand that a hamburger, for example, can fit in
as part of a balanced diet and that what is most
important to focus on would be, for example,
whether people have junk diets or not. I think that
people do understand that a hamburger, for
example, has more fat and more calories in it that an
apple or the fruit that we have introduced. They get
that fairly basic message.
Q442 Mr Jack: You have been bold enough to
provide the Committee with a document entitled
“Main Menu” which gives a very detailed
breakdown of some of the ingredients that go into
your product and you have provided the leaflet that
you have just mentioned. You seem to be willing to
help your customers where necessary with a great
deal of information but, as you probably heard from
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our previous witnesses who are in the “treats”
business where people go to enjoy themselves as
opposed to perhaps refuelling at McDonald’s, you
are willing to provide all this information because
you do not think that it harms your business, in fact
you see it as an attribute to the business, yet our
previous witnesses said that if they had indulged in
all of this, it would be a turn-oV. What is the
diVerence?
Mr Hilton-Johnson: I think we are very happy to
provide this information because we do not feel that
we have anything to lose by it. Perhaps it is not a
well-known fact that a Big Mac Meal with a diet
Coke contains less than a third of my recommended
daily intake of calories. It is actually quite a powerful
message. There are of course other products that we
sell that are higher in fat and calories. I think as well
there may be a diVerence between us and, say, a
company like Whitbread in their restaurant
operations in that we have a much more
standardised menu and it is easier for us to provide
information of this sort.
Q443 Mr Jack: You obviously feel an obligation in
a way or let us say a responsibility to provide this in
the eating-out world in which you operate. You have
a very positive philosophy of wanting to advise your
customers.
Mr Hilton-Johnson: We do provided of course that
it does not interfere with what I might broadly call
“normal restaurant operations”. We are a fast
business and we have to allow people to make
choices very, very quickly but we do not feel that we
have anything to lose in terms of talking about the
content of our food because it fits into and can be
part of a balanced diet and it is as simple as that.
Q444 Mr Jack: And you almost felt an obligation,
I think you indicated earlier when you were talking
about the introduction of salads, to move towards
this diVerent oVer in terms of food as a result of the
noise from Government and customers.
Mr Hilton-Johnson: The noise principally I would
have to say or almost exclusively from customers. It
would be fairly pointless for us to put something on
the menu because the Government wanted us to if no
one bought it.
Q445 Mr Jack: Do you think the very fact that
McDonald’s oVer salads in the way you are doing
now is sending out a very powerful message to food
consumers that this is the way they ought to be
going? In other words, you have reacted to the
market but you could also be said by that message to
be driving it.
Mr Hilton-Johnson: There is a possibility that that
kind of message is getting out. It is not why we have
done it—as I said, we have done it because our
customers say they want it—but because we serve a
very large number of people and the fact that we are
doing it, I am sure that some people will take that out
from it, yes.
Q446 Mr Jack: Do I conclude from that that there
is a powerful interplay between the oYcial messages
which oYcial bodies, Government, the Food
Standards Agency are putting out about what
people ought to be eating and the perception of the
wider public of what that means to them and
somehow it gets translated into a message back to
you that we would like more choice and more salads?
Is it as chainlike as that or not?
Mr Hilton-Johnson: I have never thought about it
specifically in that kind of way but I understand the
point you are making. I think the key for me is that
companies such as McDonald’s that are large and
that serve a large number of people every day can
very much be a force for good in the whole obesity
debate. As I have said, we have sold 3.5 million
salads since we introduced the range on 29 March.
People come to us and, with respect to Government,
they probably trust us a lot more than they trust
Government. So, if the industry can engage properly
with Government, the messages will be very, very
powerful. If the industry does not engage with
Government or if Government send out confused
messages, then it is going to be much more diYcult
for people to understand messages about healthy
eating. We fundamentally believe that our product
range, our food and drinks, sits very easily within a
balanced diet and a healthy active lifestyle and that
is why we are very, very pleased to engage and we
have done a fair amount, partly through things like
this five-a-day leaflet—I have to say that we have not
been prosecuted for it yet; I did open and check it a
few moments ago—in which we say, “Keeps kids
healthy and boosts their immunity” which I think we
can probably get away with! I forget how many of
these leaflets we produced but they were in the
hundreds of thousands and, because they have been
written in an engaging way and probably because
they are written by McDonald’s, I think they are all
the more powerful.
Q447 Joan Ruddock: I am a little puzzled and, as I
had to dash out, maybe it is my fault. This is a piece
of information about the food that is on the main
menu. This is not your main menu.
Mr Hilton-Johnson: I am sorry, what are you
looking at?
Q448 Joan Ruddock: The one you distributed. My
reason for asking, if I can just explain it, is that this
does not include chips, it does not include any of the
salads, just meat, cheese and some vegetables but not
salad dishes. As I understand it, you do main courses
which are a salad dish.
Mr Hilton-Johnson: Yes.
Q449 Joan Ruddock: But it is not on this.
Mr Hilton-Johnson: What you have there is an
extract from a book that is 38 pages long. This book
has been in existence since about 1984 in one shape
or form and Salads Plus is listed in it—we reprinted
it—and, at the same time that we introduced the
Salads Plus range, we gave information separately
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about it and one of these was given to each person
that bought Salads Plus for the first several weeks
that the new product range was available.
Q450 Joan Ruddock: Let me put to you what I see as
one of the diYculties. There are two issues. One is
that some people eat most of their meals in your
outlets or they buy them and take them away. I
know families who collect hamburgers for their
breakfasts or bring their children to sit in the outlet
and eat their breakfast. Have you done any analysis
of the frequency with which some people actually eat
in your establishments?
Mr Hilton-Johnson: Yes, of course.
Q451 Joan Ruddock: I would be interested to know.
Mr Hilton-Johnson: I am not an expert on it but the
average people will come in of the people who do
come in will come in between two and three times a
month. I think there will be extremely few people
who fall into the category to which you refer, with
respect. There may well be some but they will be
very, very few and far between.
Q452 Joan Ruddock: But it could be that that small
group of people, bearing in mind the millions you
are actually serving, are being seriously adversely
aVected by taking this limited diet which does still
have, I believe, quite a high fat and salt content.
Mr Hilton-Johnson: It would depend what they were
eating and it would depend what their lifestyle was
like.
Q453 Joan Ruddock: Some of us know of some of
these lifestyles, I can assure you.
Mr Hilton-Johnson: We have never advocated a onedimensional lifestyle and it is slightly diYcult for us
to police that particular aspect of our business. We
cannot stand at the front counter and tell people that
they have had enough in the way that you might be
able to if you were serving someone an alcoholic
drink and someone appeared to by slightly tipsy. It
is very, very diYcult to do this.
Q454 Joan Ruddock: If you were to move to some
kind of traYc light system such as has been
discussed, it would be more apparent were it to be
raised in public consciousness that they should not
be eating all reds every single day, for example. This
could be helpful, could it not?
Mr Hilton-Johnson: I think most people understand
that they should not be eating certain types of food
all day every day.
Q455 Joan Ruddock: Some people do not.
Mr Hilton-Johnson: I would suggest that those
people are few and far between. We are interested in
the traYc light system. We do see certain issues with
it given the fact that we are a restaurant business and
the fact that people need to be able to make their
choices about what they eat very quickly. We are in
the fast-food business and we have not endless but
a very large number of diVerent permutations in the
food that we sell and that make up a meal
combination. I also think—and I believe we have
research to this eVect—that people are more likely to
respond to positive messaging—“This is a good idea;
this is why this is good for you”—and, to be fair, this
is what we have tried to do in our Happy Meal than
to something which simply says, “No, there is a red
cross here or a red traYc light” whatever it happens
to be. My own view is that positive messaging about
benefits rather than negative messaging about bad
consequences is a better way to go.
Q456 Joan Ruddock: Obviously it was a positive
message to introduce salads.
Mr Hilton-Johnson: Yes.
Q457 Joan Ruddock: How do you respond to an
analysis—I think it was in The Guardian—that
showed that the salads with the chicken and the
salads with the bacon, or maybe it is a combination
of both, actually have as many calories as your
standard hamburger/beef burger?
Mr Hilton-Johnson: I am glad that you have asked
me that because it gives me the opportunity to
comment. Our salad range starts at a side salad
which contains 13 calories. You then have a range of
diVerent options that you can construct how you
wish to. My own personal favourite is a grilled
chicken salad that has 222 calories in it. If you
choose to have fried chicken, obviously it goes up. If
you choose to have dressing, it goes up even further.
If you choose to have croutons, it goes up further
still. I think it was a slightly unfair comparison
because these meals are main menu salads and the
comparison was not made against main menu, it was
compared to one hamburger only. So, I think it is a
little disingenuous to compare the two—I was going
to say “apples and pears” but that is probably a bad
pun. The fact is that the Salads Plus range starts at
13 calories and, for the full meal, it starts at 222
calories and these are large salads. Honestly, that is
my favourite salad and, because it has cheese in it,
my own personal view is that it does not need any
additional dressing or croutons.
Q458 Joan Ruddock: You said that a single Big Mac
and a diet Coke would only be a third of the daily
calorie intake, but what is the average meal going to
be in terms of a daily calorie intake if people have the
whole range, the chips and the sauces and the
additions?
Mr Hilton-Johnson: It would depend specifically on
what that was going to be.
Q459 Joan Ruddock: You told us where it starts;
where does it end in terms of calorie content for
your meals?
Mr Kenny: It depends what you have.
Mr Hilton-Johnson: If you have an ice-cream and a
large milkshake—
Q460 Joan Ruddock: Of course, but I am not
suggesting that you have six Big Macs, you know
what your people eat, what is the range?
Mr Hilton-Johnson: Most people will have
something like a Big Mac Meal with either a diet
Coke or a Coke and, if it is a Coke, it goes up to
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about 900 calories. Increasingly, we are selling more
drinks such as water, orange juice and that kind of
thing and more diet drinks and that is across the
range, not just with adult meals. Obviously, you can
have whatever you want.
Q461 Joan Ruddock: Do you not feel that it would
be useful to people just to have that limited amount
of information actually put before them?
Mr Hilton-Johnson: It is diYcult. You could be
forgiven for saying that we have bombarded people
with this, with our customer services help line and
with the interactive menu.
Q462 Joan Ruddock: On your menus, it is diYcult to
know because, if you take a salad, you can fool
yourself into thinking you are doing terribly well and
you could have a calorific content greater than some
other product.
Mr Hilton-Johnson: Not if you were going to have a
meal. Even if you had the croutons and all the
dressing, it would still be less than a particular meal.
The problem with marking menus is that it becomes
very confusing and it does not allow for particular
menu combinations and it slows people down. That
is why we do not do it. People who want to know can
find it, it is there, and we have done it since 1984.
Some people do and some people do not. I think the
real challenge—and we have not cracked this yet—
is to try and get more people engaged about food
and to try to get them more engaged about the way
in which information is given because, at the risk of
talking myself down, it is all very well us sitting here
and looking at calorie counting but what we need to
try and do is to move to a system where it is much
easily accessible to more people. We are working on
that; we have not cracked it; that does need to be a
consideration in promoting messages about food.
Q463 Chairman: If I went into one of your
restaurant today, where would I find information
about calorie content of diVerent meals?
Mr Hilton-Johnson: If you went into a restaurant,
there is a notice board type thing, a “Did you
know?” board and that is located either next to or
close to the front counter.
Q464 Chairman: Is where I could find it in one of
these leaflets?
Mr Hilton-Johnson: Yes. There are other places you
could find it but, if you went into a restaurant, that
is the principal place where you would find it.
Q465 Mr Jack: Why could the nutritional
breakdown document which you have provided not
be displayed in the store in its raw form?
Mr Hilton-Johnson: It is displayed in the store in the
sense that it is in the Our Food leaflets and it is also
on the back of tray liners. So, if people buy a meal in
the restaurant, they will get a tray liner along with
their tray and it is on the back of that if they care to
look at it.
Q466 Mr Jack: The reason I am asking the question
is that you have quite rightly counselled us that
customers make up their meals by a combination of
diVerent items and, bearing in mind that there are
some super energy hits like pancakes and syrup and
pancakes and sausage and, if you combine that with
enough other things, you can probably knock up
somewhere near your daily intake of calories in one
visit to McDonald’s. There are some people who
might need to think, what does this all mean? I was
just intrigued to know why this was not, if you like,
available for somebody if they wanted to have a
quick point of reference and look and see what their
combination totalled up to because the actual
display of this information is very detailed, it is very
clear, you can see protein, carbohydrate, fat, fibre,
sodium, the lot, but because you then have to go and
find a booklet, you might want to just stop for a
second and say, “This is what the implication of my
choice is”, if you were so minded to make an inquiry
like that.
Mr Hilton-Johnson: I think if people were so minded
to make an inquiry, they probably would not go to
the Our Food leaflet, they would ask a member of
staV. We are this year doing nutrition training for all
78,000 of our employers and, to be fair, it is there if
they want it. The trick is to try and get them to want
it, not the fact that it is not there.
Q467 Mr Jack: I suppose what I am driving at is the
degree of responsibility which a company likes yours
and indeed our previous witnesses must feel towards
getting the right balance between information and
enjoyment. Given all that you have said and given
that, to a degree, whilst people go for pleasure, I
think from Joan Ruddock’s question earlier, it is
also an indication that people go, if you like, to
refuel as much as sit down for an experience which
might be the case in the Whitbread outlet—
Mr Hilton-Johnson: I am afraid I would dispute that
quite significantly. Of course, there are people who
go to McDonald’s as a quick pit-stop but for a
number of people, myself included when I take my
children, it is absolutely not that, it is a fun and
pleasurable family experience. Not everyone sees it
in that way and of course not everyone goes but I am
afraid to dismiss McDonald’s as a refuelling stop is
something I would take issue with.
Mr Jack: I was not trying to imply that everybody
goes to refuel but, on the other hand, it is interesting,
when you look at the amount of detailed
information, I could not see a problem in you
putting it up for people to read. Anyway, there we
are.
Q468 Mr Mitchell: I can see a problem. It is
enormously complicated. You would have to go in
with a pocket calculator or a computer! It baZes me
where my colleagues eat. If you come to Hull for a
meal and you say, “I’ll have two ounces of this and
so many calories . . . ” It is a mad house! This is far
too complicated for the casual eater in a restaurant
that they are not going to embark on it. Is not a
better way than labelling, which I accept is diYcult
for restaurants, to guarantee assurance as to the
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quality of the food? McDonald’s have their own
assurance scheme which I think you introduced a
couple of years ago. Why did you introduce your
own scheme rather than relying on the existing farm
assurance schemes?
Mr Kenny: You are talking about our Agricultural
Assurance Programme. We have a number of
quality assurance schemes. Initially, the first part of
our quality assurance is with the people who
manufacture our food and that is where we kind of
start our quality assurance and then we go back in
stages. Now, we have found that there is more and
more pressure and more and more reason to go back
and assure the quality of the raw ingredients that we
use. We do work with the National Farm Assurance
Schemes and the standards that we have are not
meant to replace those Farm Assurance Schemes.
Q469 Mr Mitchell: Are yours higher?
Mr Kenny: It is a set of standards which, in most
instances, is higher than our national schemes and
the approach that we have taken is to say that these
are the standards that we would like to see operated
in our agricultural supply chain across Europe and
we want to and we are engaging with the National
Farm Assurance Schemes in each country to try and
encourage them to adopt, where there are diVerences
between the two standards, our standards where
they are higher.
Q470 Mr Mitchell: Do other food companies do the
same? Are you unique in having your own
assurance scheme?
Mr Kenny: I think we are quite unique in publishing
these requirements pan-European and that is a
challenge for us as well because, wherever we source
our food—and the vast majority of it is sourced in
the UK—when we do source raw materials across
Europe, we want to be sure that the raw materials
have come from the standards of animal welfare, of
transparency, traceability and so on.
Q471 Mr Mitchell: I would like to move on to
advertising because you sponsor various athletic
events including the Athens Olympics and indeed
Euro 2004 but we will not talk about that, let us talk
about the referee instead! Is it really reasonable or
appropriate to associate McDonald’s as a product
with a healthy sporting lifestyle?
Mr Hilton-Johnson: I think you will probably find
that a number of the athletes who compete do eat in
McDonald’s. As I said from the start, McDonald’s
food, be it hamburgers or be it salads, can fit in as
part of a healthy and a balanced diet. I personally
have no problem with it. It also provides us with
opportunities as a company far greater than just
branding opportunities. We associate ourselves with
it because of what it can do for us internally as well.
Our employee of the year this year, Rapson Wiley
from Haringey, for example, was one of the people
who carried the Olympic flame through London and
we were able to send 30 of our staV on packages to
matches out in Portugal as well. So, it is not just
about branding. I do think that it is appropriate for
McDonald’s to associate itself with events in that
way.
Q472 Mr Mitchell: So that and having sports
personalities on site, like the Williams sisters, in
advertising attempt to gain a healthy living image for
McDonald’s?
Mr Hilton-Johnson: I think it is about general
marketing but, much more than that, as I have said
as well, I do not think it is specifically about a
healthy living image, no.
Q473 Chairman: Can I ask you for your views as a
major retailer on the clarity of the messages you get
from Government when it comes to communicating
food information. Do you think there is a consistent
message from diVerent government departments
and agencies?
Mr Hilton-Johnson: I think we recognise the whole
debate in this area is exceedingly complex. The truth
is we actively want to engage, and I think we have a
pretty good track record of engaging, and want to
play our part in making a diVerence. As I said
before, our size means we are able to do that. For
example, we were I think the first major company to
respond to Tessa Jowell’s call to the industry to use
its creative ability positively by saying we would
commit over £1 million to children’s advertising
which does not promote McDonald’s products but
does communicate a healthy, active lifestyle message
to them. That will happen in the summer. In recent
weeks, there does appear to be a better joined-up
message from Government but clearly the more
joined-up it is and the more focused it is, the more
we can actually do. I would comment that north of
the border we have also engaged and we have found
there are fewer players and there is really quite good
co-ordination through the Scottish Food Tzar which
has made the job a lot easier. I would also say they
seem to be focused on the outcome rather than the
players, and we have certainly found we are pushing
at an open door, and they have been perfectly happy
apparently to give credit where credit is due.
Particularly when it comes to the food industry,
giving credit where credit is due, and praising rather
than shaming, is an extremely important part of
Government and industry working together.
Q474 Joan Ruddock: You say you have put £1
million towards this healthy campaign directed at
children and you say it is not promoting
McDonald’s products, but surely promotion is all
about name recognition? If you spend £1 million on
advertising McDonald’s, then you are getting a good
return, are you not, because you are advertising the
place, the concept, you do not need to advertise Big
Mac alongside fruit.
Mr Hilton-Johnson: The way these ads are executed
is that they will be centred on characters called the
Yums, which are not actually McDonald’s
characters. They are associated with McDonald’s by
the fact they live inside Ronald McDonald’s
stomach. We are quite comfortable with that
because we know that Ronald connects with
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children, and the messages will be all the more
powerful because of that. It is not that there is
absolutely no connection whatever, and forgive me
if that is the impression I gave, but it is not overt
plugging of particular products, it is rather diVerent
from that and we are not expecting to see our sales
increase as a result of it.
Q475 Joan Ruddock: We could have a really
interesting debate about this because I suspect you
just need to hold your customers, if not increase
them, and advertising to children is very, very
important. I think you are advertising to children,
whatever the messages are. I want to go back to these
charts because what this illustrates for us I think is
how a supplier of food such as yourselves with a very
standardised menu can indeed give very accurate
and consistent food information. Here you have
been able to put on the calorific value of every
product you are selling in a McDonald’s outlet, so it
would be so easy when you ring up the till and they
have all your products to put at the end of the bill the
number of calories. You could do the arithmetic.
Everyone would know exactly what they had eaten
and how many calories. I suggest to you, despite the
diYculties you actually have foreseen, because of
your standardised product, you would not have to
slow anybody down but you could provide them
with very important information.
Mr Hilton-Johnson: There are a number of
initiatives which are being looked at, and that is one
of them, and we will be monitoring the success of
those initiatives and taking action. I understand
what you are saying but we have to evaluate the tests
which are on-going.
Joan Ruddock: We would love to know about those
tests. Thank you very much.
Chairman: Thank you very much indeed, gentlemen,
for your evidence this afternoon. It has been
extremely helpful. If there is any additional
information which you think would be useful for the
Committee to have, please do submit it to us. You
have agreed to provide some information to us based
upon some of the questions we asked earlier. Thank
you very much.
Memorandum submitted by Dr Richard Baines
Executive Summary
This memorandum of evidence mainly focuses on the role of Private or Voluntary Assurance schemes in
defining and communicating information to consumers and Government about the food produced under
such protocols.
The evidence provided addresses communication within the supply chain and to consumers of
information in relation to food safety, systems of production and ethical considerations. It also addresses
the implications of Government involvement and the implications for trade negotiations under WTO.
In terms of food safety, there is significant harmonisation of approaches beyond the farm gate with the
adoption of HACCP for identifying and managing food hazards. At the farm level food safety is passively
managed through adherence to assurance protocols. We see this as a weakness in the supply chain. Food
safety is not communicated to consumers overtly and nor should it as claims over the safety of one product
implies that others are less safe. What is needed though is appropriate risk management along the chain and
eVective technical communication from primary production to retail or food service.
Most farm assurance schemes claim to encourage or ensure that systems of production meet consumer
(or retailer) aspirations. However, the majority merely underpin legal farming in terms of environmental
protection and animal welfare. This is why there is no premium for farm assured. Some schemes do require
additional conditions to be met by producers; however, there is no evidence of this adding value for those
who deliver these enhanced conditions. This is attributed to the fact that most consumers see environment
and animal welfare as public goods.
There is a wide range of information attached to food products that claim additional assurances such as
farm assured, free-range, local, from small farmers etc. Few of these are part of the conditions of farm
assurance and are therefore not verifiable. Where they are subject to verification, the standards often relate
to the organisation as opposed to the product. Exceptions to this include Fair Trade products and worker
welfare under the EUREP schemes. In any event, there is a need for such claims to be independently audited
and then linked to legal labelling.
Finally, it is important for Government to be cautious over their direct involvement with private
assurance schemes, especially where resultant standards exceed the minimum levels set by WTO or other
agreements. There is an opportunity, however, for the Government to use private assurance mechanisms as
a way of supporting primary production through green box payments. The mechanism described would
meet the aspirations of consumers and producers, but would require appropriate labelling and
dissemination of information for it to be successful.
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1. Terms of Reference
1.1 The terms of reference of the enquiry are to look into the ways in which messages about food are
communicated to consumers by the food chain, Government and others. The focus on food information is
in relation to nutritional content, safety, means of production and any ethical considerations. The inquiry
will also focus on the impact of communicating such information to consumers on the one hand and on
WTO trade negotiations on the other.
1.2 In relation to these terms of reference, the author will focus on the following key issues: the role of
private or so called voluntary assurance standards in communicating food safety, systems of production and
any ethical considerations; and the link between such assurance schemes, Government actions and WTO
issues. The authority to comment on these issues comes from over five years of benchmarking assurance
standards in the UK and Globally, from completing research and consultancy reports for a range of clients
(UK and other Governments, Industry Associations etc) and from presenting papers on quality assurance
at international conferences.
2. The Evolution of Private Assurance Mechanisms
2.1 Several factors have influenced the evolution of private assurance mechanisms. These include
globalisation of food supply (where more food is purchased unseen, requiring independent certification),
the increase in food safety incidents and scares that have highlighted the limitations of regulatory
surveillance, and the increasing dominance of “chain captains” who define market access requirements that
often go beyond regulatory inspection alone.
2.2 The main driver for assurance in the UK was the introduction of the Food Safety Act in 1990 with
its requirement for all those involved in food production, processing and retail to demonstrate that they have
taken all reasonable care to ensure food safety. The Act also introduced the defence of “due diligence” to
counter the rights of consumers, through their Environmental Health OYcers, to seek compensation for
damages linked to “unsafe food”. As the Act comes into force at the consumer interface, then food retailers
and food service are most exposed to this legislation.
2.3 The UK multiple retailers dominate our food supply with over 70% of the national shopping basket
being purchased through their outlets—they are the chain captains. Therefore it was logical that these large
businesses addressed their own food safety management first. Once this was done, the main risks were
perceived to come from their suppliers, so it was logical for these retailers to demand assurances from their
suppliers to meet the retailers own assurance systems. One consequence of this was a common approach for
all suppliers to retail (apart from those supplying M&S) known as the British Retail Consortium Standard.
This is based on the adoption of HACCP (Hazard Analysis, Critical Control Point) as a food safety risk
assessment and management tool plus technical specifications for product quality (that will vary from
retailer to retailer). The BRC standard does not, however, include any reference to systems of production
or any additional ethical considerations.
2.4 The main integrators who supply our retailers will be subject to regular audits by independent
inspection bodies against the BRC standard or equivalent. In addition, they will be subject to the normal
regulatory checks carried out by Government and Local Authority Agencies. It is reasonable to argue that
the BRC HACCP check is considered to be the food safety firewall between retailers and the rest of the
supply chain and that they require this assurance to address their potential liability in the event of a food
safety breakdown or scare. Integrators, manufacturers and processors source their raw materials from
primary producers either in the UK or from abroad. It is important to note what assurance they are buying
into and how these relate to the stated requirements of retailers. It is interesting to note that the main retailers
claim that the producers who supply “their” integrators are farm assured, however, there is no formal audit
of this in the BRC or equivalent standards. Moreover, in many of the primary product sectors, the
proportion of product assured and the proportion going to multiple retailers do not equate.
2.5 Imported raw agricultural products will be subject to regulatory surveillance, however, homegrown
produce is largely unregulated in terms of food hygiene! However, in response to changes in the supply chain
beyond the farm gate, producers have developed their own assurance systems. In the UK this was initially
in opposition to what retailers were demanding of them, but through the actions of the NFU and others a
national set of farm assurance standards have evolved under Assured Food Standards and the British Farm
Standard logo of the “Little Red Tractor”. Although food safety is cited in these schemes, management is
merely by following scheme protocols that “should” reduce hazards. The main focus of these schemes is
around legal farming. As such, the schemes provide the opportunity for independent inspection of selected
environmental attributes as defined in the Codes of Good Agricultural Practice and animal welfare
legislation. Finally, these schemes do not set minimum product quality limits even though this is a critical
attribute further along the supply chain.
2.6 This brief overview of voluntary assurance systems along whole supply chains clearly demonstrates
that there is not a consistent approach to food safety, product quality, systems of production and any ethical
considerations of food supply. Taking each of these in turn, the following picture emerges:
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3. Food Safety and Assurance
3.1 The preferred approach of Governments to managing food safety is the adoption of the 12 steps and
seven principles of HACCP by industry as a tool to actively identify and safely manage food hazards. Indeed
Codex HACCP provides the international foundation for Government to Government agreements on food
trade and is the basis for WTO arbitration on food hygiene. Furthermore, HACCP adoption along the
whole food chain, including primary production, is advocated by the EC in the 2000 White Paper on
Food Safety.
3.2 Although stated in the White Paper, it appears that the EU is moving away from the notion of
HACCP at the farm level. We consider this to be a fundamental mistake that weakens whole-chain food
safety management by industry. As previously stated, schemes under the British Farm Standard do not
require HACCP to be in place and therefore it could be argued that safety is not being actively managed at
this stage, even though safe food claims are communicated to consumers through promotional materials and
the “Little Red Tractor” web site. Similarly, HACCP is not part of any of the organic standards operating in
the UK, so the reservations over farm level food safety management can be equally applied to organic
produce.
3.3 The adoption of HACCP beyond the farm gate is the norm, including organic food businesses. This
is either mandated by legislation for high-risk foods or is required as a condition of market access by the
chain captains described earlier. These combined approaches result in a far greater emphasis on addressing
food safety along supply chains along with improved technical communication of safety and quality between
suppliers and buyers. This communication does not, however, extend to consumers and nor should it! Food
safety should be taken as a given by consumers, whereas active promotion of one product’s safety implies
that other products are less safe! The whole industry should be working towards preventing unsafe food
reaching consumers irrespective of consumers’ ability to pay.
4. Systems of Production
4.1 Consumer interest in how food is produced has grown in the last decade or so. This is in part due to
food scares linked to particular approaches to production and in part due to the intensification of agriculture
as producer’s battle to overcome reducing farm margins. Such consumer concerns have been reflected in
various assurance schemes. Examples of this include the adoption of integrated crop management in the
Assured Produce scheme and the additional environmental auditing under the LEAFMarque scheme;
higher (than legally mandated) animal welfare under Freedom Foods; and high environmental and animal
welfare requirements under organic schemes. In addition, Tesco’s Natures Choice and Sainsbury’s Living
Landscapes schemes require direct or premium suppliers to develop nature conservation or biodiversity
action plans. All other schemes claim to, and promote, systems of production that are environmentally and
animal welfare sensitive, yet they merely require members to meet minimum legal requirements in these
areas.
4.2 Overseas suppliers of primary produce have to meet the equivalent legal requirements of home
production in order to gain access to the EU. This regulatory oversight mainly focuses on food hygiene as
opposed to systems of production, though the regulations on acceptable and banned medicines and
pesticides do impact on how production is carried out in third countries (at least those aiming at export
markets).
4.3 Like their UK counterparts, overseas producers also have to meet chain captain requirements to gain
market access. This is also achieved through assurance schemes like the EUREP schemes. These schemes
generally mirror UK schemes in that they define “legal farming” in relation to the environment and animal
welfare (and address food safety through general advisory prescriptions).
4.4 Irrespective of the origins of primary produce, very little information is communicated to consumers
over systems of production where food is produced under recognised assurance schemes. We consider there
are two main reasons for this. First, although producers are required to be members of assurance schemes
at their own cost, there is no audit trail to ensure only assured produce reaches and is sold by the retailers.
Secondly, the main multiple retailers aim to promote their own brands of food. Any additional “assurance
label” has the potential to dilute their own brand and as such retailers in our view actively discourage and
prevent other labels reaching “their” consumers.
4.5 One area of concern to producers and consumers is the use of uncontrolled terms in food labelling,
especially where such terms are not verified in any way. Such terms as free range, barn reared, natural, or
local can be misleading. Also, the use of claims linked to sustainable sourcing such as the Marine
Stewardship Council is confusing mainly because of the complexity in defining and measuring sustainability.
Even farm assured, when not backed up by a recognised assurance system, can mislead consumers over what
they are paying for. We would argue that such terms should be subject to some form of control over their
use. Similar arguments can be made for labels claiming functionality or health attributes of food, however,
this is beyond the scope of this written evidence. Given that such attributes of food can be defined and
become part of legal labelling, then there would be benefits to consumers and producers alike.
