Subsections

Food Advertising

It is unclear how child's behaviour is affected by the comprehension by the intends of food advertising. Research conducted by the broadcast advertising regulator, Ofcom, in 2004 raises this important question.

Promotional material in television programming
Advertising remains the main source of finance for EU TV broadcasters. The EU report from the Commission examined the development evolution in current practices, such as product placement spot advertising, the handling of different techniques, such as interactive advertising, split screen techniques and virtual advertising to see whether they are used and whether specific regulation exists.

The preliminary results of the study show that these new techniques are in their infancy, and have not, as yet, a real financial impact on media advertising revenues. Indeed as the figures show, between 96-99% of all advertising revenue across the different media is still on traditional advertising. [1512]

For scheduled broadcasting, the Commission proposes to remove red tape, make existing rules more flexible for new forms of advertising, and encourage self- and co-regulation. Instead of detailed prescriptions on how often and under which conditions programmes may be interrupted by advertising, the modernised Directive would simplify the existing EU rules.

In the future, broadcasters would be able to choose the best moment to insert advertising in programmes, rather than being obliged, as they are now, to allow at least 20 minutes between advertising breaks.

However, the quantity of advertising would not be allowed to increase as the Commission proposes to maintain the existing 12 minutes per hour ceiling.
The new Directive would also support new forms of advertising, such as split-screen, virtual and interactive advertising. Product placement would, for the first time, be explicitly defined and provided with a clear legal framewk. [1513]

Except in news, current affairs and children's programmes, clearly identified product placement would be permitted in Europe, both in linear and non-linear audiovisual services. To prevent surreptitious advertising, consumers would be infmed at the start of a programme that product placement is in use.

These new rules should remove legal uncertainty, provide additional funding for European productions and thus enhance the competitiveness of Europe's audiovisual sect. [1514]

The "Television Without Frontiers" Directive (TVWF Directive) rests on two basic principles: the free movement of European television programmes within the internal market and the requirement that television channels, where practicable, reserve over half their broadcasting time for European works ("broadcasting quotas").

The proposed revision of the Television Without Frontiers directive 89/552/EEC partially lifts regulations on advertising and product placement. Junk food marketing may thus be legal during minor broadcasting times and contribute to elevated obesity.

Product placement is the paid-for placement of goods in movies, shows and even news programmes. Product placement is currently illegal in most EU states.

The watchdog Which? analysing marketing devices Soft drink and junk food product used to persuade children to demand high-fat high-sugar junk foods has found a number of products carrying misleading labels inadequate information about nutritional content and actively promoting themselves as perfect for lunch boxes can be classed as potential lunch box material such as:

Capri Sun Blackcurrant drink having lots of blackcurrants shown on the front of the pack when in actual fact it contains only 5.1 per cent of blackcurrants. There is a similar amount of apple content (4.9 per cent) but this is only mentioned on the back of the pack. [1515]

During a discussion about children's diets and the promotion of food launched by the UK FSA one study was presented which found that the more a child watched food adverts on television, the more snacks and calories they ate. It was stressed that the diet being advertised is far from a healthy nutritious one: fun, fantasy, taste are the lures. [1516]

Under the newly proposed Television Without Frontiers Directive, companies will not be allowed to use product placement in children's programmes, although prime-time family television will be exempt from this rule.

Junk-food advertisers use to pay sports and pop celebrities to endorse foods, many of them being not properly balanced diets. [1516]

The Union of European Beverages Associations (Unesda) said some of its members would stop advertising soft drinks to children under the age of 12.

According to UNESDA the development of obesity is related to a number of different contributing facts. The genetic make-up of an individual plays a key role in the development of obesity countries.

Physical activity levels have fallen so dramatically so that even despite consuming lower energy intakes, we are still, on average, eating too much for our needs despite falling total calorie consumption. [1517]

Television advertising of food and drink products to children in UK

[1519]
Ofcom found it appropriate and necessary to adopt restrictions intended to reduce significantly the exposure of children under 16 to advertising of food containing high fat sugar and salt (HFSS).

Ofcom's co-regulatory partners, the Broadcast Committee on Advertising Practice (BCAP) and the Advertising Standards Authority, are now responsible for implementing the new scheduling and content rules and securing compliance respectively. The new rules will form part of the BCAP Television Advertising Standards Code.

Scheduling restrictions The scheduling restrictions will now come into effect on a phased basis for all channels, as follows: The Food and Drink Federation and the Advertising Associationt is campaignin to prevent the imposition of a 9pm watershed on advertising HFSS foods These organisations argue that the most popular programmes with kids are not aimed at their age-group,and regulation restrictions around programmes made for the under-10s are ineffectual.

The Advertising Association reports that there has been a shift in the nature of food advertising on television in the last three years away from HFSS foods and says that it is building on self-regulation in order to avoid the imposition of new regulations. [1520]

Junk food adds in USA

The Federal Communications Commission and the Federal Trade Commission [11]
In the 1970s and 1980s, the Federal Trade Commission considered restrictions on junk-food advertising aimed at kids, but those efforts were blocked by food, toy, broadcasting, and advertising industries. The FCC adopted rules limiting the amount of time that could be devoted to commercials during children's programs and banning such practices as selling by the host and program-length commercials. Congress rejected the idea and cut the funding for the agency. FTC to demand information on food and beverage marketing to kids [1521]

CSPI says that with rates of obesity at all-time highs in children, now is the time to set standards on what foods may be marketed to kids on television and in schools. CSPI also recommends that governments sponsor media campaigns that encourage healthy eating and physical activity, and that grocers put low-nutrition foods at parents' eye level, not kids' eye level.

The Federal Trade Commission report on "Children's Exposure to TV Advertising in 1977 and 2004"

[1521]
According to a notice on April 2007 of the Commission informations are requested from food and beverage industry and quick-service restaurant companies in the United States. On June 01, 2007 the Federal Trade Commission report on Children's Exposure to TV Advertising in 1977 and 2004 concluded that children were exposed to 9% less food ads in 2004 than in 1977. The Report says that today's children see more promotional ads for other programming, but fewer paid ads and fewer minutes of advertising on television, according to a report released today by the staff of the Federal Trade Commission. The research looks at television add exposure for children in the year 2004 and compares it to similar research from 1977.

The American Psychological Association report

[1522]
The American Psychological Association on February 23, 2004 called for the government to restrict ads aimed at children under 8. The APA report recommended:
- Governmental action to protect young children from commercial exploitation through advertising.
- Making sure disclosures and disclaimers in advertising directed to children are in language easily understood, such as "you have to put it together,"rather than "some assembly required".
- Investigating how young children comprehend and are influenced by advertising in new interactive media environments such as the Internet.
- Examining the influence of advertising directed to children in the school and classroom.

According to the research of the American Psycological Association (APA) in 2007 children under the age of eight are unable to critically comprehend televised advertising messages and are prone to accept advertiser messages as truthful, accurate and unbiased. This can lead to unhealthy eating habits as evidenced by today's youth obesity epidemic. The report recommends that advertising targeting children under the age of eight be restricted.

The IOM Report

[1523]
The Institute of Medicine Report 2005 (IOM) written for Congress calls for major changes in the way the food, beverage, restaurant, and entertainment industries approach food advertising aimed at children, because kids under the age of 12 are influenced by food advertising and have poorer diets because of it. The report concludes that there isn't enough scientific evidence of a direct causal link between food marketing and obesity in children, however, the association is strong.

The report recommends that if the industry does not move to a healthier advertising, the Congress should pursue legislation that would mandate changes in both broadcast and cable television. Other countries such as Norway and Denmark, have already restrictions on television ads aimed at kids under age 12 for years. US is lacking behind European countries when it comes to protect individuals from the proliferation of the industry lobby.

