CASH esponsd to FSA Letter re: Revision of Council Directive 90/496/EEC on the Nutritional Labelling of Foodstuffs

14th May 2007

Consensus Action on Salt and Health (CASH) is a group of medical scientists who are the leading experts in the UK on the relationship between salt and blood pressure. CASH was set up in 1996 with the aim of reaching a consensus with the food industry about the importance of salt in elevating blood pressure and to devise strategies to reduce salt intake in the UK in order to reduce the very large number of unnecessary strokes, heart attacks and heart failure. As far as it is able in conjunction with the food industry, Department of Health and the Food Standards Agency, CASH will seek to ensure that the target of 6 grams for all adults and much lower targets for children are achieved by 2010.  For further information please go to www.actiononsalt.org.uk.

Front of Pack nutrition signpost labelling

1. The Commission is considering including provisions for some form of front of pack nutrition signpost labelling in their proposals for revised nutrition labelling rules.  We would be interested to know whether you think the format of front of pack nutrition signpost labels should be prescribed and if so in what level of detail. If not, how would you suggest that schemes are regulated to ensure that consumers receive consistent, meaningful and transparent information both within Member States and across the EU?

It is essential that the nutrients to be included in front of pack labelling are prescribed by the Commission. In regards to salt, this should be salt per portion.

It is also essential the Commission prescribe a method of indicating whether this salt per portion is high, medium or low in relation to the recommended maximum daily intake. We recommend the Commission utilise the UK Food Standard Agency’s traffic light labelling method for this. However, we recommend that the cut off point for a product to be labelled red for salt should be no more than 30% of the maximum daily intake for an adult. Additionally, the Commission should prescribe that the salt per portion is expressed as a percentage of the recommended maximum daily intake.

Due to the differences in salt intakes used by different countries, we recommend that the WHO recommendation of 5g of salt a day for adults is used as the recommended maximum daily intake and that this becomes standard across the EU. This front of pack labelling combination of indicating whether the concentration of salt in the product is high, medium or low and the contribution the salt per portion makes to the recommended maximum daily intake is currently present on some ASDA own-label products in the UK and provides all the information a consumer requires to make an informed choice. There is mounting evidence in the UK that consumers prefer and understand better the traffic light signpost labelling system employed by some companies compared to the percentage of the maximum daily intake employed by others companies.

For products such as breakfast cereals, it should also be prescribed whether the front of pack labelling should include serving with milk. This is so that consumers can make an accurate comparison of products as some companies are not including the milk in the front of pack information making their products seem falsely better than competitors in terms of salt as their appears to be less salt.

In summary, the minimum nutrients to be included in front of pack labelling (salt per portion), the method and cut-off points for indicating whether this is high, medium or low and the method of indicating the product’s contribution to the maximum recommended daily intake should be mandatory and prescribed by the Commission. The WHO recommendation of a maximum of 5g of salt per day should be utilised when setting cut-off points for salt..

Mandatory nutrition labelling

2. The UK Government made a commitment in the Choosing Health white paper to seek mandatory nutrition labelling on prepacked foods, the Agency will be pressing for any new rules on nutrition labelling to be evidence based and to make sure that any costs to industry are reasonable and proportionate to the benefits that they provide to the consumer.  With this in mind, if nutrition labelling were to be mandatory should there be:

• exemptions for certain food items, non pre-packed goods, products sold in small packages or products packaged at point of sale?  If so which foods should be covered and why?

There should be no exemptions as the consumer should be able to access nutrition information for all foods so that they can make an informed choice. Products packaged a point of sale such as bread produced in a supermarket bakery are controlled in terms of ingredients and therefore nutrition information can be provided.

• concessions for SME’s such as derogations and if so what they might be and why?

• a requirement to label certain nutrients?  If so, which ones and why?  The Agency believes that there is a case for the labelling of calories, fat, saturated fat, salt and sugars.  Should additional nutrients be allowed to be declared on a voluntary basis?  If so, should these be restricted to those that are associated with public health issues?