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5.1 Higher environmental or animal welfare conditions could be considered as examples of ethical
considerations. Others include fair trade, social accountability, worker welfare and support for overseas and
small-scale producers. It could also be argued that local supply is an ethical consideration if the impact of
food miles is considered to be a significant detrimental impact on the environment or communities.
5.2 Several of the above ethical dimensions of food supply are covered by agreed and recognised
standards. Indeed some have developed audit and reporting protocols to “prove” the ethical stance of
organisations subscribing to the standard. Others are less well defined or measured.
5.3 With reference to voluntary assurance schemes, none of the UK farm level schemes include any
ethical considerations, though organic standards include the notion of locally grown and consumed as a
principle of organic systems. The EUREP schemes do include worker welfare conditions aimed at
addressing conditions for overseas workers. More recently, UK schemes like Assured Produce have had to
consider the implications of worker welfare in relation to some of the illegal practices associated with gang
labour that is controlled from outside the business.
5.4 Where ethical considerations are included in assurance schemes, there is little communication of this
to consumers through food labelling. The main exception here being fair trade. Moreover, many of the
ethical standards relate to overall business strategies and performance as opposed to product specifications.
6. The Role of Government and Trade Implications
6.1 Both the Government and the food industry have roles to play in ensuring the safety and quality of
our food. The above evidence defines how the market place has gone beyond regulatory compliance in
developing and implementing private assurance systems. In doing so, this poses no problems for
Government in relation to WTO rules and barriers to trade. If however, Governments become actively
involved in the development or ownership of assurance schemes and if these schemes exceed the minimum
standards defined under SPS or TBT agreements, then challenges from trade partners should be expected.
6.2 The food chain captains are defining the main market access requirements for food. Although claimed
to be voluntary, the dominance of these chain captains makes these conditions eVectively mandatory. This
is not a problem as long as those delivering the additional requirements are adequately rewarded. In order
to realise this, labelling must diVerentiate foods with these extra assurances so those consumers interested
in such foods can identify and preferentially source them. For such a system to work, however, consumers
must be prepared to pay the added value of the product and this added value must then flow to those who
provided the extra attributes. This raises a core issue for Governments and the food industry linked to added
value products and assurance systems.
6.3 As citizens we all would subscribe to higher environmental conditions and animal welfare linked to
food production. Indeed many would also support higher worker welfare, the notion of fair and ethical trade
and even locally sourced foods. However, as consumers few of us are prepared to pay a premium through
food for these attributes. As such, higher standards attached to food can be considered to be public as
opposed to private goods. This raises key questions for the industry and Government.
6.4 If such attributes are public goods and are beyond legal compliance, then the chain captains have no
right to demand them of suppliers unless they are prepared to directly reward the suppliers themselves. This
is not the case at the moment so suppliers bear the cost of these extra conditions and retailers benefit
from them.
6.5 From the Government’s perspective, if we as citizens want higher standards of say production, then
the Government has two options. They can either tighten legislation to achieve what society claims it wants,
or they provide incentives to encourage suppliers to meet societies aspirations. The former option may result
in disputes under WTO if legal requirements result in trade barriers for imports, while the latter would have
to be funded out of government revenue.
6.6 There is a third option that should be considered. If there is a desire to support agriculture through
rewarding good environmental performance (as outlined in the Curry Report), then there is a need to ensure
only those who deliver environmental goods are rewarded. If auditable environmental (or other conditions)
are developed, then the existing private inspection mechanisms could carry out the additional audit points
(as is currently done for LEAF Marque). The cost of this, however, should be borne by the Government,
as the additional benefit is a public good. Through such a mechanism, only producers who deliver benefits
would be rewarded and the audit burden would not increase significantly. As a fail safe, Government
sampling of private audits could be carried out along with Government audits of non-assured producers.
Given such a mechanism, appropriate labelling and communication would enable consumers to select such
foods at no extra cost. The other benefit is that such a mechanism would enable Government to support
agriculture through green box payments without undermining WTO rules. The Royal Agricultural College
would be very interested in developing this concept further.
6.7 Irrespective of the strategies employed by the food industry or Government, there is a need for
appropriate communication within the industry and to consumers. This should be in the form of labelling
on products, promotion at the point of sale and through public promotional and educational activities.
19 April 2004
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Witness: Dr Richard Baines, Principal Lecturer in Management Systems for Food Safety and the
Environment, Royal Agricultural College, examined.
Q476 Chairman: Dr Baines, thank you for
submitting evidence in writing and for coming to the
Committee this afternoon. We are bit behind our
schedule. Can I begin the questions by asking for
your general assessment on the value of food
assurance schemes, which is the issue you cover in
most detail in your evidence, given for example that
the National Consumer Council suggested that food
assurance schemes are as likely to confuse and
mislead consumers rather than inform them. How
far would you agree with that type of assertion?
Dr Baines: We try and communicate information to
consumers about particular farm assurance as it
heads up the chain, and that is probably the wrong
strategy, and that is perhaps where the confusion is
coming from. I see the role of farm assurance as a
way of communicating to the next people in the
chain what eVort has been put into that food to
move it along, and it should be more in the form of
a technical communication––trying to link the goals
at diVerent parts of the chain. The benefits I see,
particularly at the farm assurance level are, if they
are designed in the right way they can, first of all,
enable the producer to demonstrate due diligence in
relation to food safety, and that is probably the most
important driver in all stages in the chain. Secondly,
if it is developed in the correct way, it can drive
internal business eYciency to oVset the costs, and in
some of the schemes I have studied from around the
world we can demonstrate that, there have been
those eYciencies. Thirdly, assurance can be used as
a marketing and promotion tool to those people you
are selling to, and farmers generally do not sell to
consumers. I think the fact we are trying to get farm
assurance, the NFU in particular and the Assurance
Food Standards, to create that link right through the
chain and perhaps do not always bring the rest of the
chain along, this is where some of the confusion has
come about.
Q477 Mr Mitchell: Why do you say imported
agricultural products are subject to regulatory
surveillance but home-grown products are largely
unregulated? I do not see that.
Dr Baines: First of all, if we look at agricultural
production in the UK or the European Union, from
a domestic production point of view, from a hygienic
perspective it is largely unregulated.
Q478 Mr Mitchell: Here and in the rest of the EU?
Dr Baines: Yes. As a farmer, I do not have to have a
licence to produce food to sell into the food chain.
As a purveyor of food, or if I was going to do onfarm processing, I do have to have a hygiene licence.
That is the point I was making.
Q479 Mr Mitchell: Is that not the same in North
America or New Zealand?
Dr Baines: Domestically, there are significant
derogations in the food chain for small and mediumsized businesses which maybe cannot comply with
the strict hygiene regulations we tend to impose on
the larger operators.
Q480 Mr Mitchell: If they are supplying a British
market, then they have got to be regulated?
Dr Baines: No.2
Q481 Mr Mitchell: Are you saying the domestic
market is always less well regulated?
Dr Baines: When I say “domestic market” I should
put it in the context of a domestic European market,
because once food is produced and goes on to the
next stage it can move to anywhere in the European
Union, the same as imported food. The point I was
making is that before food can be imported, first of
all the manufacturer processor, integrator,
whatever, has to go through European inspection to
ensure they meet the European regulatory
standards, and that will be the standards of the best
of our European manufacturers, our large scale
abattoirs, pack houses and food manufacturers, not
the average, which will include small scale that may
have derogation. Often, and I have looked at these
schemes in Australia, for example, that will include,
if you are looking at meat supply, the ability of those
European inspectors to judge the farms which are
supplying [the slaughter house]. By that, there is
another tier of regulatory inspection which a
significant amount of domestic food would not be
subject to. That is the point I was making there.
Q482 Mr Mitchell: Are you not satisfied with the
legal requirements in respect of food hygiene in this
country and food safety?
Dr Baines: I am comfortable with the food safety in
the European food chain when things are going
okay. I have concerns when things go wrong and we
have seen evidence of that. I am comfortable, with
some reservation, over what is happening beyond
the farm gate in terms of the major messages coming
from the drivers of food safety, which I see as being
the major retailers, more so than perhaps
Government, and they are driving this for very good
reasons. The systems of identifying and managing
food safety risk are well in place, and we see from
Government and major industry leaders the
adoption of HACCP—the Hazard Analysis, Critical
Control Point—but we see politically an
unwillingness to look at this at the farm level even
though there is good evidence of food risks at the
farm level and food safety break-downs which are
accounted for at that level as well. I have experienced
schemes where farms are required to do appropriate
risk assessment, and are able to do that in just as
good a way and with the same sort of costs as we
would see with our current farm assurance scheme.
So, yes, I would challenge whether we should be
requiring all producers to be more active in their
assessment of food risk. I think the fact we just will
not seem to address this is something which has
evolved politically. Often it is argued it is too diYcult
for farmers to do, but I have seen farmers do it. It is
said it is expensive; I think we can challenge that.
One of the reasons is that there are some very good
firewalls further up the chain which protect those at
2
Not in terms of regulated food hygiene. There are exceptions
eg annual dairy plant inspections.
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29 June 2004 Dr Richard Baines
the end of the chain where consumer protection
legislation comes in. I am thinking, for example, of
the British Retail Consortium audit which most
food manufacturers are going through. That is a
good firewall and you could maybe argue that safety
could be better managed by being strategically
placed at some point in the chain.
Q483 Mr Mitchell: If that was installed at some
earlier point in the chain?
Dr Baines: The counter-argument is that all of those
in the food supply chain have a responsibility.
Q484 Mr Mitchell: Yes.
Dr Baines: I believe we should all be addressing that
at whatever level we operate at. If there is a food
safety break-down, if you are not addressing it, you
have not got a defence. The blame will be passed
down to you and if you have no defence, you have a
problem.
Q485 Mr Mitchell: So was Mrs Curry right or
wrong?
Dr Baines: When she told the truth?
Q486 Mr Mitchell: She told the truth?
Dr Baines: Yes. Politically, she was wrong, in my
view.
Q487 Mr Jack: Can I follow Mr Mitchell’s line of
questioning? In your evidence, at paragraph 3.2, you
draw the Committee’s attention to the line of
argument you have just put forward with reference
to HACCP at the farm level. It causes me to pose the
question as to whether in fact that kind of
information undermines the messages that people
draw out of the little red tractor symbol that
somehow this is good, wholesome, safe, everything
is okay if I buy this product. The statement you put
at 3.2 would suggest that it rather undermines the
assurance message which is embodied in the little
red tractor.
Dr Baines: Yes, I have challenged those who support
the British Farm Standard, both publicly and in
terms of academic writing. As with virtually all the
other farm level schemes I have seen around the
world, they are addressing food safety but they
address it in a sector-specific way. It is a prescription
almost; “If you do this, food risk should be
reduced.” If you look at that from a food safety risk
management perspective, what we are actually doing
is what we call the pre-requisite programmes; those
things which should lower risk, but it does not
actually require a producer to actively assess
whether the risk has been lowered or not. That is the
diVerence between active risk management on food
safety and passive management. It is not a problem
at this stage because the number of risks which do
occur at the farm level are few, but they do occur.
Examples can be where we have seen human-borne
pathogens or zoonotic pathogens from animals
which have got into either the water or through food
handling, particularly in fresh produce chains. That
is the most rapidly growing area of food safety
concerns for the farm level at this stage. Most of the
others in grains are about storage, salmonella and
aphlatoxins3 in grain storage through fungal
growth, and then other ones could be animal
pathogens which can largely be addressed at
slaughter. So there are examples where there are
concerns at the farm level. Doing the pre-requisite
programmes and lowering the risk on prescriptive
management helps, but I believe we should be going
a stage further, and I do not believe it is costprohibitive to do that.
Q488 Mr Jack: So if people are going to draw lots
of positive conclusions from symbols like this, your
judgment is that if that message has been gathered by
the consumer then it may be under a false premise
and it is not as thoroughly underpinned as they
might assume?
Dr Baines: I would have to check this and I am going
on recollection, but when we first saw the website
and the promotion of the British Farm Standard, it
was claimed as being British food, safe British food,
high quality, high animal welfare and environmental
responsibilities from those who produce it. In actual
fact it is demonstrating for those selected areas of
animal welfare and the environment merely legal
compliance, and that is why there is no premium, but
there is a cost. It does not address quality, there is no
audit point within the British red tractor or
anywhere which says, “This is quality or not
quality”, and on safety, as I have already mentioned,
it is a sector approach to safety rather than an
individual business approach. As you and I know, as
in any food business, individual farms will have
better or worse records in terms of how they manage
safety, and we need to address those who are not so
good at the job.
Q489 Chairman: From what you have been saying
this afternoon, is it fair to say your view is that to
regard farm assurance schemes as some useful form
of food information for the consumer is really just
the wrong road to go down?
Dr Baines: If you try and claim too much on what it
stands for, you are going to create a problem. Let me
just balance that up with another comment, and that
is the fact that if we look at British agriculture and if
we look at its overall safety record in terms of
volume and the problems we have, if we look at the
environmental performance of agriculture, if we
look at the animal welfare performance of
agriculture, generally it is very good. The fact that
we value the landscape we go and see is a good
example of that. So I am not trying to say that
British agriculture has got problems, it has issues to
address as with any other sector of the industry, and
it is seeking to make a margin where a margin is
disappearing, and in any leverage of marketing they
are trying to do that. I believe that the British Farm
Standard should be trying to get its message across
to those people whom the farm produce is sold to,
who themselves are then passing a message on to the
next part of the chain, who are themselves passing it
on to the consumer.
3
Aphlatoxins from aspergillus species plus other myco-toxins
from plant pathogens.
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Q490 Chairman: Can you give us an estimate of the
number of farm assurance schemes currently
operating in Britain?
Dr Baines: I think it is important that you define
what you mean by farm assurance. If we look at
schemes which meet the requirements of the rest of
the food chain in terms of assurance, in other words
their independent verification to a set of agreed
standards, we are really looking at primarily the
schemes under the British Farm Standard, Quality
Meat Scotland, Scottish Salmon, the Northern
Ireland schemes et cetera, and probably those 10 or
12 schemes we could put in such a group are
accounting for the majority of the assured produce
moving forward. Beyond that, you will get other
assurance claims which are perhaps better defined as
branding or promotional, which may be something
to do with things like localness. We have to separate
those as promotional elements from those which
have some form of audit to say what they are
claiming has been assessed. We also have schemes
which operate further up the chain, so they may be
led by the manufacturing level. I guess the first one
of these which probably started it all was Bird’s Eye
and their frozen peas. Perhaps a good one at the
moment would be Jordan’s with their cereals. That is
sending a lot of messages back to farmers about how
they farm, but it is sold to the consumer as this
wholesome breakfast cereal, and this is nothing to
do with telling the consumer what is happening in
farming, but the farmers who are participating are
contributing to a system which adds to that
aggregate product which is valued by some
consumers.
Q491 Chairman: Is there not a case for having some
overarching body, be it Government or industry,
which has oversight of this area and indeed could
regulate a number of schemes and the verification
of them?
Dr Baines: We already have elements of regulation,
first of all, for them to be claimed as assurance
schemes under EM45011, they go through UCAS
accreditation. That is the first level, the system of
certification and the mechanisms are already
internationally recognised and regulated. The
problem with that is they are voluntary schemes and
they [certification bodies] are there to inspect or
certify whatever the scheme owners have decided to
put into the scheme. Secondly, yes, it is important to
try and get some co-recognition, some
understanding, and that is why I started some five
years ago comparing schemes around the world
because I had heard so many times about level
playing fields and about other people not doing what
we do. Yes, I have been doing bench-marking for
several years, what has been happening is that we
have the British Farm Standard and Assured Food
Standards seeking to be an umbrella organisation,
but Quality Meat Scotland do not want to be part of
it because they believe their brand is better and they
have arguments for that and they see that as a
marketing angle. We also have emerging probably
what I think is the start of this convergence of
schemes and co-recognition, and that is that all of
the schemes which are operating above the farm
level—there are relatively few global schemes now
probably only five. These are being bench-marked
by the CIES, which is the global retail forum, which
many of the retailers here are members of, and they
are bench-marking their schemes at least in relation
to food safety and how it is delivered. Does it address
it in these key ways? At the moment, the CIS is
developing the mechanism to bench-mark farm level
standards. So from the retail side and the food
manufacturing side, we will see a global
benchmarking of schemes. I know the CIES have
been in negotiation with Assured Food Standards,
they have been involved in talking to various scheme
owners around the world about this. What it does
not do at the moment is address the other issues of
farm assurance, the animal welfare, the
environment, the fair and equitable trade and so
forth; all those other areas in which there is an
interest are not going to be addressed through that
mechanism. But they are suggesting that schemes
can co-recognise against each other where they meet
similar standards. In my opinion, what they are
really saying is, they want to see all schemes benchmark themselves against the EUREP Scheme which
is a European retail alliance scheme at the farm level.
It (EUREP) started oV with fresh produce, we now
have livestock, cereals, cut flowers, and I think they
are developing a fish one as well. I guess, and I would
perhaps like to check this, the McDonald’s farm
assurance scheme is probably very closely linked to
the EUREP Scheme as they are a member of that
group, but I would have to check on that. Really
what they are saying is, “We, European retailers,
have developed a scheme and we want it to
dominate”, and that worries me.
Q492 Joan Ruddock: Does the EUREP Scheme
generally just guarantee that minimum standards
are being met, that the legal requirements are being
met? It does not actually take you beyond that? The
consumer is not getting something beyond that?
Dr Baines: There are in the new animal and cereal
schemes three levels. There is a basic level, which is
very much equivalent to the British Farm Standard, it
is about legal compliance in those key areas. Most of
them are around protection of soil, air and water and
where there is a link to human safety in terms of
pesticides. Generally what they are looking for in the
second level up is worker welfare, the correct and
legal treatment of workers, which came in initially for
outside-of-European supply, but now we are finding
a significant number of fresh produce growers in the
UK are saying, “I am going to convert from assured
produce to EUREP because I have operations in
South Europe and elsewhere where I need it, because
I want to do whole-year round supply to try and keep
my share of the market.” The third level, which is an
optional level, is about an encouragement to improve
bio-diversity management at the farm level. But I
have not found a scheme anywhere, including Tesco’s
Nature’s Choice and Sainsbury’s Living Landscapes,
where the farmer is rewarded for going further than
legal compliance.
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Q493 Joan Ruddock: It seems to me even if people
were going to the second or third level, as far as the
consumer being presented with a message is
concerned, it could be the lowest level. Is that
correct?
Dr Baines: Yes.
Q494 Joan Ruddock: They would not know any
diVerent. So every consumer, I would have thought,
would expect those minimum requirements and the
legal regulations would be met by all producers. So
they gain nothing really from an assurance scheme?
Dr Baines: No.
Q495 Joan Ruddock: Nothing.
Dr Baines: Correct.
Q496 Joan Ruddock: They are pointless in many
cases.
Dr Baines: I would love to be able to get a group of
producers together and say, “Shall we stop doing
them”, and I think I would probably get a fair degree
of support for that. Unfortunately, the market place
is sending us messages which say, “We won’t accept
that.” The consumers are really getting an assurance
that farmers have been made aware of their legal
responsibility and the market place is checking this
out where at the moment Government cannot aVord
the level of oversight it would need to have that same
level of confidence. Really we are seeing almost a
privatisation of legal farming to the market place, to
the chain captains.
Q497 Joan Ruddock: Yes. If they are going to go
beyond legal requirements, surely the consumer
ought to be made aware of what they have done in
addition to what they are required to do?
Dr Baines: Yes.
Q498 Joan Ruddock: And also, surely, there ought
to be a premium? If there is not a premium being
paid, why are people opting into these assurance
schemes which do require the higher standards?
What are they getting out of that?
Dr Baines: They get somewhere to sell their produce,
because the message coming down the chain is, “If
you do not do this, we are not going to deal with
you.” I have an example on this one from abroad
where a supplier has been supplying into the UK for
some 15 years under a standard scheme which has
been fully accepted by one of our major retailers,
and they have just been informed by their integrator,
who acts on behalf of that retailer, unless they
transfer to the EUREP Scheme they will not have
supply. That is the message but it is not a message
from the retailer, it is from the integrator, who is
acting de facto on behalf of the messages coming
from that level. The other problem is, if we could
communicate that message, we would have to have
the agreement that that message is going to go to the
consumer in some way. If you add that message
there, you are going to take away from the main
message in the main outlets for food, which is the
retailers’ own label. It is quite understandable that
retailers will protect that level because that is their
market power, that is their way of competing with
each other.
Q499 Chairman: So who is gaining from these
schemes then? From what you are saying, the
consumer is not gaining, the producers are not
gaining, the retailer is not gaining. Why are they
there?
Dr Baines: I would disagree with you. I think the top
end of the chain does benefit from this at the expense
of the lower end of the chain.
Q500 Chairman: In what way?
Dr Baines: If we look at some of the ones on the
environment side, as an example where there is some
interest by some consumers to pay a premium, we
have an example of retail support for the LEAF
Marque, which supports integrated crop
management under the LEAF Organisation. To go
through that, to have the LEAF Marque on your
products at the processor/packing stage, the farmer
has to be farm assured for the crops or produce, but
in addition they have to have an additional element
of audit at their own cost to show they are meeting
elements of LEAF. It is an extra cost to the producer
to get that label on their product, but there is no
premium for that extra eVort. The argument is that
you will get improved market access if consumers
buy more of it. But if you sell more, perhaps the
benefit you get is you are spreading the cost of that
extra audit over a larger number of units, so there is
not actually a benefit, you are just lowering the unit
cost by selling more. There is an example where it
has worked. I am sure you are aware of Sainsbury’s,
Budgen’s, Co-op I think and one other I cannot
remember, who are supporting a brand of milk
called White and Wild, which I think is a great name.
White and Wild is linked to the farmers who are
committing to a higher level of biodiversity
management, and they are rewarded in the market
place, I think they get an extra 3p a litre because they
are committing to that. This premium is transferred
into a higher price on the shelf. But I would not mind
betting that if that does not sell, the scheme will
wither away and die. We saw the same when Unigate
tried to introduce one called Forage Plus, but they
could not realise a premium themselves so they
dropped it.
Q501 Joan Ruddock: Forage Plus is a diYcult
consumer message.
Dr Baines: It was the wrong name, was it not, that
was the problem with it. Most consumers do not
know what we mean by “forage”. It was aimed at the
farmers but the wrong name, I guess. Whereas White
and Wild is a brilliant name, it has good promotion,
it is great to see the website, it has in-store
promotion. However, I would not mind betting that
if I went and did an evaluation on the shelves, it is
probably only 6 to 7% of the milk volume being sold,
which is about the proportion I would estimate of
people who are prepared to pay a premium for
environmental benefits. Most people see improving
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the environment as a public good, and that is why in
my evidence I did suggest possibly other
mechanisms to reward farmers who are going
further than legal compliance, without addressing
the problems of higher legislation which might put
the UK Government into conflict with other
European partners or indeed WTO rules over
barriers to trade.
Q502 Chairman: Dr Baines, that concludes our
questions this afternoon. Once again, thank you for
coming along to give your evidence. If there is any
additional information on the points you have put to
us which you want to supply us with, please feel free
to do so. Thank you for coming along this
afternoon.
Dr Baines: Thank you very much.
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Monday 12 July 2004
Members present:
Mr David Drew
Joan Ruddock
Memorandum submitted by the Food and Drink Federation
Executive Summary
1. A large amount of information is required to be given on the labels of pre-packed foods. Attention is
drawn to the information load on food labels and the need to review current requirements in the light of
modern technology and increasing information demands. Whilst manufacturers give a wide range of
supplementary information on packs, this is limited by available label space.
2. Such consideration is timely in the context of current European Commission reviews of both general
food labelling and nutrition labelling. Information about non-prepacked foods should also be taken into
account.
3. This submission addresses the topics identified in the Inquiry terms of reference. “Organic” and GM
are given as examples of providing information on means of production of foods. Ethical considerations
provide an example of the need to communicate in a more explanatory manner oV-label. FDF consumer
information programmes are introduced as examples of wider means of facilitating consumer understanding
of specific food information and of appropriate food handling.
Introduction
4. FDF welcomes the Inquiry’s inclusion of other means of communication than labelling. The food
product label is legally required to carry substantial information and demands to include more continue.
Although technology, communications and consumer awareness and demands have progressed rapidly,
there has been no fundamental review of the basic EU legislation, from which UK food labelling
requirements stem, since 1979. Accordingly, FDF believes that it is timely to identify priorities for on-label
information and also to identify acceptable, alternative means for making available supplementary
information. This need is emphasised by the increasing need for multi-lingual labels to facilitate the
movement of goods in an expanding EU.
5. At the same time, consideration should be given to information requirements for non-prepacked foods
and how best to communicate it to consumers.
6. The primary role of the food label is to provide key information, not to act as a means of education.
Account should be taken of the important role of industry-run consumer awareness programmes, and
Government-funded consumer education, in equipping consumers to make better use of the information
available. Information should be useful, usable and used. Attention to public education, as well as to the
content and presentation of consumer information, are necessary to achieving this objective.
The Nutritional Content of Foods
Legislation and voluntary provision of information
7. The basic requirements for nutrition labelling are set out in Directive 90/496/EEC and implemented
as part of The Food Labelling Regulations 19961. This defines certain nutrients, prescribes how nutrition
information is to be derived and how it is to be displayed on food labels. Nutrition labelling is voluntary
except that it must be given where a nutrition claim (also defined) is made. Nonetheless, some 80% of prepackaged, processed foodstuVs manufactured in the UK are estimated to carry on-pack nutrition labelling.
Given that there are sound reasons why some packs cannot carry this information, this represents a high
level of information provision.
8. In addition to the statutory information, some manufacturers chose to give guidance on the
contribution of their products to a balanced diet by provision of information on the percentage of the
Guideline Daily Amount (GDA) of energy or certain nutrients provided by the product. Further
information is available. Some companies advise on-pack on lifestyle information, or provide links to other
sources of information by means of care lines, websites and other contact routes.
1
(SI 1996 No 1499).
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9. DG Sanco is reviewing EU requirements and a consultation document on amending the Nutrition
Labelling Directive is expected shortly. FDF supports up-dating of the legislation at EU level. It is likely,
however, that DG Sanco will propose making nutrition labelling mandatory. This would necessitate
establishment of a number of exemptions to allow for practical problems with on-pack declaration, even if
this information had to be made available by alternative means.
10. Proposals have been made by a number of bodies regarding the provision of additional, explanatory
information alongside the on-pack nutrition data. Generally, this tends to be subjective, seeking to classify
individual food products in respect of their content of specific nutrients. More consideration is required to
ensure such schemes are useful in terms of assisting consumers to achieve a balanced diet and do not distract
from the legibility of the basic data.
Educational programmes on healthy diets and lifestyles
11. It is important that nutrition information is available to consumers to enable them to make
appropriate dietary choices. Consumer understanding of nutritional data is key to this process and, more
fundamentally, an understanding of the importance of a balanced diet and adequate exercise is a basic
contributor to maintaining good health.
12. FDF supports the enhancement of consumer understanding of nutrition, with reference to available
nutrition information, whether given on-label or by other means. One of FDF’s consumer information
programmes, “foodfitness”, promotes healthy diet and lifestyle through a range of resources, providing both
public information and educational materials. Details can be found at http://www.foodfitness.org.uk
13. FDF believes that the relevant national authorities have an important role to play in educating
consumers in their understanding of nutrition information and in linking nutrition information to healthy
living/eating campaigns.
The Safety of Foods
14. Whatever style or “quality” of food product is chosen, consumers should be able to rely upon the
safety of their food supply. This is the top priority for food manufacturers.
Directly relevant to food safety, The Food Labelling Regulations require that labels carry:
— The appropriate durability indication (date-mark).
— Any special storage conditions or conditions of use.
— Instructions for use if it would be diYcult to make appropriate use of the food in the absence of
such instructions.
15. With the increasing range of manufactured foodstuVs, particularly in terms of their content,
presentation and storage, and the range of heating and cooking options available, manufacturers are giving
multiple on-pack preparation instructions, the clarity of which is enhanced by the use of appropriate icons
(eg cooking methods and microwave ratings).
16. To extend food safety into the home or catering establishment, it is essential that consumers are aware
of safe food handling practices which should be applied to the various types of food, both raw and cooked.
This includes appropriate storage of products and appropriate handling and preparation once they are
removed from their protective packaging.
17. Safe food handling should feature in everybody’s education and food safety messages need to be
conveyed regularly to the public to increase general awareness as well as good practice. Environmental
Health OYcers have a major role in encouraging good practice and there is a substantial amount of public
information on the FSA website.
FDF’s Public Information Programme on Safe Food Handling
18. FDF has a longstanding public information programme on safe food handling called “foodlink”.
Details can be found at http://www.foodlink.org.uk. foodlink is organised by FDF in association with FSA,
the Royal Environmental Health Institute of Scotland, the Chartered Institute of Environmental Health,
the Local Authorities Coordinators of Regulatory Services (LACORS), the Departments of Health, Food
and Education, the National Farmers Union, the British Retail Consortium and the British Hospitality
Association. Support is also given by several other organisations. The programme provides a focus for
communicating messages on the basic precautions to reduce the risk of suVering from food poisoning.
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The Means Of Production of Foods
19. The Food Labelling Regulations require that food shall be labelled with information about its
physical condition or treatment (eg that it has been concentrated, freeze-dried or smoked) where a purchaser
could be misled by the omission of such an indication. It is taken, however, that “means of production” in
the Committee’s terms of reference refers principally to primary, agricultural/horticultural production, and
associated handing and storage practices, prior to final processing. Examples are “organic” and “GM”.
Organic Foods
How can consumers tell that food is organic?
20. It is illegal to sell any food as organic unless it has been produced in full conformity with EU Organic
Regulation (EC2092/91) and by registered producers. It is not possible to determine, just by looking at food,
or by testing it, whether or not it is organic. Therefore, inspection during production is essential. By this
means, the use of the word “organic” on the label is the guarantee that it has been organically produced.
Could information be better conveyed to consumers?
21. Consumers already have a good understanding of organics due to marketing campaigns by the major
retailers and extensive media coverage. There remains some confusion among consumers on the health
issues surrounding organic food consumption, which FSA is seeking to address via a research project.
22. The Advertising Standards Authority has introduced a code of practice concerning the advertising
of organic foods which has gained the support of the organic industry.
23. The European Commission is seeking to develop a European logo for organic foods as part of its
European Organic Action Plan. Steps have also been taken at a European level to restrict the use of such
terms as “Eco” and “Bio” to organic products, to avoid misleading consumers. There is need, however, to
resolve conflict with the established use of the term “Bio” to refer to some fermented products such as
yogurt.
24. The DEFRA Organic Action Plan aims to identify what is required to ensure stable and strategic
growth for the organic sector. It sets out a series of practical measures which the Government and the food
and farming industry will take to encourage a sustainable organic farming and food sector in England. It
includes ensuring that consumers have access to relevant information.
