Front-of-packaging nutrition labelling

Health Canada is turning up the heat on healthy eating. In October the minister of Health invited comments on its Healthy Eating Strategy. This includes, among other things, revising Canada’s Food Guide, reducing the amount of sodium, removing industrially produced trans fat, and restricting the advertising of “unhealthy” foods to children.

There has already been a reduction in trans fat through the current voluntary approach. The goal now is to complete the process of eliminating man-made trans fats, largely contributed by partially hydrogenated oils. In spring 2017 Health Canada (HC) is expected to begin consultations to establish new sodium reduction targets. HC will also consult with stakeholders on restricting advertising of food to children. This effort will review the Senate Bill S-228 tabled in September. The Bill, which identifies children as persons under 13 years of age, proposes to restrict both advertising and labelling.

The Healthy Eating Strategy includes food labelling amendments related to nutrition and ingredient labelling. Final regulations are expected to be published in Canada Gazette II by the end of 2016. A five-year transition period to implement the new rules had been proposed. The proposed rules did not include requirements for mandatory front-of-packaging (FOP) nutrition information. That is, however, part of HC’s current discussion on possible labelling amendments.

Current rules in the Food and Drug Regulations (FDR) prohibit representations that characterize the energy value or amount of a nutrient in a food. The regulations further define what type of representations may be included in labelling or advertising of a food. One such provision permits manufacturers to include statements outside the nutrition facts table (NFt) regarding the content of energy or a nutrient if expressed in applicable units per serving of stated size. It is not uncommon to see the voluntary FOP icon declarations showing the amount of calories or nutrients, or where applicable a per cent daily value (DV). Such nutrition information, also known colloquially as nutrition keys, is currently provided for by the FDR, but is not mandatory.

Some food retailers in Canada have evolved their own nutrition programs, including Loblaws’ Guiding Stars, which provides a three-tier star rating based on the pros and cons of a food’s nutritional value. Australia and New Zealand have a voluntary FOP Health Star Rating system which incorporates a star rating along with nutrition keys. The Nordic Keyhole program, a simple iconic approach guiding consumers in making food choices, is used voluntarily in Sweden, Norway and Denmark. In contrast, Chile requires foods high in calories, saturated fat, refined sugars and sodium, to include FOP stop sign icons alerting consumers of the higher amounts of these nutrients. The conversation in Canada appears to be heading in the direction of mandating uniform and predictable FOP nutrition labelling in addition to the more traditional NFt that appears elsewhere on the label.

There are a number of complex considerations involved. The idea of making FOP nutrition information mandatory signals that the traditional NFt alone is not adequate in helping consumers make better food choices. A voluntary approach is nice, but would not be consistent and predictable. Achieving a better dietary outcome for all Canadians would mean leaning in the direction of a mandatory approach.

A blended approach might be more compatible with meeting individual dietary needs. The use of positive or negative symbols alone seems to encourage the view that foods are healthy or unhealthy, rather than focusing on one’s total diet. Other issues involve preparation and consumption. A potato as per Loblaws’ Guiding Stars program, for example, scores three stars, the highest rating. Will the FOP information also require guidance on preparing potatoes without frying, or on the use of excessive amounts of sour cream and salt? In a mandatory FOP nutrition information regime, potatoes would likely not trigger any cautionary callouts related to saturated fat, sodium and sugars. A blended approach might help expose the good nutrient aspect of potatoes in a more tangible way for consumers to compare with similar food selections. A system with just cautionary nutrition keys is relatively easy, as the food would either exceed threshold limits, or not. A system that incorporates calculations to quantify the “healthy” value of a food requires much more thinking to develop, and would add more complexity for manufacturers to implement.

Ultimately, HC needs a simple, easy to understand and implement FOP nutrition labelling program. It must be effective in helping consumers make better food choices in order to achieve a healthy, well-balanced diet. This will not be easy and this will not happen quickly.