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If the Policy Review results in a voluntary system with incentives, can you give us suggestions for incentives?

No. CSPI is adamantly opposed to a voluntary labelling system.

If the Policy Review results in a mandatory system with exemptions, what foods and businesses would you see exempted?

All foods (including fresh meat, poultry, fish, seafood, fruits and vegetables) should carry nutrition labels with the following limited exceptions:

1.      Foods that contain insignificant amounts of all core list nutrients (e.g., many spices) need not disclose any nutrition information provided that:
a.      They do not contain amounts of other nutrients which could give rise to public health concerns if consumed in excessive quantities; and
b.      The product label bears no nutrient content claims or other health- or nutrition-related information or symbols.
2. Foods contained in small packages could be permitted to list the required information in text form. In extreme situations, where listing the required information is physically impossible, manufacturers could be permitted to merely display a toll-free number which consumers can call to retrieve the required nutrition information in both official languages.
3. Foods sold in bulk should be required to provide nutrition information at the point-of-sale through a bin label in the same standardized format as is required on a packaged food label.
4. Food combined on the premises of a retail business may be exempted to accommodate concerns about the difficulty that retailers may have in providing nutrition information for such foods. This exemption should not apply to chain stores that combine foods in central processing plants for sale in retail stores.
5. Foods served in restaurants may be subject to special requirements. While it would be beneficial to require that menus — at least at chain restaurants — provide nutrition information, we acknowledge that such labelling may go beyond the scope of this consultation and fall outside the jurisdiction of the federal government.
6.Alcoholic beverages should be prohibited from bearing full nutrition labels because, though some types of alcohol may provide minimal amounts of beneficial nutrients, consumption of alcohol presents too many adverse health consequences to justify nutritional information being used for promotional purposes. However, it would be valuable for them to disclose the calorie content per serving. Considering the prevalence of obesity, it is important for consumers to be alerted to the ample calorie content of alcoholic beverages.
7. Foods normally used in religious ceremonies (where those foods are not consumed for nutritive purposes) should be exempted from nutrition labelling requirements.
8. Foods manufactured, packaged, or distributed by companies that have less than $500,000 in gross annual revenues, produce fewer than 10,000 average units of the relevant food product, and employ fewer than ten employees in either of the two calendar years prior to the sale of the food could be exempted provided that the food bears no nutrient content claim on labels or in advertising.
We currently have a voluntary nutrition labelling system. Do you want it to change to a mandatory system? Why?

CSPI believes that a voluntary nutrition labelling system is woefully inadequate and should be changed to a mandatory scheme for the following reasons:

Mandatory rules are necessary because many manufacturers will not provide nutrition information unless forced to do so.

Under the current voluntary system, about half of all packaged foods do not provide any nutrition information.(20) Those foods include major brand name products such as:

• Heinz Tomato Ketchup• Campbell’s Chicken Gumbo Soup
• Coca-Cola Classic• Green Giant Cream Style Corn
• Hormel Spam Luncheon Meat• Hellmann’s Real Mayonnaise

Interestingly, products that are sold in the U.S. under the same brand name have complete nutrition labelling. This shows that, in many cases, manufacturers already have extensive nutrition information about their food products, but choose not to share this information with Canadian consumers. This is particularly troublesome when a food, like many of those listed above, is high in fat, saturated fat, trans fat, cholesterol, added sugars, or sodium. For example, an American consumer can read on the label of Hellmann’s Mayonnaise that a one-tablespoon serving contains 11 grams of fat, but Canadian consumers are provided with no information at all.

Simply revising the current voluntary labelling system will not motivate manufacturers to provide nutrition information. In fact, the probable expansion of current voluntary core list will create additional disincentives for manufacturers to voluntarily provide this information. Manufacturers may determine that the new labelling requirements are too burdensome or that the additional nutrient disclosures do not favourably portray their products. As a result, revising the current labelling requirements without making them mandatory may have the unintended consequence of decreasing the amount of nutrition information that is supplied to consumers. Thus, nutrition labelling must be made mandatory.

The current voluntary nutrition labelling system may deceive consumers.

Under the current labelling scheme, nutrition information is required only when a product label makes a nutrition claim. When a nutrition claim is made, only the amount of the nutrient (or related nutrients) for which the claim is made must be disclosed, but companies may voluntarily list other nutrients as desired. Because manufacturers may list selected nutrients and are not required to list the amount of other important nutrients, consumers are often deceived about a food’s overall nutritional value.

For example, the label of Campbell’s V8 Cocktail reveals that it has little fat and is a good source of vitamins A and C. Based on this information, consumers might logically assume that V8 is a very healthful drink. However, the label fails to disclose that V8 also contains very high amounts of sodium.(21) That information is important for consumers who are trying to follow a healthful diet and is absolutely essential for those who are medically advised to limit their sodium intake.