The reaction of the industry

[1524]
In 2007 major US manufacturers have agreed to stop advertising junk foods to kids. NBC Universal combats advertising unhealthy snack and junk foods to children blocking these adds on its children's programming by June 2008. According to the CSPI, voluntary measures are promulgated by advertising- and food-industry groups whose main goals are to forestall serious government action and to generally make life easier for advertisers. Unfortunately the Federal Trade Commission and the Federal Communications Commission are also more oriented to protecting business than helping parents and protecting children. [1525] The International Association for the Study of Obesity (IASO) [1526]
The International Association for the Study of Obesity is an umbrella ganisation for national obesity associations. In 2002, the International Association for the Study of Obesity and the International Obesity TaskForce (IOTF) merged. The IOTF as part of IASO is working with partners in the Global Prevention Alliance to support new strategies to improve diet and activity and prevent obesity and related chronic diseases with a special focus on preventing childhood obesity. [1527]

According to International Obesity Task Force head Profess Philip James, the governments should use the health clauses allowed under WTO rules to protect people's health. He regrets failure of the Doha Development Agenda in 2006 which aimed to free global trade by cutting industrial and agricultural tariffs and by reducing farm subsidies, with a special focus on achieving concrete benefits for developing countries.

James argues that unchanged farm policies could continue to damage people's health due to overproduction of oil, fat and sugar, largely due to government subsidies to protect farm industry revenues.

Call for ban of junk food advertising at the International Congress on Obesity in Sydney 2006 [1528]
IASO president Profess Claude Bouchard calls for a ban of advertising junk foods and non-nutritious foods aimed at children. He sees junk food as the core of the problem of obesity. Australians federal Health Minister Tony Abbott, however, ruled out banning junk food commercials, saying it is parents' responsibility to monit what their children eat.

Profess Arne Astrup, a Danish expert on obesity, suppted banning junk food commercials referring to the good results of banning trans fatty acids in in Danish food.


Marketing and brand exposures on young children influences taste preferences.

[1529]
According to Robinson and colleagues 2007 children preferred the tastes of foods and drinks if they thought they were from McDonald's. Greater effects of branding among children with more television sets in their homes and children who ate food from McDonald's more often were found.

The authors conclude that branding of foods and beverages influences young children's taste perceptions, urging to regulate marketing to young children. The researchers suggest branding as a useful strategy foe improving young children's eating behaviours.

The White Paper on nutrition, overweight and obesity.

[1530]
The white paper on A Strategy for Europe on Nutrition, Overweight and Obesity related health issues was adopted by the European Commission on 30.05.2007. It is based on the EU Platform for Action on Diet, Physical Activity and Health, initiated in 2005, and green paper on promoting healthy diets and physical activity 2005. The paper contains principles for action and partnership approach. It focuses better-infmed consumer, allowing them to make informed, evidence-based decisions about what foods to buy to tackle obesity. [1530]

The Commission's preference, at this stage, is to keep the existing voluntary approach at EU level due to the fact that it can potentially act quickly and effectively to tackle rising overweight and obesity rates. [1530]

Voluntary efforts to ensure adverts aimed at children should be combined with rules at the level of individual member states, such as those recently implemented by the Office of Communication in the UK. Industry has already taken important steps but these have not always been uniform across products and Member States. Some Member States are encouraging reformulation of foods, for example in terms of their levels of fat, saturated and trans fats, salt and sugar. [1530]

All these refmulations (and there are only few of them) took place under heavy pressure of consumer associations retailers fearing bad publicity.

The CIAA has fought against being seen as a scapegoat for obesity and welcomes the White Paper, enforcing physical exercise to reduce obesity, and refers to its own Brochure [1531] [1532]

Eurocommerce, speaking for its members, welcomes the White Paper stressing the importance of education programme in schools, since nutrition and healthy lifestyle education should start at an early age. [1533]

The European Consumers Organisation BEUC, however, says the White Paper is disappointing because it relies on revision of nutritional labelling. Advertising of food for children is mentioned vaguely about partnerships and voluntary measures, with a review in 2010.

BEUC says what consumers urgently need is simple and understandable on-pack labelling to help them make the most appropriate nutritional choices, since they cannot rely on advertising. Promotion of foods high in fat, sugar and salt for children exerts pressure on parents, but the solution, relies on the source of pressure on advertising. [1534]

The 100-calorie packs

[1535]
Introducing 100-calorie packs was a good idea. The portion control may help consumers control their cravings. Its the good feeling when the empty container is discarded.

However, according to CSPI Executive Direct Michael F. Jacobson. 100-calorie packs cost, on average, about two-and-a-half times as much per ounce as similar products in larger packages.

Shoppers may not notice the price differences since most varieties of 100-calorie packs are priced similarly to a box of cookies crackers, at about 3 USD per box. But consumers who want to control their weight, could save money by dividing their regular box themselves if they are worried about downing the whole container. Better yet, they could skip the junk foods altogether and reach for a piece of fruit.

Eating regularly in some fast-food chain outlets is unsafe in many parts of the world according to a study presented at the 15th European Congress on Obesity Budapest.

[1536] [1537]
Food quality and ption sizes need to be improved dramatically, according to the Copenhagen University research group, led by Prof Steen Stender, who found major variations in the quality of products offered by the same chains across 35 countries.

Fast foods examined in the global survey were found to have not just a high fat content, but also up to 17 times the level of trans-fatty acids legally permitted in Denmark, which introduced a ban in 2004. Business directs deliberately breaching the Danish restriction could face stiff fines and up to two years in jail.

Countries with unsafe foods:

Eastern Europe fared particularly badly in the survey with Hungary, Bulgaria, Poland and the Czech Republic topping the table with levels of unhealthy trans-fats accounting for 29-34% of the fat content.

Countries meeting the Danish standard:

Fast food in India, Russia, Spain and in Scotland met the Danish standard requiring less than 2% of the total fat content in a product to be trans-fats.

Wide discrepancies with McDonald's food:

Checks on McDonald's also revealed wide discrepancies, with the highest percentage of trans-fats found in Oman at 20%. In the United Kingdom, samples in London, Glasgow and Aberdeen reached 15-16%, with levels of 14-15% in Hong Kong, Poland and South Africa, compared to 14-16% found in US outlets.

After analysing 74 samples of French fries and fried chicken (nuggets/hot wings) bought in McDonalds and KFC outlets in 35 countries in 2005 and 2006, they concluded that the idea that a typical fast-food meal was the same worldwide was "a myth".

According to Prof Arne Astrup the companies selling foods with high levels of trans-fat disregard customers' health. They will only really respond when there are regulations as tough as they are in Denmark.

Recommendations to Fast Food chains:

The authors suggest fast food chains should provide reliable nutritional information, which requires better standardisation of the foods used and recommend suppliers take action to reduce portions to "normal" sizes and eliminate industrially produced trans fat, as well as offering burgers made of lean meat, whole grain bread/buns, fat-reduced mayonnaise, add more vegetable, lower-fat fried potatoes and reduced-sugar soft drinks.

International code needed to protect children from Internet and TV marketing Excesses

IOTF mediarelease, September 5 2006

Youngsters should be protected from exploitative marketing techniques used on the internet as well as from television advertising as part of an all out bid to halt the rise in childhood obesity, according to a new report from the public health think tank, the International Obesity TaskForce released today. [1538]

With the global epidemic of obesity already triggering the development of type 2 diabetes in increasing numbers of children, the IOTF, part of the International Association for the Study of Obesity (IASO), said an internationally enforceable code was needed to give clear principles for governments, industry and others to follow.

IASO agreed during its International Congress on Obesity taking place in Sydney, Australia, this week, to demand a ban of all advertising of junk foods and non-nutritious foods aimed at children.

The call to action is also being considered by members of the Global Prevention Alliance, a consortium of concerned NGOs. The Alliance includes the World Heart Federation, the International Diabetes Federation, the International Pediatric Association and the International Union of Nutritional Sciences, led by IASO. It works to combat childhood obesity and obesity-related chronic disease through high level policy initiatives, with a global network of national Alliance groups.

The proposal calls on WHO member states to ask WHO to take the lead, with other UN agencies, governments, international partners and other stakeholders, to develop international standards to protect children.