GM Foods
The New EU Controls
25. The new GM labelling Regulations began to apply from 18 April and will aVect all foods produced
from or containing GMOs or GM derivatives. This marks a major shift in the GM labelling regime from a
basis of detectability to a basis of traceability, ie the scope includes all foods and food ingredients derived
from GMOs, not just those in which GM material is detectable. FDF has consistently pointed out that this
basis for labelling is unenforceable in practice. Such is the consumer climate at present, however, where
understanding and acceptance of GM technology is low, that manufacturers tend to avoid those few
ingredients that would be required by law to carry such labels. Thus, very few products are currently on the
market labelled as produced from or containing GMOs.
FDF’s Information Programme on GM Food and Farming Issues
26. FDF’s foodfuture programme promotes public understanding of genetic modification and food. Its
core publication, Food for Our Future, explains what GM crops and foods are and what benefits and risks
might arise from their use. It examines some of the concerns most commonly raised about the technology
and reviews the regulatory controls. An accompanying glossary provides a simple explanation of the
technical terms and a list of useful websites facilitates access to more detailed information on diVerent
perspectives on GM. It can support classroom study and help inform consumers more generally and it is
hoped that it will make a useful contribution to a balanced debate on this important subject. Food for Our
Future also forms the basis for the programme’s website http://www.foodfuture.org.uk
27. FDF companies are committed to ensuring that relationships with suppliers are ethically as well as
commercially based. FDF works closely with UK, EU and international bodies to promote the
dissemination of best ethical trading practice to help members tackle this complex issue. FDF’s Declaration
of Ethical Trading Values can be found at http://www.fdf.org.uk/about—ethical.aspx.
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28. Labelling can be a useful means of conveying ethical information about a product to a consumer. It
is not, however, the only means, nor will it be the most appropriate or eVective in all circumstances. For
example, corporate values statements and traditional product information provision are other means of
eVective communication. Accordingly, FDF believes that ethical labelling should remain voluntary. FDF
also believes that any attempt to restrict EU imports for ethical reasons would be in conflict with WTO
obligations. Furthermore, we would not support any attempt to harmonise the ethical component of
international production standards as, in our view, there can be no universally acceptable, objective level at
which such standards could be set.
29. To ensure that consumers have reliable information, ethical and associated logos relating to
production methods should be backed by established schemes, information on which is accessible to
consumers and compliance with which is independently audited.
30. FDF supports the comments (in response to this Inquiry) of the Biscuit, Cake, Chocolate and
Confectionery Association on ethical labelling. We would emphasise the general point that communication
about ethical considerations requires a diVerent approach from that about analytically verifiable,
compositional information or advisory information on product safety. Ethical claims cannot be verified
from inspection of the products about which they are made. Accordingly, FDF supports the oV-label
provision of background information which can help interested consumers to understand the context and
limitations of the ethical information given on product labels.
Food Information in the Context of Trade Negotiations in WTO
31. Further trade liberalisation through the WTO can be expected to lead to an increase in the volume
of UK and EU imports from developing countries. This increase will inter alia require as full a system of
traceability of ingredients as is needed to ensure that all exporters are complying with the provisions of the
WTO Sanitary and Phytosanitary (SPS) Agreement, other international product and production standards,
and EU standards where appropriate. Labelling may well have a role to play in this communicative process.
Where, however, developing countries are supplying raw agricultural materials for further processing in the
UK, documentary provision of information should be suYcient.
32. There is no mandate for labelling to be part of the current round of WTO negotiations and nor do
we consider there should be. If a product meets all legally required specifications, no WTO member has any
authority to restrict its trade because of the manner of its labelling.
Other Means of Communication
33. FDF believes that the essential information for food labelling concerns what the food is and contains,
with how it should be handled and prepared. Accordingly, we do not support the principle of having to put
information on food labels regarding, for example, production technologies and processes and origin of
ingredients, which makes little or no diVerence to the final composition of the food (except where it would
be misleading not to give such information). Increasing the information on labels restricts the space for, and
thus reduces the legibility of, the essential compositional and safety information.
34. As reflected above, given the space constraints on labels, manufacturers are making increasing use of
other means of communication, particularly customer care lines and company websites. Retailers are also
providing means of access to fuller information. Such means enable provision of specific information on a
range of topics that may be required by only a minority of consumers and which cannot be accommodated,
and may not be able to be provided, in the format of pre-printed product labels.
Note on the Dg Sanco Review of EU Food Labelling Legislation
35. In mid-2002, DG Sanco contracted the European Evaluation Consortium to undertake an evaluation
of the general food labelling legislation. (DG Sanco is also reviewing nutrition labelling as a separate
exercise.) The food industry made inputs into the review. The final report was given to DG Sanco in October
2003. A 19 page summary has been placed on the DG Sanco website, which can be viewed at:
http://europa.eu.int/comm/food/food/labellingnutrition/foodlabelling/eZ conclu.pdf
36. The Report draws a number of conclusions about information needs and clarity of presentation and
recognises that, given the limited space available on food labels, there needs to be a re-think about the
priority information which should be put on labels and alternative means which might be used to convey
other information. DG Sanco comments that the report identifies “the key points on which the Commission
will now have to focus for drawing-up a future proposal with a view to modernising the Community
legislation on labelling. It is expected that such a proposal could be put forward in 2005, following a
consultation process with all interested parties.”
37. This would provide the opportunity for the Commission to prepare a White Paper on labelling, an
initiative which FDF would support, thus avoiding piecemeal changes being pursued for the sake of
delivering short-term results.
April 2004
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Witnesses: Mr Martin Paterson, Deputy Director General of FDF, Ms Valerie Saint, Unilever UK Ltd and
Chairman of FDF Labelling Committee, and Mr Michael Hunt, Secretary of FDF Labelling Committee,
Food and Drink Federation, examined.
Chairman: Good afternoon, ladies and gentlemen. My
apologies for the slight delay before we were able to
begin our proceedings this afternoon, but welcome to
the Sub-Committee. We look forward to hearing your
oral evidence this afternoon and I would like to invite
Joan Ruddock to begin our questions.
Q503 Joan Ruddock: Thank you very much, and
welcome. There are quite a number of things which
you say in your evidence you do not want to see in
terms of food labelling, things which you reject. I
wonder, ideally, what information you would like to
see as required information, really what is the bottom
line that you think should be on food labels?
Ms Saint: I think, as far as we are concerned, the
bottom line is that it should be key information which
is important for the majority of consumers. We have a
lot of demands from diVerent groups of consumers
who want to have additional information and we can
provide that in diVerent ways, sometimes on pack and
sometimes oV. With regard to the food label itself, I
think it is important that it should concentrate on the
identification of the product, how to use the product,
how to cook it, how to store it, the ingredients are
obviously important, basically the information which
currently is required as the standard information
under the food labelling regulations. We feel that
additional information could be provided for those
groups who need it, either on pack, if there is room and
the facility, or by other means.
Q504 Joan Ruddock: Is there anything which is
required at the moment which you think should not
be on food and drink as a label, as a requirement?
Ms Saint: We have looked at this. It is very diYcult
to say for all products that any particular thing is or
should not be required. Double-labelling of
sweeteners is always one thing we quote as being
slightly over the top. Apart from that, it is diYcult
to say that any of the legal requirements are not
important for some products. It is not necessarily so
that they are important for all products, of course. I
think what we are looking for really is some
consideration of the quantity of information. When
something new is introduced there should be some
prioritisation, really. Do we think that everything
which goes before is just as important as the new,
because if we do not prioritise in that way there will
not be the clarity of the information on the pack. We
have to bear in mind that some packs are not very
big and it is quite important that the food safety
information, in particular, should be very clear to
consumers, on storage, and so forth. Therefore, the
more additional information you put on the more
you could sacrifice that clarity.
Q505 Joan Ruddock: I can see that point for the very
small packages and I think everyone is bound to
concede that point, but most packaging and most
food and drink products are of such a size that it is
possible to have clear information additional to
what is required, and indeed we saw some examples
of that from others who have given evidence. Do you
not think that where it is possible this is a reasonable
request that should be made?
Ms Saint: I think, on a voluntary basis, we are all
providing a lot of additional information over and
above the statutory requirement, and certainly that is
true of things like nutrition information. For food
manufacturers, I think we estimate about 80% of our
products have nutrition information on them, and I
would say a very high percentage is the big eight
nutrition information. That is voluntary. It is
necessary in a few instances if a nutrition claim is made.
I think we are providing the information. The trouble
is, with the statutory requirement it is overarching, it is
for everything, and then you have to start making
exceptions. The current small pack exemption relates
to very small packs indeed. The more information we
require by statute the more we ought to be thinking
about how those exemptions should work. It may be
that something like a stepwise approach could be
appropriate. I think, of the 20% of products which do
not contain nutrition information, a number of those
could bear a limited amount of nutrition information,
but of course the big four is the minimum we can give,
if we give anything.
Q506 Joan Ruddock: If that were in statute we would
end up perhaps with 90% of products
comprehensively labelled?
Ms Saint: If it were in statute, I suppose it would be
100%, in some fashion.
Q507 Joan Ruddock: Are you saying you would have
to have exemptions?
Ms Saint: Yes. I think, if you could adopt a stepwise
approach, let us suppose that, if you take nutrition
information as an example, the very small packs would
not have any, maybe the next size up could have
whatever was deemed to be most appropriate, maybe
“fat” and “calories” or something, then above that
four or eight I think you would get a very large
proportion of products with nutrition information. Of
course, there are some which do not contain it at the
moment. It does not seem particularly relevant, maybe
a packet of tea, or something, which is not terribly
relevant to those sorts of product.
Q508 Mr Drew: If we can look at this particular issue
of nutrition and what it is appropriate to inform the
customer about, can I start by asking what your views
are in terms of what is containable to make it sensible
on an ordinary piece of foodstuV? What sort of
information would you expect to see?
Mr Paterson: I am not quite sure.
Q509 Mr Drew: We are looking at nutrition
information on the label. What would you think was
a reasonable amount of that information to be
contained on a label, without being seen to be over
the top?
Mr Paterson: I do not think it is a question of being
seen to be over the top, it is a question of trying to
make a judgment about at what point you give more
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12 July 2004 Mr Martin Paterson, Ms Valerie Saint and Mr Michael Hunt
information than is useful and what information is
useful, in the context in which that information is
useful or not. If you are giving information which a
consumer would find diYcult to understand, we
have got, and I am sure we will talk about it at some
point, the conflict between salt and sodium, for
example. That is an area where you have to give
careful consideration as to what information is
there. I think, if you are provided with information
about, let us say, the three main nutrients, which are
the subject of discussion at the moment, salt, sugar
and fat, in the context of, say, a guideline for the
amounts of those nutrients, that would be the core,
I would suggest, of valuable nutrition information.
Individual consumers then break down into any
number of areas of interest. Some people are looking
for information relating to allergies, relating to the
way in which they want to conduct their diets,
relating to the way in which they want to do their
shopping.
Q510 Mr Drew: Do you think it is fair that those
products which contain a higher degree of content of
salt, sugar and fat should have that clearly labelled,
so that the customer is absolutely clear that if they
eat this they eat at their own risk?
Mr Paterson: I think that brings us back to what I
said about context. It is important that consumers
get clear, accurate information, and if there are X
grams per hundred grams, let us say, of fat in a
product then that is very useful information for
consumers to have. However, that has to be taken in
the context of the individual consumers themselves.
Consumers come in all sorts of shapes and sizes. The
product itself may be a product for sharing, it may
be a product for eating individually, it may be a
product which you use in cooking to make another
meal, so again it all comes back to context.
Mr Hunt: I think there is the context of the overall
diet as well. You used the term “eating at their own
risk” and I think we have said the industry supports
the provision of nutrition labelling, there is a large
amount of it given. The first line is just the factual
statement of protein, carbohydrate, fat and other
nutrients on the label. I think we believe that the
current requirements are not unreasonable but there
is scope in a forthcoming review of nutrition
labelling, which the Commission is going to
undertake, to consider, as Valerie has said, whether
there could be a shorter list for small packs to
increase the possibilities. The solid fact of
information given in nutrition labelling in listing the
nutrients, the understanding of that information and
the placing of that product in the overall diet, that is
another issue. Also we feel it is a Government
responsibility to see that there is adequate advice to
consumers actually to understand and use the
straightforward factual information which is given.
Q511 Mr Drew: Is there an argument that producers
should not include nutrition information? Is there an
argument, or is it now given that it is the quality of
that information and the amount?
Mr Paterson: I think the latter. It is a matter of the
quality, the amount and the context.
Mr Hunt: Also it raises the point that manufacturers
are prepared to tell consumers about their products,
the issue sometimes is can you or can you not get that
on the label? There is no question nutrition
information should be available for everything but
can you put it on the label and can you put the
current requirement on the label? If it is not possible,
it is possible to get that information by other means
if required.
Ms Saint: I think the use of free care lines has
extended the availability of all sorts of information
about products and our consumers can ring up for
additional guidance and help on products if they
want to.
Q512 Chairman: What is your view on the proposals
being discussed within the European Union and the
European Parliament prior to the elections on food
labelling? What is your Federation’s view on those
proposals? There is ongoing discussion within the
European institutions, as you know. What is your
view on the various options which have been floated
certainly within the Parliament and within the
institutions?
Mr Hunt: I am still not clear what the question is.
There is an overall potential review of food labelling,
which will now wait for the next Commission to
come in. We were hoping that DG Sanco would look
at the totality of food labelling in fact, including
nutrition labelling, and stand back and look at it
again and say, “Well, what are the priority items,
what must go on the label, what could be provided
by other means?” Maybe there are standard ways of
provision by other means to enhance consumer
comprehension. Certainly we would welcome that
general debate at this point in time. With food
labelling, so many bits have been added on to, what
really is rather old legislation.
Q513 Chairman: What I was trying to find out was
your Federation’s view on whether there should be
such nutrition labelling legislation adopted at the
European level, and are you actually in favour of it
happening, not just in favour of a debate?
Mr Hunt: First of all, on nutrition labelling, because
we have nutrition labelling legislation, currently it is
voluntary although the format is standard and that
is very important to take account of so it is
comparable between products. The view, I think,
within the Commission is towards mandatory
nutrition labelling, our preference is to retain a
voluntary approach. If it were made mandatory then
all sorts of considerations would have to be taken
into account in terms of small packs, products for
which it is not so relevant and whether we could have
a shorter list of nutrients which could be applied to
more packs. There are all sorts of technical
adjustments which need to be made to the old
legislation as well. Our view is preferably to retain a
voluntary approach with a standard format.
Q514 Chairman: How would you respond to a
suggestion that food and drink be required to be
labelled with its means of production rather than
that information being provided on a voluntary
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basis, so that, for example, non-free-range eggs and
hormone-added beef would be required to display
that information on the packs?
Mr Hunt: I think that is a very good example of the
kind of information which arguably is of interest to
specific groups of consumers and could be catered
for very adequately by providing information by
other means than on the label. I do not think we
would be in favour of a very greatly increased
requirement. Of course, manufacturers can provide,
and do provide, any information which they wish to,
and of course if something is being sold on that basis
then the information would be given, otherwise
there is not the basis for the purchase. In general, I
think we would see methods of production as being
an area for alternative means of communication and
the essential role of the label being to say “What is
the food, what is in it, how much is there, how long
is it going to last, how can I safely handle it and
consume it?” It is about the product and not about
its history. You can go on and on painting in the
history of a product and that information we would
prefer not to have to put on the pack.
Ms Saint: It could be provided by those
manufacturers who are targeting that particular
market, because it is not all consumers who are
interested in those kinds of issues.
Q515 Joan Ruddock: Your evidence seems to
suggest that you support farm assurance schemes.
To what extent do manufacturers require their
suppliers to be members of farm assurance schemes?
Mr Hunt: Manufacturers do need to source, bearing
in mind the vast quantities of food which are
produced, from wherever they are able to source to
required standards of safety and quality, very
broadly speaking, and so there is not a fundamental
requirement for farm assurance produce. Individual
companies may well build that into their
specifications, they may require that, it would be on
a company basis. If a company were on its product
carrying through some kind of claim about one of its
ingredients which was backed up by a farm
assurance scheme then of course they would have to
make sure that was all in place. Broadly speaking,
the issue is to source materials to the required
standards of safety and quality from wherever they
happen to be available. There has to be a certain
flexibility of supply because if one should fail then
you can keep making the product if you can source
from an alternative place.
Q516 Joan Ruddock: Is it a growing phenomenon,
manufacturers requiring produce to come from farm
assurance schemes?
Mr Hunt: I am unable to answer that, I am afraid.
On the whole farm assurance movement, one can
have great sympathy for the desire, as it were, to sort
of badge farm assurance onto agricultural and
horticultural produce for consumers for whom the
whole agricultural and horticultural industry, I
suppose, is something of a haze and bring it nearer
home and give that connection with the consumer.
With regard to our supply of materials, we are not
generally carrying through farm assurance marks
into manufactured products in respect of
ingredients, they tend to be there in respect of
primary products and very lightly processed
products. It is only just on the edge of our direct
concern.
Q517 Joan Ruddock: Given that is the case, is it your
view that manufacturers would be very concerned to
check the claims which had been made by those farm
assurance schemes, or do you think they would just
take it that if they are in the scheme they are in the
scheme and that is okay?
Ms Saint: I think, if we were making any claims in
connection with any of those assurance schemes,
clearly we would want to be reassured that the claims
were supported and that would be part of our due
diligence. I think it is very important to us that our
specifications are met and that is part of our
commercial relationship with our suppliers.
Q518 Joan Ruddock: They would not have checks in
place unless, as you say, they intended to pass on the
farm assurance information?
Ms Saint: I think that rather depends. It can be part
of our specification anyway. I do not mean farm
assurance marks on packaging, but in our general
corporate imagery, so to speak. We might be wishing
to say we will source our beef from British cattle, we
know the farms, or whatever it is, in which case,
clearly, that is still part of what I would refer to as
specifications to meet our claims. I think that is the
most important thing for us.
Q519 Mr Drew: Has traceability gone as far as it can
do, in terms of the labelling which retailers expect
from the manufacturers, who in turn want to know
where the animals come from in terms of the
producers?
Mr Hunt: Traceability systems are a vital part of
companies’ quality assurance procedures and go
way beyond the narrow issue of whether you are
backing up an origin claim or not. The need to know
where the ingredients come from and where the
products go to obviously is very important in terms
of being able to track back a problem or recall things
which have gone forward. If an origin claim is made
then the traceability system should be there to
demonstrate the claim, I think that is all I can say.
Where it is diYcult to make specific origin claims, for
example, in the mixing of huge quantities of bulk
ingredients, you can’t be very, very specific. There
again you are buying to a quality and a safety
criterion and it may be much more diYcult to know
about specific origin. In that case you would not be
making a claim. I think the systems are there to
support the claims which are made, they have to be.
I do not know if I have quite answered your question
but sometimes there is confusion between the farm
assurance and the origin claim and the issue of
traceability, which is altogether a much vaster
subject.
Q520 Mr Drew: It is, but I think the consumer would
want to know that traceability is as good as it
suggests it is, and one would have thought that it
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would be an obvious area for the consumer to expect
the food chain to invest time and money in, which is
to look at the nutritional input right from the
producer up the line. Really I am asking you again,
is traceability something which can be improved
upon?
Ms Saint: I think it would be quite hard to improve
on it. Certainly I think that responsible companies,
and hopefully our members are, find this an
incredibly important area. I think, to be honest, the
Food Safety Act in 1990 was one of the things which
stimulated a huge amount of work on traceability of
ingredients from the safety perspective. That has had
a very positive impact on traceability of all kinds.
We are able to trace our supplies back. That is
important to us, from the product liability point of
view, but also it is important because of our promise
to our consumers.
Q521 Chairman: Can you tell me how active a role
you play, as manufacturers, in supplying
information to your customers in the food service
sector? This is a sector where caterers, in general, are
not required to provide their customers with
nutrition information, and by and large do not do
so. Are they aware themselves of the nutritional
profile of the food which they are serving, and what
do you think is the role you have got in ensuring that
your own customers are providing information of
that nature?
Ms Saint: Certainly we are required to give certain
information to the food service sector, that is
absolutely important, and ingredients and general
safety information, and so forth, about the product
we have to do as statute. Whilst nutrition
information is voluntary we do give that
information to our food service customers if they
require it, if they want it they can have it. I think
quite a lot of us are giving it voluntarily anyway,
whether they want it or not, but certainly, if they do
require it, it will be a commercial arrangement
between us to provide it. What they do with that
information, of course, subsequently is slightly more
complex because it will depend how they are using
our products. Where they are serving them in a
formulaic sort of restaurant, if you like, where
everything is very much the same, then it is very easy
for us to provide them with information and for
them just to translate that directly into consumer
information. However, if we are providing
something which is to be served with other
ingredients or to be dressed up by the chef to be a bit
more creative then clearly they have to allow for
what they are doing to our products when they are
giving nutritional information to their consumers.
The answer to your question is that certainly we will
give them the information if they require it. Very
often we give them the information even if they do
not want it.
Q522 Chairman: Do you find there is any substantial
number of customers who ask you for that
information or require you to give more information
than normally you would provide? Is there a demand
for it?
Ms Saint: I cannot answer that question.
Mr Paterson: I am afraid I do not know the answer
to that question. I am very happy to go back and see
if we do know the answer and write to you,
Chairman. The fact is, that the nutrition
information is there, and is available to customers.
Q523 Chairman: If you do have that information
available it will be helpful for us to receive it in
writing after the meeting. Can I turn now to the role
which Government has to play in the issue of food
information. How clear a message do you feel you
get, as an industry, from Government and from the
diVerent departments and agencies of Government
on what should be the priorities for communicating
information in the food information field?
Mr Paterson: I think in the last couple of years there
has been something of a history of a lack of clarity,
a lack of joined-up government, if you like, but
actually that has been getting better. I think that the
process, particularly the consultation process of the
proposed White Paper, “Choosing Health”, has
enabled an easier focus, through the Department of
Health, on what is important. The roles of the Food
Standards Agency and the Department of Health
are sometimes diYcult for manufacturers, and
indeed other stakeholders up and down the food
chain, to unpick. In both cases we have taken the
view that both organisations are arms of
Government and that we must do our very best to
not pick a path between them but to engage fully and
completely with both operations.
Chairman: I think Joan Ruddock wants to pursue a
particular example of policy.
Q524 Joan Ruddock: It is the initiative on cutting the
salt level. Obviously, this has proved quite
controversial. I would be interested to know whether
you felt this was an appropriate initiative by
Government and how you would respond to that?
Mr Paterson: Can I start by giving just a little bit of
history. In fact, up until 2000, there was no
nationwide, industry-wide information on the use of
salt or sodium in manufacturing foods. The Food
and Drink Federation commissioned and produced,
for the very first time, a survey to provide us with a
baseline for that very information. This was of
course before the Food Standards Agency came into
being and we shared that information with the
predecessor organisation.
Q525 Joan Ruddock: What was the motivation for
doing that?
Mr Paterson: That was in the discussions leading up
to the Food Safety Bill which brought about the
Food Standards Agency, and discussions with the
shadow agency, which was called, I think, the Joint
Food Safety Standards Group. Conversations were
facilitated. The whole process of establishing the
Foods Standards Agency was to unpick food safety
issues from the then MAFF. As part of that, we were
able to engage from the very beginning in pretty
fruitful dialogue, and as a result of that we
undertook to do this piece of work, which took quite
a long time, I think about 18 months, and then we
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shared that information. As you can well imagine, a
lot of the information was produced on the basis that
it was to be shared with the JFSSG and that it was
still commercially confidential. In fact, this was the
basis for what you have described as a Government
initiative, it was pretty much a partnership between
the then Food Standards Agency predecessor and
the food and drink manufacturing industry. If I can
leap forward in time, during the course of the year
before last, with the results coming last year, we
agreed sectors of processed foods to which the Food
Standards Agency felt contributed substantially,
particularly to children’s diets. Also the Food and
Drink Federation set about pulling together the
main operators, trying to see, on an industry-wide
basis, whether we could reduce salt in a way which
would be monitored by the Food Standards Agency
and in a way which would be satisfactory to them. I
am quite keen to make something of that, because
one of the reasons for a certain amount of ire, which
you may just have detected perhaps in a letter which
was published, which we sent to the Health
Secretary, was the suggestion that perhaps we were
dragging our feet and perhaps we had to be whipped
along a little. We do think it is a very worthwhile
initiative, as do the companies out there on the
ground who actually have to sell these products. We
feel that targets cannot be plucked out of the air, that
if you take salt out of a product and it is left on the
supermarket shelf, or a consumer puts salt into that
product at home, then nobody has been served,
potentially the product has been damaged and
potentially the company and the jobs reliant on that
company have been damaged. This is a process
which perhaps in some areas is reaching the edges of
the technological potential of salt or sodium
reduction. We feel that a great deal of work has been
done and the industry has demonstrated a
willingness to play a part.
Q526 Joan Ruddock: Do you think you might ward
oV legislation?
Mr Paterson: The intention is not to ward oV
legislation, the intention is to play our part. We took
a view as an industry after much hand-wringing and
internal argument over what was correct and
appropriate and the extent to which an industry’s
sense of responsibility as part of the community
should override. There will be some cases with,
clearly, potentially financially diYcult and
technically diYcult issues, and we took a view as an
industry that we would participate, that we would
play our part as corporate citizens and we are going
down that road.
Q527 Joan Ruddock: How do you explain the fact
that some companies clearly have made good
progress voluntarily and others, as the Minister has
said, just have not?
Mr Paterson: In fact, of course, it is all voluntarily.
Q528 Joan Ruddock: Sure, but I am saying
voluntarily without being part of an industry-wide
shift. Some companies have gone ahead, made
progress, made significant cuts and the range of
foods is pretty similar, is it not, across diVerent
companies?
Mr Paterson: Frankly, it was something of a
triumph that, as a trade association, we were able to
abstract the commercial and competitive elements
from what became known as project Neptune, which
was a group of companies agreeing to take salt out
of soups and sauces. That was very diYcult to do,
actually, but as part of this process, you are quite
right, many companies looked perhaps at the
processes and realised they could do diVerent things
in diVerent areas, and so forth, and they are perfectly
at liberty to do that, and that is the way that these
things work. It is the case that they take a calculated
risk—but a risk nevertheless—that their consumers
will not try that product once, put it back and go
back to another product which perhaps has got a
little more salt in it. We make no bones about it.
There are many technological reasons and many
food safety reasons, but on the majority of occasions
salt is used primarily for taste.
Q529 Chairman: How many of your members have
subscribed to the salt reduction programme?
Mr Paterson: In terms of the areas which we agreed
with the Food Standards Agency, which was soups
and sauces and then we went on to quantify
reductions which could be made in cereals and
reductions which could be made in bread, that was
the entire sector. I do have to say though, because we
are coming no doubt to the same thoughts in the
other areas of fat and sugar, that it is a diVerent
kettle of fish, and those discussions no doubt will be
had. I would not be as confident, knowing that it was
quite a diYcult job, as I say, to abstract the
competitive element of salt reduction, when we come
to sugar and fat. I think that already we are seeing a
great deal of movement by individual companies
who are either making changes to the composition of
individual products or they are making variants of
products with diVerent compositions. They are
providing choice in order that the market can work
in that way and consumers benefit from that. It is not
necessarily the case that we will be able to do the
same thing in sugar and fat as we will be able to do
for salt.
Q530 Joan Ruddock: If you are saying, which you
did just then I think, that consumers benefit from
these reductions—
Mr Paterson: They benefit from choice, is what I
said.
Q531 Joan Ruddock: They benefit from choice. The
science suggests, and I think this is pretty much
agreed, that lower levels of salt, sugar and fat than
we are used to in processed foods is to the benefit of
most people’s health. Given that you acknowledge
the diYculties which may be faced in trying to get
companies to reduce in the other areas of sugar and
fat and that salt itself has been diYcult, is not this a
reason for ensuring that every product has got
nutrition information on it, and indeed that the
Government ought to legislate to make this a
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requirement? The choice would still exist but at least
everyone would have the opportunity to know
exactly what they were eating?
Mr Paterson: I think, as my colleague has mentioned
already, overwhelmingly nutrition information is
available one way or another now.
Q532 Joan Ruddock: Not on the products. Is not this
the point, that now we all have these ideas? I can take
my own example. I was always taking a bottle of
fruit juice, as far as I knew just fruit juice, every
lunchtime, and when we began this inquiry I made a
point of checking up—it was one of these energydense products, unknown to me—and found that
actually I was taking far more than I needed in terms
of calorie intake and I could easily swap to
something else. I would not have had a way of
finding that out easily if it had not actually been on
the bottle?
Mr Paterson: I appreciate exactly the situation you
found yourself in there, but for the various reasons
already expounded by my colleagues we do not think
that a mandatory legislative route would be helpful
overall because it would catch the other areas which
my colleagues have already spoken about.
Chairman: I think that concludes our questions this
afternoon. Thank you very much indeed for coming
along to the Committee. Thank you for mentioning
that you will supply us with some additional
information in writing, which we look forward to
receiving in due course. Thank you very much
indeed for both your oral and your written evidence.
Thank you.
Supplementary memorandum submitted by the Food and Drink Federation
This is to follow up the Food and Drink Federation’s (FDF) undertaking, during oral evidence to the
Sub-Committee on 12 July, to respond in writing to the Chairman’s question as to whether there is any
substantial number of foodservice customers who ask for nutrition information or require manufacturers
to give more information than normally they would provide.
A brief survey of some major FDF members supplying the foodservice industry has indicated that
products supplied are routinely accompanied by Group 2 nutrition information, usually on the product and,
otherwise, in documentation. Foodservice companies regularly seek a substantial quantity of information
on products purchased, including Group 2 nutrition information. Manufacturing companies’ own standard
specification documents always contain Group 2 nutrition information.
It would appear to be the general case that full nutrition information is available on products sold to
foodservice companies, is usually asked for and is routinely provided by means of labels or documentation.
July 2004
Memorandum submitted by the Trading Standards Institute
1. Nutritional Content of Food
1.1 Trading standards is becoming more proactive in publicising the nutritional content of foods,
particularly school meals and meals on wheels, as part of the overall health agenda. However as Trading
Standards is local authority based any publicity tends to be mainly local, often regional (through regional
co-ordinating groups) or sometimes nationally through the TSI. It is an area, which TSI see as an important
element to help education consumers to make informed decisions on their diet, which will help to drive up
the health of the nation.
1.2 The way forward must be through a medium which can be understood by all, in a format which
consumer will buying in to and understand, this will require a number of diVerent formats, some people will
be interested in a detailed programme looking at the nutritional content of food, others will be not so
proactive in looking for the information and in many ways the information will have to come to them in
bite size pieces, simple messages.
