Since December 2016, nutrition labelling in the EU and UK has been mandatory. This must include the energy value of the food as well as the amounts of total fat, saturates, carbohydrate, sugars, protein, and salt. Other information can be included but voluntarily, for example monounsaturated or polyunsaturated fat, fibre, or vitamins. This declaration typically forms the back of pack labelling (BOPL), and is done so in tabular format, unless space dictates it be done in linear format. Energy values must be in both kilo joules (kJ) and kilo calories (kcal), and nutrients must be displayed in grams (g).
Where does front-of-pack labelling (FOPL) come into play?
FOPL is simplified nutrition information to help consumers make healthier food choices. These either repeat information contained on the BOPL, as in the UK with the ‘traffic light system’ which highlights amounts of fat, saturated fat, sugar, and salt, or it can be an overall assessment of the quality of the food, for example the Nutri-Score system developed in France. In May 2020, the European Commission published it’s Farm to Fork (F2F) strategy, which makes up part of the European Green Deal. F2F aims to make food systems fair, environmentally friendly, and healthier. One way of promoting healthier diets is the harmonisation of FOPL across the whole of the EU.
The Nutri-Score system is considered the most likely option to be implemented across the 27 members of the EU, as this has already been adopted by Belgium, Luxembourg, Spain, Germany, and the Netherlands (Santé publique France, 2021). There is evidence that the Nutri-Score system increases the likelihood of selecting more healthy products (Song et al. 2021), and that purchases of foods higher in total energy, sodium, and saturated fat decreased with the NutriScore system in place (Croker et al. 2020). Clearly, there is a benefit to the NutriScore system, and given its status as the most studied systems in the EU (van der Ben at al. 2022), it makes sense that the NutriScore be the system to be implemented. So why is there so much debate about this?
Italy gives NutriScore an ‘E’ rating.
In August 2022, the Italian Competition Authority (AGCM) announced that Nutri-Score will not be used on the basis that the NutriScore system does not consider the traditional context or appropriate portioning of certain foods, such as oil and cheese. Ratings are based on a calculation using an alogirhtm that subtracts from the total value of “unfavourable” components, such as total energy, fat and sugar, from the total value of “favourable” components – fibre, protein, percentage of fruit and vegetables etc. This is done on a ‘per 100 g’ or ‘per 100 ml’ basis, which the AGCM argues is not appropriate for the aforementioned items, which are consumed in smaller quantities. This also ignores the healthful components of these items; it is well known that olive oil is an important component of the Mediterranean diet, considered one of the highest quality diets in the world, yet under the NutriScore, olive oil would have the lowest rating, ‘E’ due to its fat content. The NutriScore is clearly an imperfect system to tackle a complex and nuanced problem that cannot be simplified easily into a simple traffic light system. This is highlighted by the British Dietetic Association’s consultation on Front of Pack Labelling (BDA, 2020) with the examples shown below. These four cereals have different compositions, indicated by the Traffic Light system below each image, yet they all score ‘D’ on the NutriScore, meaning that differences in fat and sugar content are not captured by this system, and higher fibre cereals are perceived to be just as healthful as low fibre, high sugar cereal.
What other options are there?
Positive endorsement systems
These systems apply front of pack logos to food products based on certain criteria within their country of application. For example, the Nordic Keyhole Scheme, which is voluntary for food companies to utilise, requires the product in question to have a maximum threshold of total fat, a minimum amount of healthy fat, and dictates the product must contain no sweeteners, and cannot be targeted to children under 36 months; amongst other requirements (Swedish Food Agency). Similarly, to adorn the ‘Healthy Choice’ logo, a product must meet certain nutrient criteria, which includes total fat, saturated fat, protein, fibre, and iron. This cannot be applied to infant formula, dietary supplements, medical foods, or alcoholic or mineral beverages.
Traffic Light System
The Traffic Light System used in the UK is a mixture of red-amber-green colour coding along with percentage of reference intake to highlight amounts of fat, saturated fat, sugar, and salt. This graphic also contains the words ‘LOW’, ‘MED’ or ‘HIGH’ inside each box to reinforce the colour coding used, as well as the energy contents of each portion of the food item in both kilojoules and kilocalories. Colour coding is based of per 100g information for ‘low’ criteria (≤ 3 g per 100g of fat, (≤ 1.5 g per 100g of saturated fat, 5 g per 100g of total sugar, and ≤ 0.3 g per 100g of salt) and for total amounts per portion for ‘high’ criteria (≥ 21g per portion for fat, ≥ 6g per portion for saturated fat, ≥ 27g per portion for total sugars, and ≥ 1.8g per portion of salt).
Nutrient Specific Traffic Light System
In response to the 2012 Ecuadorian National Nutrition and Health Survey, which found that high prevalence of overweight and obesity (combined prevalence of 65.5% in females and 60.0% in males; ENSANUT-ECU 2012), the Ecuadorian government implemented traffic light nutritional labelling on all processed food and beverages. Unlike the UK’s traffic light system which is voluntary, this system is mandatory, although criteria for the system is similar (≤ 3 g and ≥ 21g per 100g for low and high fat content of food, respectively, and ≤ 5 g and ≥ 15g per 100g for low and high sugar content, respectively, etc).