Alongside the think tank rept, an IOTF group today launched its draft recommendations - the Sydney Principles - proposing a range of actions that governments, the private sector and international bodies like WHO should take. These include proposals that government should:

Profess Boyd Swinburn, President of the Australasian Society for the Study of Obesity, who convened the IOTF group which developed the proposals, said: "At the moment, the need to protect children from commercial exploitation was being largely overlooked by the food and advertising industries. We need to recognize that everyone in society has a responsibility to ensure we provide healthy environments for children, and also to seek the highest standards."

They would be inviting feedback from the congress delegates in Sydney, and was consulting widely with interested parties, before publishing a final paper on its findings.

The IOTF report highlighted the failures of self-regulation favoured by industry, because self regulation lacked the means to control the "cumulative effect" of intense marketing targeting children. Dr Tim Lobstein, coordinat of the IOTF's childhood obesity working group, and author of the new report, said that powerful evidence was emerging of the way in which advertising games on the internet were being used to bypass even the present minimal standards of conduct adopted by food and beverage advertisers.

Research undertaken by the Kaiser Family Foundation in the USA found that 85% of businesses advertising to children on television also had interactive websites for children promoting branded products, which incorpated not only games but promotions, using viral marketing techniques, membership opportunities, as well as movies and television tie-ins. []

Over 12.2 million children had visited commercial websites promoting food and beverage products over a three month monitoring period last year. In the UK the Food Commission found that most major food brands had sites designed to attract children as young as six years old.

A separate new analysis of the use of the internet to target children has revealed that even existing weak voluntary advertising codes are being breached routinely on websites targeting children. "While the regulators, even the industry itself in various countries, through self- regulation, has regulated advertising to children and pledged responsible marketing to this segment, the same advertisers appear to forget the promises as soon as they are advertising online. As such, they are in breach of the spirit of the current self-regulaty provisions that apply to other forms of marketing communications", a team of marketing experts from the Middlesex University Business School concluded in their report, Analysing Advergames: Active Diversions Actually Deception. [1540]

The Middlesex report highlighted the use of pressure to purchase, with some websites requiring purchases before children could play online games, and one popular children's sweet brand requiring children to find the magic code. "This practice would appear very dubious, as this practice appears to clearly entice young consumers to purchase the products - a point that is clearly ruled out in the code of conduct," the authors observed. Viral marketing downloads and links from advergames to corporate websites were "against the spirit of the self regulation system's provisions," they added.

The authors concluded: "While it is relatively easy to control the content of television and print advertising, controlling the content of online advertising, and advergames with different levels in particular is a lot more complex and demanding on a regulator. At the same time the global reach of the internet throws open the question who should ultimately regulate such websites, and which code of conduct should they follow?"

The need for WHO to deal with the issue of marketing to children was recognized in the WHO Global Strategy on Diet, Physical Activity and Health approved unanimously by ministers at the World Health Assembly in 2004. WHO is preparing to publish a report on marketing to children after it convened a conference and expert consultation held in Oslo in May 2006; WHO is also inviting European Health Ministers to adopt a Charter on Obesity in November, which will include reference to the marketing issue.

"The UN Convention on the Rights of the Child requires that children should be protected from economic exploitation and also defines how the advertising world should not take advantage of the gullibility of children."

"We need to take a much firmer position in tackling this. If we are to succeed in the halting the global epidemic of childhood obesity, we must challenge all governments, the whole of the business world, and society at large to join with us in tackling this together," said Neville Rigby, director of policy and public affairs of the IASO. The IOTF briefing on marketing to children is available for download from the IOTF website: www.iotf.g

IOTF paediatric cutoffs questioned by L D Voss [1544]
Paediatric cutoffs from the age of 2 years for overweight and obesity, based on adult thresholds published by the International Obesity Task Force (IOTF) were questioned by L D Voss and colleagues, saying that until we understand more about which children acquire such risk facts, any such thresholds for overweight and obesity should be used with caution in the very young, as they may unnecessarily stigmatise the heavier child.

Other IOTF associated activities against obesity
EU Platfm for Action on Diet, Physical Activity and Health [1541]
Under the leadership of the Commission was launched in 2005, bringing together industry associations, consumer groups, health NGOs and political leaders to take voluntary action to halt and hopefully reverse the rise in obesity, particularly among children. Poor diet and lack of exercise are among the leading causes of avoidable death in Europe.

World Heart Federation [1542]
The World Heart Federation is committed to helping the global population achieve a longer and better life through prevention and control of heart disease and stroke, with a focus on low and middle-income countries. It is comprised of 189 medical societies and heart charities from more than 100 countries.

The World Heart Federation members and partners run the World Heart Day 2006, taking place on Sunday 24th September.

The International Diabetes Federation[1543]
The International Diabetes Federation (IDF) is the only global advocate for people with diabetes and their healthcare providers. We work together with our member associations to enhance the lives of people with diabetes worldwide. Our mission is to promote diabetes care, prevention and a cure worldwide.

IDF has evolved into an umbrella organization of over 190 diabetes associations in more than 150 countries. IDF is a non-governmental organization in official relations with the World Health organization.

International Pediatric Association [1545]

IOTF - SCOPE programme [1546]
The IOTF - SCOPE programme is a major initiative to tackle the growing epidemic of obesity with a campaign for improved medical education and a new register of obesity expertise in Europe The IOTF - SCOPE programme (SCOPE stands for Specialist Certification of Obesity Professional in Europe) will recognize and encourage high standards for top rank obesity clinicians.


How the brain can be fooled by anticipating messages [1547]
Dr Jack Nitscke from the University of Wisconsin-Madison found that subjects were led to believe that a highly aversive bitter taste would be less distasteful than it actually was.

Functional magnetic resonance imaging were used to demonstrate that expectancy modulates neural responses in humans. the primary taste cortex was less strongly activated.

This study published in the journal Brain, Behaviour, and Immunity demonstrates how anticipation of sensory input can influence the human brain to react in a prescribed way.

The power of anticipation can help in the treatment of certain psychological conditions, but also helps the food marketing to turn the expectation of the product higher as the product in reality has to offer.

Pavlovian conditioning and food advertising

[1260] John P. O'Doherty and colleagues found that food preferences are acquired through experience and can exert strong influence on choice behavior. In order to choose which food to consume, it is necessary to maintain a predictive representation of the subjective value such as a name brand of the associated food stimulus.

In a study published in 2006, the scientists found a Pavlovian conditioning association in subjects using blackcurrant, melon, grapefruit, and carrot juices and a tasteless, odourless control solution. Pavlov conditioning was first studied in dogs associating a stimulus such as a bell with food. The authors say that associating brand items with other rewarding appetite stimuli accounts for efficacy and power of advertising.

This study demonstrates the dangers of food advertising in the hands of global players conditioning buyers to certain brands such as baby food, liqu, snacks and sweets.

Debate over advertising children's products

[1261] [1262] Many cereal companies, among them Kellogg's, are promoting ready to eat breakfast as a healthier option compared with kids who skip breakfast eating nothing.

In a study leaded by Kellogg's schoolboys eating Kellogg's Cornflakes were more energised and alert than those who hat eaten nothing. The TV spot claimed:
"Research shows that when they eat a cereal like ours, kids are on average 9 per cent more alert."
"Alertness measured by parents, comparing 63 children eating Kellog's Corn Flakes to 34 children skipping breakfast."

The UK Advertising Standards Agency (ASA) suggested to compare children who ate Kellogg's Cornflakes with those eating their normal breakfast.

The ASA found that the research behind it was not 'robust enough' and claims it contained were 'misleading'. ASA asked Kellogg's not to show the television advert.

Other ads were found to be backed on researches which were not rigorous enough to justify the claims:
St.Ivel's "advance milk", suggesting the product could make children cleverer.
Fla pro.activ claiming the product keeps blood vessels healthy as well as lowering cholesterol.
All ads were asked to be pulled.