1.3 Of course the best way to communicate the nutritional content of food must be at the point at which
the consumer makes the choice to buy the food, for prepacked foods the nutritional content should be
prominently displayed of the pack, not hidden away and it should be on all foods, not just those making a
claim about being low in fat for example.
1.4 As regards food sold at catering establishments or food sold loose, there is currently no requirement
to display the nutritional content of the food, however the consumer must be empowered to know what is
the nutritional content of foods. To that end the nutritional content must be displayed for all foods no matter
how they are sold.
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2. Safety of Foods
2.1 Consumers do not really need to know that food is safe to eat, as all food should be safe to eat, they
need confidence that food is safe to eat. They do, however, need to know the cumulative eVects of eating a
food or a particular ingredient, which may be in a number of diVerent foods, eg artificial colours. RDA’s
may help here.
3. Means of Production
3.1 The means of production with the except of fish and eggs is not communicated to consumers, there
should be no reason for this not to be indicated to the consumer, however the consumer must be able to
understand what each method really means and the eVects of that method of production.
3.2 Communicating the means of production is relatively straight forward, however, educating
consumers about the implications of these methods is some what harder.
3.3 Approval schemes and logos can be useful but have an unfortunate history as regards their credibility.
If such a scheme is to be used the rules must be transparent and have consumer backing.
4. Ethnical Considerations
In this mutli-cultural society consumers will have ethnical considerations about the foods they eat, the
method of slaughter etc, most of this information could be and often is either labelled on the food or made
know at catering outlets, it is, however, a positive indication, only food purporting to be Halah is labelled,
consumers are often confronted by food with no indication for which they must assume is not ethnical. This
is not particularly helpful, also, consumer who eat out may want information on ethnic considerations
before they book a table, it is part of their considerations for choosing a restaurant for example. May be
caterers could be encouraged through a code of practice to indicated particular ethnical concerns in any
advertisement and/or menus.
20 April 2004
Witnesses: Mr David Pickering, Joint Food Lead OYcer, and Mr Phil Thomas, Joint Food Lead OYcer,
Trading Standards Institute, examined.
Chairman: Good afternoon and welcome to the
Committee. Thank you for submitting written
evidence and we look forward to your oral evidence
this afternoon. Could I invite David Drew to begin
our questions.
Q533 Mr Drew: Good afternoon. I saw your report,
which has got the benefit of brevity, which we always
like in this Committee, but it does sound as though
you are a bit underpowered in this area, that is my
observation, given that I imagine your members
have a great wealth of anecdotal evidence, to call it
that, where you might want to go further. I wonder,
as an association, how much you feel this is an area
which is important to your members and really you
would want to see some improvements which then
you could police?
Mr Thomas: In terms of nutrition labelling, yes, we
do feel that we are underpowered, in that the
requirements to mark food with its nutrition
information is limited to either where a claim is made
or it is a voluntary declaration by the manufacturer.
There is lack of consistency in terms of providing the
information to the consumer.
Q534 Mr Drew: Do you feel that you have got the
expertise amongst your members? If there was a
statutory enforcement of nutrition information,
maybe backed up with some ethical considerations,
do you feel that without a great deal of training,
retraining, this would be impossible?
Mr Pickering: I think we have been enforcing
nutrition information requirements for the period
since they came into legislation anyway, so whilst
there is always scope for improvement I think that
there is a wealth of experience there already.
Q535 Mr Drew: What would be useful is for you to
give us a feel for where the existing rules are woefully
inadequate if you want to see this area developed
properly, and where currently the anomalies exist so
there is confusion, certainly in the mind of the
consumer, who comes to you and says “I thought I
was buying something that was going to be a
relatively low-fat, low-salt, low-sugar content and
now I find it’s just the opposite of that”?
Mr Thomas: Where we feel there are anomalies
with the legislation is that, obviously, as
mentioned previously, it is not a compulsory thing
on all foods to have nutrition information. Most
of the foods which tend to be high in sugar,
particularly, and also fat, unless they make a
claim, do not tend to declare the nutrition content
or any nutrition information. Also products which
are sold at catering establishments, the consumer
has no idea of what the nutrition element of that
would be. For example, if you take a typical
sandwich, I think a lot of consumers would
anticipate a sandwich being fairly low in fat, but if
they have used mayonnaise and butter then the fat
content will be fairly high.
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12 July 2004
Mr David Pickering and Mr Phil Thomas
Q536 Chairman: Where there are food labelling or
food safety laws, how many prosecutions actually
take place? How many do you estimate there have
been, say, in the past 12 months, or breaches in
this area?
Mr Pickering: The figures for the last 12 months are
not available as yet.
Q537 Chairman: For the last period you know
about?
Mr Pickering: For the last period that we have got,
on average, it was four per authority per year.
Because the Food Standards Agency collate figures
from each authority, and having looked at the last
report which was issued by them, it came out at
about that, and that was purely on food standards.
Q538 Chairman: We might pursue that point with
the Food Standards Agency later. In your view, how
adequate are the penalties where prosecutions are
successful? Are the fines high enough to act as a
deterrent, or are they somewhat small, given the
turnover of the companies involved?
Mr Pickering: I think there are a number of issues
there. One of the things which we were going to
mention was not so much the penalties, because the
penalties are pretty much in line with other
consumer protection pieces of legislation, there are
other issues relating perhaps to time limits, certainly
for food labelling oVences. Also the fact that when
you are investigating an oVence you have to go
through the legal process, quite rightly, but that
places a number of obstacles in the way, especially
with criminal oVences, which we have to take to
prosecute a company. We have to prove it beyond all
reasonable doubt in a court. One of the
developments in other areas of trading standards
legislation is the use of the Enterprise Act. That is a
route via the civil law format whereby an injunction
can be taken out against the company or the
oVender if they are trading in such a way that is not
compliant with the law. Although penalties are an
issue, we thought about it and felt that really, in a
way, it was the whole method of having to go
through the criminal law system which probably
inhibits authorities from taking cases, because
companies, for whatever reason, quite rightly, do
tend to use legal process to put their case, but it does
take a lot of time. The time limit for food labelling
oVences is six months and, although that may seem
like a long time, as is the case now quite often, larger
companies tend to want to be interviewed formally
by letter, which can eat quickly into that six months’
time limit. In a way, probably the process is not
served particularly well by having to go through the
criminal law side.
Q539 Chairman: You mentioned the Enterprise Act
as a possible means of addressing this issue. Have I
understood you correctly in that and has that been
of any use to you so far?
Mr Thomas: The problem with the Enterprise Act is
that one of the specified acts which it covers is not
food and so we have not been able to use it, but we
foresee it being a way in which we can achieve quick
compliance without the need to go through a lengthy
formal criminal prosecution, which at the end of the
day is what we want to achieve. What we want to do
is ensure that the food which is being sold complies
with the law in terms of its composition
requirements and also its labelling requirements.
Q540 Joan Ruddock: You said an average of four per
authority, have you looked at those statistics by
authority? Is it a case that there are some
enthusiastic oYcers and a few authorities have done
lots and lots and lots and most authorities do not do
any at all?
Mr Pickering: I think it varies by authority. I think
it is not as polarised as that. Most authorities do take
their obligations under the Food Safety Act
seriously and most authorities, maybe not in that
particular year, will take action, they will not take
prosecutions but will take some form of action.
Again, the Food Standards Agency will be able to
give you figures probably better than we can, but
certainly there has been an increase, I think, in the
use of formal Home OYce cautions as an alternative
to prosecution. That fits in with the idea that, if a
company will agree to accept it, for an authority that
is a far cheaper and easier route to achieve
compliance than trying to take that company to
court. I think written warnings will happen, but in
terms of consistency throughout the country there is
not any. Probably that is because there may be local
issues which will mean one authority will be more
active than another.
Q541 Joan Ruddock: Do they tend to be proactive as
opposed to consumers coming to the authority with
a complaint; it is going out and making
observations?
Mr Pickering: There are complaints we deal with but
also each authority will have a food standards plan
in which normally they set out the number of
inspections and sampling projects they are going to
carry out. It is not just a case that authorities sit back
and wait for complaints, there is normally an active
inspection regime, plus, coupled with that, a
sampling regime. I do not know what the figures are
but there are formal actions resulting from
complaints and the inspections and sampling which
have been carried out.
Q542 Joan Ruddock: Are most local authorities
resourced suYciently to do that and follow it
through with prosecutions, if that is the only way to
deal with a persistent oVender, for example?
Mr Thomas: It depends very much on the amount of
complaints and the depth of detail of the
investigation but on the whole trading standards are
equipped to carry out investigations. We investigate
complaints and criminal activity in all the consumer
protection legislation with which we deal. To focus
in on one as opposed to the rest of them, I think a
general picture would be that we are able to cope.
Mr Pickering: I think it would be fair to say that
occasionally authorities do try to go for the nonformal route rather than the formal. Certainly in the
authority I have worked in it has got to a situation
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where, because of the process, we have decided to
abandon a prosecution because we did not feel we
were in a position to gain enough evidence within the
time limit which we had.
Q543 Joan Ruddock: That is quite important, if you
are saying you abandoned it not because of lack of
resources but because you could not get the evidence
in time. You are saying that the process is wrong, are
you, or inadequate?
Mr Pickering: The process does not help but in terms
of resources there is an issue, because if you have the
resources probably you could throw the resources at
it to get it within the time limit. Given the resources
which we have got, it can be quite diYcult when a
company which you are investigating comes up with
evidence which you feel you have got to counter to
win the case, but you do not have the resources to
throw at it but the major companies do. It could be
a small unitary authority, a London borough, or
whatever, with a small budget, trying to take a case
against one of the major corporates, and it is
diYcult.
Q544 Joan Ruddock: It is not so much the Eddie
Grundys—I do not know if you are aware of the
Archers case and his meat—it can be major
companies which are not complying and local
authorities are pitted against major companies?
Mr Thomas: To be fair, yes. As an enforcement body
what we try to do is seek compliance, so we will try to
get compliance first before we prosecute. Although
prosecution is principally the only tool which we
have got to ensure compliance, it is seen very much
as a last resort and we will use a number of diVerent
methods which we have got open to us, advising the
trader and using the home authority principle which
we have which works very well. In general terms, the
people who push the boundaries and cause the more
complex investigations tend to be the major
manufacturers and retailers because of the technical
abilities they have to push the legislation as far as
they can make it go.
Mr Pickering: I think they accept that part of that
process is the fact that they are trying to establish a
bigger market share than their competitors. They are
the people who will be pushing the legislation to its
limits and normally that is where we end up in court
if maybe we cannot agree on that interpretation.
Q545 Joan Ruddock: It is very interesting. Is it a
diYculty for local authorities, we were talking about
resources but just in terms of the number of statutes
which you have to enforce? Where does looking after
food labelling and safety laws sit in relation to all the
many duties which trading standards oYcers have?
Mr Pickering: It is part of the core function of most
trading standards departments and it is treated as
that. Some authorities will have dedicated food and,
these days, farming teams because of the food chain
issue, but even where they have dedicated teams now
it will mean that most authorities will have oYcers
who can enforce food legislation. I think that the
vast majority of authorities take it as being a core
function of what they do. Certainly I think that, and
again, obviously, the FSA would be able to
comment on it, the audit programme which the FSA
have carried out has shown that within trading
standards, within the Service, that is the case.
Mr Thomas: Because we are based at local
government level, you will find that we respond to
local needs. In certain authorities they may have a
higher profile of food manufacture because of their
general location, and so it is right that they would
deem food to be a higher profile in those areas than
in one perhaps where there was not any
manufacturing taking place. As a whole, I think it is
one of the core functions.
Q546 Joan Ruddock: Are there any other bodies
which can enforce, not just local authorities?
Mr Thomas: The FSA can enforce.
Mr Pickering: We had a think about this and we
could not think of any other organisations which
would enforce food legislation.
Q547 Mr Drew: If we can talk about the infamous,
notorious, whatever you want to call it, case of Tesco
and Asda, can I be clear which trading standards
department is taking action?
Mr Thomas: Shropshire are taking the case against
Tesco and the authority for which I work, Swindon,
are taking action against Asda.
Q548 Mr Drew: You received a complaint, if you are
wearing your Swindon hat, and you are acting on
that complaint?
Mr Thomas: No. The information was picked up by
an oYcer who was shopping there oV duty and he
saw the sign and realised that it oVended the
regulations.
Q549 Mr Drew: Do you not need this like a hole in
the head? I can think of plenty of actions you might
want to take, like Tesco and Asda, but without
prejudging the legal outcome this is a big case and,
in a sense, it is carelessness on their part rather than
deliberately trying to mislead?
Mr Thomas: It is diYcult to comment on the case
because it is still going on. Definitely you are right
that if they had been more careful the claim would
not have been made. If we were given the choice
between having to prosecute and not having to
prosecute then we would pick not having to
prosecute. Nevertheless, we are forced into a
situation where we have to, to ensure compliance.
Q550 Mr Drew: In a sense, if we get further along the
statutory line, with regard to food labelling,
inevitably this is going to lead to many more
prosecutions?
Mr Thomas: Yes, although, interestingly, with this
particular claim, if the new health claims Directive
ever becomes law and pre-approval was required
then obviously that would have negated this
particular action because they would not have been
able to make that claim with the pre-approval.
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Q551 Chairman: On that general point, what is your
view of the debate which is taking place within
Europe about the additional labelling and health
claims? What is your Institute’s position on what
should be coming out of Europe?
Mr Thomas: We support fully the proposals that
health claims should be regulated and that there
should be pre-approval for all health claims which
are made, even ones which relate to generic ones.
For example, not picking them for any particular
reason but health claims such as the branding like
“too good to be true” or “be good to yourself”, those
particular pseudo health claims, which do not
actually make a health claim but give the impression
to the consumer that the food has a health benefit
to them.
Q552 Chairman: What implications would that type
of legislation have for enforcement, your ability to
enforce the rules?
Mr Pickering: It depends how the legislation is
worded, of course, but in theory it should make our
lives easier because we will not necessarily have to
take a company to court in relation to a health claim
type scenario. The health claims area probably is the
one which is causing a lot of issues at the moment
because of the growth of the types of foods which are
coming onto the market at the moment. At the
moment it seems that every food which comes onto
the market has got some benefit for us, and
inevitably this leads to more claims in terms of
people’s health and it makes our job quite diYcult.
We were going to mention the work of the Joint
Health Claims Initiative, which is helping to a
certain extent in terms of verifying claims. That is the
other issue. It is not just whether or not the claim can
be made, if it can be made it is how then can it be
verified, which, as you can imagine, is quite a diYcult
one to verify from our point of view, it is a lengthy
investigation. Hopefully, if it can be worded in such
a way that will work, it should make our life a bit
easier in that area.
Q553 Joan Ruddock: We have heard a lot about
nutrition requirements being displayed, labelled, on
processed food and food in supermarkets, but it is
much more diYcult when it comes to catering outlets
and food which is sold loose. Have you any ideas you
can share with us as to how it might be possible to
signal nutrition requirements in these outlets?
Mr Thomas: There is a proposal to have traYc
lights. I am not entirely sure how that system will
work and how the message will be conveyed to the
consumer as to what foods are good to eat and what
are not. We appreciate that it is very diYcult for
catering establishments, particularly if they are
making the products from raw materials, to work
out what the nutrition content of the food is. We see
it as a vital thing that they do, because obviously so
much food is eaten from catering establishments
these days that whilst consumers might be very
particular about the foods they eat which are prepacked, where they are given the information, all
that good work can be undone by eating the wrong
sorts of foods at catering establishments. From that
perspective, we would see it as an important thing
that, by whatever means, that information is given,
particularly in terms of fat, sugar and salt and also
the calorific value, because obviously they are the
four in which consumers are most interested, in
terms of their health and well-being.
Q554 Joan Ruddock: Do you think it would be
possible for your members to police a traYc lights
system which made it easier?
Mr Thomas: It would depend on how the traYc
lights system was to work. I think the hardest part of
a traYc lights system is getting the information to
the consumer so that the consumer understands
what is meant by the traYc lights system. If
something is high in sugar but low in fat, is that a
green traYc light, an amber traYc light or a red
traYc light, and how many amber traYc lights foods
can a consumer eat before they do themselves some
nutritional harm?
Q555 Joan Ruddock: Clearly, that would all have to
be worked out and agreed across industry to make it
work at all?
Mr Thomas: Indeed.
Q556 Joan Ruddock: Supposing all that work had
been done then how would you view that, as
something which your oYcers would have to police?
Mr Thomas: It would be just another add-on to the
work they do within the food area. We take
thousands of samples of food per year. We take them
to look at the labelling, the compositional
requirements and against any nutrition claims which
are made. Obviously, that would be another thing
that we would analyse for, to make sure that it
conformed to whatever light there was in the traYc
lights system.
Q557 Joan Ruddock: How do you think they will
enforce it? You say they would have to take it on, but
spot checks, or what?
Mr Thomas: Probably we would do it as part of a
sampling programme.
Mr Pickering: I think it would be just part of the
normal work really. I think the key to it is, as Phil
said, if we did try to take action against a product
which seemed to be oVending, would the criteria be
suYciently precise for us to take it? To be honest, if it
is another scheme which comes in which is not wellworded probably it will do more harm than good.
Then, for us as enforcers, eVectively it becomes
another claim which manufacturers can use to sell
their products in a way in which perhaps we would
think, “Well, really should that be sold in that way?”
Q558 Joan Ruddock: Another meal for the lawyers,
is that what you mean?
Mr Pickering: You mentioned farm assurance
schemes earlier on. There are sorts of things like the
red tractor logo and again that is something we saw
as perhaps a good idea but there are problems with
it.
Chairman: That is a point I think David wanted to
pursue.
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Q559 Mr Drew: Yes. This issue of relationships with
central government, I am interested to know what
information you receive from central government on
two aspects of this evolving area. Firstly, are they
proactive with you in encouraging you to take more
interest, including prosecutions? Secondly, what
level of information have you got with regard to
progress in Europe as a whole to see if it is possible
to get a common system? For example, do you meet
with your colleagues in diVerent countries to see
what sorts of things they are doing and to see if there
is some commonality of approach which may be
possible?
Mr Pickering: I think, generally speaking, the
relationship with central government in terms of
individual agencies is quite good and, on the whole,
we feel involved in the process of putting together
legislation. Certainly the FSA does involve us in
consultations on a regular basis, so we do not have
any real issues about that in terms of the FSA. I
think perhaps where the issue comes is in terms of
interaction between the diVerent central government
bodies, Defra, FSA, the DTI even.
Q560 Mr Drew: The ODPM?
Mr Pickering: Yes. We have got quite a few masters
at central government level and I think sometimes
there is confusion and maybe there is not the joinedup element which we would like. The production of
service plans perhaps is an example, where one
central government body will require it and that may
well cross over into other areas which another
central body deals with but they do not require a
plan. As local authorities we are producing these
plans, which are fine in themselves, but I do think
that perhaps there is an area of overlap. In terms of
the relationships, certainly I think that the FSA
value what we do and, on the whole, we have found
the FSA to be a good thing really.
Q561 Mr Drew: If there was a statutory
underwriting of food information, in terms of the
labelling, would this be an area in which oYcers
within trading standards would have to specialise
because of the level of knowledge which would be
required? Presumably, your oYcers are mainly
generic at the moment, they are not necessarily
specialising in the food area, but if there was a
proper statutory code they would need to know
what they were doing to the nth degree?
Mr Pickering: It tends to vary from authority to
authority. I think that the way in which the training
of trading standards oYcers is moving now is
towards an idea of a person with certain skills and
knowledge rather than a person who knows
everything about a particular piece of law. I think
what you will find is that those sorts of people who
are going out there doing it will have a suYciently
good base knowledge to enforce the everyday
information, but in terms of maybe the more
specialised stuV normally there will be an expert in
each department. Certainly there is a Food Safety
Act oYcer nominated by each authority.
Q562 Mr Drew: Can I be clear where the dividing
lines are between trading standards and
environmental health where you have got two-tier
authorities?
Mr Pickering: In two-tier authorities, I work for
Buckinghamshire, so in Buckinghamshire there are
four or five local district councils where their
environmental health oYcers sit. They deal with
food hygiene matters primarily. We will deal with
food standards. There is liaison between both levels
of government and we have regular bi-monthly
meetings of the food authorised oYcers from each
local authority.
Q563 Mr Drew: Can I be clear. If a member of the
public was to go to either trading standards or
environmental health and really it impinged upon
the other area, you would be able to point them in
the right direction? There must be some diYculties,
in the sense that hygiene is an area where labelling
could imply one thing but clearly the actual quality,
the word “fresh”, for example, is an interesting one
to try to define as well, so really what I am saying is,
is there going to be a drawing together? You have
answered previously that there are going to be
specialists but will there be a drawing together
between the field of environmental health in this
particular domain and trading standards?
Mr Pickering: I think probably it would stay the
same, to be honest. There is an understanding of
where our responsibility ends and that of
environmental health oYcers begins and vice versa.
I think anything to do with labelling they are more
than happy to give to us, because by the nature of it
they are not involved in it on a day-to-day basis.
They know enough to think “That’s wrong but
perhaps I’m not quite sure what advice I should
give,” just as if we saw a potential hygiene issue we
would contact them and say “I’ve just seen
something that doesn’t look particularly good; is it
of interest to you?” On a day-to-basis there are quite
good contacts, and certainly, as an example, with
food hazard warnings, these are issued by the FSA if
there is a particular problem with a foodstuV and we
co-ordinate on them to take appropriate action.
Certainly at the two-tier level, I am not speaking on
behalf of environmental health oYcers but they
seem quite pleased to be able to give the food
labelling to us because they do not deal with it. I
think they would say they do not necessarily have
the skills or the time to deal with it. In unitary
authorities sometimes it is dealt with by
environmental health oYcers.
Q564 Joan Ruddock: On a completely diVerent tack
altogether, when the Government is looking at
devising food policy, to what extent might they ask
you about how you think “healthy eating” messages,
for example, can be communicated? Is that
something with which you get involved?
Mr Thomas: We get consultations through from the
Food Standards Agency and I suppose, in many
respects, the Food Standards Agency is the link
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between Government and local government in food
enforcement. We will comment and consult on issues
which the Food Standards Agency brings to us.
Chairman: Thank you very much indeed for the
evidence you have given us this afternoon. I think
that concludes our questions. It has been very
helpful, as indeed was your written evidence.
Thank you.
Memorandum submitted by the Food Standards Agency
Executive Summary
One of the Food Standards Agency (FSA’s) key objectives is to promote informed consumer choice by
improving consumers’ access to information about individual foods and food safety and standards issues.
Its consumer information strategy recognises that consumers obtain this information through a number of
diVerent routes. The FSA recognises the key importance for informed consumer choice of clear, informative
food labels and has developed an active programme of work, based on consumer research, to improve food
labelling. The FSA also aims to provide balanced information for consumers about food risks, increase
consumer awareness of key hygiene messages and improve consumer understanding of what constitutes a
balanced diet.
Introduction
1. This paper describes the FSA’s strategy for promoting informed choice by improving consumers’
access to information about food and food-related issues. It sets out the FSA’s policy on food labelling and
its approach to providing consumer information and advice. It then addresses in turn the four issues
identified in the terms of reference of the inquiry, outlining the information provided on food labels and any
information disseminated by the FSA. Finally, it considers the impact of WTO trade negotiations on food
information.
The FSA’s Consumer Information Strategy
2. Since most consumers read food labels at least occasionally (in a 2003 survey2 31% of consumers said
they always read food labels, 26% usually and 21% occasionally) clear, informative labels are key tools in
promoting informed consumer choice. Consumers also say they get information about food issues from
newspapers and magazines, television, supermarkets and friends and family.3 The FSA’s consumer
information strategy therefore has two principal threads: encouraging improved food labelling and
provision of consumer information and advice, both directly and via the media and other channels.
3. The FSA also aims to enable consumers who wish to do so to see how its policies are developed and
contribute their views. The FSA’s Board takes all its policy decisions in open sessions, and Board meetings
are webcast live. The FSA’s Consumer Committee4 provides an opportunity for consumer organisations
and representatives to contribute to the development from an early stage.
Food Labelling
4. Food labelling rules are harmonised at EU level; the main provisions are set out in the Annex. The
Food Safety Act 1990 and Food Labelling Regulations 1996 (and parallel legislation in Northern Ireland)
provide the legal framework for food labelling in the UK. EU and UK labelling rules closely parallel Codex5
standards and guidelines, which have wider international application. There are few restrictions on
voluntary provision of labelling information which is not required to be given by law, other than that this
information must not be false or misleading. Research6 shows that 74% of those who use labels look for
“general” information (such as name of the food, country of origin, use by and best before dates), 64% for
nutritional information (such as salt, fat or sugar content, calories), 58% for information about ingredients,
and 14% for “ethical” information.
2
2003 Consumer Attitudes to Food Standards, published by Food Standards Agency, 28 January 2004 http://www.food.gov.uk/
multimedia/pdfs/cas2003.pdf
3 2003 Consumer Attitudes to Food Standards, published by Food Standards Agency, 28 January 2004 http://www.food.gov.uk/
4 The Committee comprises six members from national consumer organisations and six individual members appointed in
accordance with the procedures of the OYce of the Commissioner for Public Appointments.
5 see paragraph 37.
6 2003 Consumer Attitudes to Food Standards, published by Food Standards Agency, 28 January 2004 http://www.food.gov.uk/
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5. The FSA has a wide-ranging Action Plan aimed at improving food labelling, comprising a mixture
of regulatory and voluntary initiatives. This work programme is based on priorities identified by consumer
research and public consultations and progress on implementation is discussed regularly at open meetings.
The objectives of the FSA’s labelling Action Plan are to deliver consumer facing legislation and to promote
best labelling practice.
6. Key outcomes since 2001 include:
— improved EU rules on declaration of allergenic ingredients; and
— publication of best practice advice on:
— clear labelling;
— the use of terms like “fresh”, and “traditional”;
— country of origin labelling; and
— assurance schemes.7
In all cases publication of advice has followed public consultation. The FSA has recently published a
survey on use of terms like “fresh” and “traditional” to help assess the impact of its advice on consumer
choice. Further surveys on clear labelling and country of origin labelling are planned.
Consumer Information and Advice
7. Because research identifies the media as key vehicles for consumer information the FSA places a high
priority on providing accurate, timely media briefing and proactive media activity. Agency advice receives
extensive unpaid media coverage reaching millions of people every year. Paid-for advertising campaigns are
also important; see paragraphs 15 and 21 for examples.
8. The FSA is becoming an increasingly important source of information about food. It is now cited by
consumers as the top spontaneous source of information about food standards and safety, increasing from
8% (2000) to 20% (2003). Most consumers receive information from the FSA through third parties including
the media, local authorities, health services, supermarkets and schools.
9. In addition, the Agency’s website (www.food.gov.uk) provides comprehensive information and
currently receives more than 160,000 visits each week and sends out 50,000 emails to subscribers every week.
Special interactive sites to encourage consumer participation have been set up covering GM, food and
farming, and food hygiene.
10. The FSA carefully targets its communications towards key issues and audiences. For example, a
number of initiatives aim to inform children. These include a Bad Food Live!8 Video and supporting teachers’
notes on food hygiene which has had more than 5,000 requests from schools and the Cooking Bus9 which
teaches more than 6,000 children every year how to cook (and teachers how to run cooking lessons) and
covers nutrition, diet, safety and hygiene as well as the cultural significance of food.
11. A new advice and information site on nutrition and diet for the use of consumers will be launched
during 2004; this follows focus group research and will enable consumers to navigate their way around the
website more easily.
12. Local dissemination of consumer information is achieved through local authorities, who place
information from the FSA and links to the FSA’s website on their own websites, for example providing
photographs of products being withdrawn, and tailor FSA press releases for issue locally.
Nutritional Content of Foods
13. Since many consumers use the nutrition information on food labels to help them make choices
between food products it is important that this information is clear and informative. The FSA aims to
supplement this label information with nutrition advice which helps consumers to choose a balanced diet.
Labelling
14. The Annex sets out the legislative position and changes in the pipeline on health claims and nutrition
labelling. Nutrition information is provided, in many cases voluntarily, on most (industry figures suggest
80%) pre-packed foods sold on the UK market. However, research funded by the FSA10 has shown that
many consumers find the current format diYcult to use, would like the panel to give levels of the key
nutrients—fat, sugar and salt—in words (high, medium or low) as well as numbers, and would find
7
See paragraph 24.
A spoof show demonstrating how not to cook.
9 Developed in partnership with the Royal Society for Arts’ Focus on Food Campaign as a state-of-the-art mobile kitchen
classroom, which visits communities and schools to communicate healthy eating messages. Priority is given to schools in low
income areas.
10 Nutrition Label Testing 2003 www.food.gov.uk/multimedia/pdfs/nutritionlabelreport.pdf
8
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information on salt levels more helpful than sodium declarations. The FSA’s research shows that an
improved compulsory format incorporating these changes would help inform purchasing decisions. The
FSA is currently considering whether voluntary additional front-of-label signposting, perhaps using a traYc
light-based approach, would help consumers to make healthier choices. Signposting could also, in principle,
be used on menus in catering establishments to highlight choices high in fat, sugar or salt, and healthier
options.
15. The FSA uses a variety of methods to help consumers choose a balanced diet, including articles and
information on the FSA’s web-site, a leaflet-series on diVerent life-stages and specific topics, media columns,
educational and other activity in schools, and use of the media to deliver key specific messages. Specific
examples include:
— use of the media to publicise results of surveys of levels of salt in processed foods, which draw
attention to the dangers of high-salt diet;
— a supporting high profile advertising campaign, planned for later in the year, which aims to help
to reduce salt intake by increasing awareness of the health consequences of high salt diets, will use
television and other advertising;
— an initiative promoting features in magazines for young women highlighting the importance of
iron to teenage diets; and
— a comprehensive range of information and advice on the FSA’s website, including an online expert
who fields consumer queries. This advice is syndicated to regional newspapers, reaching millions
of readers each year.
16. The FSA has a wide-ranging programme of surveys to provide consumers with independent
information on nutritional content. Surveys covering ready meals and sausages have already been
published, and work covering pizzas, baked beans and canned pasta is underway.
17. It is particularly important that children should receive clear advice about healthy eating. The FSA
works closely with other Government Departments, Healthy Schools Programme co-ordinators and nongovernmental organisations on school-based initiatives which promote healthy eating to children inside and
outside the classroom (the “whole school approach”). FSA initiatives include, for example:
— Five a Day the Bash Street Way, which encourages children to eat more fruit and vegetables;
— Dish it Up! an interactive CD-Rom for 11/12 year olds; and
— a toolkit for setting up a fruit tuck shop.