Nutritional Warnings
Between June 2016 and June 2019, Chile implemented progressively stricter mandatory FOPL in the form of black octagonal warning labels (Nacional de Chile, 2015.) These highlight the amount of sugar, sodium and/or saturated fat of food products when exceeding set thresholds. Since the successful implementation of this policy, with evidence that ‘high-in’ product purchasing decreased even after the first phase of implementation (Taillie et al. 2021), Mexico, Peru, and Uruguay have also implemented mandatory use of these labels.
Nutritional Warnings
Between June 2016 and June 2019, Chile implemented progressively stricter mandatory FOPL in the form of black octagonal warning labels (Nacional de Chile, 2015.) These highlight the amount of sugar, sodium and/or saturated fat of food products when exceeding set thresholds. Since the successful implementation of this policy, with evidence that ‘high-in’ product purchasing decreased even after the first phase of implementation (Taillie et al. 2021), Mexico, Peru, and Uruguay have also implemented mandatory use of these labels.
Should any of these lead the (front of) pack instead of the NutriScore?
All schemes, programs and policies have pros and cons, and varying levels of success. Endorsement symbols are easy to recognise – around 90% of Dutch consumers recognise the Healthy Choices logo – and can therefore steer healthy choices easily. However, this is based off criteria not shown on the label and does not allow for identification of specific nutrient content which is important in the context of the overall diet. Traffic light systems such as in the UK provide detailed information, but this does not always lead to positive health outcomes (Croker et al. 2020). A downside of this level of information is not only the trade-off with how attention grabbing the FOPL is, but this also require greater nutritional literacy, especially given the potentially conflicting information of ‘green vs red’ contents. Nutritional warnings have been shown to be effective in South American countries, and could be considered, although this still has the inherent issue of NutriScore in that some food items would have to display the warning under set criteria yet are more healthy options, i.e. olive oil which is high in fat.
The right choice is difficult to label
Clearly, none of the systems are perfect, and have to weigh up the delicate balance of being eye-catching, informative, and not oversimplistic. The BDA in the UK stated that educational campaigns also need to be developed, as we cannot rely on FOPL alone to achieve the difficult task of achieving healthy diets. Rather, FOPL should complement people’s understanding of healthy nutrition in order to steer them towards healthier choices. On tops of this, no single food can be considered ‘good’ or ‘bad’ and should be taken in the context of the diet as a whole. There are calls for the labelling of artificial and highly processed food and not natural products which would receive poor NutriScore ratings, again olive oil being the chief example. Importantly, FOPL not only offers consumers a tool to help make better choices, but also food companies and manufacturers the opportunity to reformulate products to also aid the promotion of healthier diets.
References
Croker H, Packer J, Russell SJ, Stansfield C, Viner RM. Front of pack nutritional labelling schemes: a systematic review and meta-analysis of recent evidence relating to objectively measured consumption and purchasing. J Hum Nutr Diet. 2020 Aug;33(4):518-537. doi: 10.1111/jhn.12758.
Department of Health and Social Care, UK Government. Guide to creating a front of pack (FoP) nutrition label for pre-packed products sold through retail outlets (2013). Available online at: https://www.gov.uk/government/publications/front-of-pack-nutrition-labelling-guidance (updated 8th November 2016, accessed 13th July 2023).
ENSANUT-ECU. Encuesta Nacional de Salud y Nutriciόn, Tomo I. Available online at: https://www.ecuadorencifras.gob.ec/documentos/web-inec/Estadisticas_Sociales/ENSANUT/MSP_ENSANUT-ECU_06-10-2014.pdf (accessed 13th July 2023).
Nacional de Chile. Ministerio de Salud. Modifica Decreto Supremo N° 977, de 1996, Reglamento Sanitario de Alimentos. (2015). Available from: https://www.bcn.cl/leychile/navegar?i=1078836 (accessed 13th July 2023).
Santé publique France. Nutri-Score. (2021). Available online at: https://www.santepubliquefrance.fr/en/nutri-score (updated 10th July 2023, accessed 13th July 2023).
Song J, Brown MK, Tan M, MacGregor GA, Webster J, Campbell NRC, Trieu K, Ni Mhurchu C, Cobb LK, He FJ. Impact of color-coded and warning nutrition labelling schemes: A systematic review and network meta-analysis. PLoS Med. 2021 Oct 5;18(10):e1003765. doi: 0.1371/journal.pmed.1003765.
Swedish Food Agency. The Keyhole. (2022). Available online at: https://www.livsmedelsverket.se/en/food-and-content/labelling/nyckelhalet (reviewed 17th March 2022, accessed 13th July 2023).
Taillie, L. S., Bercholz, M., Popkin, B., Reyes, M., Colchero, M. A., & Corvalán, C. (2021). Changes in food purchases after the Chilean policies on food labelling, marketing, and sales in schools: a before and after study. The Lancet. Planetary health, 5(8), e526–e533. Doi: 10.1016/S2542-5196(21)00172-8
van der Bend, D. L. M., van Eijsden, M., van Roost, M. H. I., de Graaf, K., & Roodenburg, A. J. C. (2022). The Nutri-Score algorithm: Evaluation of its validation process. Frontiers in nutrition, 9, 974003. doi: 10.3389/fnut.2022.974003
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