The industry has proposed a so called fourth solution which proposes a ban on food and drink advertising on terrestrial channels at times when children are likely to be watching television and a restriction on the amount of food and drink advertising on children's satellite/digital and cable channels.

The industry tries to avoid an all-out ban which would be damaging to the food and advertising industries and the broadcasters.

UK advertising business in compliance with the Advertising Codes

[1263] [1264]
Content rules on advertising food and drink products to children came into effect in July 2007 and their aims to avoid adverts of poor nutritional habits or unhealthy lifestyle in children, and encourage excessive consumption. Also the use of licensed characters, celebrities, or promotional offers should be avoided.

According to the Advertising Standards Authority's survey, held in July 2007, an extremely high compliance rate, with 99.2% of ads surveyed deemed to be compliant with the Advertising Codes was found.

This should encourage other countries to tighten the rules on advertising of junk food to children.

Food labelling

Statutes governing food labelling are codified in the United States Code (U.S.C.). Administrative agency regulations implementing the statutory requirements are codified in the Code of Federal Regulations (C.F.R.).

History of US Food Labelling Regulation: [1265]

1906: Federal regulation of food labelling began in 1906. The Pure Food and Drugs Act of 1906, which covered all foods except for meat and meat products, included limited provisions related to food labelling. Primarily, false misleading label information was prohibited, and a net contents statement was required for foods in packaged form. In implementing this law, however, the Food and Drug Administration (FDA) (and its predecess agencies) had no authority to adopt substantive labelling requirements.

1927: The Caustic Poison Act, lobbied through Congress in 1927 by Dr. Chevalier Jackson and the American Medical Association, required labels to warn parents and protect children from accidental injury and death caused by lye and 10 other caustic chemicals. In 1960 thousands of other chemical products for home use came under FDA control when the Hazardous Substances Labeling Act was passed. To administer this law and subsequent amendments which expanded it, FDA developed an effective consumer safety program. With the passage of the Consumer Product Safety Act, in 1972, the FDA Bureau of Product Safety became the operating organization of a new independent Consumer Product Safety Commission.

1938: The 1906 Act was replaced in its entirety by the Federal Food, Drug, and Cosmetic Act (FDC Act) of 1938, thereby beginning the modern era of federal regulation of food labelling. In addition to prohibiting false misleading information, the FDC Act included requirements that the label of a food product bear a statement of product identity, net contents declaration, ingredients declaration, and identification of the manufacturer, packer, distributor.

1962:A drug tragedy in Europe, the births of thousands of deformed infants whose mothers had taken the new sedative thalidomide triggered the release of the Drug Amendments of 1962. Drug firms were required to send adverse reaction reports to FDA, and drug advertising in medical journals was required to provide complete information to the doctor - the risks as well as the benefits.

1990:The Nutrition Labeling and Education Act of 1990 (NLEA) amended the FDC Act and added several important elements of the food label. For the first time, nutrition labeling ("Nutrition Facts") was required for essentially all packaged foods. Federal requirements for nutrient content claims

References:
FDA: The FDA Food Labeling web pages address the labeling requirements for foods under the Federal Food Drug and Cosmetic Act and its amendments. http://www.cfsan.fda.gov/label.html

Nutritional Products, Labeling, and Dietary Supplements: The Office of Nutritional Products, Labeling, and Dietary Supplements (ONPLDS) is responsible for developing policy and regulations for dietary supplements, nutrition labeling and food standards, infant formula and medical foods as well as for scientific evaluation to support such regulations and related policy development. http://www.cfsan.fda.gov/ dms/onplds.html

Industry information Guidance and Regulations: All relevant regulations regarding food labelling in US is available at the site of the FDA. Regulations related to nutrient content claims, comparative claims, health claims, nutrition labelling, small business food labelling excemption, import and export regulation. http://www.cfsan.fda.gov/ dms/lab-ind.html

Center for FoodSafety and Applied Nutrition (CFSAN) : Overview and history of FDA and the Center for Food Safety and Applied Nutrition http://www.cfsan.fda.gov/list.html

Common nutrition labelling scheme

The EU Directive Council Directive 90/496/EEC of 24 September 1990 on nutrition labelling for foodstuffs to be delivered as such to the ultimate consumer There have been initiatives to settle a common nutrition labelling scheme to guide the consumer to a better understanding of the nutritional facts demanded by this directive. [1266]

European Food Information Council (EUFIC) []
According to an EUFIC consumer research conducted in 2004 many consumers do not understand the language and the principles of nutritional measurement and the nutrition labels do not play a real role in their assessment of the nutritional qualities of foods the management of their diets.

However, calories are widely understood. Energy intake was identified as the nutritional information concept that is the most widely understood across different European markets.

EUFIC tested young adults, families and the elderly in France, Germany, the Netherlands and the United Kingdom to determine if communicating energy-based concepts on the front and back of products increases consumer engagement and understanding of nutrition information.

Different energy-based information concepts, like front of pack 'calories per 100g'to a 'full option' that included energy information in relation to daily energy needs for men and women, calories per portion and the amount of exercise needed to burn off the calories contained within the product.

EUFIC concluded that the consumer sees the front-of-pack flags as a true innovation and liked them immediately. Most consumers would like to see them on all packs. The front-of-pack flags were clearly seen as a complement and certainly not a replacement for the current back-of-pack nutrition labels.

CIAA The Nutrition Labelling Scheme [1268]
In July 2006, the Confederation of the Food and Drink Industries of the EU (CIAA) launched an initiative recommending front-of-pack and back-of-pack nutrition labelling, based on a uniform list of nutrients, nutrition information per serving and the introduction of Guideline Daily Amounts (GDAs). The CIAA scheme, recommended as a voluntary system, has been developed in line with the requirements of current EU legislation (Directive 90/496/EC):


Front-of-pack: Clear statement of the Calories per serving, along with the percent GDA these Calories represent.
Back-of-pack Inclusion of three elements:
  1. List of nutrients (energy, protein, carbohydrate, sugars, fat, saturated fat, fibre and sodium/salt)
  2. Nutrition information per serving, in addition to the required 100g /100ml
  3. GDAs for the public-health sensitive nutrients - energy, fat, saturated fat, sugars, sodium/salt.

Mislabelling Misdescription of foods

Mislabelling does not normally give rise to safety issues; nevertheless, when done deliberately it constitutes the crime of fraud. [1269]

The name of foods such as chocolate, milk, margarine,must comply with certain compositional regulations. Food compositional legislation lays down compositional rules f: [1270] In other cases like fish fingers (coated cod fillets ready for frying) there may be no such standards but the food still needs to be described accurately and should not be misleading.

The consumer has a right to be confident that the product matches his expectations concerning diet and health, personal taste and preferences, cost. Misdescribed foods may deceive the consumer. On the other side misdescribed can create unfair competition with the honest manufacturer and have a great financial impact.

Food authenticity is all about whether a food matches its description refering to its name, its ingredients, its origin processes undergone.

Common misdescriptions are:
Food marketing terms
Marketing terms are widely used to mislead the consumer about the real qualities of the product. Many terms are tolerated by authorities because they are insignificant and cannot be stopped by lawsuit. However, they undermine the confidence of the consumer. Some of these terms are: 'Style' and 'selected' Scepticism was an overriding response to many common marketing terms. Does not contain preservatives additives. 'No preservatives added' , Home made, Handmade, Farmhouse, Real, Fresh, Pure, Natural, Traditional, original, Authentic, Premium, Finest, Best, Quality, Selected, Export quality.

Guidance on the use of marketing terms on food labels

[1358] The Food Standards Agency of UK issued the Guidance on the use of eight marketing terms on food labels in 2002 entitled "Criteria for the use of the terms fresh, pure, natural etc. in food labelling".

Its aim was to produce an advice on use of terms to help: This advice should not be taken as an authoritative statement interpretation of the law, as only the courts have this power. Ultimately, only the courts can decide whether, in particular circumstances, an offence has been committed.