Safety of Foods
18. Although most food safety risks should be controlled during food production inappropriate
preparation and storage practice in the home can introduce significant risks; it is therefore important that
food labels carry the information consumers need to use foods safely and that key food handling messages
are communicated eVectively. The FSA also aims to provide consumers with access to honest, balanced
information about the full range of food risks.
Labelling
19. To enable consumers to reduce food poisoning risks pre-packed perishable foods must carry a “use
by” date and any special storage conditions or conditions of use. In addition, best practice guidance for the
industry issued by the FSA includes advice on the provision of appropriate cooking instructions for high
risk foods such as raw beef and poultry products.
20. Media briefing is particularly important to disseminate FSA advice on food risks. The FSA monitors
media reports carefully, and generally finds that its advice is accurately reflected. Targeting of key audiences
is important; for example, Asian media outlets have been used to alert the Asian community to the illegal
use of a carcinogenic dye, Sudan 1, in curry powders.
21. Imaginative and targeted advertising is an eVective means of publicising safe handling advice. The
FSA has developed and run seasonal safe cooking advertising campaigns directed at consumers11 during the
barbecue and Christmas seasons—two “high risk” times for food poisoning.
11
These campaigns contributed to the FSA’s wider strategy to reduce foodborne illness, involving action throughout the food
chain and including a campaign targeted at people working in the catering sector.
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22. Consumer information on a wide range of food safety issues is available on the FSA’s website. This
advice is often used by other organisations, for example Sainsbury’s uses our salad washing advice in their
stores. Where appropriate consumer advice on the website is supplemented by targeting of vulnerable
population subgroups. For example, when the results of an FSA survey conducted in 2001 showed high
levels of the potentially cancer causing chemical 3-monochloropropane-1,2-diol (3-MCPD) in soy sauce,
information published on the FSA website was accompanied by advice to consumers on the significance of
the results for food safety. The FSA worked with the Chinese community by providing leaflets in Chinese
for distribution through their own networks.
23. The Agency sets up telephone helplines in the case of potentially serious or high profile food safety
issues, for example when experts identified a potential problem of contamination of milk sold at the farm
gate from pyres during the foot and mouth crisis, and when a potential problem was identified in relation
to the lids on jars of bottled baby foods. In both cases there was very widespread media coverage but fewer
than 100 telephone calls for further information in each case.
Means of Production of Food
24. Some food labels carry claims about the food production method used. The FSA has issued best
practice advice which aims to encourage provision of clear consumer information to underpin these claims,
and encourages the food industry to provide information for all products, for example via their websites or
helplines. In addition, the FSA’s website provides information on production methods which are of
particular interest to consumers.
25. Food assurance schemes which set production standards, generally covering food safety and
traceability, animal welfare and environmental protection, and allow members to use the scheme’s logo and/
or a specific claim on their produce can contribute to the range of consumer choice.
26. In June 2002, the FSA published an independent review into the main assurance schemes aVecting
products on the UK market; advice to scheme operators based on this review was published in August 2003.
The advice, which aims to promote informed choice, recommends that the following information should be
easily accessible and clearly communicated to consumers:
— What the scheme seeks to achieve and what advantages it oVers consumers.
— In what ways, if any, the scheme standards exceed the legal minimum.
— How the scheme ensures that its standards are being met by member producers.
— The scheme’s arrangements for monitoring delivery of standards, for example through analysis of
scheme produce.
— How instances of non-compliance are dealt with.
— The evidence base for any specific claim, for example on food safety or quality.
The FSA plans to carry out a survey of the consumer information available from scheme operators and
to publish a collation of this information to help inform consumer choice.
27. The FSA’s website provides consumer information on organic food, GM food, and use of pesticides
and veterinary medicines in food production.
28. A number of claims relating to other ethical considerations, such as use of good labour practices,
feature in the UK market. The FSA is not aware of any studies which have surveyed these claims or
researched consumer attitudes to them.
Food Information in the Context of WTO Trade Negotiations
29. The WTO is concerned with the rules of trade between nations and does not deal with food
information as such. The main international forum that has relevance to international food trade is the
Codex Alimentarius Commission (Codex) which was created in 1963 by FAO and WHO to develop food
standards, guidelines and related texts such as codes of practice. Codex has produced a wide range of food
standards; there are a number of committees/task forces considering issues from GM labelling to hygiene.
The UK continues to support and encourage the development of labelling standards that provide improved
consumer information.
19 April 2004
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Annex
Food Labelling Rules
1. The FSA has lead responsibility in Government for general food labelling rules and for productspecific legislation on a number of specific foods. The Department of Environment Food and Rural AVairs
and the relevant devolved Departments lead on marketing standards, which often contain labelling
measures, as well as on rules on country of origin labelling for beef. The Department for Trade and Industry
is the lead Department for labelling rules on net quantity of prepacked foods.
General Labelling
2. The labelling Directive 2000/13/EC defines core information that must be given on food labels. This
comprises:
— name of the food;
— list of ingredients;
— quantity of certain ingredients;
— durability date (“use by” or “best before”);
— any special storage conditions or conditions of use;
— name and address of the manufacturer, packer or seller;
— place of origin if otherwise purchasers might be misled;
— net quantity of prepacked foods;
— alcoholic strength by volume of alcoholic drink (if more than 1.2%); and
— where necessary, instructions for use.
Non-prepacked Foods
3. Labelling rules in 2000/13/EC apply to both pre-packed and non-prepacked food. Member States may,
however, decide not to require all or any of the labelling particulars in the case of non-prepacked food,
provided that the purchaser receives suYcient information. UK implementing legislation requires
information on additives to be given on non-prepacked foods other than those sold in catering
establishments, and the use of irradiation to be declared on foods sold non-prepacked, including in catering
establishments.
GM Labelling
4. The use of genetically modified organisms (GMOs) or of ingredients derived from GMOs must be
declared and no GM food can be marketed in the EU without a thorough safety assessment and approval
under the relevant legislation (these rules are set out in Directives 1829/2003/EC and 1830/2003/EC). The
rules also require labelling of all GM food and feed products derived from GMOs, regardless of the presence
or absence of GM material in the final food or feed product. Foods produced using processing aids which
have been obtained with the help of GM technology (eg the enzyme chymosin, derived from a GM microorganism, which is used extensively to make hard cheeses) and products from animals fed GM animal feed
are exempt from the labelling requirements. Information on GM content must also be provided for nonprepacked foods, including in catering establishments.
Nutrition Labelling
5. The nutrition labelling Directive, 90/496/EC, specifies nutrition information which must be given when
a nutrition claim, such as “low fat”, is made. The manner of presenting nutrition information, whether
voluntary or mandatory, is defined in Directive 90/496/EC. There are two possible formats producing either:
information on energy, protein, carbohydrate and fat content per 100g/ml product; or information on
energy, protein, carbohydrate, sugar, fat, saturated fat, fibre and sodium content. In both cases information
on the amounts of these nutrients per serving may also be given. Information on certain additional nutrients
should also be given where a claim is made.
Likely Changes to Legislation
6. A proposal to harmonise EU legislation on nutrition and health claims (for example, claims such as
“low fat” and “good for your heart”) is currently under negotiation in Brussels. The proposal would
establish a list of permitted nutrition claims and would provide an authorisation procedure for health claims
involving assessments by the European Food Safety Authority. The Commission is currently reviewing both
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the labelling Directives 2000/13/EC and 90/496/EC; a proposal to amend the latter is expected later this year.
The most recent discussion paper circulated by the Commission suggests that it will propose compulsory
nutrition labelling on all pre-packed foods.
19 April 2004
Witnesses: Mr Neil Martinson, Director of Communications, and Ms Rosemary Hignett, Head of Food
Labelling and Standards Division, Food Standards Agency, examined.
Chairman: Welcome to the Committee this
afternoon. Thank you for your written evidence, and
we look forward to hearing what you have to say
today in this oral session. I would like to invite
David Drew to being the questions on our behalf.
Q565 Mr Drew: Good afternoon. Can I ask you for
an overview of the situation. What are the areas?
Certainly we have seen this to some extent this
afternoon, and last week as well, the need for clarity
in this area; obviously, there is you, the FSA, there
are the various central government departments and
there are diVerent parts of local government. Do you
find that this is an area which needs clarification if it
is to be more eVective, in terms of really being able
to guarantee to the consumer that what they are
purchasing is what they think it is as labelled and
therefore what they will be eating?
Ms Hignett: In terms of the current food labelling
legislation, particularly the areas of nutrition
labelling and health claims, which you have been
talking about earlier this afternoon, I think it is very
clear that the legislation itself is imperfect, there are
some changes which need to be made to it. I think it
is clear that we need to have nutrition information
on all foods, not just the majority of foods and not
just on a voluntary basis. I think it is clear that we
need improved legislation in relation to health
claims so that consumers can trust the information
which they see on labels. We need to have a change
in those two aspects of the legislation, certainly.
Q566 Mr Drew: If we were to look at your role,
notwithstanding at the moment there is no statutory
underwriting, either nationally or through the EU,
what additional powers would you want at the
moment, but if there was to be a statutory
underpinning would you need?
Ms Hignett: Both of those areas, health claims and
nutrition labelling, fall within EU competence, so
those rules need to be changed at EU level. The
Agency is actively promulgating, if you like, in
Brussels ideas for changes to the legislation and
supporting the proposal for changes in health claims
legislation, which is under negotiation at the
moment. I think that the Agency has within its remit
responsibility for negotiating on those two issues in
Brussels and we are positively arguing for change.
Q567 Mr Drew: Who takes the lead within Europe
at the level of these negotiations?
Ms Hignett: When they are being taken forward at
oYcial level the Food Standards Agency leads for
the UK Government and the UK Government line
is agreed across Whitehall in the usual way. When
decisions are taken at the Council of Ministers it is
usually at the Agriculture Council and it would be
the relevant minister from Defra who would be
involved but the briefing would be provided by the
Food Standards Agency.
Q568 Mr Drew: Presumably there are some fairly
strong opponents of these moves within the larger
companies in the food industry?
Ms Hignett: I would not say that quite categorically,
actually. In relation to nutrition labelling, I think, as
we have heard, there is the desire to keep the
arrangements voluntary. There is not a very strong
resistance to provision of information and I think
perhaps there is an acceptance on the part of
industry that compulsory nutrition labelling of some
form is on its way. In relation to health claims I think
there are mixed views, because of course industry
has the opportunity, through a single European
approval system, of gaining access to the whole
European market through a single approval. If you
like, there is resistance to legislation but also an
acceptance that there is an opportunity there. I
would say that broadly, and there are mixed views,
the industry view is in favour of the type of
regulation which is being proposed in Brussels.
Q569 Chairman: What is the nature of your
relationship with Defra and how closely do you find
yourselves working with it, given that of course your
accountability is not through Defra?
Mr Martinson: With Defra and indeed with all of the
government departments that we work with closely
we have concordats which spell out in a fair degree
of detail what the nature of the relationship is. Also
the Chairman of the Agency meets on a regular basis
with Defra ministers and, as you would expect,
oYcials meet with Defra oYcials on a regular basis
as well. I think I would say also that we work on a
very practical level on a whole range of issues, and I
would say very constructively if we take issues like
BSE controls, where there are shared responsibilities
in diVerent parts of the food chain, there is very, very
close working indeed and I think very constructive
working.
Q570 Joan Ruddock: On communicating messages
about food information, obviously the public being
on the end of it, who do you see as communicating
those messages at the moment and what sorts of
messages are people receiving and what value is
there in the messages, do you imagine?
Mr Martinson: In terms of who has responsibility for
communicating messages, clearly the food industry
has a significant responsibility because every day
millions of products of food are bought and what is
on the label is incredibly important in helping
consumers to choose. Also, we as the FSA have a
role along with the Department of Health in terms
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12 July 2004 Mr Neil Martinson and Ms Rosemary Hignett
of trying to influence the balance of the diet. We have
taken up particular initiatives, for example, salt,
which was mentioned earlier. Also I think it is
important to recognise the role of people like the
NGOs and public health charities, because often
they are able to raise issues which might have
escaped our attention. I think one of the things
which we have been keen to do at the FSA is
encourage a much wider debate around food-related
issues which recognises there is a wide range of
voices involved. As far as the messages which are
communicated, one of the things which is
interesting, in terms of looking at the evidence in
terms of consumer understanding, is actually there is
a fairly high degree of awareness among many
consumers of what kinds of foods they should be
eating, foods which contain less fat, less salt, and so
on, more fruit and vegetables. As I am sure you are
aware, there is also a huge variance between what
people know and what people do, and I think for
many of us in government that is one of the key
issues, how we try to turn that kind of knowledge
into some kind of behavioural change. It is a very,
very big challenge.
Q571 Joan Ruddock: There is also an interesting
example, is there not, about what you said, that
people think they know what they should be eating,
and the messages which you give on the GM issue,
where the public have said, “No, no, no, we’re
absolutely not going to eat it,” and eVectively you
have said “There’s no reason why you shouldn’t”?
Mr Martinson: What we have said is that, in terms
of food safety, the GM foods which have been
approved are as safe as their conventional
counterparts. In our submission to Government last
year we said there were lots of reasons why
consumers probably did not want to eat them, which
were much broader than the food safety issues alone
although they are still very significant, also it
included environmental issues. I think we have tried
to acknowledge a wide range of consumer concern.
Q572 Joan Ruddock: I do not want to go too far on
the GM issue, but, I must say, when you say that
“they are as safe as,” I think many people would say
they are as safe as, as far as we know?
Mr Martinson: That is true of many things which
we eat.
Q573 Joan Ruddock: In terms of the overall
messages, how much authority, notwithstanding
what I have just said, do you think the FSA has? We
know that there is a growing acceptance, or more
people believing that the FSA is the place to get their
information. Do you believe that you have good
credibility with the public?
Mr Martinson: No. We have worked very hard to try
to establish our credibility and we set ourselves a
fairly ambitious aspiration to be the most trusted
source of advice on food safety standards and
nutrition in the United Kingdom. The way we
measure progress is by doing a lot of consumer
surveys, a lot of consumer research, and on a
number of key indicators confidence in the Agency
has increased and trust in the Agency has increased.
We are not complacent about the kinds of challenges
which remain. We are also very conscious, in terms
of food safety, that we cannot get it wrong at all,
there is no room for manoeuvre there at all, we have
to keep it right all of the time. That is a very
considerable pressure.
Q574 Joan Ruddock: Have you done any research to
establish what use the public makes of the
information once they have received it?
Mr Martinson: It depends on partly from whom they
receive it but also their own personal circumstances.
Food is an incredibly personal issue. What we try to
do, in terms of the information which we have
provided, which is fairly consistent now in terms of
good practice, is target the information towards life
stages. For example, we know that when women are
pregnant they are much more receptive to, and
indeed want, more information about food, in the
same way as when women are breast-feeding. We
have an enormous amount of information targeted
at particular life stages, and it may be pregnant
woman or indeed it may be people as they grow
older. In those kinds of situations the evidence we
have is that there is a fairly high use of information.
I think also it is important to say that, in a sense, it is
quite fragmented and it is very clear that the poorer
people are the less use they make of information and
the less access they have to information. Conversely,
the better oV people are the more information they
have, and in a sense they are information-rich.
Q575 Joan Ruddock: How do you account for the
fact that most mothers now wish to feed their
children with organic products, despite the fact that
you say there is no nutritional gain in having organic
products?
Mr Martinson: I think that mothers will make
decisions for a whole range of reasons. We are not
here to tell them what they should or should not do.
In terms of nutritional benefit, certainly there is no
reason to consider that organic baby food is any
worse than conventional baby food. We have never
claimed that, ever.
Q576 Joan Ruddock: No, you have been neutral, but
clearly they are not taking your advice, are they?
They are specifically rejecting that advice and going
for something which they believe does make a
diVerence?
Ms Hignett: I think we have not advised people
either to use or not use organic food. What we have
done is analyse the available evidence and we have
said that, on the basis of the available evidence, there
is no diVerence in nutritional or safety terms
between
food
produced
organically
or
conventionally. We have said also that we consider
organic food to be a helpful addition to the range of
choice available to consumers, and we are quite
neutral as to whether people choose to buy organic
on that basis or not.
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Q577 Joan Ruddock: It would suggest that people
are giving a diVerent weight perhaps to diVerent
sources of information; do you think that?
Mr Martinson: I am not sure we have a huge amount
of information or evidence in relation to mothers
choosing baby food in that kind of sense. Certainly it
is something which it would be worth understanding
better, in terms of motivation.
Joan Ruddock: It is a very significant consumer
phenomenon. Thank you.
Q578 Chairman: One of the issues which we have
been looking at in this investigation has been the
food information, or the lack of it, which is provided
at catering outlets, restaurants and pubs, this kind of
area. What is the Agency’s view on how food
information issues should be addressed in that sector
of industry?
Ms Hignett: I think it is particularly important in
relation to healthy eating choices, because people
are eating out more frequently, and because we are
trying to encourage particular choices in this case so
we do mind what choices people make in relation to
nutrition content. It does seem to us that we must
look at ways of making it easier for people to make
healthier choices when they are eating in catering
establishments. I think that is particularly the case
when we are talking about the sort of routine eating
out, so the lunchtime, daily eating out occurrence,
maybe not necessarily as much the celebratory,
restaurant occasion. Certainly there does seem to be
interest both amongst consumers and, to some
degree, from the food service sector in using
signposting of healthier options to help consumers
make healthier choices when eating out.
Q579 Chairman: What are you doing about that?
Ms Hignett: We are looking at sign-posting
generally, so both in food service and in the retail
situation, and really there are two things which we
have to do. The first is consumer research to find out
what consumers want and we have plans to do that
shortly. The second is to look at criteria for
diVerentiating between healthier and less healthy
choices, and we have a project underway at the
moment to work up those criteria.
Q580 Chairman: What about advice and
information on things like portions and on repeat
oVers? Most members of this Committee, since we
started the work, have begun to see things anew
wherever we go. I was visiting a multiplex cinema at
the weekend, and once you get past the bowls of
pop-corn, which appear to be available in only ten
kilograms or upwards, there are big food oVers with
which you get oVers to buy more things on top of
that. Does that have to be addressed as well, because
information takes you only so far if you are fighting
against these kinds of factors?
Ms Hignett: Certainly we think so. We think that
whole area of promotional activity is one which
needs to be looked at and we have been looking at it
particularly in relation to choices for children,
commercial activity aimed at children. We want
particularly to encourage supermarkets, for
instance, when they are making “two for the price of
one” type oVers, to take into account the nutritional
quality of the food which they are encouraging
people to buy more of, if you like, as part of
corporate social responsibility. We do think that
there is more which could be done in that area to
encourage healthier choices.
Q581 Chairman: How are supermarkets and the
catering outlets of the food and drink industry
responding to your concerns? Are they moving in
your direction and how quickly?
Ms Hignett: I think it is fair to say that it is very early
days, and I think it is fair to say that there are some
encouraging noises, but I do not think I would want
to go any further than that at the moment.
Q582 Mr Drew: Could I ask you to paraphrase this
issue of where we are at the moment with the
satisfaction with food labelling and what would you
want to see to improve it further, with also in mind
how the EU is going about doing this?
Ms Hignett: I think all the consumer research that
we have done indicates that people are becoming
increasingly interested in healthier choices and they
are looking for an easier format to use for nutrition
information on labels. That is the priority. I think
our feeling, as far as the way things are going in the
EU is concerned, is that there are some promising
signs.
Q583 Mr Drew: What is the timescale? We hear
about the next 18 months, but is that feasible, is that
deliverable?
Ms Hignett: The expectation is that there will be a
proposal on nutrition labelling by the end of this
year, which would mean probably, if all went well, it
would be coming to a climax during our Presidency
at the end of next year, and if all went well perhaps
it would be agreed by the end of next year.
Q584 Mr Drew: One thing which has surprised me
about this inquiry is the degree to which people do
read labels. It would be interesting to know that as
many people read the political manifestos. The
figures are surprisingly high, and do you think that
the general public will feel that they have been shortchanged if they get a fairly rapid response from
Europe which says, basically, “Carry on as you are.
Voluntary controls are as good as we’re going to
get”? That is not going to wash, is it?
Ms Hignett: I think, if we do not see an improvement
in the usability of the nutrition information, and that
does not necessarily have to be done by statute, it
could be done voluntarily, so we could have a
response from the industry which was helpful in that
regard. If we do not see an improvement then, yes, I
think consumers will be very concerned.
Q585 Mr Drew: Is that something which you think
the industry has understood? Part of the problem is
surely, when you are talking about the industry,
there is no industry. There is a series of highly
diVerentiated elements, from the larger companies,
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which presumably would not want to upset their
customer base, to those which are “fly by night” and
it is not their problem?
Ms Hignett: I think, on the whole, I would not say
that industry is resisting placing nutrition
information on packs. I think the issue is to get
agreement on a simplified sign-posting system which
is helpful to consumers, because when you start
talking about simplification then, of course, there
are always risks of oversimplification, so we have a
challenge to get people to agree to a simple way
forward, I think.
Q586 Mr Drew: In terms of food safety, presumably
this is very much at the back of the consumer’s mind,
if nothing else. I do not know whether the figures are
higher in this country than they are elsewhere in
Europe but one would have thought that BSE, foot
and mouth and various other interesting diseases
which we have managed to visit on ourselves must
have pushed up people’s interest in knowing what is
on the label and interpreting whether in fact it is
true?
Mr Martinson: I am not sure that is the case. One of
the trends in the last four years is that consumer
concern in the UK over BSE has decreased
dramatically. When we measured it in 2000, 61%
said they were concerned about BSE, now it is down
to 42%. There was a recent study by the European
Commission across six European countries and, I
think probably you will find this surprising, it found
that consumer trust in the United Kingdom in terms
of food was the highest among the six countries. I
think what is happening and what appears to be
picked up by our work is that there is an increasing
consumer concern around personal health and
personal nutritional issues. That is reflected in the
market. TSI were talking about the increase in the
number of foods coming onto the market making
health claims. That is happening partly because
consumers are saying, “Actually, we’re concerned
about our personal health, we want to improve our
own health outcomes.” In a sense, there is a trend
there on which we are very keen to try to capitalise.
Q587 Chairman: Have you been involved in any
discussions within the EU on the introduction of a
traYc lights system? Does it exist in any other EU
Member State and what is your own view, as an
Agency, on such a system?
Ms Hignett: What does exist in other Member States
is a green light only system. In Sweden and in
Finland we have a symbol which indicates a
healthier choice, and I guess we have that already in
our own supermarkets with the “healthy option”
type ranges. There have not been any substantive
discussions at EU level on a sign-posting system
which would work right across the EU. When we are
thinking about sign-posting actually we are thinking
about something front of pack which would be in
addition to the full nutrition information on the
back of the pack. Otherwise I think you do run into
great diYculties in terms of oversimplification
because there are so many individuals and groups of
individuals who have particular needs, so you need
quite a decent amount of information on a pack in
order to serve those diVerent needs.
Q588 Chairman: Could a traYc lights system be
introduced into the UK by legislation without
European legislation, in your view?
Ms Hignett: No, because it is an area of EU
competence. Certainly a voluntary scheme could be
introduced and that is what we are working towards
at the moment.
Chairman: As you will have gathered, we have some
diYculties with the timescale this afternoon. We are
expecting a vote very shortly and I do not want to
start a new line of questioning and be interrupted for
an adjournment. What I would like to do, with
Members’ agreement, is draw the Committee to a
close at this stage and our Clerk could discuss with
you perhaps how we can pursue at a later stage the
other points with which we wish to deal. I apologise
for that but I think it is better to break at this stage
rather than have a break at a later point. I would like
to thank you for coming along this afternoon and
perhaps we will be seeing you or hearing from you
again shortly. Thank you very much indeed.
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Tuesday 20 July 2004
Members present:
Mr David Drew
Mr Michael Jack
Mr Austin Mitchell
Joan Ruddock
Witnesses: Mr Neil Martinson, Director of Communications, and Ms Rosemary Hignett, Head of Food
Labelling and Standards Division, Food Standards Agency, examined.
Q589 Chairman: Good afternoon, ladies and
gentlemen. Welcome back to Rosemary Hignett
and Neil Martinson from the Food Standards
Agency. Thank you very much indeed for returning
to our evidence session this afternoon. My
apologies once again for the way we had to end the
session last week and we are grateful that you have
returned today. Could I begin by asking for your
views as to how clear it is who and which
departments within government have responsibility
for food policy? It has been suggested in some
quarters that it is fragmented in certain ways. How
far do you find the diVerent parts of government
work together and relate to what you do as an
agency?
Mr Martinson: The Agency has concordats in place
with both Defra and the Department of Health.
They spell out the principles and in some cases some
degree of detail as to what the division of
responsibilities is. In relation to the Food Standards
Agency, it is fairly clear that we are responsible for
issues in relation to food safety, food standards and
enforcement, and also in providing primarily the
evidence and the advice in relation to nutrition
policy.
Q590 Chairman: Are you aware of any crossdepartmental working bodies being set up, for
example, in which you have an involvement?
Mr Martinson: There are a considerable number of
cross-departmental working bodies on anything
from BSE to contributions to the Food and Health
Action Plan. I cannot list them all but there is a very
significant number, and, of course, oYcials work
on a daily basis across departments on particular
issues.
Q591 Mr Mitchell: I got the impression from the
retailers that you focus heavily and heavy-handedly
on them primarily so that as soon as a food scare
hits the headlines, now almost weekly, you come
down heavily on the retailers because that is the
most convenient point of access for you. Do you
accept that charge that you are working most
assiduously on the retailers rather than any other
section of the food chain?
Mr Martinson: What we try to do is deal with the
issues as they arise in a fair and consistent and
proportionate way. Clearly, in terms of the
retailers, they do represent a very significant part of
the market. Some 90-odd per cent of consumers buy
their food from the major supermarket retail
chains, so inevitably if, for example, we are doing a
survey, which is quite often based on market share,
retailers will appear fairly high up, but certainly we
would say that we deal with it in a fair and
consistent way.
Q592 Mr Mitchell: Yes, but things like labelling go
right back down the food chain, do they not? How
do you ensure that your message is going to reach
the key players before the supermarkets?
Mr Martinson: We also have a relationship with the
major manufacturers through organisations like
the Food and Drink Federation, and clearly in
terms of any of our major surveys major branded
products appear in them as well, so I do not think
we quite accept that particular line of argument.
Q593 Mr Mitchell: That is surveys that you are
talking about, but when it comes to labelling and
instructions it is easiest for you, is it not, to work
through the supermarkets and tell them they must
do so-and-so? My impression is that that is what
you do because it is an easy way out.
Ms Hignett: When we are developing labelling
policy we always discuss our ideas and the issues
with all stakeholders and that will always include
the retailers. We also always include manufacturers
and it will also include enforcers and the catering
sector where that is relevant. We are always careful
to involve everybody in those discussions.
Certainly, as Mr Martinson has said, retailers are
major players so they must expect to be involved.
Q594 Mr Mitchell: You referred to a proportionate
response. What is a proportionate response? When
you get these food panics developing and the Daily
Mail highlights something as dangerous, children
are dying and shock, horror, how do you respond
because they are going to blame you, are they not?
Mr Martinson: If we could just deal with the issue
of what have been called food scares, over the last
four years what we have been doing is dealing with
food safety issues in a much more transparent way,
and when there is an issue all the major players
involved are aware in advance of what the
particular issue is. They are informed in advance of
the action that the Agency is taking. If I could just
quote from our annual consumer survey about the
issues around food scares, when we have asked
people, “How concerned are you about diVerent
issues?”, in the year 2001 around 11% said they were
concerned about food scares. In a later survey,
2003, around 2% of consumers said it was an issue
for them. What we think is that in the way that we
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manage food safety now, both by informing and
involving stakeholders across the spectrum (and we
also involve consumer groups) but also by being
transparent, it has helped to improve confidence in
food safety in the United Kingdom.
Q595 Mr Mitchell: That is interesting; that is a
cheering statistic. Does that mean you have
anticipated most of the food scares in advance so
you have got them on your agenda?
Mr Martinson: I do not think we can always
anticipate any food scare that is going to come up,
but what it does demonstrate is that it pays to be
transparent, that in terms of some of the headlines
that you might see in some newspapers it does not
necessarily translate that all consumers are taking
that message away with them. They will base it on
their own experiences as well.
Q596 Chairman: Can I follow up Mr Mitchell’s
point regarding the impression that it is the
supermarkets which perhaps get the focus of
attention? We had questions last week, as you will
recall, on the catering sector and the type of
information that this sector provides to its
customers. What you told us last week was that this
was an area in which there were encouraging noises
that more needed to be done. It did not strike me
that this was an area which at present was being
regarded as a priority by yourselves and yet it is one
which is obviously important to many consumers in
terms of the information they get about the choices
they make. Does that not perhaps back up the kind
of suggestion that Mr Mitchell was making about
the emphasis of your work?
Ms Hignett: I do not see us as giving priority to any
particular sector. I think there is a distinction
between pre-packed foods where inevitably the
discussions focus on manufacturers and retailers
and non-pre-packed foods where the food service
sector is more important and the issues become
more diYcult and more challenging in the food
service sector because it is diYcult to think in terms
of a one-size-fits-all solution because the range of
operations is so wide. Whilst for pre-packed foods
the discussions tend to focus on legislation at EU
level and then voluntary action in the UK, in
relation to the food service sector the starting point
is slightly diVerent. The starting point is one which
is very much focused on what it is practical to
achieve rather than a legislative starting point.
Q597 Joan Ruddock: I do not know whether the
FSA did the research or whether it published the
research, but it is the issue of organic baby food
recently in which it was stated that there were more
organic baby foods containing higher levels of
dioxins than non-organic baby foods. I wondered
what the FSA thought it was doing in terms of
communicating to the public when all of the
products surveyed had dioxins that were very well
within the safety levels? What was it you were trying
to achieve in commenting on that research?
Mr Martinson: We did not make the comment in
terms of organic baby food. I think that was made
by a Scottish newspaper. We do a wide-ranging
number of surveys where we try to benchmark the
level of contaminants that may be in a range of
foods and in that way we are able to use it partly in
terms of dietary information so it is possible to find
out if in fact the picture is getting better or worse.
In terms of most environmental contaminants the
picture is getting much better. There is a reduction.
When we published that, which we published on
our website, we made it very clear that on the basis
of expert advice there was no reason to be
concerned about the level of contaminants because
they were all well below any levels that would give
any reason for any parent to be concerned across
both organic and conventional baby foods.
Q598 Joan Ruddock: Does that not pose a problem
though, because this could amount to a food scare
for parents who have very specifically chosen
organic baby foods because they want their babies
to be safe? Here is a suggestion that dioxins, which
most people believe are very unsafe, are more
present and yet we all know that they were well
within the safety limits. What do you feel about the
message that you have communicated and your
responsibilities for that?
