Food Law News - UK - 2010

FSA News Item, 5 March 2010

NUTRITION LABELLING – FSA Publishes Proposals for Enhanced Front of Pack (FOP) Nutrition Labelling

The Agency has today published a paper, which will be discussed at an open Board meeting next week, setting out proposals for front-of-pack (FOP) nutrition labelling. The Agency is proposing a flexible approach to implementing a single front-of-pack label to help consumers make healthier choices when they buy food.

In March 2006 the Agency recommended a set of principles for FOP labelling that would help consumers easily understand the levels of fat, saturated fat, salt and sugars in food products. Currently, the majority of UK food manufacturers and retailers are voluntarily using FOP schemes.

The various FOP labels being used meet some or all of the Agency’s existing recommendations in how the amount of each nutrient (fat, saturated fat, salt and sugars) is displayed. Some schemes also use colours other than the Agency’s recommended 'traffic lights' or use colours as a design feature simply to highlight the different nutrients: for example, green for fat and yellow for salt.

An independent evaluation of the effectiveness of these schemes was published in May 2009. This robust study found that the co-existence of different FOP labels confused consumers. It concluded that the words ‘high, medium and low’ were understood best, and combining this text with traffic light colours and percentage Guideline Daily Amounts (% GDAs) would enable more people to make healthier choices easily. However, consumers in 'citizens’ forums' subsequently run by the Agency, particularly liked traffic light colours as an 'at a glance' cue. In the light of this evidence, together with feedback from a public consultation, the Agency has developed proposals to implement a single approach to FOP labelling.

The Board paper proposes that the way information about the amount of fat, saturated fat, salt and sugars in a product is presented should use three elements: traffic light colours, text and % GDAs. Some companies are already using this approach whereas others are using FOP schemes that provide some of these elements. To assist the transition to this single approach, some flexibility has been included within the proposals, which allow a minimum of two elements be used initially.

Tim Smith, Food Standards Agency Chief Executive, said: 'This approach is all about what consumers have told us they want. Independent research and citizens' forums told us that people were confused and wanted a single approach developed by government. We also appreciate and understand that food businesses are starting from different positions. Our proposals respond to what consumers want but also provide some flexibility for business.'

The FSA Board will discuss these proposals at its open meeting on 10 March in Cardiff. Following the Board’s decision, the Agency will then formally submit its recommendations on FOP to Health Ministers.

The following is the main element of the Board Paper.  There are a large number of supporting Annexes.  A copy of the full paper is available on this site.  See: FSA Board Paper – FOP Labelling


1. The Agency has been considering what more can be done to deliver a single effective approach to front of pack (FOP) labelling which assists consumers to make healthier choices. The Agency has taken into account the findings from the independent FOP evaluation research, the consultation with stakeholders and citizens’ forums held on this issue. The Agency also sought to convene a high level stakeholder meeting to discuss the matter further. However, due to the short notice of calling the meeting, it was not possible to secure attendance from all the senior executives from organisations with a direct interest in the issue.


2. Since the Agency made its recommendations on FOP labelling in 2006 a number of manufacturers and retailers have voluntarily introduced FOP labels. Given the co-existence of different FOP schemes in the UK marketplace, new information on how consumers understand and use them, legislative developments at an EU level, and the UK Government’s commitments in relation to FOP labelling it is necessary to review the Agency’s recommendations to Government.

Strategic Objectives

3. Meets the Agency’s commitment in the new Strategic Plan for 2010/2015 to “promote the adoption of a single, simple and effective FOP labelling approach”.


4. The UK Government has developed a programme of work to reduce obesity, improve diets and reduce the prevalence of diet-related diseases, such as diabetes, coronary heart disease and some cancers.