FSA assessed the impact of this guidance in 2005 .
The FSA found that consumers considered quality, finest, handmade and original the four easiest phrases to understand in the context of food labelling.

The terms "quality", "finest" and "home made", were more likely to influence purchase decisions where two similar products were being compared.

However, 31 per cent of people look after the brand when making a purchase decision and 25 per cent felt the ingredients were the most important piece of inormation. Only 6 per cent of people claimed that the product descript, such as natural, fresh pure, was the most important piece of information. Only 14 per cent claimed to ever look at this on food packaging. [1271]

UK Advertising Standards Authority (ASA)

The Advertising Standards Authority is the independent body set up by the advertising industry to police the rules laid down in the advertising codes. The strength of the self-regulaty system lies in both the independence of the ASA and the suppt and commitment of the advertising industry, through the Committee of Advertising Practice (CAP), to the standards of the codes, protecting consumers and creating a level playing field for advertisers. [1272]

The ASA's mission is to apply the advertising codes and uphold standards in all media by being a customer focussed, best practice regulat, where expertise is valued and shared.

ASA and the consumers: The ASA helps the consumer in situations which needs to stop misleading offensive advertising, to ensure sales promotions are run fairly to reduce unwanted commercial mail and resolve problems with mail der purchases.
The ASA judges advertisements, direct marketing and sales promotions against a set of Codes.

ASA and the marketing industry: The UK marketing industry's system of self-regulation helps to ensure that consumers continue to accept advertising and that advertising remains effective: honest advertising helps to keep customers coming back.

In the UK, the rules for advertising are the responsibility of the advertising industry through two Committees of Advertising Practice: CAP (Broadcast)and CAP (Non-broadcast). CAP (Broadcast) is responsible for the TV and radio advertising codes and CAP(Non-broadcast) is responsible for the rulebook for non-broadcast advertisements, sales promotions and direct marketing.

ASA and the new media: New media includes mobile phones, handheld computers (also known as Personal Digital Assistants PDAs), electronic kiosks, electronic posters and computer games and the World Wide Net. The ASA ensures that non-broadcast advertisements, sales promotions and direct marketing in new media meet the British Code of Advertising,.

Claims companies make on their own websites, for example, do not fall within the scope of the Code. This is because the ASA does not rule on the editial content of publications, except where space has been paid for to promote a product, service cause. The ASA also recognises a distinction between media that consumers have chosen to access and material that they have not purposefully sought out to view.

Advertising in UK: The Code
Non-broadcast advertising [1273]
In the UK non-broadcast advertising is regulated by the British Code of Advertising, Sales Promotion and Direct Marketing (the Code) is the rule book for non-broadcast advertisements, sales promotions and direct marketing communications (marketing communications).

The Code applies to: Broadcast advertising
Broadcast advertising is split into two main sections - Television and Radio.

Radio Advertising Standards Code [1274]
The Radio Advertising Standards Code sets out the rules that govern advertisements on any radio station licensed by Ofcom. The rules are framed to ensure that advertisements are 'legal, decent, honest and truthful' and do not mislead cause harm serious widespread offence.

TV Advertising Standards Code [1275]
Television Advertising Standards Code sets out the rules that govern advertisements on any television channel licensed by Ofcom. The rules are framed to ensure that advertisements are 'legal, decent, honest and truthful' and do not mislead cause harm serious widespread offence.

TV Advertising of food and soft drink products to children[]
A draft of the guideline is already available. [1276]

New rules part of the BCAP Television Advertising Standards Code and the new rules on scheduling restrictions on TV advertising of food and drinks[1989] [1990]
Ofcom issued extended restrictions on the television advertising of food and drink products high in fat, salt and sugar (HFSS) including programmes and channels aimed at children aged under 16.

Rules in Annex 4 of this Statement apply to all food and drink advertising to children irrespective of when it is scheduled prohibiting the use of licensed characters, celebrities, promotional offers and health claims in advertisements for HFSS products targeted at pre-school primary school children. [1991]

According to Which? a 9 pm schedule should be observed for these restrictions.

The Food and Drink Federation FDF argues that the regulations were based on scientifically flawed nutrient profiling model.

The restrictions will come into effect in April 2007 regarding HFSS advertisement for children aged four to nine. In January 2008 this restriction will be extended to HFSS advertising to children under 16.

According to Leech of Ofcom, the TV advertising has a modest, direct effect on children's food choices and is only one among many influences. He addresses the food and drink industry which, together with government, have to add their part to solve the obesity issue.

Responsible for the implementation of the content rules and their compliance are the Broadcast Committee on Advertising Practice (BCAP) and the Advertising Standards Authority.

OFCOM new rules o television advertising of food and drink products to children in UK

[1992]
Ofcom has concluded it is appropriate and necessary to adopt restrictions intended to reduce significantly the exposure of children under 16 to high fat, sugar and salt foods (HFSS) advertising.

Ofcom's co-regulatory partners, the Broadcast Committee on Advertising Practice (BCAP) and the Advertising Standards Authority, are now responsible for implementing the new scheduling and content rules and securing compliance respectively. The new rules will form part of the BCAP Television Advertising Standards Code.

Scheduling restrictions

The scheduling restrictions will now come into effect on a phased basis for all channels, as follows:

Children's channels will be allowed a graduated phase-in period, with full implementation required by the end of December 2008.

Content rules

The reaction of the advertising industry:

The Food and Drink Federation and the Advertising Associationt fight to prevent the imposition of a 9pm watershed on advertising high fat, sugar and salt foods These organisations argue that the most popular programmes with kids are not aimed at their age-group, and regulation restrictions around programmes made for the under-10s are ineffectual. Both organisations say that they follow self-regulation in order to avoid the imposition of new regulations.

OFCOM UK advertising regulations is far better than US self regulation.
There are three industry-funded US organizations engaged in developing technical guidelines. According to their homepage they are devoted to the following goals: Finally, the Federal Trade Commission, which is in charge of advertising affairs in US, has indicated it won't restrict food advertising on children's television.

The Center for Science in the Public Interest (CSPI) says that the CARU's technical guidelines do not consider the nutritional quality of foods. The CSPI has therefore threatened litigation to protect kids from junk-foods ads in 2006. Actions against the marketing practices of Kellogs and Viacom (a kid-friendly network) are running [1280]. CSPI legal affairs direct Bruce Silverglade says that British regulations issued by OFCOM, are far superior than the situation in the US, where the Federal Trade Commission continues to support a failed self-regulaty system. [1281].

The lawsuit on Mercury and acrylamide [1282]
Attorney General Bill Lockyer on August 26, 2005, filed suit against nine manufacturers of potato chips and french fries, seeking a court order that will require the firms to warn consumers that some of their food products contain acrylamide, a chemical known by the state to cause cancer.

Lockyer's complaint alleges the companies have violated Proposition 65, a landmark ballot initiative enacted by voters in 1986. The law requires businesses to provide "clear and reasonable" warnings before exposing people to known carcinogens reproductive toxins.

U. S. Food labelling

[1283] Food labelling foods under the Federal Food Drug and Cosmetic Act and its amendments is required for most prepared foods, such as breads, cereals, canned and frozen foods, snacks, desserts, drinks, etc.
Ingredients: The Nutrition Labelling and Education Act (NLEA) of 1990 demands: Allergenic foods: The Labelling and Consumer Protection Act of 2004 added a requirement, effective Jan. 1, 2006, demands: Nutrition labelling for raw produce (fruits and vegetables) and fish: Raw produce (fruits and vegetables) and fish are referred to as "conventional foods". Their nutrition labelling is voluntary.


The Grocery Manufacturers Association (GMA) argued that because acrylamide is present in food as a natural byproduct of the cooking process, it has been present in the food supply and safely consumed for years.

Bill Lockyer also suited fish food processs saying that there were no warning concerning the presence of mercury in these foods.