Mr Martinson: I do not think we communicated
that particular message. In terms of the work that
we do in relation to surveys, we find what we find
and we have an obligation to report that and make
it accessible, not least because it is used by scientists
all over the world in terms of collecting data. I think
it is regrettable that it was reported in that way, and
obviously what we do is seek to avoid that, but we
cannot control such reporting.
Q599 Mr Jack: You have made some important
points about what consumers should know about
the food that they are eating. Is it important for
consumers to have some benchmark by which to
judge, for example, messages about salt, sugar, fibre
and other nutritious intakes on a daily basis?
Ms Hignett: Yes. I think the major problem with
the nutrition information as we have it at the
moment on foods is that it is just a number given in
isolation, so it depends if you like either on the
manufacturer voluntarily giving some contextual
information or on the consumer bringing a rule of
thumb of some sort to the party. Consumers may
not in fact have the ability to do that.
Q600 Mr Jack: Where would a consumer go
to acquaint themselves with this important
benchmarking information? Do you provide it?
Ms Hignett: We do have consumer advice on what
constitutes a lot or a little of fat, for instance, and
we disseminate that through leaflet material and
through our website.
Q601 Mr Jack: Your website, for example, does not
have a separate page summarising the average daily
intake of a variety of nutritious ingredients. It does
not have anything on the same page summarising
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what the daily intake of salt and sugar is. That
information is scattered about. Do you not think
that in terms of informing people there should be a
starting point from which they could then relate to
all the other information that you provide?
Ms Hignett: There is certainly advice on the website
around what constitutes a lot and a little of fat, salt,
sugar, etc. I am certain that it is possible for that to
be improved so that it is more accessible and we are
looking at how to do that at the moment. We are
also very aware that the website is probably not the
best place to be providing that information.
Q602 Mr Jack: You put a lot of emphasis in terms
of the role of the FSA as a communicator of food
information on the role of your website. Your
evidence says so.
Ms Hignett: Yes, our website is extremely
important. What I wanted to say was that we think
in relation to nutrition information that that
contextual information should be present on the
label so that it is present at the time of use.
Q603 Mr Jack: Let me move on to paragraph 2 of
your evidence in which you say, “Since most
consumers
read
food
labels
at
least
occasionally . . .”—and you put down some survey
results. Let me ask you whether you have done any
follow-up information as to what they are reading
these labels for and do they find what they are
looking for?
Ms Hignett: That information is broken down in
that survey in terms of what information people
look for, so, for instance, the highest figure is for
general information such as, what is the food, can I
put it in the freezer, that sort of thing. The headline
figure in there is that 64% of them are looking for
nutrition information, for instance, and there is
other information in the survey about what the
other key information is for consumers. We also ask
in the survey whether they find the information easy
to understand and a figure of something like 25%
find that the nutrition information, for instance, is
fairly or very diYcult to use.
Q604 Mr Jack: Given that at the moment under
labelling, and again your evidence draws our
attention to (and in fact your own comments earlier
referred to) the fact that in non-packaged lines there
is eVectively no information. Coming back to the
point I was asking about how does a consumer
establish a mental benchmark about what they
ought to be eating each day, is there not a yawning
gap in the information provided to the consumer so
that if they buy any unpackaged item of a given size
and quantity they have got no real idea how that fits
in with their overall dietary intake during the week?
The reason I ask that question is that some things
we eat are labelled as bad, but if you balance it up
with an awful lot of the things that we label as good
then you might have what some describe as a
balanced and proper diet, but I cannot see with the
array of information that is presently available how
people form such a judgment when a large chunk of
what people do buy contains no factual
information whatsoever?
Ms Hignett: That is right and that is one of the
reasons why we are in discussion with the food
service sector about what can be done to provide
more
nutrition
information
in
catering
establishments. The concept of signposting, which
is being talked about a lot at the moment and which
is giving relatively simple nutrition information in
an easy to use manner, could in principle be applied
consistently across pre-packed and non-pre-packed
foods, which would give consumers the opportunity
to look at their whole diet and take those decisions
rather more easily than is the case at the moment.
Q605 Mr Jack: In paragraph 4 of your evidence you
indicate that 58% of people look for information
about ingredients. Some may argue that things like
oranges have been around since whenever and you
do not need to tell them what is in an orange, but
if you take a banana, which contains fibre, natural
sugars, potassium, all kinds of things, how do
people know in that sector, in relation to their
benchmark, whether they are getting the right
balance or not, because the whole emphasis of the
evidence we have had so far has been on things that
are in packages? You mentioned the food service
sector, which takes us slightly beyond the retail
environment in buying food into the area where we
sub-contract our food purchases in restaurants and
so forth. We come back to the retail sector. Is there
a need in your judgment to help people put together
this overview by providing at the point of sale
information of a nutritional content nature about
non-packaged foods?
Ms Hignett: I think I would give the same answer
for non-pre-packs in retail and in catering
establishments, that yes, if we are trying to
encourage people to select a balanced diet then we
cannot expect them to do that unless we make
arrangements for them to have the information on
which to do so.
Q606 Mr Jack: What has the FSA done to move
that agenda forward?
Ms Hignett: At the moment we are in discussion
with stakeholders across the board, as I discussed
earlier, about what is being called signposting, so
ways of providing nutrition information on prepacks and non-pre-packs in catering establishments
and elsewhere in a consistent way that enables
consumers to look at their whole diet and make
those choices more easily. We have not found a
solution but we are in discussion about that at the
moment.
Q607 Mr Mitchell: I want to come back on this
because I see you are doing information promotion
for kids in schools, which is marvellous, although I
wish you had the hero of my generation, who was
Popeye, who always ate his spinach before he
fought to a finish. All you have got is the Bash Street
Kids who are not examples of good dietary
behaviour in my book. I went to my grandchildren’s
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sports day yesterday. They all sat down and stuVed
themselves with ice cream and crisps (very salty
crisps because I ate some of them myself) and pop.
If you are venturing down the labelling path is there
a case for kids’ labelling to make all this
comprehensible to kids and warn them oV certain
things?
Ms Hignett: There is a case for two things. There is
a case for looking at labelling for kids who are
buying things from their own money, if you like,
and you have to face the fact that most of the things
that are bought for kids are bought by their parents
rather than by the children. There is a case for
looking at whether the information on foods that
children are buying themselves could be better
presented but there is also an issue around
commercial activity aimed at children with a view to
aVecting their food choices and looking,
particularly in the school environment, at whether
that is appropriate and whether there are things
which could be done to make it easier for children
and for parents buying for children to make
healthier choices.
Q608 Mr Mitchell: But that is indirect, is it not?
What could make an impression on kids would be
a label on the product like “Better unsalted”.
Ms Hignett: One thing that is very clear is that
children are very much attracted by things like role
model endorsements, like cartoon characters on the
packaging. That sort of thing provides an incentive
and motivation for a child to want a particular
product, so to look at the factual information
content without looking at that overall picture
misses a very important part of the jigsaw.
Q609 Mr Mitchell: But that is an excuse for not
putting warning information on the label for kids.
Have you considered having any special system of
children’s labelling?
Ms Hignett: We are looking at signposting, as I
said, across the board and within that we are
looking at signposting in relation to children, which
gets a bit more complicated because you have got
the issues of diVerent age groups to worry about,
but we are looking at it and seeing whether there is
something that can be done.
Q610 Chairman: You mentioned features such as
the importance of role models in advertising and
packaging aimed at children. Are you doing
anything in this area? Is anyone addressing these
issues and, if so, what are they?
Ms Hignett: The Agency’s board has recently
agreed a whole work programme aimed at food
promotions aimed at children which focuses on a
number of things which could be done to make the
environment more friendly for children wanting to
make healthier choices, if you like. One of the
elements of that is that we would encourage role
models to promote healthier options rather than
high fat, high salt, high sugar foods. We have also,
for instance, looked at the initiative which BBC
Worldwide has announced, which is to only license
the characters which they own on foods with a
particular nutritional profile and we are looking at
developing guidance on nutrition profiles which
could be used by character licensers. In eVect the
aim there is to reduce the amount of fat, sugar and
salt in foods which are aimed directly at children.
Q611 Mr Jack: What kinds of inquiries do you get
on food safety issues? Can you give us the top three
things the public ask you about?
Mr Martinson: In terms of the issues of concern
almost always the top level of concern is around
food poisoning. This is not necessarily what they
ask us about but this is what is picked up in our
surveys. Four years ago the top level of concern was
around BSE and concern about that has continued
to decline. In terms of the third issue, I would have
to look it up. Can I come back to you on that?
Q612 Mr Jack: The reason I am asking the question
by reverse is to say, in terms of information given by
the sectors of the food industry which promote the
question, how could they be improving on dealing
with consumers’ concerns about food safety issues?
Perhaps once you have got the three you might like
to give us some commentary about how the
industry communicates better to its customers on
food safety issues. We tend to concentrate on
information on labels but that is not always the
place that you can deal with some of these food
safety issues.
Mr Martinson: Just on the food safety issues, if we
look at food poisoning the Agency set itself a target
when it was established of reducing food poisoning
by 20% over—
Q613 Mr Jack: From what to what?
Mr Martinson: This was from the reported figures.
Q614 Mr Jack: Which were?
Mr Martinson: Which were around 70,000 a year,
reported to what was then the PHLS, and so it was a
20% reduction on that headline figure. Clearly that
represents a much larger figure that goes
unreported which is estimated at around a million a
year. To date the figure has declined by about 18%,
so we have almost hit the target, but the main point
here is about how that has been achieved through
working with industry across the board to look at
ways of improving practices. That could be
anything from, for example, bio-security on farms
in relation to chicken and the spread of
campylobacter to working with the catering
industry to improve practices there also in order to
reduce the issues of food poisoning. In terms of
information, by and large there is quite a lot of
information out there already including that on
labels, particularly in relation to preparation and
cooking of food and particularly in terms of those
foods which could present a slightly higher risk in
terms of uncooked meat.
Mr Jack: If we are talking about the myriad ways
in which people can purchase their food outside the
home, do you believe there is any need for some
kind of nationally communicable standard by
which people can be assured that when they go to a
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restaurant or a major food chain or buy their food
out anywhere that establishment is in accord with
the best practice, because the last thing you
normally ask about when you go to a restaurant is,
“What is going on behind the scenes where I cannot
see it?”. I recently watched one of these celebrity
chef programmes where he had been advising this
guy who ran some place in Yorkshire, I think it
was—
Mr Mitchell: It went bankrupt.
Mr Jack:— and it was an unmitigated disaster,
what was shown on the television, and I am
assuming that it was an honest representation of
what was going on.
Mr Mitchell: Not in Yorkshire.
Mr Jack: It was in Yorkshire.
Mr Mitchell: Not an honest representation of what
goes on in Yorkshire.
Q615 Mr Jack: The point I am getting at is that
clearly the public could have been exposed in those
circumstances to an enormous risk and the idea of
food safety in running that particular establishment
seemed miles away, as with most things in food
preparation in this particular instance, from what
the restaurant should have been about. I question
from that standpoint how it was they deviated so far
but the people up front did not know about it.
Mr Martinson: There will be a requirement from
January 2006 for all catering establishments to raise
their game with the introduction of new rules which
will require them to document in a proportionate
way the measures that they are taking within their
restaurant in relation to food standard. It is called
HACCP. Please do not ask me what it stands for
because I always forget. That is about critical
control points in the food chain, and certainly the
Agency sees that as a good step in relation to
addressing those particular kinds of concerns. In
addition, to state the obvious, consumers also have
a role because I have to say that what I think is
paradoxical is the level of complaints and reports
that consumers make compared to what they say
their experience is. The level of complaints is very
low. Certainly if consumers were more able to
complain to the local environmental health oYcer
to investigate and then take appropriate action,
that would help.
Q616 Mr Jack: Let me conclude by asking a
question about your own role in communicating
food safety issues. You were, like the proverbial
greyhound, out of the stocks over the question of
oily fish, only on mature reflection to have to revise
that information. Do you not think, following Ms
Ruddock’s observations, that you had not quite got
the balance right in terms of waiting and assessing
before you said something? I recall that equally you
were very quick in commenting on some very early
research about the possible relationship between
sheep meat and I think New Variant CJD but
without all of the substance of science having been
completed, and therefore a worry was raised in the
consumer’s mind. How do you argue about the
balance between transparency and not worrying
people unnecessarily?
Mr Martinson: The key issue is how you establish a
relationship of trust with consumers and indeed
wider stakeholders. In relation to the risk of BSE in
sheep, this was not something that came out of thin
air. Scientists had been looking into this for some
time and the Agency was very clear that consumers
had a right to know that there was a possible risk.
We were not saying to anyone that they should
change their diet or indeed avoid eating sheep.
Certainly in terms of the research we did in relation
to understanding of that, that message did seem to
be communicated. As always with those kinds of
issues, you need to turn it on its head and we know
from previous food safety issues that it has been
disastrous when information has been withheld
from the public. On the oily fish one, I am not sure
what particular issue you are referring to.
Q617 Mr Jack: If my memory is correct, the first
announcement was two portions of oily fish a week
and only one if you were a pregnant woman, and
then you issued subsequent guidance which
indicated that a greater number of servings was
okay, and you then said that the balance of risk is
to eat the oily fish because the Omega 3 fat does you
more good than the potential risks you are coming
up against. One minute you can be running to the
fishmonger saying, “Here, you can have this lousy
fish back”, and the next minute you are going and
saying, “I will have four portions a week”.
Mr Martinson: If I can put that into some kind of
context it may help. It has been longstanding
advice, not just in this country but also in many
other countries, to eat two portions of fish a week,
one of which should be oily. A question to which
nobody knew the answer was how many portions of
oily fish, given the contaminants that might be in
them. We could not answer that question because
we did not have the scientific base on which to do
that. About 18 months ago we commissioned
independent experts in this country to look at the
research, to look at the evidence and provide us
with advice. They did that around six weeks ago
and what we then did was try to present it in a way
that we felt was understandable for most consumers
with a number of caveats in relation to vulnerable
groups. It is diYcult to see what else we could have
done because there was no evidence before we asked
the question. We have now got the evidence. No
other agency in the world has been able to provide
that advice, so we think in a sense this is a step
forward. We are able to provide it with a greater
degree of certainty. Two years ago we could not
have given the answer.
Q618 Joan Ruddock: It occurred to me that
perhaps—and I have no idea whether this is right or
not—people should be advised to take some oily
capsule as a supplement to their diet and avoid the
fish altogether. Is that something you can do or can
you only advise about the content and nutrition and
all the rest of it and the dangers of food?
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Mr Martinson: The advice that we have provided is
that you can get the benefits in relation to oily fish
from eating oily fish, but if people choose to take it
from somewhere else that is their choice.
Q619 Joan Ruddock: But that advice is something
you could or do give, is it?
Mr Martinson: Generally speaking our advice is in
terms of dietary intake from food as opposed to
supplements, but if people have specific dietary and
indeed medical needs often that advice is from
their doctor.
Mr Mitchell: A doctor telling you to take pills
instead of eating fish would be barmy.
Q620 Joan Ruddock: If the FSA thinks there is
some risk, albeit that risk is low, and you are saying
the only reason for taking that risk is because of
another benefit and the other benefit could be
provided by an alternative source, is it not
reasonable for you to advise that that is so?
Mr Martinson: Not in this particular case.
Chairman: Let us not pursue this line in too much
detail.
Q621 Mr Drew: One of the real issues about food
safety nowadays is the degree to which we have lost
national control of food safety issues because it is
invested in the EU. To what extent does the work of
the FSA and now in the European Food Standards
Agency mean that you are always subject to
intensive lobbying pressure at a level in Europe
where the big food manufacturers will literally
throw money at an issue if there appears to be a risk
of them losing their potential market?
Ms Hignett: As far as food law is concerned most of
it is made at EU level, which of course, since much
of our food is imported from other EU Member
States, is a plus as well as a minus, if you like.
Whether that subjects us to a greater level of
lobbying than would otherwise be the case I am not
sure. Whenever an important issue is tackled,
whether it is at national level or at EU level, there
will be lobbying.
Q622 Mr Drew: We all know because we have had
conversations about a particular case, which I am
not going to go into at this stage, but it is just my
experience when I have looked at the operation of
this area in particular, and this is real big bucks at
European level because obviously it is the entry into
world markets. To what extent do you think you
would be somewhat hidebound by the fact that
there would be a natural assumption that if a
product has become an established national
product it would inevitably therefore be accepted at
EU level and then there would be very little you
could do even if there was some concern over it? I
am talking about manufactured products here; I am
not talking about fresh products. We are talking
about the big scale of the market place. I wonder
what your worries would be if there genuinely were
concerns being expressed here, particularly if it
came down to the issue of how we might want to
label things with some information being required
and the other European countries being far less
concerned about that?
Ms Hignett: I think that the task we have then is to
persuade other Member States, and we are quite
familiar with being in that position of trying to
persuade other Member States. If there is a safety
concern, then whether or not a product is an
established product on the market we would be in
favour of appropriate action being taken to protect
consumers from that safety risk. On the other side
of the coin we very much oppose any moves which
would have the eVect of taking products oV the
market if there were not a safety concern, so we
would not want to see any unnecessary reduction in
consumer choice.
Q623 Mr Mitchell: I wanted to follow up something
you said in answer to Mr Jack. I think it is totally
unrealistic to place the emphasis on consumers to
invigilate conditions in restaurants. That is barmy.
That is your job. When I go to a restaurant I do not
want to inspect the kitchen—if I get food poisoning
I will sue—but it is not my responsibility to inspect
the safety of conditions, it is your responsibility,
and I think it is unreasonable to try and shift it on
to consumers. That is just by way of an observation.
The point is you said you were having some kind of
certifying scheme from January 2006, I think you
said. I was just interested in how that works,
because you indicated it would be a hazard
assessment thing done by the proprietor. They are
going to lie, are they not? They are going to fill in a
form and say “Mine is the best possible kitchen”. If
you are going to have that you have got to have an
inspection system to make sure they are telling the
truth and you have got to have some system of
certification that you can put up above the door
“This has been certified as good, clean, nutritious—
whatever it is—by the Food Standards Agency”.
Mr Martinson: Just to pick up on that, I do not
think I said consumers had a role in terms of
inspecting or invigilation. What I said was that
about 2% of consumers who say they had food
poisoning in restaurants actually make a complaint
about it. My point was that that would actually
assist in terms of trying to find out where the
problems are. There are something like 350,000
catering establishments in the UK. In relation to
your suggestion, that is being piloted at the moment
in Northern Ireland and in Wales by the FSA with
local authorities. Local authorities are responsible
for the inspection of premises rather than the
Agency, and one of the issues that we are looking
into is whether it is going to be feasible when the
new regulations come in to introduce precisely the
kind of proposals that you have just suggested.
There are a number of diYculties with it, partly in
relation to how often a premises may be inspected
because, clearly, once you have got it up on the wall
you have got no guarantees about what happens
between that and the next inspection, necessarily. I
think the other thing to say is that for most people
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in catering, clearly, they do not want to poison their
customers; it is not good for their business. So we
hope that is a good incentive.
Q624 Mr Mitchell: That is inspection by
Environmental Health, presumably. At the end of
the day, if they pass the inspection it is not just
testified to by the fact that the restaurant remains in
existence and not closed, it needs something to
display on the doorway.
Mr Martinson: We certainly are looking actively
into greater transparency for consumers in relation
to standards in restaurants.
Chairman: Thank you. We had intended to ask
some questions about the Farm Assurance
Schemes, but in view of pressures of time, if my
colleagues agree, I will pursue that in writing with
the Agency and conclude the questions at this stage.
Thank you very much indeed for coming along to
give us evidence this afternoon. Thank you.
Supplementary memorandum submitted by the Food Standards Agency
Food Assurance Schemes
How concerned are you by the National Consumer Council’s finding that food assurance schemes are likely
to “confuse and mislead consumers rather than inform them”?
The review of assurance schemes which we carried out in 20021 found that consumer involvement in
schemes was patchy and that it was diYcult for consumers to find out what standards schemes were working
to. We therefore developed, in consultation with stakeholders, including scheme operators, Agency advice
to schemes recommending improved consumer engagement and setting out the minimum information we
considered ought to be available to consumers.
Can you give us an estimate of the number of farm assurance schemes currently operating in Britain? Would
consumer confusion be lessened if there were fewer, consolidated schemes? If so, how could this be achieved?
The review we published in 2002 focused on the main schemes with a consumer face, that is where there
was a label claim or logo. We looked at 18 schemes of which 11 fell under the British Farm Standard/red
tractor umbrella.
Reducing the number of schemes might help to reduce confusion, but our view is that it is more important
that consumers should be able to find out what individual schemes oVer. For example, our advice
recommends that consumers should be able to find out easily to what extent the scheme standards exceed
the legal minimum, how instances of non-compliance are dealt with and how any specific claim has been
validated.
How can consumers best be educated about the various farm assurance schemes and the diVerences between
them? Should one individual body be responsible for this?
The Agency’s view is that providing clear consumer information about the oVer the scheme is making is
the key to facilitating informed choice. We will be carrying out a survey next year to see whether consumer
transparency has improved since our review. We also plan to collate information on the diVerent schemes
to help consumers make comparisons. The Agency believes it would be helpful if schemes worked together
to provide comparable information for consumers across schemes.
In 2003, the National Consumer Council recommended that the FSA should institute a code of practice
for food assurance schemes and a central register of complying schemes. What progress have you made in
implementing this recommendation?
Would you support an overarching body—industry or government—having oversight of this area? Is the FSA
itself an appropriate body to carry out such an oversight role?
The advice on consumer involvement and consumer transparency issued by the Agency in August 20032
covers the main issues the NCC was concerned about. The planned survey work will identify those schemes
which follow the advice and those which do not.
Consumers’ Food Safety Concerns
The Food Standards Agency tracks the attitudes of consumers to food safety and standards issues in an
annual survey involving interviews with over 3,000 people across the UK.
The attached chart shows levels of concern about specific food issues, tracked over the last four years.
Respondents were asked, “are you concerned about any of the following issues?” and provided with a list.
1
2
http://www.food.gov.uk/multimedia/pdfs/FAS Report.PDF
http://www.food.gov.uk/foodindustry/guidancenotes/labelregsguidance/foodassureguidance
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Food poisoning remains at the top of the list of concerns (60% of respondents concerned). The use of
pesticides in food is currently of second highest concern (46%). BSE has fallen from the top issue of concern
when the survey was first conducted in 2000 to joint third concern in 2003 (falling from 61% to 42%). The
same number (42%) specified the conditions in which food animals are raised as an area of concern.
Concerns about specific food issues (prompted)
Codes with biggest changes year on year shown
%
60
59
59
63
Food poisoning (eg Salmonella)
46
44
50
46
T he use of pesticides to grow food
42
39
43
41
Conditions in which food animals are raised
42
45
BSE
2003
55
61
39
41
T he feed given to livestock
50
46
38
36
38
43
GM foods
2002
2001
2000
21
27
25
Healthy eating
0
Irradiated food
19
20
20
24
18
Food allergies
22
22
25
Base : All respondents -2003 (3121), 2002 (3173), 2001 (3120), 2000 (3152)
Q30 Are you concerned about any of the following issues?
29 July 2004
Memorandum submitted by the Department for Environment, Food and Rural AVairs
Introduction
Information about food is relayed to consumers by many means covering many aspects of the quality and
provenance of food. The Government’s overriding objective is to ensure that consumers are able to make
well informed choices.
Within Government, responsibility for matters relating to food safety and standards rests mainly with the
Food Standards Agency (FSA). The FSA also leads on the labelling of food. However, Defra has an interest
in these areas and works closely with the FSA and other Government Departments on them and related
matters. Defra also has policy responsibility for a number of other areas that have a bearing on the
information and messages that consumers receive about food. This memorandum concentrates on Defra’s
role and follows the structure of the sub-committee’s terms of reference.
Information on the Nutritional Content of Food
Improving consumer information will be a key focus of the Food and Health Action Plan (FAHAP) on
which the Department of Health (DH) is about to go to consultation. The development of this plan is a
commitment in the Sustainable Farming and Food Strategy. When implemented, it will shape, co-ordinate
and drive action to improve, through nutrition and diet, the health of the people of England, at all stages
of life.
The plan will be focussed on the nutritional priorities of:
— increasing the consumption of fruit and vegetables;
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— increasing fibre in the diet; and
— reducing the intake of salt, fat and sugar.
Defra has worked with DH, the FSA, the Department for Education and Skills (DfES) and others to
develop the FAHAP proposals. The consultation will be a strand of the wider “Choosing Health?”
consultation on improving public health which DH launched in March 2004. Both consultations will inform
the production of a White Paper on public health in summer 2004.
The proposals will include bringing key stakeholders together to agree basic messages about nutrition and
health and developing and implementing a communications strategy to ensure that consumers get the
balanced information they need to make choices about what they eat.
Food Safety
In the area of pesticide and veterinary medicine residues in food, Defra’s responsibilities complement
FSA’s wide ranging role on food safety. Defra’s role on pesticides encompasses the assessment of risks to
workers, the environment and consumers. On the latter aspect we work closely with the FSA.
The Government currently spends £2.2 million per year on a nationwide programme of pesticide residues
surveillance in food and drink. Such a programme has been in existence since the 1970s and forms part of
the statutory controls relating to the approval of pesticides.
In 2000 an independent non departmental government body, the Pesticide Residues Committee (PRC),
was established to oversee the surveillance programme. In part this was to ensure that the findings were
made available to consumers and the food and farming industries in a way which is comprehensive,
understandable and timely.
Since the establishment of the PRC there have been many improvements in the way that information on
pesticide residues is made available to consumers. Instead of one annual lengthy technical report, reports
are now made available quarterly on the PRC web-site. In addition a more user friendly summary of the
information is published as an annual report of key findings and the PRC hold a public meeting each year.
More recently, the PRC website has been re-designed and a new web-site can be found at prc-uk.org. A
new leaflet specifically for consumers called “Pesticide residues in food—facts not fiction” will be launched
in May.
Defra’s role on veterinary medicines encompasses the assessment of risks to the target species, the person
administering the medicine, the environment and consumers. On the latter aspect we work closely with
the FSA.
Veterinary medicines residues surveillance is carried out under two programmes. The larger statutory
programme meets the requirements of EU legislation. The annual costs of £3.7m are met by industry. The
Government spends £1.1m on a complementary programme looking principally at imported produce.
In 2001 an independent advisory committee, the Veterinary Residues Committee (VRC), was established
to advise the Chief Executives of the Veterinary Medicines Directorate (VMD) and FSA on the surveillance
programmes.
Information on veterinary residues, including all test results and follow-up actions, is published on the
VMD website and in the VMD’s quarterly newsletter. The VRC publishes its papers and minutes on its own
website and produces an annual report explaining the process and commenting on the positive results found,
in a user friendly way. The VRC will hold its first public meeting later this year.
In the animal health area, Defra works closely with the FSA and with other interested departments and
organisations on animal diseases such as BSE which have implications for food safety. Defra is responsible
for the animal health aspects of these diseases, and the FSA is responsible for the food safety aspects.
Means of Production and Production Standards
Eggs and poultry
EU egg and poultrymeat marketing legislation sets down optional indications of certain alternative
farming methods, referred to as Special Marketing Terms. These specify criteria such as stocking densities,
etc which must be met before claims about certain types of farming, eg “free range”, can be made. The
Government supports the operation of these standards as they protect the consumer by setting high uniform
standards and provide informative labelling.
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Beef
EU rules on origin labelling for fresh, chilled and frozen beef and veal were introduced in 1996 during the
BSE crisis with a view to ensuring public health and increasing consumer confidence in beef. Regulations
1760/2000 and 1825/2000 require beef to be labelled with a traceability reference code, the countries in which
the animal was born, raised and slaughtered, and in which the meat was cut. The label must also show the
approval numbers of abattoirs and cutting plants. There is a limited derogation for minced beef.
The regulations require operators in the beef supply chain to maintain traceability systems to support
their labelling claims. They also provide for operators to make voluntary labelling claims; these require prior
approval by the Competent Authority and are subject to independent third party verification. In the UK
voluntary claims are administered under the Beef Labelling Scheme.
EU marketing standards for fresh fruit and vegetables
EU marketing standards exist for a wide range of fresh produce. Their objectives are to keep products of
unsatisfactory quality oV the market; to ensure that produce is accurately labelled; to guide production to
meet consumer requirements and to facilitate fair trade under fair conditions. The standards also provide
consumer protection in a sector where many products are highly perishable and serious defects can
develop rapidly.
EU marketing standards generally apply at all stages of the distribution chain, including retail, and at all
such stages there must be clearly visible information about the produce. At the retail stage this must include
the nature of produce, its quality (eg class I or II), its country of origin and, where applicable, the variety
name. At point of sale, this information can be given in a number of diVerent ways: for example, as a printed
label on pre-packed produce, or a shelf label or display card for loose produce. (Further information on the
standards and their enforcement is available on the Defra website at http://www.defra.gov.uk/hort/
hmi.htm)
GM Foods
Defra and the FSA have been working together on the development of the EU Regulations on the
traceability and labelling of GM food and animal feed. These rules require labelling of all GM food and
feed products, including those derived from GM organisms. They aim to improve consumer information
by extending labelling requirements, lowering thresholds and heightening requirements on the retention of
records throughout the supply chain. Defra and the FSA held joint stakeholder meetings on the
implementation of these new regulations last autumn and launched a joint consultation exercise on guidance
in March.
Organic Food
Organic standards in the UK are based on the EC standards set out under Council Regulation 2092/91
(as amended). The UK standards diVer slightly in that they are stricter in some areas, mainly in relation to
livestock standards, in which member states have discretion.
The use of the term “organic” on food is strictly controlled. Anyone wanting to produce, prepare, import
and, from 1 July 2005, store organic food will need to be registered by an approved Certification Body and
subject to an annual inspection by them. The licensee must demonstrate that the produce has been produced
to at least the UK national standards, or if it is an import from outside the EC, to at least to the EC
standards.
Defra publishes on its website a large amount of information on organic food and farming, including
standards and the environmental and other sustainability benefits of organic production methods. We and
the other UK rural aVairs departments have each published Action Plans to develop organic food and
farming. At EU level a European Action Plan is under development to complement national initiatives with
particular emphasis on improving distribution networks and information for consumers.
Assured produce
Assurance schemes provide consumers with information about the way that food is produced, as well as
a reassurance that certain standards have been met. The main baseline schemes use the Red Tractor logo
which is administered by Assured Food Standards (AFS), though some also have their own logos, as do the
higher tier schemes such as Freedom Food and LEAF. Most schemes also have websites which give details
of the standards that their members have to observe.
The Government believes that assurance schemes have helped to re-establish consumer confidence in the
safety of British food and can help to distinguish products on the market place. Although the schemes are
privately owned and operated Defra has actively encouraged their development, including the introduction
of new governance arrangements for AFS and support to help it rationalise schemes and develop a
marketing and communications strategy.