5. The 2004 White Paper: Choosing Health for England and Wales (see Note 1 below) included a commitment to address the difficulty many consumers have using nutrition information as currently provided on food labels (see Note 2 below) by commissioning the Agency to work with industry to develop, by 2006 ‘ a clear, straightforward coding system that is in common use, and that allows 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 ’

6. The Scottish Government recognises the importance of enabling consumers to make informed choices at a glance about the food they eat (Healthy Eating, Active Living: An action plan to improve diet, increase physical activity and tackle obesity (2008-2011)). The Welsh Assembly Government's Quality of Food for All strategy calls for better nutritional labelling, and the Northern Ireland 'Fit Futures' health strategy note the importance of FOP nutrition labelling in enabling consumers to choose healthier diets.

7. More than 130 UK food manufacturers and retailers have voluntarily introduced FOP labelling. While there is much in common in terms of the information they provide, they differ in the way in which the information is presented. There are currently four main types of FOP schemes in use in the UK (Annex 1):

8. In light of these developments and the consumer’s desire for a single FOP approach the (Westminster) Government obesity strategy document Healthy Weight Healthy Lives included a provision within the Healthy Food Code of Good Practice that called for:

“A single, simple and effective approach to food labelling used by the whole food industry, based on the principles that will be recommended by the FSA in light of the research currently being undertaken”.

Independent FOP Evaluation Research

9. The independent evaluation research published in May 2009 found that the coexistence of FOP labels with differing interpreting elements was causing a degree of confusion and distraction for the UK consumer (see Note 3 below). It suggested that the use and comprehension of FOP labelling could be improved if a single FOP approach was used in the marketplace and concluded that a format which incorporated „high, medium and low’ text, traffic light colour coding and percentage of Guideline Daily Amount (GDA) was the format which best enabled consumers to make healthier choices. The Board was briefed on the findings of this research in June 2009 (See Note 4 below).

FOP Consultation

10. On 30 July 2009 the Agency launched its formal stakeholder consultation on the practical issues which need to be resolved for a single approach to FOP nutrition labelling to work in real life settings and help consumers to make healthier choices (Annex 2). A total of 96 responses were received from a range of stakeholders including industry, consumer groups, public health bodies, enforcement bodies and members of the public and the advisory committees in Scotland and Northern Ireland (Annex 3). A summary of the consultation responses received can be found at Annexes 4 and 5.

11. Many respondents chose to comment on wider issues relating to FOP labelling as well as the technical issues and the draft Impact Assessment on which views had been sought. A number of responses made reference to a critique of the independent FOP evaluation research commissioned by the Food and Drink Federation (FDF) and questioned some of the conclusions in the independent FOP evaluation research. The comments raised, together with the critique and a response from the contractors who conducted the research, are attached at Annex 6. On the issue of a single FOP approach responses generally fall into one of the following three groups:

12. Very few comments were received on the draft Impact Assessment (IA). Those who did respond on this point considered the cost of introducing a single approach had been underestimated and some additional figures (e.g. for design and plate changes) were provided (Annex 7). The draft IA has been adjusted accordingly.

Citizens’ Forums

13. The Agency commissioned eight „citizens’ forum workshops within the UK to learn about consumers’ relationship with food labels, their awareness and understanding of FOP nutrition labelling (see Note 5 below). FOP nutrition labelling was considered an important way to save time and make informed decisions but found the variety of different FOP approaches currently in use in the marketplace a hindrance.

14. There was wide support for a single FOP labelling approach that could be widely understood by consumers to make quick and informed decisions, especially if combined with food education for young people. It was felt that the Government should be responsible for the development of such an approach and that it should be adopted by all retailers and manufacturers. Overall there was a perception that a single approach would be easier to understand and more convenient to use, particularly for consumers who considered that trying to interpret several different schemes was inconvenient and time-consuming. The report of this work is available on the Agency’s website (see Note 6 below).

Proposed Framework for FOP Labelling

15. It is widely accepted that FOP labelling is useful and valued by consumers, making it easier for them to make healthier choices when shopping. However research and feedback from consumers has indicated that the use of FOP labelling to inform consumer purchasing decisions could be enhanced further if there were a more consistent approach to FOP labelling. In working up a possible framework to strengthen arrangements further the Agency has taken account of consumer and industry needs, informed by responses to the formal consultation, the output from the citizens’ forums and the research from the independent evaluation. The Agency’s science checklist (Annex 8) and governance arrangements have been adhered to throughout this process.