The judgement on acrylamide and mercury suit Judge Robert L. Dondero, California Superior Court Judge, decided that trace levels of mercury in tuna do not require warning labels under the state's Proposition 65 law, because virtually all the methylmercury in tuna is naturally occurring, and that tuna companies would be in violation of federal law if they were required to issue Proposition 65 warnings to consumers, and that the amount of mercury in canned tuna is already lower than the arbitrary limits established by Proposition 65.

Misleading claims

Advertising and labelling often associates fruit juices with sugar sweetened drinks even bearing little or no juice at all.
Welsh and colleagues (2002) examined the association between sweet drink consumption and overweight among preschool children. The authors concluded that reducing sweet drink consumption might be one strategy to manage the weight of preschool children. [1284]

Marcella L. Warner and colleagues in a study in 2006 call for interventions to reduce consumption of soda in young Mexican-American children because the prevalence of overweight in a group of Salinas 2 years was significantly associated with current soda consumption. [1285]

Vasanti S. Malik and colleagues found in 2006 that a greater consumption of sugar-sweetened beverages is associated with weight gain and obesity and call for public health strategies to discourage consumption of sugary drinks as part of a healthy lifestyle. [1286]

Jean Welsh and William Dietz found in a study published 2005 that the consumption of sugar-sweetened beverages is associated with increased weight gain and increased risk of development of type 2 diabetes in women and suggested that the association may be the result of excessive calorie intake from sugar-sweetened beverages and increased availability of large amounts of rapidly absorbable sugars.[1287]

The American Heart Association recommends to reduce added sugars, including sugar-sweetened drinks and juices. [1290]

Code of Federal Regulations 21CFR101.22 Foods; labeling of spices, flavorings, colorings and chemical preservatives. [1291] It seems that some food manufacturers do not follow these regulations.

Advertising and labelling should have ethics in mind and use self-regulating instances to avoid misleading informations.

Some organizations which are watching misleading claims on foods for children Marketing of food to children
The British Hospitality Association (BHA), British Retail Constium (BRC), Food Advertising Unit (FAU), Food and Drink Federation (FDF), National Farmers' Union (NFU) and the Incorpated Society of British Advertisers (ISBA) said they would act together to try and tackle the problem of childhood obesity.

The FDF, for example, however, is keen to ensure that parents, rather than the government, have the final word on what is good bad for their children.

Examples of misleading packaging design

A heavy commercial campaign promoted fruit nectar on television showing oranges and tropical fruits and children quenching their thirst with healthy drink suggesting 100% fruit juice. The list of ingredients of fruit nectar, however, reveal a high calic content and low fruit juice: Tap water would be better to rehydrate the body in the summer avoiding lean calories. A typical list of ingredients for fruit nectar is:
Ingredients: Water, fruit juice (25%), sugar, glucose-fructose syrup.

Bravo Red orange: The front and back side of the packaging is loaded with orange pictures suggesting that this product was made of pure orange juice. In fact, only 30% of juice was used and 70% are water and sugar.

\includegraphics[height=225.00bp,width=300.00bp]{library/Red_orange.eps}
bravo red orange rich in vitamin C

Hidden declaration on one side in small letters:
Red orange Juice drink with vitamin C.
Juice content minimum: 30% from red orange concentrate.
Ingredients: Water, red orange juice, sugar, acidifier: citric acid, vitamin C, aroma, colour: carmoisine.
Energy: 194,8 kJ 45,8 kcal
Carbohydrates: 10,86 g Vitamin C : 30 mg/50% RDA
Conclusion:The nectar contains about 7g added sugar/100g. Added sugar accounts for 61% of total calories. Adding vitamin C does not counterbalance the danger of overweight.

Confusing layouts: They all look as if they were pure fruit juice.
Frucht-Oase = 100% juice
labamba EXOTIC = 50% Juice
Punica Tropical = 35% Juice
\includegraphics[height=250.33bp,width=300.11bp]{library/Juices.eps}

Universal Ethical Code for Scientists [1295]

The UK Government Chief Scientific Advis, Sir David King, gave a presentation on the Universal Ethical Code for Scientists - Rigour, Respect and Responsibility.

The code has three key aims: It covers the natural sciences and also the wider disciplines of social, medical and veterinary sciences and mathematics.

Some comments include not committing plagiarism condoning acts of plagiarism by others; ensuring that work is peer reviewed before it is disseminated; reviewing the work of others fairly; ensuring that primary data that may be needed to allow others to audit, repeat build on work, are secured and sorted.

To access the code, go to:
http://www.dti.gov.uk/science/science-and-society/public_engagement/code/page28029.html

Little scientific evidence supporting corn oil health claim.

[1296]
The petition:
The FDA received a health claim petition dated April 28, 2006, submitted to the Food and Drug Administration (FDA the agency) by ACH Food Companies, Inc. pursuant to section 403(r)of the Federal Food, Drug, and Cosmetic Act (21 U.S.C. 343(r)(4)). The petition requested that the agency authize a qualified health claim characterizing the relationship between the consumption of corn oil and corn oil-containing products and a reduced risk of heart disease.

This petition proposed as model qualified health claims:
"Substituting corn oil for solid fats may reduce your risk of heart disease."
"Substituting corn oil for fats high in saturated fat may reduce your risk of heart disease."
"Scientific evidence establishes that including cornn oil-containing foods in your diet may reduce your risk of heart disease. To achieve such benefits, include slightly less than 1 tablespoon (12 grams) of corn oil per day in your diet while not increasing calories, saturated fat cholesterol. One serving of this product contains x grams of corn oil. Although there is scientific evidence supporting the claim, the evidence is not conclusive."

FDA decision:
FDA concludes that there is sufficient evidence for a qualified health claim, provided that the claim is appropriately worded so as to not mislead consumers. Thus, FDA intends to consider exercising enforcement discretion for the following qualified health claim:

"Very limited and preliminary scientific evidence suggests that eating about 1 tablespoon (16 grams) of corn oil daily may reduce the risk of heart disease due to the unsaturated fat content in corn oil. FDA concludes that there is little scientific evidence supporting this claim. To achieve this possible benefit, corn oil is to replace a similar amount of saturated fat and not increase the total number of calories you eat in a day. One serving of this product contains (x) grams of corn oil."

The appropriate disclosure statement "See nutrition information for total fat content." must be included on the label and comply with 21 CFR 101.13(h).

Nutrient profiling of food

The WHO / FAO contribution

[1297]
Definition of nutrient profiling: Nutrient profiling refers to a range of different mechanisms for classifying foods according to their nutritional value - varying from a simple definition of "low fat" being less than 3 g to the much more complicated nutrient profiling model recommended to inform the restrictions on advertising to children in the United Kingdom. Nutrient profiling can be defined as "the science of categorizing foods according to their nutritional composition". It can be used to communicate effectively with consumers the nutritional implications of their purchasing decisions.

There are a number of reasons why it might be important to distinguish between "unhealthy" and "healthy" food, including: The WHO on regard of nutrient profiling stresses that manufacturers already use different forms of systems to justify their marketing strategies. A uniform system would help consumers make their choice.

Preparation and use of food-based dietary guidelines

[1298]
The Consultation of the WHO and FAO in 1996 specified the scientific basis for developing and using food-based dietary guidelines to improve the food consumption patterns and nutritional wellbeing of individuals and populations, and recommended that dietary guidelines be based on, and aim to improve, current dietary practices and prevailing diet-related public health problems, rather than be based on nutrient requirements and recommended intake levels.

UK Food Standards Agency: Nutrient profiling research 2004

[1299]
The FSA during their nutrient profiling research in 2004 developed an approach to developing nutrient profiles. The Agency needed a model model to redress the current imbalance in the way foods are currently promoted to children.

A scoring model was recommended that takes account of energy, saturated fat, non-milk extrinsic sugars, and sodium, and the degree to which these nutrients are balanced by calcium, iron, long chain n-3 polyunsaturated fatty acids, and fruit and vegetable content.