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If assurance is to continue to be relevant to consumers it is important that scheme standards are both
credible and realistic, and that the way that they are set and monitored is transparent. We therefore support
the guidance on assurance that the FSA issued following its review of assurance schemes.
EU protected food names scheme
EU legislation provides for a system for the protection of food names that have an established link to a
geographical area or are based on traditional recipes. Names that have been granted protection can only
be used within the Community for products that have been produced within a defined area to an agreed
specification. Producers of such foods are subject to regular inspection by accredited certification bodies to
ensure conformity with the registered specification. Registered products are entitled to carry an EU symbol
that can help consumers recognise the product as traditional and authentic.
Thirty five UK products have been registered under the scheme including Cornish Clotted Cream, Stilton
Cheese and Arbroath Smokies.
Local food
There is an increasing interest among consumers and retailers in local foods. In developing our policy on
local foods we found that there are diVering views on how the term “local” should be defined. We have
discussed this with the FSA who are considering the possibility of producing guidelines on the use of the
term.
Farm shops and farmers’ markets represent an important outlet for locally produced food. They also
enable consumers to deal directly with producers and, in doing so, provide an opportunity to learn more
about the way that food is produced. Defra sees the growth of the farmers market movement as a positive
development. We have been actively supporting the work of the National Association of Farmers’ Markets
and its successor, the National Farmers’ Retail and Markets Association.
Ethical considerations concerning issues such animal welfare, the environment and labour standards
underlie a range of products and schemes. Defra has been working with DFID, which provides financial
support to the Ethical Trading Initiative (ETI), and the DTI to encourage food and drink companies to
observe ethical standards in international supply chains such as coVee.
We have also been working with a broad group of businesses and organisations in the food supply chain,
brought together by the ETI, to trial a Code of Practice for labour providers in the fresh produce sector.
The Code sets a standard for how professional labour provider businesses can operate within the law.
Retailers, who have an important role to play in promoting ethical practices at all stages in the food chain,
have been closely involved with the preparation of this code.
The Government is supporting Jim Sheridan MP’s Gangmaster (Licensing) Private Members Bill. This
Bill will require all agricultural labour providers to be licensed. The retailers support this initiative and will
be able to reinforce its provisions through their involvement with the food chain.
Information about the systems used to raise animals for food is widely used and some descriptions, such
as those on eggs and poultry that are referred to earlier in this memorandum, have a legal base. The best
known example is probably free range egg production. Such information can be used by consumers as a
basis for their buying decisions. But the production system alone is not a reliable indicator of animal welfare.
Welfare also depends crucially on the way in which the animals are managed and that cannot readily be
described on a label.
WTO
The WTO trade round negotiations (the “Doha Development Agenda”) primarily concern trade
liberalisation, with a special emphasis on development issues. Nevertheless, in the context of negotiating a
new Agreement on Agriculture (an essential part of the round), the European Commission has sought to
introduce the concept of mandatory labelling of food products by proposing the inclusion of an
authoritative interpretation of Article 2.2 to the WTO Agreement on Technical Barriers to Trade. This
Article concerns the mis-use of technical regulations as an unnecessary obstacle to international trade.
The proposed interpretation would grant WTO members the right to choose the level of consumer
information and protection they deem appropriate with regard to the characteristics, production and
processing methods of agricultural products. In pursuance of this, the mandatory labelling schemes would
be presumed not to create an unnecessary obstacle to international trade. So far the proposal has been met
with almost unanimous rejection by other WTO members, who see it as an attempt by the EU to introduce
further protectionism through the back-door.
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Support for the Promotion of Information about Food
EU regulations for the promotion of agricultural products
Defra administers EU Commission Regulation 2826/2000 which provides for the joint funding of generic
information campaigns for certain agricultural products and food quality schemes. The qualifying themes
include information about protected food names, organic farming, agricultural production systems that
guarantee product traceability, the quality and safety of food and its nutritional and health benefits, and the
EU code printed on eggs.
Proposals should normally be tri-partite funded by the Commission, the organisation running the
campaign and the Member State in whose territory the campaign is taking place. The most recent UK
campaigns approved by the Commission focus on the promotion of organic produce, milk in schools and
information about meat.
Rural enterprise scheme
Among other things, the Rural Enterprise Scheme can help provide support towards projects that involve
the marketing of quality agricultural products. This can include start-up costs for projects that promote to
customers the benefits of particular production processes, eg organic, and the development of regional or
local branding.
Educating the Public about Food and Agriculture
Farming and countryside education
Defra works closely with Farming and Countryside Education (FACE). FACE was set up by the National
Farmers’ Union and the Royal Agricultural Society (RASE) in 2001 with the aim to increase the number
of school children who visit farms. It helps teachers and school children understand food, farming and the
countryside through the use of class visits to farms and horticultural nurseries and through farmer visits to
schools. More information on FACE can be accessed at www.face-online.org.uk
As part of its work, FACE commissioned jointly with the DfES and the Countryside Agency research
on young people’s views on and understanding of food, farming and land management. The research was
undertaken by King’s College, London and the National Federation for Education and Research. A copy
of its report “Improving the Understanding of Food, Farming and Land-Management Amongst Schoolage Children: A Literature Review” can be found on the DfES research website at www.dfes.gov/research.
FACE has also produced, in partnership with the Environment Agency, a video and DVD “Questioning
the food you eat” to support the teaching of geography, science and citizenship at Key Stages 2 and 3. The
video and DVD consists of short clips featuring experts who have diverse opinions about food and farming
issues. These can be used individually or together to stimulate discussion within the classroom. “Questioning
the Food you Eat”, which is free, is proving to be very popular with schools and more copies are having to
be produced in order to meet demand.
National advisory group for growing schools
Defra is also represented on the National Advisory Group for Growing Schools, a Government initiative
funded by DfES. Among other things, Growing Schools aims to raise awareness of the rural sector, of food
and where it comes from, of farming and agriculture, of countryside issues and healthy lifestyles, and about
increasing understanding and responsibility for the environment. The programme has been running since
September 2001 and Defra have been actively involved in its development from the beginning. The new
Growing Schools website, due to be launched imminently on Teachernet (www.teachernet.gov.uk/
growingschools), will provide access for teachers and providers to the vast education resource that exists in
this sector. The Countryside Stewardship educational access site details (see below) will be incorporated into
this new website.
Countryside stewardship educational access
Countryside Stewardship is a Defra scheme which oVers payments to farmers and other land managers
to enhance and conserve English landscapes, their wildlife and history, and to help people to enjoy them.
The educational access option promotes the use, enjoyment and study of the countryside by schools,
colleges, and groups for life-long learning. Stewardship agreement holders with educational access make
arrangements with local schools or groups to visit the farm for learning purposes.
There are currently over 800 sites available to visit throughout England, details of which are
available on the educational opportunities section of the Stewardship access website at http://
countrywalks.defra.gov.uk. Each site oVering school visits has a teacher’s information pack which explains
what is available on the farm, the facilities available, and suggests activities and educational opportunities.
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The pack was updated in 2003, with a new version being produced in association with FACE. This shows
how farm visits can link to a range of national curriculum subjects, and how farming links to a range of
services, including food production.
Access to farms partnership
Countryside Stewardship is represented on the Access to Farms (ATF) Partnership which brings together
various organisations (including Countryside Agency, DfES, FACE, Groundwork, NFU, Countryside
Foundation for Education etc) that provide farm visits for schools. ATF meets several times a year to discuss
various initiatives, and to co-ordinate promotion of school visits. A number of agreement holders are also
currently involved in a pilot for a voluntary accreditation scheme for farmers providing school visits being
run by the Countryside Agency. If successful, we are likely to recommend accreditation to our agreement
holders.
Role of the levy boards
The statutory agriculture and horticulture levy boards also produce information about the food produced
by the sectors they cover. This can range from the general to the specific depending on the foodstuV in
question, and the specific approaches taken by the diVerent Boards to meet identified needs.
28 April 2004
Witnesses: Lord Whitty, a Member of the House of Lords, Minister for Food, Farming and Sustainable
Energy, Mr Bill Scriven, Head of Food Chain Marketing and Competitiveness Division and Mr Ian Newton,
Head of Trade Policy Unit, European Union International Division, Department for Environment, Food
and Rural AVairs, examined.
Chairman: Good afternoon, Lord Whitty. Thank
you for coming to give us your evidence this
afternoon, and we are sorry we are running a little bit
behind schedule. I see you are joined by two
members of your department this afternoon. Could I
begin by inviting Michael Jack to open our questions
this afternoon?
Q625 Mr Jack: Thank you very much, Chairman.
Lord Whitty, you are no stranger to our method of
inquiry. I read your evidence with keen interest and
without doubt you have summarised in four pages
an awful lot of activity that is going on in various
ways in which information is being transmitted to
various consumers, young and old, in the field of
food, but nowhere in the document could I find a
statement about, for example, who in government is
responsible for policy on food information. In the
context of labels, for example, there is no statement
in your evidence saying what is Defra’s view about
labels, their contents and their future development.
Could you enlighten me on, first of all—you are the
sponsor ministry for a £55–60 billion industry, the
food and drink industry—who is responsible for
policy within government for food information?
Lord Whitty: If you are talking about mandatory
information provided by regulation in relation to the
food safety or nutritional content, then the FSA is.
The FSA, as you know, is an independent agency—
you have just been talking to them—and they come
under the aegis of the Department of Health. There
are, of course, other methods of information about
food including assurance standards, retailers’
information and other forms of information in
which we, as sponsor ministry, encourage the
industry to provide as accurate and as detailed
information as they can in various ways, but the
actual regulatory dimension of it is the FSA.
Q626 Mr Jack: That is a good answer from the
regulatory side but that was not the question I asked.
The question I asked was about food information.
The Government has had presented to it the Health
Committee report on obesity, and the antidote for
that—or part of it—is good advice and information
to the consumer. The Government, by definition,
when it responds to that report, will have to have a
view about these matters. So I ask again, in putting
together views on issues like that and bearing in
mind your department’s key sponsorship role for the
food industry, who is in charge within government,
on the question of food information for, from the
Government’s standpoint, transmitting messages
about food or deciding what messages the
Government would like to transmit about food?
Who is in charge?
Lord Whitty: The response to the report will be a
cross-government report but the FSA are the lead
department.
Q627 Mr Jack: So you are saying that your
department has no view on this matter?
Lord Whitty: No, I just said we have a view on a
number of matters and we, clearly, have a view in
relation to what information should go in, but if you
are asking who is in charge, who is the lead
department in relation to food information, and on
the regulatory and educational side, if you like, it is
the FSA.
Q628 Mr Jack: The FSA told us there were lots of
cross-government committees that meet on this
subject to decide policy.
Lord Whitty: Indeed.
Q629 Mr Jack: Could you give us a flavour of what
your input to any of those is?
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Lord Whitty, Mr Bill Scriven and Mr Ian Newton
Lord Whitty: At the moment, the dynamics of it are
largely being led on the health side by the
preparation for the Food and Health Action
Programme and the Public Health White Paper.
That is the main, active co-ordination at oYcial level
that operates in that area. There have been
previous bodies—
Q630 Mr Jack: So Defra is involved in that?
Lord Whitty: Defra is involved in that.
Q631 Mr Jack: What kind of input do you have to
that? What is your role in that? What kind of things
do you put on the table for others to digest?
Lord Whitty: We are responsible for the
sustainability of the British food sector. That
includes concern about the economics of it, the
environmental impact of it and the social, which
includes the nutritional, aspect of it. So we therefore
have a view on all of those, but it may be that other
agencies are the main bodies. For example, we
are the co-ordinating department for public
procurement of food. We do not actually have a big
public procurement programme ourselves but we
are the co-ordinating department encouraging the
Department for Education, the Prison Service, the
Armed Forces and the NHS and so forth to improve
the quality of their public procurement of food, both
in terms of the amount that is sourced both locally
and from British sources and the nutritional quality
of it. So we have that role, for example.
Q632 Mr Jack: Let me just stop you. I went and
looked at your website today, and on food it covers
food manufacturing, importing, exporting, and
general information on regulation, and it touches on
eggs, poultry and milk products, beef labelling,
competition, food chain, and organic production.
However, as the department, for example, that is
responsible for the production side, if you like, of all
of the fresh food in the country; there is no
information to relate that area of your responsibility
to food information. So, in other words, if a member
of the public thought “Defra: food. I will go there for
information”, they are going to be left sort of feeling
around. I just wondered why this lack of engagement
in having—
Lord Whitty: There is no lack of engagement; it is a
daily engagement between my oYcials and the FSA
and other agencies. You will know, in terms of the
machinery of government, that it was a deliberate
decision of government to remove the regulatory
and informational side—consumer-oriented side—
from the production side. So what became the FSA
was removed from MAFF by a deliberate decision
and placed under the aegis of health ministers. You
can argue whether that was wrong or right but it was
a deliberate separation. We have maintained a very
high level of continuous engagement with the FSA
and with the Department of Health on all of these
issues but our role is not the provision of
information except in a few limited areas, like
veterinary medicine—
Q633 Mr Jack: You said your oYcials were involved
in the working up of this Food and Health Action
Plan.
Lord Whitty: Yes.
Q634 Mr Jack: What is the message? What are you
telling your oYcials (I presume they report back to
you on what goes on in this body) they ought to be
doing from the Defra standpoint to ensure, as your
note says, “Improving consumer information will be
a key focus of the Food and Health Action Plan.”
What is Defra’s contribution to that? What do you
think this Food and Health Action Plan should be
doing? Therefore, what are you telling your
representatives on this cross-government body to
do? What is the Defra message?
Lord Whitty: We should seek to ensure that the
information provided to consumers who will sustain
the future health of the British food industry is
understandable, is accurate and is able to be
delivered by the industry itself. To do that there is
the question of its form, both its regulatory form and
its form over and above regulation, and there is a
question of how we engage the various parts of the
industry in delivering that information. So whether
we are talking about retailers or restaurateurs or the
manufacturers, we want to see that process of the
Food and Health Action Plan and the broader
strategy for public health to engage positively the
food industry in delivering the message and making
sure that the message is something which the food
industry can or ought to be able to deliver.
Q635 Mr Jack: Are you, in any way, instructing
your oYcials about the balance that should be struck
in terms of the messages that this Food and Health
Action Plan puts out between, for example, fresh
and manufactured foods, bearing in mind your
sponsorship of both sides of the industry? There are
some who may have a very distinct view about what
is good versus bad, from the health standpoint. You,
on the other hand, represent producer interests—
Lord Whitty: I do not represent producer interests; I
represent the public’s interests in the success of the
British food industry.
Q636 Mr Jack: You make it clear that you are
unique in government, in that you have the
responsibility for this great food and drink industry;
you are the sponsoring body of it and you are there
to champion—
Lord Whitty: But I do not represent them.
Q637 Mr Jack: You represent their views. I am sure
if the food—
Lord Whitty: They may well want me to represent
their views a little bit more explicitly and precisely,
but I represent what I think is their long-term
interest, which is a diVerent thing from representing
their views. Their long-term interest is in ensuring
they have got informed, healthy, long-lived and
understanding customers.
Chairman: I think there was an issue Austin was
going to take at this stage, and then you can follow
your point further.
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Q638 Mr Mitchell: I was as delighted as Michael
clearly is to hear that you are the sponsor of the food
industry because, Britain being the largest
concentration of food production (?) as Europe’s
food town, it is nice to have such a benign and
amiable sponsor, I must say. Like him, I want to ask
what it involves. You are saying that what you are
doing is ensuring they have long-lived, healthy
customers. How far are you also promoting the
industry’s economic interests and its development?
Lord Whitty: We are clearly promoting the
industry’s economic interests in the sense that we are
looking to them to raise their game, in terms of their
technology, their taking on board the demands of
the consumers and of the environment and their
trade issues—whether they are issues of import or
export—and so forth. Then, within the Government
machine, we are acting, if you like, as their critical
friend.
matter for health ministers and, to some extent, the
FSA. We want to ensure that the British industry can
supply the healthy elements—
Q639 Mr Mitchell: Whitbread told us you were not
spreading enough information about; you did not
know enough about the food industry to tell other
departments what is involved there.
Lord Whitty: I would be surprised at that, but I think
they have enough engagement in various parts of
Defra to know what we do and what we do not do.
There will be some criticism but, in general, I think
the food industry is pretty clear on who its sponsor
is, what we are prepared to do for them and what our
relationship is with the other key departments who
interface with them.
Q645 Mr Jack: How?
Lord Whitty: There are bits of regulation which after
the removal of the FSA from the old MAFF stayed
with what is now Defra. One of those bits is the bit
you picked up here under marketing standards for
fresh fruit and vegetables. That has remained,
perhaps slightly anomalously but it has remained,
with Defra. We are therefore responsible for
carrying out the EU regulations in that area.
However, over and above that, as part of our overall
food policy in the Sustainable Food and Farming
Strategy adopted following the Curry report, we are
party to cross-government commitments on diet and
a balanced diet, which includes, for example, the
Five-a-day, the fresh fruit in schools and various
elements which promote fresh produce. If you are
saying do I want to go beyond that and persuade
retailers and others to advertise the specific benefits
of specific fresh products then that is probably going
a bit far, but the general message that fresh food,
fresh fruit and fresh vegetables—which includes
lettuces and salads—are of benefit, then, yes, we
would wish to encourage those who purvey them
whether they are restaurants or retailers, so to do.
That should benefit elements of the primary
producers as well.
Q640 Mr Mitchell: So you are sponsoring both the
producers and the manufacturers?
Lord Whitty: Yes.
Q641 Mr Mitchell: The food service sector as well as
the food chain? The whole lot?
Lord Whitty: Yes.
Q642 Mr Jack: Can I just tell you why I have been
pursuing my line of inquiry about what your
department’s actual views are on some of this? For
example, in your evidence under the paragraph that
talks about EU marketing standards, you quite
rightly describe at the retail stage: “This information
must include the nature of produce, its quality and
whether it is Class 1 or 2”. However, part of this
great plan for Food and Health Action will, no
doubt, deal with nutrition and ingredient contents. I
would have thought that you might have had a view,
for example, with the marketing of fresh produce, as
to whether it would enhance the sales of those items
in the context of this plan if consumers were better
informed about, for example, what the nutritional
content of the banana, the apple, the beef, the pork,
etc, was, but you are neutral in your views about
these issues in your evidence. Why?
Lord Whitty: I do not think we are neutral about
them in our evidence or in practice. We are clear that
part of the responsibility of the food industry in all
its manifestations is to deliver a wide range of choice,
certainly, and the option of pursuing a healthy diet,
but the balance of that healthy diet is primarily a
Q643 Mr Jack: I know that, but if you take, for
example, lettuce, which is high in folic acid and good
for pregnant mothers I understand, I would have
thought Defra might have had a view as to whether
that piece of information ought to be given by
retailers, for example, to customers in addition to
the fact of describing whether it is a Class 1 or 2
lettuce or what its weight was. Yet you do not seem
to have a view.
Lord Whitty: I think you are mixing up the issue of
what is regulated and what is not.
Q644 Mr Jack: Do you want to go beyond
regulation then?
Lord Whitty: Yes.
Q646 Mr Jack: We have talked about health and we
have talked about your position. North of the
border there is a Scottish Food and Health Coordinator who manages to bridge these gaps. Have
you given any thought to the appointment of such a
person south of the border?
Lord Whitty: My understanding of the Scottish
position is that there is somebody within the Scottish
Executive who is, if you like, the point of contact so
that there is a one-stop-shop for food policy issues,
but she is not, as I understand it, the executive
responsible in all the areas of the Scottish Executive;
the health department, the agriculture department,
the education department—they have a similar
structure to us. Of course, the FSA, which is the
main regulator in the industry, is a national, UK
body; therefore, it is not an analogous position. It is
certainly not a co-ordinator in the sense of a
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superstructure over all the departments and agencies
which have bits of responsibility for food. If you are
saying should there be more of a one-stop-shop for
information, well, that is something that we could
certainly look at. At the moment we are focusing
strongly on the health element and there may be
recommendations in relation to how you get
information on food health coming out of the Public
Health White Paper. I think it is wrong to say (as I
have seen this position in Scotland described) it is a
Food Tsar; it is nothing of the sort, it is a coordicator of information—or least a focal point for
information—not an executive job.
Chairman: There was a particular issue regarding the
industry/government interface that I think Joan
Ruddock wanted to pursue.
Q647 Joan Ruddock: I think the Minister is saying
that there is going to be a White Paper, that there are
clearly discussions going on and we will know in due
course, but some things have already come to our
attention, namely the initiative on salt and the way
in which the Minister for Health has named
companies and said that there would be a need to
take some stronger action. To what extent has Defra
been in discussions with the Department of Health
over that particular initiative, which is on-going at
the moment?
Lord Whitty: The issue of salt in food is quite a longrunning one in which MAFF, and then Defra, have
been involved with the Department of Health for
some time. The particular initiative on naming the
companies we are not directly involved in but,
clearly, that was an initiative in which the
Department of Health were trying to ratchet up the
pressure on some of the manufacturers they felt were
not delivering enough on that front. However, the
basic policy we have been involved in.
Q648 Joan Ruddock: Given that that has been
publicly stated, is Defra then working with the
industry in any sense to reinforce those messages? Or
do you say “That’s them, and they did that and it is
nothing to do with us, really”?
Lord Whitty: No, we are not; we are keeping in close
touch with the Department of Health on all these
things, but it is their initiative to actually pick out
salt as one of the principal areas. We have had a salt
reduction policy which is a Defra, and before that
MAFF, policy as well as a Department of Health
policy for some considerable time, and certainly
quite a lot has been achieved on the bakery side,
for example.
Q649 Joan Ruddock: Should it not be a joint policy?
Should you not be jointly tackling this issue?
Lord Whitty: We are a joint party to it but the setters
of the targets are those who are responsible for
health, in eVect, and that is why the Department of
Health set the targets and monitors against those
targets. So they are, therefore, best placed to say if
companies and products are falling below those
targets.
Q650 Joan Ruddock: Given that we have had a lot of
evidence that suggests that the voluntary initiative is
somewhat faltering, do you think the Government
ought to take a stronger line and, possibly, ought to
legislate in this field?
Lord Whitty: In which field?
Q651 Joan Ruddock: In terms of quantities.
Lord Whitty: We are still on salt?
Q652 Joan Ruddock: We all know that sugar and fat
is the same issue, really, but it is about the levels that
are healthy or unhealthy and about the information
that ought to be given to people to try to make an
assessment to do what is best for them diet-wise.
Lord Whitty: I think there are two separate issues.
On the question of whether, in eVect, some heavilysalted products should be eliminated from the
market by regulation if the voluntary system does
not do it, the voluntary system has eliminated quite
a lot of heavily-salted food but some other,
particularly highly-processed, products have come
in, so that there is a highly-salted processed thing
where bread has reduced its salt content. So if the
direction was faltering entirely then I think the
option of looking at regulation in these and other
fields might be appropriate. The issue of information
is, of course, one which is under active
consideration, principally with the FSA and the
Department of Health, but I suspect that the issue of
information on salt, fat and sugar will form part of
the consideration of the Public Health White Paper,
and maybe regulation on what information should
be given. There is, of course, some dispute as to what
information is useful and what is not, which may
make actual regulation more diYcult, but we are still
generally at the point where, product-by-product,
salt is being reduced by, largely, voluntary action.
We need to take that faster. If it fails to speed up then
I suppose there may become a case for actual bans,
but I think we are not at that point at this point.
Q653 Joan Ruddock: Might not regulation of that
kind, that could ultimately be a ban, create a level
playing field? Some of the evidence given to us has
been suggesting that people like the taste of salty
food and, therefore, those who continue to market
salty foods could gain market advantage over others
who have been more responsible?
Lord Whitty: Yes, although that has not been the
economic eVect of the reduction in salt in bread.
Q654 Joan Ruddock: It has not?
Lord Whitty: It has not, in that it has not been the
saltier breads which have prevailed. Certainly, to
some extent, the less-salty breads have had a bigger
market share. However, that could happen; I
appreciate it could happen. One of the problems in
all this—and I am not saying anything diVerent, I do
not think, from what the Department of Health or
the FSA would say—is that if you focus on one
aspect of unhealthy food then, clearly, if you have a
couple of bags of crisps a week, however salty they
are, if you also eat lots of fresh fruit and vegetables
and have a reasonably healthy lifestyle it is not going
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to do you much harm, but if you only eat highlysalted food and sit in front of the television all the
time, then, by and large, you are going to end up in
a pretty poor condition by the time you are my age—
if you should get that far. So there is this question of
whether banning particular foods is the appropriate
response except in extreme circumstances or whether
the overall message, which I think does need to be
the overall message, of a more balanced diet is the
more appropriate way forward.
Q655 Mr Drew: In terms of the relationship with the
FSA, I do not want to keep going over old ground
but in a sense, in setting up Defra—which was quite
a radical thing to do and to actually give food its own
ministry—it does seem rather bizarre that the key
agency that reports through to government is
actually reporting to another department. Is it not
about time that the Government actually did what it
said it was going to do, which is treat food as an
important issue and not relegate it to health, which
clearly it has to be in terms of all the other panoply
of things that health does?
Lord Whitty: I do not think the term “relegation” is
the appropriate one. Food is, clearly, a huge aspect
of health and one that is most appropriately dealt
with in the health context.
Q656 Mr Drew: Why?
Lord Whitty: Because the public interest in what
food you eat is how healthy it is. There are other
public interests, like does it cause environmental
damage in its production or how much does it
produce into the balance of payments, which may be
more appropriate for departments dealing with
economics—as sponsors for the environment as we
do through environmental legislation. The health
and diet elements seem to be the most important
public concern about food, and it was felt at the
time—and I think I would agree with this—that
having the department which was basically a
production department, which was even more a
production-focused department when it was
MAFF, also responsible for the regulation at the
consumer end was a conflict of interest. In a sense,
that is no diVerent from saying that the DTI is the
sponsor for the chemicals industry but the
Department for the Environment regulates its
environmental eVect. That is probably beneficial.
There are indeed problems, as you know, in the
transport sector, which I used to be familiar with,
where if you have, within the Department of
Transport, also the responsibility for health and
safety in transport then there are potential conflicts
of interest. Now, you cannot resolve all these
conflicts of interest by drawing diVerent lines across
government, but it seems to me quite a consistent
line that the producer department and the main
regulator ought probably to be separated. Whether
you just do that by hiving it oV into an agency or
whether you do it by having an agency which is
responsible to another ministry is a matter of the
Prime Minister of the day’s decision, in a sense, but
it does seem to me you do have to separate the two
somehow. It was not considered, historically, that
MAFF did separate them suYciently.
Q657 Mr Drew: I wonder if the Treasury has quite
the same qualms about having that degree of
accountability through some of its agencies. I just
think—
Lord Whitty: I am not answering for the Treasury.
Q658 Mr Drew: I am not going to ask you to speak
for the Treasury, I am just posing that as a dilemma.
I am just thinking that, really, the Government
actually, as I said, it is very radical—it actually gave
food its own ministry. It may be seen as a producer
oriented agency of government initially but it could
have, obviously, then been able to do some of the
things that, if you like, many of us would want to see
happen, which is make these connections. There is a
danger that we have now ended up with a bit of a
hotch-potch which means that an area like labelling,
which we obviously cannot take today, falls down
between a numbers of diVerent stools.
Lord Whitty: I do not think it falls down. There is a
separation and there is a separation of the consumer
information responsibility and the sponsorship of
the industry. Part of the sponsorship of the industry
is to ensure that the industry at all levels from
primary agriculture right through to the retailers is
upping the quality of its product. That is consistent
with ensuring that the best information goes to the
consumer. There is no falling between two stools;
there are diVerent departments responsible for
diVerent sides of the same coin.
Chairman: Can we now turn to the question of
European food legislation issues and related issues?
Mr Jack: I was just going to say to my colleague, Mr
Drew, with a reshuZe coming up, so I am told,
perhaps you will be the Secretary of State for the
balanced diet in future administrations.
Mr Drew: They would not be eating much, though,
would there? Certainly not fish.
Q659 Mr Jack: Minister, as far as Europe is
concerned, Europe dictates the terms of much of our
food labelling policy. The emphasis seems, at the
present time, to be on a labelling regime which is
about what is in food in terms of ingredients, but
there are signs that they are moving away from that
towards recognising the importance of nutritional
information. If that is the way things are going, who
within the United Kingdom Government is
determining our policy towards this particular
matter? Who speaks for Britain on these issues?
Lord Whitty: The department that is primarily
responsible for this is still the FSA.
Q660 Mr Jack: They do not go to the Council of
Ministers, do they?
Lord Whitty: If you will allow me, the issue in
Europe is that they are dealt with largely on the
Agriculture Council.
Q661 Mr Jack: Ah, so you are responsible for
labelling?
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Lord Whitty: Our ministers are responsible for
negotiating in Europe but we are responsible on the
basis of briefs from the FSA.
Q662 Mr Jack: That sort of brings us round full
circle from my first line of questioning. When you
are deciding policy, give us a flavour as to how the
policy responsibility in government is lined up to
decide what the Defra line to take will be in the
discussions in the Council of Minister on these
labelling issues. Who are the people who input to
you? Who is in charge of policy in this area?
Lord Whitty: If there is a proposition for a new
directive, for example, from Europe, which there is
currently, as you rightly say, in relation to labelling,
then the FSA are the lead department to gain the
cross-departmental view within Whitehall. So they
would lead the consultation with other government
departments in Whitehall on the proposition coming
from the Commission or being proposed by the
Commission. That would be agreed. We would feed
into that, as would other departments, but we would
feed into that in the light of our sponsorship and our
view on where the industry should be going and the
impact, detrimental or positive, this might have on
the industry. So we would feed into that. There
would then be the normal Cabinet OYce writeround and we would hopefully reach a consensus
position which would then be taken away in detail by
the FSA who would be producing a brief so that
when it actually arose it would be FSA oYcials who
would be in contact with the Commission oYcials
and by the time it reached the Council the FSA coordinated brief would be the basis on which the
Secretary of State, or I, or whoever is representing us
at the Council, would deal with it.
Q663 Mr Jack: Given that the process on the new
labelling regime has begun, what in summary is the
Defra input to the FSA voices-gathering exercise in
government? What is your department’s view on the
current line of thinking in the Commission?
Lord Whitty: There are two or three diVerent
dimensions to what the Commission is currently
proposing. There is the issue of nutrition and health
claims. Obviously, the Department of Health has to
make a decision on whether it is desirable to have
nutritional aspects labelled in this way, but we would
then qualify that by saying: “Is it possible, with this
product, to identify quite so clearly the nutritional
value or otherwise? Is it detectable? What is the
science of the issue”—because we are, by and large,
responsible for the scientific basis of not all such
claims but of how we produce the food. I suppose,
summed-up, it is the practicality of propositions in
terms of how all levels of the industry should display
the information. Our view is really on that
dimension rather than do we second-guess the
Department of Health on whether milk is good for
you or not?