CASH believe that salt per portion and salt per 100g should be labelled.

• nutritional information for alcoholic drinks?  If so, which nutrients should be required to be declared and why?  

Trans Fats

3. The current nutrition labelling rules do not allow businesses to give customers information on trans fat levels unless they make a claim.  Current dietary intakes, and voluntary industry action to reduce trans fats levels in foods, would not suggest that there is a need to introduce specific measures to ban or limit trans fats in foods.  However, we would be interested to hear your views on options for providing consumers with this information to enable them to make informed decisions on the foods that they buy when in the shopping environment?

Presentation of nutrition information

4. How should the amount of a nutrient present in a food be presented on the label - per 100g or per portion or both?  Are there other formats that would provide consumers with the information that they need to make informed choices?  Explain the rationale for your suggestion.

CASH believe that salt per portion and salt per 100g should be labelled. Salt per portion enables the consumer to understand the contribution a suggested portion will make to their daily intake. However, consumers also require information on the concentration of salt so that they can build up an understanding of which products are high in salt.

5. Should GDA information be harmonised at EU level and be included in the nutrition labelling panel?  How should GDA information be presented so that it is meaningful in an international market?

CASH believe that GDA information be harmonised at EU level as many products are sold across the EU and this will make it easier for companies to provide this information alongside the contribution that a product makes to the GDA. However, it is vital that it is always made clear whether the GDA is a maximum or a minimum for each nutrient. For example, it is not of benefit to health for consumers to believe that they must consume 5g of salt a day, it is essential that this is shown as a maximum target.

Respondents are also asked to provide assessments of costs and benefits of doing / not doing any of the above to help inform the Commission’s thinking when drawing up their proposals.

Based on the assumption that improved labelling of salt will reduce the amount of salt consumed, the benefit of mandatory labelling of salt would be the consequential reduction in blood pressure and the subsequent reduction in strokes and heart attacks. Recent research has shown that people who are able to reduce their salt intake by just 3g per day can reduce their risk of having a stroke or heart attack by one quarter .

CASH would also like to point out the economic costs of CVD and CHD to the UK. Please see the following information from the British Heart Foundation Statistics Website.
http://www.heartstats.org/datapage.asp?id=101 accessed 16th May 2007.

Both CVD and CHD have major economic consequences for the UK as well as human costs.   

Health care costs
CVD cost the health care system in the UK around £14,750 million in 2003. This represents a cost per capita of just under £250. The cost of hospital care for people who have CVD accounted for about 76% of these costs, that of drugs and of dispensing them for about 18%.   

CHD cost the health care system in the UK around £3,500 million in 2003. This represents a cost per capita of just under £60. The cost of hospital care for people who have CHD accounted for about 79% of these costs, that of drugs and of dispensing them for about 16%.   

Non-health care costs
Looking only at the cost of CVD to the health care system grossly underestimates the total cost of CVD in the UK.   Production losses from death and illness in those of working age and from the informal care of people with the disease contribute greatly to the overall financial burden.   

In 2003, production losses due to mortality and morbidity associated with CVD cost the UK over £6,200 million, with around 60% of this cost (£3,677 million) due to death and 40% (£2,556 million) due to illness in those of working age. The cost of informal care for people with CVD in the UK was over £4,800 million in 2003.

In 2003, production losses due to mortality and morbidity associated with CHD cost the UK over £3,100 million, with around 70% of this cost (£2,173 million) due to death and 30% (£961 million) due to illness in those of working age. The cost of informal care for people with CHD in the UK was around £1,250 million in 2003.

Total costs
Overall CVD is estimated to cost the UK economy just under £26 billion a year. This represents an overall cost per capita of £434. Of the total cost of CVD to the UK, around 57% is due to direct health care costs, 24% to productivity losses, and 19% to the informal care of people with CVD.

Overall CHD is estimated to cost the UK economy over £7.9 billion a year. This represents an overall cost per capita of £133. Of the total cost of CHD to the UK, around 45% is due to direct health care costs, 40% to productivity losses, and 16% to the informal care of people with CHD.