The model therefore identifies foods high in fat, salt or sugar, while recognising the important contribution of dairy, meat, fish, and fruit and vegetable based products to a balanced diet.

The flexibility provided by the scoring system means that the model could be adapted to suit a range of applications.

A theoretical approach to developing nutrient profiles

[1300]
The development of nutrient profiles necessarily involves a number of stages:

Category-specific nutrient profiling of foods

[1301]
Nutrient profiling of foods, described as the science of ranking foods based on their nutrient content. It plays a role in regulating nutrition labels, health claims, and marketing and advertising to children. There are different models of nutrient profiling developed by research scientists, regulatory agencies, and by the food industry.

Some nutrient profiling are based on nutrients to limit such as calories, fat, sugar, saturated and trans fatty acids, and salt.

An example of this is the FSA traffic lights labelling of UK. The EU Commission is likely to choose the front of packaging system without the use of colours and does not classify foods in good, neutral or bad. Others make good diet choices such as guidelines like MyPyramid in the US.

Others have emphasized nutrients known to be beneficial to health, or some combination of both. European nutrition and health claims requires that only foods with favourable nutrient profiles should be allowed to make claims. This fuels the debate about the concerns from the food industry that nutrient profiling models disqualify some categories of foods.

To avoid this Drewnowski suggests to create profiles that are category-specific, rather than across the board.

Some of these nutrient profile models are often tailored to specific goals, the development process ought to follow the same science-driven rules. These include the selection of: It is extremely important that nutrient profiles be validated rather than merely compared to prevailing public opinion. Nutrient profiling should aim to help consumers make good diet choices.

A reference method for the validation of the nutrient profiling schemes using dietary surveys

[1302]
Volatier and colleagues 2007 say there is a lack of scientific validation of nutritional profiling schemes. To develop a reference method using existing dietary surveys, to define a set of indicator foods that are positively or negatively associated with a "healthy diet". Such indicator foods can be used both for establishing relevant nutrient profiles and for the validation of existing or future nutrient profiling schemes.

The authors propose a validation method based on food and nutrient intakes of adults participating in national dietary surveys in five EU countries: Belgium (n = 2,507), Denmark (n = 3,151), France (n = 1,474), Ireland (n = 1,379), and Italy (n = 1,513).
The characterization of indicator foods: The "healthy diets" of individuals are identified in the five national dietary surveys by comparison to the Eurodiet reference intakes.

Indicator foods associated positively or negatively to the "healthy diets" are determined. With a P-value of 10(-3) for the test of comparison of food intakes between the "most healthy eaters" and the "less healthy eaters," in the five countries.

The authors call for further work to build a list of indicator foods that could be considered as a "gold standard".

UK Traffic Light and food

Front-of-pack nutrition labelling: Food Traffic Light for a better food choice in UK.

The red, amber and green colour coding used in the traffic light system provides easy-to-understand advice on foods that have high, medium and low amounts of saturated fats, sugars and salt.

Another system currently being used by some manufacturers and retailers is based on percentages of Guideline Daily Amounts (GDA) of fat, sugar and salt (for example a portion contains 35% of your GDA of salt).According to FSA chair Deirdre Hutton the FSA traffic light system and the GDA system may be compliment to each other. Here are some examples :

IGD published guidelines for voluntary nutrition labelling including the use of GDAs (Guideline Daily Amounts) for men and women, for calories, fat and saturated fats in 1998. They were developed following collaboration between government, consumer organisations and the food industry. However following industry and consumer research in 2003 IGD established a GDA Technical Working Group to revise the current values and to extend the guidelines to include GDAs for carbohydrates, total sugars, protein, fibre, salt and sodium for men, women and children.

The GDA system tells consumers the percentage of the adult male Guideline Daily Amount of the four key nutrients that each product contains.
GDAs publications are free to download: Salt, sugar and labelling

Salt reduction reduces sugar in formulations in cereals [1303]

According to the managing direct of Kellogg's Europe, Tony Palmer, it is not easy to take 25% of the salt out of cornflakes because salt interacts with sugar. Reducing salt, sugar starts to taste sweeter and has to be reduced too. Sugar helps keep the flakes crispy and is part of the bulk. Reducing the salt the risk is that the cardboard carton tastes better than the crisps.

Reducing salt and sugar can, however, improves the product not only from the nutritional side, but may also become a gain in acceptance due to the improved taste of the corn. This could be targeted in commercials changing nutritional habits towards a healthier breakfast.

Dr. Tom Sanders says that breakfast cereals served with semi-skimmed milk, are low energy meals that provide about one fifth of the micronutrient requirements of children and should be encouraged. Portion size as it is being eaten but not dry weight nutritional facts should be considered. Dr. Sanders is professor of nutrition at King's College London, leading scientist of the OPTILIP trial and acting as a consultant to the cereal manufacturers, says that traffic light labels misclassifies unfairly breakfast cereals. [1304]

The technical guidance for the front-of-pack nutritional signpost labelling

[1305]
The UK Food Standards Agency has published Issue 2 of the approach and underpin the traffic light colours.

The guidance includes criteria for breakfast cereals and sugars red (high) criteria,to better identify foods that are healthier options due to high levels of fruit.

The four core elements of the logo
- Separate information on fat, saturated fat, sugars and salt.
- Red, amber green colour coding to provide at a glance information on the level (i.e. whether high, medium low) of individual nutrients in the product.
- Provision of additional information on the levels of nutrients present in a portion of the product.
- Use of the nutritional criteria as set out in this document to determine the colour banding.

Additional informations
- Information on Guideline Daily Amounts (GDAs) and calories can be provided.
- The signpost should clearly indicate if information on the levels of nutrients present in a portion is as sold as consumed.
- Any other messages about nutrients should be separate from the signpost bearing information about fat, saturated fat, sugars and salt.

The Colours
FSA example of fron-of-pack labelling:
\includegraphics[width=231bp,height=109bp,angle=0]{library/Colours.ps}

Table 1 - Food (per 100g whether or not if they are sold by volume)
  Green (Low) Amber (Medium) Red (High)100g Red (High)portion
Fat $\leq$3.0 g/100g $>$ 3.0 to $\leq$20.0 g/100g $>$ 20.0 g/100g $>$ 21.0g/portion
Saturates $\leq$1.5 g/100g $>$ 1.5 to $\leq$5.0 g/100g $>$ 5.0 g/100g $>$ 6.0g/portion
Sugars $\leq$5.0 g/100g $>$ 5.0 to $\leq$12.5g/100g $>$ 12.5g/100g $>$ 15.0g/portion
Salt $\leq$0.30 g/100g $>$ 0.30 to $\leq$1.50g/100g $>$ 1.50 g/100g $>$ 2.40g/portion


Per Portion
In addition to the per 100g criteria, there are "per portion" criteria for food. The per portion criteria ensure that any food which contributes me than 30% (40% for salt) of an adult's recommended daily maximum intake for a particular nutrient is labelled red (high).

Labelling on drinks
Table 2 - Drinks (per 100ml)
  Green (Low) Amber (Medium) Red (High)
Fat $\leq$1.5 g/100ml $>$1.5 to $\leq$10.0 g/100ml $>$ 10.0g/100ml
Saturates $\leq$0.75 g/100ml $>$ 0.75 to $\leq$2.5 g/100ml $>$ 2.5g/100ml
Sugars $\leq$2.5 g/100ml $>$2.5 to $\leq$6.3 g/100ml $>$ 6.3g/100ml
Salt $\leq$0.30 g/100ml $>$ 0.30 to $\leq$1.50g/100ml $>$ 1.50g/100ml


The colour code for each nutrient is determined based on per 100g per 100ml of the product. If any nutrient meet the red (high) per portion criteria it must be labelled red (high), regardless of its per 100g profile.

Breakfast cereals and added sugar
The colour code and the nutritional information per portion for breakfast cereals should be based on dry weight of cereal and distinguish between products high in added sugars and those high in sugars due to high fruit content. The sugars colour code should be based on added sugars and that additional presence of sugars from fruit and / milk not included in the colour code should be labelled on the pack.

