Accounting & accountability – front-of-packaging labelling

Health Canada’s (HC) front-of-packaging (FOP) labelling initiative was launched on Oct. 24, 2016 as part of HC’s Healthy Eating Strategy for Canada program. The FOP initiative’s purpose is to introduce mandatory front-of-packaging labelling “for foods that are high in nutrients of public health concern, namely saturated fat, sugars and/or sodium.” The proposed FOP legislation was published in the Canada Gazette, Part I (CG1), on Feb. 10, 2018.

Nutrients of public health concern

In addition to mandatory labelling for foods high in saturated fats, sugars and sodium, the legislation incorporates numerous other initiatives. The details can be accessed at http://gazette.gc.ca

The justification to legislate the labelling of foods high in these ingredients is that excessive consumption of foods containing high amounts of these ingredients along with a sedentary life style contribute to and/or are associated with the diseases of concern. Compare this to the direct correlation of alcohol consumption with liver disease, smoking with cancer, as well as obesity with type 2 diabetes, heart disease and strokes.

Don’t get me wrong. I am in total agreement with HC that a diet of foods high in sodium, saturated fats and sugars is not good for you. Eating wisely is important. However, this legislation and the Healthy Eating Strategy program stop far short of what must be done to reduce obesity, heart disease, strokes, cancer and type 2 diabetes. So what could be done? Funding nutrition and physical education programs in our schools will, in my opinion, pay faster and bigger dividends to the health and welfare of Canadians.

Cost-benefit analysis

The Treasury Board now requires that new legislation undergo a cost-benefit analysis to assess the costs of the new regulations as well as the potential benefits of the same. HC consulted extensively with stakeholders in carrying out this analysis for FOP labelling. It is estimated that in 10 years the total net benefit of this legislation will be $2.36 billion after industry compliance costs of $836.05 million are deducted from the forecast total healthcare savings of $3.19 billion. This assumes an annual 1.5-per-cent improvement in health outcomes from those diagnosed with the diseases of concern. Please remember that aside from the ban on trans fats, the major focus of this legislation is on the FOP labelling.

Although we would all like to see a 1.5-per-cent annual improvement in health outcomes, 1.5 per cent could be optimistic for three reasons. Firstly, most people suffering from the conditions in question will already be following the dietary advice from a healthcare professional and diligently monitoring their diet. Secondly, if they are not, will FOP labelling have any influence on these patients? Thirdly, countries that have introduced FOP labelling, whether compulsory (Chile in 2016, Ecuador in 2014, Mexico in 2014) or voluntarily (France in 2017, Britain in 2016, Australia/New Zealand in 2012), have not reported any health benefit outcomes. However, all countries claim that their programs have had some effect on consumer food choices and have led to companies reformulating products to comply with the new guidelines.

Implementation & enforcement

Implementing and enforcing FOP regulations is the responsibility of the CFIA. These responsibilities will be incremental to the many new responsibilities that are sure to come out of the Safe Foods for Canadians Act (SFCA) and also from the CFIA Modernization and Food Labelling Modernization initiatives. The foreign supplier verification program is something Canadian food processors are hoping the CFIA will aggressively pursue. Whether the Agency will receive the necessary funding and people to do all that it will be called upon to do is an open question.

I applaud HC’s efforts to consult with stakeholders prior to the publication of CG1 and subsequently. The Healthy Eating Strategy and the FOP legislation have well-intentioned outcomes. No one would argue against improving consumer dietary knowledge. Sustaining the well-being of all Canadians is something we all want, however, the contribution by FOP labelling will be small when compared to the benefits of long-term funding of nutrition and physical education programs in our schools.

Dr. R.J. (Ron) Wasik, PhD, MBA, CFS, is president of RJW Consulting Canada Ltd. Contact him at rwasik@rjwconsultingcanada.com