Similarly, the label of Mr. Skinny Low Fat Noodles in a Cup states that there are only two grams of fat per serving. Based upon this limited information, consumers may erroneously assume that this is also a heart-healthy food. However, the label fails to disclose that a serving also contains 1340 milligrams of sodium — more than half of the daily maximum recommended by most health authorities.(22)

A package of Dare Real Fruit Gummies, featuring pictures of assorted fruits, boasts that they are “fat free” and made “with real fruit.” In light of those claims, consumers might incorrectly conclude that this product is a healthy snack and a good source of fruit and vitamin C. However, the label fails to inform consumers that the entire bag contains only a minimal amount of vitamin C, as well as considerable amounts of added sugars.(23)

Furthermore, even the mere absence of nutrient disclosures misleads many consumers. A recent survey revealed that 49% believe that if a nutrient is not listed on a food label, then it is not present in the food.(24)

A voluntary labelling system allows manufacturers to mislead consumers by selectively disclosing or withholding information to make products appear more healthful than they really are. Full, mandatory nutrition labelling is thus essential to ensure that food companies do not deceive consumers.

Mandatory nutrition labelling will help consumers select more healthful foods and reduce their risk of disease.

Many products have no nutrition labels at all, while others carry labels that selectively omit information about important nutrients. A voluntary labelling scheme makes it extremely difficult for Canadians to reduce their intake of fat, limit their intake of sodium, increase their intake of fibre, or follow other nutrition recommendations. Only mandatory nutrition labelling will enable consumers to follow the advice of health professionals and improve their diets.

In the U.S., nutrition labels are extremely useful for consumers in selecting healthful foods. A recent survey found that 80% of adults read nutrition labels on packaged food.(25) Similarly, a survey conducted shortly after nutrition labelling became mandatory revealed that 61% of American shoppers almost always read the nutrition label when they purchased a food for the first time.(26) Many Americans read the nutrition label to avoid foods that are high in particular nutrients, especially fat, calories, sodium, and saturated fat.(27) 59% of American consumers said they stopped buying a food product, and 56% said that they switched to a different brand, because of something they read on the nutrition label.(28) Fat content was the most common reason why American shoppers decided to stop buying a particular product, while sodium and calories were other frequent motivating factors.(29)

Surveys in the U.S. have also found that shoppers on a restricted diet are more likely than those with no specific restrictions to check the nutrition label for information about sodium, cholesterol, and saturated fat.(30) For example, patients with hypertension or elevated cholesterol levels are more likely to look for sodium and fats, respectively, on the nutrition label.(31) Another study showed a high statistically significant association between reading nutrition labels and eating a lower-fat diet. Those who read labels consume approximately 30% of their calories from fat, while those who do not read labels consume about 35%. The researchers interpreted this finding as evidence that persons who wish to reduce fat intake are using nutrition labels to help them select lower-fat foods.(32)

Such changes in nutrient intake may generate large public health benefits. For example, in the U.S., estimates of the number of discounted life-years gained nationwide for the first 20 years after the implementation of mandatory nutrition labelling in the U.S. range from 40,000 to 1.2 million.(33)

Mandatory nutrition labelling will encourage food manufacturers to produce healthier foods.

If all foods are required to provide nutrition information, food companies will be encouraged to compete on the basis of nutrition.(34) As a result, they will be more likely to reformulate their products and provide new healthier items.

In fact, that is exactly what happened in the U.S. Since nutrition labelling became mandatory in 1994, manufacturers have reformulated hundreds of food products and introduced more than 5,000 new low and reduced-fat foods. The U.S. Food and Drug Administration (FDA) studied the impact of the new labelling regulations on market trends and concluded that “there have been impressive changes in the availability and market share of food products promoted on the basis of health and nutrition.”(35) The FDA documented the market response in a number of product categories suitable for the introduction of fat-modified versions of traditional products: cookies, cheese, crackers, peanut butter, and tortilla/corn chips. In every case, the FDA found “impressive simultaneous increases in new product introductions and market share for the fat-modified products.” For example, the market share for fat-modified cookies increased from nearly zero in 1991 to 15% in 1995. Fat-modified cheeses more than doubled their share of cheese sales from 4% to 10%.

Mandatory nutrition labelling will likely result in a greater number and variety of healthier, reformulated food products that will give Canadian consumers more choices and a better ability to improve their diets. Moreover, consumers who may not even read nutrition labels will still benefit from these product reformulations. Under a voluntary system, manufacturers will not have as much incentive to improve the nutritional quality of their products since they can simply choose not to disclose nutrition information and avoid competing in the marketplace on the basis of health.

Mandatory nutrition labelling will result in financial savings to the health care system.