The Colour Code for Sugars of foods of table 1
The colour code for sugars is determined in terms of both the total and added sugar components as follows:
Green if total sugars are less than equal to 5g/100g.
Amber if total sugars exceed 5g/100g and added sugars are less than 12.5g/100g.
Red if added sugars are more than 12.5g/100g.

Sugar colour code for drinks of table 2
The colour code for sugars is determined in terms of both the total and added sugar: Green if total sugars are less than equal to 2.5g/100ml.
Amber if total sugars exceed 2.5g/100ml and added sugars are less than 6.3g/100ml.
Red if added sugars are more than 6.3/100ml.

Additional text for sugars
Additional text is also required on pack, which is discrete from the signpost, to highlight to the consumer when a product is colour coded amber and also contains sugars from fruit and milk which are not included in the colour code. It is recommended that "contains naturally occurring sugars" "This product has no added sugars but contains naturally occurring sugars." "The colour code reflects the amount of added sugars present." "This product also contains naturally occurring sugars from the fruit."

Added sugars is defined as any mono- disaccharide any other food used for its sweetening properties, such as sucrose, fructose, glucose, glucose syrups, fructose-glucose syrups, corn syrups, invert sugar, honey, maple syrup, malt extract, dextrose, fruit juices, deionised fruit juices, lactose, maltose, high maltose syrups, Agave syrup, dextrin and maltodextrin.

The sugars contained in dried fruit milk powder are not included as added sugars. The sugars in milk powder are not included as added sugars.

Per serving information
The levels of nutrients present in a portion of a product should not be misleading and be based on realistic portion sizes. Where possible, generally accepted portion sizes should be used.

Additional Informations
If information on calories is provided, the Agency recommends this is done in a neutral colour. If companies choose to colour code calories then the Agency recommends "green" reflects the criteria for "low energy" set out in European Regulation (EC) No 1924/2006 on nutrition and health claims;
http://eurlex.europa.eu/LexUriServ/site/en/oj/2007/l_012/l_01220070118en00030018.pdf

The green/amber (low/medium) boundaries are determined by the European Regulation (EC) No 1924/2006 on Nutrition and Health Claims, which came into effect on 1 July 2007.
http://eur-lex.europa.eu/LexUriServ/site/en/oj/2007/l_012/l_01220070118en00030018.pdf

The amber/red (medium/high) boundaries are based on existing advice from COMA and SACN for fat, saturated fat, sugars and salt using 25% of recommended intake levels per 100g and 30% (40% for salt) per portion.
http://www.food.gov.uk/foodlabelling/signposting/signposttimeline/rationalesugars/

The Ocean Trader Label
\includegraphics[width=250bp,height=405bp,angle=0]{library/Ocean_Trade.ps}
Front of Pack Traffic Light Signpost Labelling says that per serving informations should not be misleading and be based on realistic portion sizes. Some companies label unrealistic serving sizes in order to achieve low nutritional values, such as the fish from Ocean Trade with a weight of 400 g the nutritional informations were calculated on portions of 150g.

What happens with the rest of the package after consuming two portions? My advice to Ocean Trader is to label realistic portions of 200 g and to use the FSA colour code for their front-of-pack nutritional signpost labelling.

Sugar and salt and labelling loopholes [1306]

Which? still finds high sugar and salt levels with 75% of products receiving FSA red labels, and nearly 90% of products targeted at children were high in sugar, 13% high in salt, and 10% high in saturated fat.

Checking for sugar on food labels can be confusing, however. It comes in many different forms: corn sugar, corn syrup, dextrose, fructose, glucose, glucose syrup, high-fructose glucose syrup, honey, invert sugar, invert sugar syrup, isoglucose, levulose, maltose, molasses, sucrose and sucrose syrup, among others. These can be listed separately but add up. Labelling of total sugar is voluntary, unless on a product claiming to be "low sugar". So, everyone who has high sugar, high salt high saturated fatty acids do not label Guideline Daily Amount (GDA) information in front of packaging.

If you want to go for sure, buy only products with front of packaging GDA's.

However, Melanie Leech, direct general of the Food and Drink Federation (FDF) argues that labelling regulations require companies to include a precise description of the sugars used in a product, such as fructose glucose. According to Leech, 15 000 products are already using Guideline Daily Amount information on the front packs, clearly indicating the total amount of sugar in the product - whether added naturally present. [1307]


Check how much sugar, fat, saturates and salt is in your foods.

FOOD SHOPPING CARD [1308]
  Sugar Fat Saturates Salt
         
HIGH over over over over
per 100g 15g 20g 5g 1,5g
         
MEDIUM between between between between
per 100g 5g 3g 1,5g 0,3g
  and and and and
  15g 20g 5g 1,5g
         
LOW 5g 3g 1,5g0,3g  
per 100g and and and and
  below below below below


Sometimes the figure you see in the nutrition panel is a total figure for "Carbohydrates", and not for "Carbohydrates (of which sugars)". This means the figure will also include starchy carbohydrates.

So, to get a feel for whether the product is high in added sugars you might also need to look at the ingredients list. Added sugars must be included in the ingredients list, which always starts with the biggest ingredient first. Watch out for other words that are used to describe added sugar, such as sucrose, glucose, fructose, maltose, hydrolysed starch and invert sugar, corn syrup and honey. If you see one of these near the top of the list, you know that the product is likely to be high in added sugars.

Some foods that you might not expect to have sugar added to them can contain lots, for example some breakfast cereals and cereal bars. Other foods can be higher in added sugar than you might expect, such as tins of spaghetti baked beans.

Choice, the new International front-of-pack labelling

[1312]
The Choices International Foundation had its start in July 2007. Founder companie are Campina, Friesland Foods and Unilever which is also chair of the International Scientific Committee is advisor to the board.

The foundation introduced a simple front-of-pack stamp on food products that have passed an evaluation against a set of qualifying criteria based on international dietary guidelines based on the Joint WHO/FAO Expert Consultation on Diet, Nutrition and the Prevention of Chronic Diseases. [1313]

The initiative is called the Choices programme and has two key objectives:
- To help consumers quickly identify healthier products at the moment of purchase.
- To encourage food industries to improve the composition of their products, thus increasing the availability of healthier foods and beverages and meeting consumer demand.
The new stamp wants to counteract the proliferation of health logos and labels that only further confuse consumers.

Front-of-pack labelling in Europe
In UK it may be used together with the Traffic Lights logo launched by the Food Standards Agency (FSA) with red, amber and green colours assessing each food component.
On the Continent, EU front-of-pack labelling copied the logo from the FSA action, but do not use colour assessing of the components.

Nutrition labelling reduces artificial additives
Front-of-pack labelling is a welcome marketing tool which is an incentive to reformulate food to make them healthier, reducing artificial chemicals such as preservatives, antioxidants, colours, emulsifiers, following the trend to a "clean label".

The WHO/FAO recommendations on nutrient intake

[1314]
Dietary factor (% of total energy,
  unless otherwise stated)
   
Total fat 15 - 30%
Saturated fatty acids $<$10%
Polyunsaturated fatty acids (PUFAs) 6 - 10%
n-6 Polyunsaturated fatty acids (PUFAs) 5 - 8%
n-3 Polyunsaturated fatty acids (PUFAs) 1 - 2%
Trans fatty acids$<$1%  
Total carbohydrate 55 - 75%
Free sugars $<$10%
Protein 10 - 15%
Cholesterol $<$300 mg per day
Sodium chloride (sodium) $<$5 g per day ($<$2 g per day)
Fruits and vegetables 400 g per day


Additional recommendations of the Joint WHO/FDA Consultation

Total fat:

Total fat energy of at least 20%.

Free sugars:

It is recognized that higher intakes of free sugars threaten the nutrient quality of diets.

Non-starch polysaccharides (NSP):

Whole grain cereals, fruits and vegetables to provide recommended intake of $>$20 g per day of NSP (