16. Given the aspects of FOP where there is common agreement and consistency in approach (i.e. nutrients and weight in grams of individual nutrient per portion) and the current use of various interpretative elements (text to indicate the levels of the nutrients (High, Medium and Low), %GDA, traffic light colour coding and combinations of these), progress towards a single approach could be made by updating the existing Agency FOP principles and adopting a framework approach which consists of all of the following:

I. Provision of information on the amount of fat, saturated fat, sugar, salt and calories. Amount of each nutrient present (in grams) in a specified portion of the product.

II. Provision of portion information. The size of the portion should be described in an easily identifiable way (i.e. 1/4 pie or 1 biscuit) as well as the weight in grams. The number of portions/servings per pack should also be stated within the FOP label.

III. Provision of the interpretive elements found by the independent FOP evaluation research to aid the understanding and use of the nutritional information provided within the FOP label. This could be achieved by applying 2 of the 3 elements initially but incorporating all 3 elements over time, i.e.:



IV. Flexibility in presentation of FOP information provided the label design does not mislead or confuse the consumer.

V. Application of the FOP label to be extended to a wide range of prepacked composite processed foods - Prioritised according to benefit for consumer and based on the approach outlined in Annex 9.

17. Such a principle based framework would be expected to make it easier for more UK consumers to use FOP labelling when shopping, help consumers make informed choices about food and drink products they purchase and encourage further product reformulation by industry. The approach being proposed would enable businesses to decide which interpretative elements to include in the FOP label (text and/or traffic light colours to indicate the level of nutrients, in addition to %GDA) in the first instance. Business decisions would be taken in the full knowledge that research since 2004 has consistently shown that UK consumers when given a choice prefer and value a FOP approach which includes traffic light colours over and above any other interpretive element. This approach would also be expected to provide the flexibility needed to deliver greater harmonisation of FOP schemes over time. Annex 10 contains visuals to illustrate how the principles contained within the proposed framework might be incorporated into a FOP label design. To assist the transition to this single approach, we recognise that some companies may need to make adjustments in a phased manner and some flexibility has been included within the framework to allow for this.

European Dimension

18. FOP nutrition labelling is not covered by existing nutrition labelling legislation, which is set at an EU level, but is contained within the Commission proposal for an EU Food Information Regulation (FIR). This will strengthen arrangements to enable UK consumers to make a healthier choice.

19. EU negotiations are ongoing and are unlikely to conclude before the end of 2011. Once agreed it is expected that there will be a 3-5 year period before they start to come into effect. Discussions have recognised the need to allow the various FOP approaches currently in use in EU Member States whilst evidence of their effectiveness is researched. It is encouraging that consumer and the public health protection needs of individual Member States are being addressed in a flexible manner in the context of the FIR. The principle based framework being proposed would enable UK consumers to benefit from a more consistent and effective approach FOP labelling over time and would be in keeping with the aims of the EU FIR proposal. Until such time as FOP labelling is made compulsory the voluntary approach should remain in place.

Next Steps

20. Ministers will be informed of the Board’s decisions. The Agency will then update its existing FOP nutrition labelling technical guidance to reflect the principles outlined in the framework for a single approach to FOP labelling and will conduct a further public consultation. The Agency will then formally submit its recommendations to Health Ministers in the Autumn.

Board Action Required

21. The Board is invited to:


1. In Scotland, the Scottish Executive’s Eating for Health: Meeting the Challenge (2004). In Wales, the Food Standards Agency and Welsh Assembly Government’s Food and Well Being: Reducing inequalities through a nutrition strategy for Wales (2003). In Northern Ireland, work is progressing to develop a Department of Health’s food and nutrition strategy.

2. Food Standards Agency Nutritional Labelling Qualitative Research, Final report November 2001



5. The forums were conducted in two parts. The same participants took part in both parts.


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