Mandatory nutrition labelling will likely result in a decrease in consumers’ intake of fat, saturated fat, and other undesirable nutrients, and an increase in fibre, calcium, and other desirable nutrients. In turn, those changes in nutrient intake will likely reduce the occurrence and associated cost of nutrient-related diseases.

The U.S. Food and Drug Administration studied the potential impact of mandatory nutrition labelling on reductions in premature deaths and health care costs.(36) The study focused on changes in consumers’ dietary intake of total fat, saturated fat, and cholesterol. The changes in these nutrient intakes were estimated and the potential health benefits resulting from the associated reduced risk of coronary heart disease and cancer were calculated. The researchers generated four forecasting models to predict the likely impact of the nutrition labelling changes.

The study concluded that the nutrition label changes would result in $4 billion to $118 billion in cost savings over a 20-year period resulting from reductions in premature deaths and health care costs. However, those estimates are likely to be quite conservative given the fact that there are several limitations inherent in the FDA study:

  • The FDA study did not examine the changes in consumers’ dietary intake of other nutrients, such as fibre or calcium.

  • The FDA study did not examine the health benefits resulting from the reduced risks of other nutrition-related diseases, such as stroke, osteoporosis, obesity, diabetes, birth defects, or dental caries.

  • The FDA study did not account for the effect of decreased workplace absenteeism.

  • The FDA study did not account for the fact that mandatory nutrition labelling resulted in thousands of healthy new products and product reformulations.

  • The FDA study did not include decreases in morbidity that are likely to result from more healthful diets.

  • The FDA study did not account for the fact that user-friendly mandatory nutrition labels might trigger an increased understanding about, and interest in, the relationship between diet and disease.

Because of those limitations, the impact of mandatory nutrition labelling on the Canadian economy is likely to be even greater, per capita, than the FDA estimates. To achieve those benefits, however, nutrition labelling must be mandatory for all foods. A voluntary labelling system will obviously result in greatly reduced health care savings.

Mandatory nutrition labelling is necessary for consumers to compare different food products.

It is impossible to compare the nutrient content of two different food products unless both provide nutrition information on their labels. Furthermore, nutrition information is impossible to compare unless all essential nutrients are reported. For example, even though Kraft Peanut Butter and President’s Choice Peanut Butter both provide some nutrition information, the information provided is incomplete. Consumers cannot compare the sodium, saturated fat, or cholesterol content of those two brands of peanut butter since only the President’s Choice label lists those nutrients.

Under a voluntary labelling scheme, nutritional comparisons are often impossible because many products refuse to provide any nutrition information. Even when products do provide nutrition information, comparisons are still limited to a few select nutrients. Thus, mandatory nutrition labelling is necessary for consumers to compare nutrition information among a variety of food products.

Mandatory nutrition labelling addresses consumers’ concerns.

Surveys show that the majority of Canadian consumers believe that nutrition is an important factor in selecting food.

  • A 1994 National Institute of Nutrition report revealed that 87% of Canadians find nutrition extremely or very important in choosing food.(37)

  • A 1995 survey by the Grocery Products Manufacturers of Canada found that 79% of Canadians say that nutrition is extremely or very important.(38)

  • A 1996 survey by the Canadian Foundation for Dietetic Research, Dietitians of Canada, and Kraft Canada revealed that 89% of Canadians say that nutrition and health are important factors when choosing what to eat.(39)

  • A 1997 survey conducted by Canadian Facts for the Centre for Science in the Public Interest, found that 95% of adult Canadian grocery shoppers surveyed said that nutrition is very or somewhat important when selecting foods at the grocery store.(40)

  • A 1999 survey conducted by Canadian Facts for the National Institute of Nutrition found that 90% of respondents believe nutrition is extremely, very or quite important in choosing foods. 71% believe that nutrition information on food packages is extremely, very or quite important in choosing foods.(41)

Although the majority of Canadians believe that nutrition information is important, only 34% of Canadian consumers believe that the nutrition information on product labels is satisfactory.(42) In fact, 74% believe that nutrition information should be provided on all foods.(43)

Voluntary nutrition labelling is inadequate to satisfy the wishes of Canadian consumers. To respond to Canadians’ desire for more widespread and informative food labels, nutrition labelling must be made mandatory.

The benefits of mandatory nutrition labelling greatly outweigh its costs.

The costs incurred as a result of mandatory labelling will be greatly outweighed by the benefits. The U.S. Food and Drug Administration study concluded that mandatory nutrition labelling would result in $4 billion to $188 billion in cost savings over a 20-year period resulting from reductions in premature deaths and health care costs. Those savings greatly exceed the estimated $1.5 billion to $2.5 billion associated with introducing the labels.(44) Moreover, as the U.S. Department of Agriculture’s Economic Research Service concluded: “The high value that consumers place on health and life means that information programs with demonstrated efficacy in improving health will offer benefits that consumers will likely feel exceed reasonable costs.”(45)

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