Q664 Mr Jack: What I am just ever so slightly
struggling with, because the input of the United
Kingdom is very important on this, is who has got
the ultimate, if you like, veto on the Government’s
position? The FSA gather the information, you have
just indicated that on health claims the Department
of Health has a view and then you have a view on the
sort of measurability side of these matters. The Food
Standards Agency’s reporting line is to health
ministers (that is who they are answerable to) and yet
you are leading, as a department, on the Council on
all of these issues.
Lord Whitty: By the time it reaches the Council there
will be a cross-government position which will have
taken into account our views on the practicality. It
is not just the measurability it is also how you label
things—whether it is a reasonable burden on the
industry to provide that degree of information,
whether it is comprehensible to consumers and
whether it actually conveys the information that it is
intended to convey—and we will have views on all of
those things. There will be a cross-departmental
view on that informing the position that we take
when the issue comes to Council, which is pretty far
down the process.
Q665 Mr Jack: Do you have any specialists with
Defra who guide you? Are you the minister that goes
to the Council?
Lord Whitty: Not generally, the Secretary of State
normally goes.
Q666 Mr Jack: So within Defra does she have a
group of people who are providing her with a
uniquely Defra-based perspective? If she has to go
and discuss with the Secretary of State for Health the
evidence that comes from the Food Standards
Agency, I presume she must have some advice that
comes from somewhere within Defra. Is there a
group which works on these matters?
Lord Whitty: Not in that sense. The implication of
such proposals coming from other government
departments or indeed from Europe for the industry,
clearly, there are experts within the department who
can advise on it. There are some areas where we are
the experts. There are some areas, like, in fact, in
veterinary medicines, plant health and animal health
related issues, and some other things like quality of
fresh fruit, where we actually also are the experts,
but in general it is our view on the impact of these
proposals on the industry, which includes the impact
on the industry’s consumers.
Q667 Chairman: How do you avoid any
discontinuity between what is being said at oYcial
level by an independent agency and then by
ministers politically at the Council level? It is quite
an unusual situation, is it not, compared to other
areas of government responsibility, if it is an
independent agency, eVectively, representing the
UK at oYcial level?
Lord Whitty: The independent agency may or may
not be accompanied by Department of Health
people. I do not think it is particularly unusual. The
Environment Agency are quite often in the same
position, as are the HSE.
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Q668 Joan Ruddock: I am interested to know if the
pathway by which the UK Government decided to
support 0.9% contamination for GM labelling was
the same. Did that begin with the technical advice of
the FSA?
Lord Whitty: The advice of the FSA in that respect
was two-fold. One: is there a safety issue involved
here and, two, is there a consumer issue involved
here? The FSA view is that provided the GM
products have gone through the process it is unlikely
there is a food safety issue. Nevertheless, on the
consumer issue it is very clear that consumers want
to know whether the products contain GM or not.
Our position on this was (a) we are responsible for
looking at the environmental eVects of GM in
relation to crops and (b) we are responsible for
seeing whether any standards which are set are
actually enforceable. So our view was that when
people were calling for a 0.1% rate, that would not
actually be enforceable because at those kinds of
levels it would be pretty diYcult to detect whether it
was 0.1 or 0.2, whereas at 1% or thereabouts this was
eminently detectable on current technology. So our
view was, again, in relation to the practicality of the
regulations and how they would be enforced in the
industry or in the enforcers.
Q669 Joan Ruddock: I apologise for contradicting
the Minister but, of course, 0.1% is the detectable
level and it is the one that most supermarkets adopt.
So as far as I understand it, the practicality is in no
way in dispute; 0.1% can be policed, and that would
be the desire of consumers. It was a very strange
decision for many consumers that the Government
did go to 0.9%.
Lord Whitty: There are diVerent stages of being able
to detect it. Clearly, if you have a boat-load of soya
landing from, say (let us not say the United States),
Brazil, which may or may not contain it, then the
actual sample you take is unlikely to be able to detect
0.1% with any degree of accuracy. If you are talking
about in single products then it is likely to be higher,
if you are talking about highly processed goods then
it is probably not detectable at all. There are
diVerent levels of detectability, but 0.9% is not a
particularly totally robust figure, in that you are
saying 0.8% is not detectable and 1% is, but it is
roughly the area where for most products you could,
under existing technology, find whether there was
GM presence or not.
Q670 Joan Ruddock: Is it not a fact that when
supermarkets claim for their own products that they
are “GM-free” they are actually saying that this is a
product that does not have more than 0.1% GM in
it?
Lord Whitty: That is what they claim to say, yes, and
they do that by ensuring they know the sources and
that therefore they know that their soya milk, for
example, is produced by non-GM soya farmers and
they would say that the chances of contamination
are pretty unlikely. However, when you are coming
to regulate, you have to have a higher degree of
accuracy there because, if you breach the regulation,
then there is a sanction and the sanction can only
really apply if you have proof and, in general, the
technical advice to us would be that you could not
get proof much below 0.9%.
Q671 Mr Drew: What consultation did the FSA
undertake before it came up with the advice that it
gave to both yourselves and the Department of
Health? Did they undertake a major consultation
exercise?
Lord Whitty: Are we talking about on the GM?
Q672 Mr Drew: Yes, on the GM.
Lord Whitty: Yes, certainly, quite a number of times
in the period up to 2003 when the regulations were
adopted, certainly in the previous two years.
Q673 Mr Drew: I think it is a fair presumption from
all the evidence that I have seen in terms of opinion
polling that the public would have wanted the lower
threshold rather than the higher threshold.
Therefore, on what grounds did the FSA decide that
it was satisfactory to go for a higher threshold? I
understand that they may have actually given the
advice to say, “Ministers, there are two thresholds
and here are the reasons for both of these”, but they
actually came down in favour of the 0.9% threshold.
Lord Whitty: The FSA are working on the same
basis as us, that regulations have to be enforceable.
I have no doubt that you are right, that consumers
would by and large like to know, “Is this GM or is it
not?” but, when you are making a regulation, you
have to ensure that any breach of that regulation can
be proved and that the sanction is therefore
not challengeable. Some of these were joint
consultations between ourselves and the FSA, but
both of us would say that good regulation requires
any breach to be detectable or indeed compliance to
be detectable and, if it is not, then it is not good
regulation.
Q674 Joan Ruddock: Is there not a proposal for 0.5%
for seeds? How is that going to be policed if it is
not possible?
Lord Whitty: Seeds are a single product. None of this
is 100% statistically accurate but it is easier to detect
out of a bag of seeds whether there is 0.5% when they
are an homogenous product than when it is a whole
boatload of soya which may well have come from
several diVerent sources or a processed product
which will include ingredients which are from several
diVerent sources and probably from several diVerent
countries. I may be wrong and I will check on this
but I think that 0.5% is a figure which has been
included for other things/seeds regulations.
Q675 Chairman: I think this last exchange illustrates
one of the issues which has come up a number of
times in our inquiry which is the wide range of
messages that consumers get about food and from a
range of sources leading to the question of, who
should consumers trust when they are trying to reach
conclusions about what we should be eating? One of
the witnesses has said that they did not trust
Government and that they were not too keen on a
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number of other possible sources of advice as well.
What is your view as to how this issue should be
addressed and, more specifically, how far should
Government be taking the lead in trying to bring
about reasonably clear and consistent messages to
consumers?
Lord Whitty: It is pretty clear that they do not trust
Government, they do not trust scientists and they do
not trust the agriculture sector, they do not trust the
food manufacturers and they do not even trust
the newspapers. They trust slightly more the
supermarkets and that is because they think that
they oVer eVective assurance schemes and that, by
and large, those respectable purveyors of food—it is
not a particularly logical position—have a standard
themselves that they enforce for their own
commercial interests and because they want to serve
their consumer interest well. That is why it is so
important that messages are not just regulatory
messages, that they are well beyond regulation, and
that there is a degree of consensus about what kind
of messages you hope to put across because most of
the messages that impact on people would not be the
minutia of the EU labelling standards or even the
actual labels themselves, they will be the advertising,
the way things are presented in the shops, the way
they are presented on menus and the way they are
presented in other literature which the industry
create and that does mean that you have to have
established probably a greater degree of consensus
on these things than yet exists and part of the process
of the Public Health White Paper in food dimensions
is hopefully going to create a greater consensus
around, broadly speaking, the balanced diet
approach and the information that is needed for that
can then be followed through. You are certainly
right that if you rely on the Government giving the
information, then that is not necessarily the most
trusted form of information to the consumers.
Q676 Chairman: To take one example of how
information can be presented to consumers, we have
heard a great deal of discussion, of which you will
obviously be aware also, on the possible
introduction of a traYc light system of labelling.
What is the view within Defra on this at the moment?
Lord Whitty: There are some diYculties about the
traYc light system. Tesco have adopted it; I think it
is a useful initiative and we ought to see how well it
works in both senses as to how much information
they can convey through it and what the actual
consumer behaviour in response to that is. So, whilst
we are not sponsoring what Tesco are doing, we do
think it is a very useful attempt to try and convey
information in a way which is more understandable
than perhaps historically we have managed.
Q677 Chairman: How far can this be done on a
consensus basis and a voluntary basis amongst the
retailers for example because again one of the pieces
of evidence that we have had has pointed out that, if
there was an inconsistency in message, then
consumers would not understand the message when
it came from diVerent quarters? So, if it is going to
work, there have to be schemes, be it traYc light or
anything else, which apply across large parts of the
sector. Is that not one where there is a role for
Government?
Lord Whitty: I would agree with you but there are
admissions against this. Even on five a day, the
supermarkets have tended to try and present it in
slightly diVerent ways in their own slogans. Now,
that is the market. As long as broadly speaking they
are doing the same message, then it is not too bad
but, if we were to introduce an across-the-board
traYc light system, it would be necessary that all
retailers had pretty much the same kind of concept
of what the traYc lights meant and, if you try and do
that without regulation, it is actually quite diYcult
because one can get it at Tesco at the moment and
presumably one can see a competitive advantage in
them being the traYc light merchants for the
moment. If we were to regulate on it, we would have
to be much more specific. The other way of getting
it across the board, particularly in relation to fresh
produce, is assurance schemes where there is some
progress made in terms of the red tractor and other
indications of assurance. At the moment, the
assurance that the consumers by and large trust most
is the very fact that it is on the big supermarket
shelves because they think that actually of itself
conveys assurance, but there are substantial areas
where assurance schemes could play a bigger role in
raising public awareness about the safety of food,
particularly maybe in the dietary eVect of it.
Q678 Chairman: Whether it is a traYc light system
or another form of labelling standard or whether it
is assurance schemes, should there not be a role for
Government to be taking the lead in trying to bring
about those standards, be it by a regulatory—
Lord Whitty: If it is regulatory, it would have to be
an EU body and of course one of the options under
the current EU discussions is whether there should
be an EU traYc light scheme or at least an EU green
light system. In terms of providing information,
clearly the FSA would be in the lead here but the
FSA are in a position and it is part of their mandate
to produce information and guidance to everybody
in the food trade as to how they should convey
information about their food, so there is a
Government educative and advisory role, if you like.
Q679 Mr Jack: Does Defra think that traYc lights
are good or bad?
Lord Whitty: There is not an answer to that. We
think that greater clarity of message would be
helpful. If the traYc light system can convey that
accurately and people respond to it, then they are
good.
Q680 Mr Jack: If you were pressed to try and define
a traYc light system that you could endorse, what
would its characteristics be?
Lord Whitty: The problem is that traYc lights may
apply to diVerent things. You can have a traYc light
system in salt content or you can have a traYc light
system in fat content but it is diYcult to have a traYc
light system which conveys everything that we would
want people to understand about a balanced diet.
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Therefore, if people are looking already to limit their
fat content or their salt content, then a traYc light
system could be very helpful but it is not going to say
how much of this bit of medium salty bread should
I have as compared with vegetables and as compared
with roast beef a week. It is diYcult to convey that
through a traYc light system.
Q681 Mr Jack: Can I just ask you about assurance
schemes; you put particular weight on that. Do you
think that they are a good way of communicating
messages about the nature of the way that food is
produced bearing in mind that many of the
assurance schemes we have come across seem only to
indicate an adherence to minimum statutory
standards and do not in any way relate to the quality
or other attributes of the food produced but
sometimes the logos that are used seem to convey
lots of those extra bits of information together with
country of origin messages and therefore the logos
go beyond a simple point of reassurance? Are you
happy with that?
Lord Whitty: Certainly the red tractor is intended to
convey not only the way that the food is produced
and the compliance with minimum standards but
also that it has been produced from a farm which has
been properly inspected and which meets those
standards and, by and large, that is a standard which
people are beginning to recognise. There are other
series of standards, for example leaf or freedom
foods, which convey other aspects of how food is
produced and which probably have a more limited
segment of the consumers who relate to them. One
could argue that the organic label was similar but is
one that is subject to a higher level of standard if you
like, so there is not a single standard that is going to
actually convey all the information but the
comprehensiveness for fresh food of a clearer and
recognisable standard for the basic level of quality
and quality production is important and that is
where red tractor is trying to go. The higher level
standards are also, by and large, not yet suYciently
recognised by a large enough section of consumers
to have achieved the ratcheting up, if you like, of
quality standards, but I believe that they will be there
and that, with increased consciousness, they will
make a contribution. If you are asking me if
assurance schemes can convey a balanced diet, then
the answer is “no” anymore than a single
dimensional traYc light system can.
Q682 Joan Ruddock: I want to turn to the WTO and
the negotiations that the EU is having in relation to
Article 2.2 which we know is about not having
barriers to trade. The argument has been put that
mandatory labelling in the context of the WTO can
be seen to be a barrier to trade. How successful are
we being within the EU in trying to persuade other
countries of our point of view which is that
mandatory labelling is an important aid in itself and
should not be seen as an anti-competitive measure?
Lord Whitty: I think that, in general, we are up
against a diYculty. The EU has established that they
would wish to preserve their labelling system and
indeed enhance some, as is currently under
discussion. In the WTO’s negotiations, the
European Commission has actually tried to keep the
concept of mandatory labelling of foods in play for
the negotiations. It has to be said that almost all the
other negotiating partners are in some diYculty on
this and do regard it certainly beyond pure safety
issues as being a form of hidden protection and that
the other partners to the WTO may well see that this
is an EU attempt to introduce further protection by
the backdoor. The current position is that it is part
of the EU’s negotiating mandate. There are aspects
of mandatory labelling which could lead us into
protection and therefore the UK within the EU is
careful to try and ensure that we do not get into that,
but those negotiations still have to take place. You
will probably know that the latest development is
that there is a new framework which has been
produced only last Friday, the full implications of
which I am not in a position to tell you, but the idea
is that that will go to the WTO over the next few days
for the WTO General Council on I think the 29th of
this month and that we would therefore have a
framework for further negotiations on the
agriculture chapter of the WTO. Whether that
occurs before or after the American elections and
various other changes is not for me to decide but
there are some developments on what we are going
to discuss in the WTO which will need updating
within the next fortnight.
Q683 Joan Ruddock: It does not sound all that
helpful. There has seemingly been a move and this is
of course again where we caught on the GM issue by
the WTO arguing very narrow Sanitary and
Phytosanitary regulations rather than the wider
issues and there is a great concern amongst those
who have given us evidence that we could see
ourselves going into a position where we cannot give
our consumers what they are demanding
particularly, for example, on ethical issues.
Lord Whitty: I think that is probably true. If you
make the labelling mandatory, then we do run the
risk of there being a WTO beyond the safety issue.
The Codex Alimentarius is recognised in the WTO
structure, so the safety issues—and those are
increasing all the time—are protected but, if you go
beyond that, then there are potential WTO cases like
the GM one.
Chairman: Lord Whitty, thank you very much. That
brings us to the end of our questions this afternoon.
Your evidence has, once again, been most helpful
and that now concludes the meeting of the
Committee this afternoon.
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Written evidence
Memorandum submitted by the British Soft Drinks Association Ltd (BSDA)
BSDA represents the collective interests of UK manufacturers and distributors of soft drinks, including
carbonates, still drinks, dilutables, fruit juices, juice drinks and bottled waters. The total sales value of the
market in 2003 was worth £11 billion and the industry directly employs about 19,000 people. The industry
is dedicated to providing a wide range of choice so that individuals can construct a balanced diet which
includes adequate fluid intake.
1. Introduction
1.1 BSDA fully supports the provision of clear information to consumers so that they are in a position
to make informed choices.
1.2 Information may be supplied through a variety of means:
— pack labelling;
— advertising;
— promotional activity;
— other information sources, such as customer care lines and websites.
1.3 On-pack labelling: this is the foremost means of supplying consumers with full information about
products. It is a highly regulated area to ensure that consumers are not misled; that they understand the true
nature of the product; and can store, prepare and consume the product safely by the “use by” or “best
before” date. The label also carries important information in relation to the manufacturer and batch
numbers so that any post-sales problems or complaints can be eVectively addressed.
1.4 Advertising and Promotion: are designed to inform consumers of the availability of a brand on a
highly competitive market place. They do not necessarily have to carry all the statutory information required
on food labels but must nonetheless conform with the Codes of Practice relating to advertising and the
relevant provisions of legislation relating to the labelling, promotion and advertising of food. Advertising
and promotion assist market competition and the launch of new products. They contribute to competitive
pricing, the development and maintenance of high standards, the development of new products: all these
are of benefit to consumers.
1.5 Other Information Sources: customer care lines and websites are other key sources of information
for consumers.
1.6 BSDA oVers primary and secondary schools an educational resource pack, Liquids Mean Life, which
is designed to inform children about the production and marketing of soft drinks, including fruit juices and
bottled waters, environmental considerations and the importance of fluid intake
2. Efra Questions
2.1 Information on the nutritional content of foods
2.1.1 BSDA supports the provision of clear and meaningful on-pack nutrition information so that
consumers can choose products suitable for their needs and tastes. It believes that the current legislation is
not necessarily appropriate for drinks, particularly when these contain only certain nutrients. The result is
that nutrition panels can be cluttered with zeros which confuse rather than inform. The industry also believes
that it is more helpful to provide nutrient information per serving, ie in the quantity the consumer is likely
to consume, rather than per 100g/ml which might not be a standard portion size particularly where fluids
are concerned.
2.1.2 DiVerences in normal serving sizes between solid and liquid foodstuVs must also be taken into
account when requirements are set for the addition of vitamins and minerals. The definition of “significant
amount” should be appropriate to a realistic quantity consumed and, again, not fixed per 100g/ml.
2.1.3 The Food Standards Agency has been reviewing appropriate criteria for nutrition labelling and
BSDA recommends that it bases its review on clarity and key information. FSA has considered
“signposting” foods but it remains essential that information is suYciently factual and placed within the
context of a balanced diet if nutrition messages are not to be over-simplified to the point of confusion. If
FSA wishes to influence people’s dietary choices then this is most eVectively achieved through public
education and not by manipulating choice through food labels.
2.1.4 Consumers are becoming increasingly interested in the functionality of foodstuVs and the soft
drinks industry wishes to label products so that specific nutrient or health benefits can be communicated.
The industry has no intention to mislead or misrepresent products and believes that all claims must be
substantiated. Nonetheless, providing essential safety and labelling provisions are respected, it believes that
all foods should be permitted to carry justified nutrition or health claims.
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2.1.5 Soft drinks in the UK have been fortified for more than one hundred years and have been
appreciated by generations of consumers. They enable people, particularly certain segments of the
population, to enhance nutrient intake through the foods which they normally eat and enjoy. BSDA is
concerned that, should restrictions be placed on the ability to make nutrition or health claims, that fortified
products might be curtailed to the detriment of consumers.
2.2 The Safety of foods
2.2.1 Food safety should be every manufacturer’s foremost priority. It is the producer’s responsibility to
produce safe food with the label providing information to the consumer so that it can be consumed safely.
It is very important that the consumer understands the importance of storing, preparing and consuming
food safely and, in addition to providing the legal framework for production standards and enforcement,
Government needs to ensure that consumers receive adequate advice and education.
2.2.2 It is also crucial that Government support the regulatory framework for food safety and inspire
public confidence in this framework in its communications. For example, when questions arise about the
safety of additives which have been authorised for use in food, it would be judicious for the Food Standards
Agency to confirm their safety in use. This would help to educate consumers and allay fears which often
arise from ignorance. The lack of clarity in oYcial statements—or the absence of any statement—allows
concerns to proliferate without justification.
2.2.3 Risk communication is another area where Government should review its approach. There is little
point in public pronouncements which are meant ostensibly to allay concerns about risk and then suggest
that consumers might choose not to consume the food in question. This is gratuitous, ambiguous and raises
doubts that food is safe. Food choices are always up to the consumer and there is no need to state the
obvious: it is Government’s role to assess and manage risk.
2.3 The means of production
2.3.1 Providing information on means of production can be useful to consumers in making food choices.
However, it is crucial that there are agreed uniform and meaningful definitions for these terms and that these
are understood by consumers. Where use of the term “organic” is concerned, BSDA believes that the setting
of standards and certification procedures should be harmonised and delegated to a single, impartial entity.
As things stand, diVerent certification bodies set diVerent standards which means that the term “organic”
has no uniform meaning.
2.4 Ethical considerations
2.4.1 BSDA has participated in the development of a Code of Practice in relation to Ethical Trade in fruit
juice which is now being piloted by the European fruit juice industry’s raw material assurance scheme. This
is designed to demonstrate the industry’s commitment to Corporate Social Responsibility and to promoting
good labour practices in countries which provide raw materials. Such schemes are not easy to implement or
enforce and have to take account of the prevailing economic conditions in the country concerned.
Nonetheless, is it the intention to address consumer concerns in the EU about labour standards and,
importantly, contribute to the improvement of standards.
2.5 Trade in food
2.5.1 As far as possible, BSDA wishes to have internationally harmonised rules for food labelling so that
foods can be traded without hindrance. It is nonetheless recognised that foodstuVs and their denominations
can vary from country to country and that international uniformity is neither possible nor necessarily
desirable. Supplementary labelling should be considered acceptable in order to provide consumers with
appropriate information to make purchasing choices. This could avoid barriers to trade caused, for
example, by national compositional standards.
2.5.2 One area of particular concern to BSDA is the language of labelling and the consumers’ ability to
make purchasing choices if a food is not labelled in a language which they understand easily (as specified in
UK and EU labelling law). This is particularly important for consumers who wish or need to avoid certain
ingredients and for them to understand important information such as best before dates, conditions for
storage and safe consumption and contact details for the person responsible for putting the product onto
the market. UK Courts have ruled that products sold in the UK should be labelled in English and BSDA
would like UK regulators and enforcement agencies to take stronger action against imports which are not
labelled correctly. Whereas UK manufacturers are subject to strict control and expected to withdraw
products which are improperly labelled, the same standard is very seldom applied to imports. Crucially, the
Food Standards Agency needs to explain how it would deal with the recall of products in the event of a safety
issue when the name of the distributor is not known and brands have been imported without the consent of
the brand-owner.
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3. Final Comments
3.1 The labelling, advertising and promotion of foods are highly regulated and subject to frequent
amendment. Often manufacturers are criticised for the way food is labelled when they are actually
complying with what has been prescribed by the regulator. It is therefore important that the regulator:
— educates consumers so that they can understand food labels and use the information to make
informed choices;
— recognises that the amount of information which can be included on a label is finite and that
information can be provided by other means;
— takes account of consumer requirements and understanding when devising new rules;
— seeks to enforce existing rules rather than introduce yet more rules to compensate for inadequate
enforcement;
— has an adequate evidence base to justify proposed measures;
— ensures that labelling rules are coherent and meaningful to consumers;
— subjects proposed labelling changes to a cost-benefit analysis.
On a practical note, industry would urge Government to synchronise labelling changes so that these can
be introduced rationally, cost-eVectively and with adequate lead-time.
2 April 2004
Memorandum submitted by the British Medical Association
We have been concerned for some time about the need to clarify and regulate health claims made by food
manufacturers throughout Europe, in order to increase consumer protection and choice.
The BMA strongly advises that accurate food labelling and clear information is imperative so that the
public can make informed choices about their diet. Both nutritional and content claims on labels, and
functional claims on packaging and in advertising, need to be addressed. All claims need to be assessed from
both the generic food category level and the specific product level. Claims must be clear and unambiguous,
specific rather than generalised, and accurate and verifiable.
Accurate and clear information must not be limited to the labelling of products. Information can be
presented in many formats, including leaflets and posters, newspaper, television and radio advertisements
and information on the internet. Complete information on advertised products should be made available,
for example the full nutritional facts regarding convenience foods should be communicated to consumers.
The BMA believes that regulations must apply to all traders, suppliers, manufacturers, caterers, agencies,
retailers and importers of foods. They must be adequately policed and monitored by a regulatory board such
as the Joint Health Claims Initiative. Manufacturers should submit scientific evidence to support their claim
and Europe-wide guidelines should be set on what constitutes acceptable evidence. For example, the
scientific evidence should be independent and peer reviewed by a panel of experts. The involvement of health
professionals, including nutrition experts and physicians in various relevant specialities, is vital to assess
evidence and provide advice. Claims should be assessed on a case-by-case basis and extrapolations to similar
claims should be avoided.
6 April 2004
Memorandum submitted by the National Youth Agency
Executive Summary
The National Youth Agency supports those involved in young people’s personal and social development
and works to enable all young people to fulfill their potential within a just society. The Agency welcomes
the Committee’s inquiry into many aspects of food production and labelling and education on nutrition,
particularly with regard to the needs of young people. Our submission reflects our concern about the
growing problems of poor nutrition, the issue of industry regulation and the long-term health and societal
implications of obesity and limited exercise.
Our response focuses on three main areas:
1. The need to involve young people from the outset in devising approaches and educational programmes
which will help frame the issues in contexts which have meaning for their daily lives. In rural areas, some
young people will be able to contribute their personal experiences of modern farming practices and the
implications for health and the economy.
2. The importance of seeing the food and nutrition issues as components in the larger health and wellbeing agenda. Much evidence points to the ineVectiveness of isolated interventions which do not take
account of wider issues such as food poverty (the cheapest and most filling foods are often those made of
poor raw materials, high in sugar, fat and salt), poor education in nutrition and poor examples of food
provision in the public sector (eg schools, leisure centres), and lack of opportunities for young people to buy,
prepare, cook and eat nutritious meals. In addition, there are fewer and fewer places and spaces for children
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and young people to play and take exercise, yet evidence indicates that the rising tide of obesity requires
action both on consumption and physical activity. Recent medical and other research indicates the huge
benefits of young people drinking more water on their health and educational achievements. We urge the
provision of water coolers and dispensers in public buildings and spaces.
3. A more robust approach from government on meaningful food labelling which puts ingredients in the
context of recommended daily allowances (eg “This pasty contains 90% of your daily salt requirement and
exceeds the RDA for fat”) and clarification of what labels like “low fat” and “low salt” mean for a healthy
diet, coupled with hard-hitting public education campaigns akin to those for smoking cessation. Education
about ethical issues in food production, food miles, genetic modification of crops etc should be included
in the school curriculum and clear labelling with generic symbols should inform the consumer about the
provenance, growing and manufacturing processes of the food. Such information should be included on
wrappings for fast food in an easily accessible format.
15 April 2004
Memorandum submitted by the Biscuit, Cake, Chocolate and Confectionery Association (BCCCA)
Summary
— Owing to space constraints on labels, and varying levels of interest among consumers in complex
information, food labelling cannot be clear and comprehensible if at the same time one attempts
to make it comprehensive.
— Food packs are already legally required to carry a great deal of information. This, together with
brand names, promotional information and non-statutory warnings, puts great pressure on space.
— Forthcoming changes in EU requirements will increase this pressure.
— Over 80% of this industry’s products carry nutrition labelling. The BCCCA has recommended to
members that all products should carry at least the “Big 4”: energy, protein, carbohydrate and fat.
Some manufacturers provide more than this.
— If the EU decides to introduce mandatory nutrition labelling it should limit the list of nutrients (to
perhaps six) and should permit amounts per serving or per pack—instead of per 100g—on smaller
products.
— Many other proposals for information to be included on packs are impracticable and should be
resisted.
— Providing information in respect of ethical concerns requires a diVerent approach.
— Labelling requirements impose costs which ultimately tend to be passed to consumers, especially
on low-margin products.
— Labelling requirements should not act as a barrier to free trade.
— Pressure on space will make multi-lingual labelling very diYcult, potentially harming British
exports.
Introduction
1. The Biscuit, Cake, Chocolate and Confectionery Association (BCCCA) welcomes the opportunity to
provide evidence to the Committee’s Inquiry into Food Information. Although the Committee’s terms of
reference are broad, the BCCCA has confined its evidence to matters of particular concern to its members:
food labelling; other means of informing consumers; information about sourcing of raw materials; and
(briefly) the impact on WTO negotiations.
What Should Food Labelling be Seeking to Achieve?
2. The argument is sometimes heard that food labelling should be “clear, comprehensible and
comprehensive”. In fact, those are incompatible criteria. Space on labels is limited, especially on labels for
small products like standard size bars of chocolate, or roll packs of sweets. It would be impossible to provide
comprehensive labelling in such a small space. Even where space is less of a problem, many consumers would
be unlikely to want or to read, or take in, large amounts of information.
Information Already Provided on Labels
3. It is already a legal requirement that all labels should carry the following information:
— The name of the food.
— A list of ingredients, including additives.
— The quantity of certain ingredients or categories of ingredients (the so called QUID rules).
— The appropriate durability indication (eg “best before . . .”).
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— Any special storage conditions or conditions of use.
— The name, or business name, and an address or registered oYce of either, or both of, the
manufacturer or packer, or of a seller established in the EC.
— Lot marking to enable recall in the event of accident or contamination.
— Specific requirements for particular products—eg the Chocolate Directive requires a declaration
of cocoa solids and a statement alerting consumers when chocolate contains other vegetable fats
in addition to cocoa butter. Products containing certain sweeteners must carry statements “with
sweeteners” or “with sugars and sweeteners”. Food containing aspartame must additionally carry
the words “contains a source of phenylalanine” and food containing more than 10% of added
polyols must be labelled “excessive consumption may produce laxative eVects”.
— A weight statement for packs above 50g.
4. For a small pack, that is already a lot of information to provide in the available space. Additionally,
there is key information that the manufacturer needs to get onto the product and space must be found for
that. This includes:
— The brand name—research has demonstrated that this is usually the first thing that consumers
look for. Most food products are bought as repeat purchases by consumers who use the brand
name as an indication of the product’s quality and value for money.
— Claims—for example if a product is reduced fat or sugar-free it is important to alert consumers.
Where claims are made, nutrition

Food information - Publications.parliament.uk

Transcription

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