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Do you agree with the nutrients being proposed for the core list?
CSPI congratulates Health Canada and the Nutrition Labelling Advisory Committee for proposing an expanded ten-nutrient core list consisting of: energy, fat, protein, carbohydrate, dietary fibre, saturated fatty acids, trans fatty acids, sodium, calcium, and iron. This list is considerably more comprehensive than the existing core list (i.e., energy, protein, fat and carbohydrates) set out in section 5.1.3 of the Guide to Food Labelling and Advertising.(1)
In particular, we applaud Health Canadas decision to include trans fatty acids in the core list. This is one nutrient with adverse health consequences that is rarely disclosed on any Canadian or U.S. food label. In the U.S., efforts have been made to have trans fatty acids added to the list required by the Nutrition Labelling and Education Act since shortly after the bill was passed in 1990. Those difficulties highlight the importance of ensuring the core list is sufficiently comprehensive from the outset. We suggest, however, that consideration be given to listing trans fatty acids as saturated fat. This step will simplify the core list and facilitate consumer understanding.
Although CSPI agrees with the nutrients being proposed for the core list, we have two important reservations:
First, we wish to emphasize the most important issue: that the core list be made mandatory. Though using a more expansive core list is a step in the right direction, continuing the current system of triggering rules could seriously undermine their impact on the quality and availability of nutrition information for Canadians. The potential public health benefits of an improved core list of nutrients would be undermined by permissive rules that allow food manufacturers to report nutrients from this core list optionally. Indeed, if a core nutrient list containing ten or more nutrients displaced the current core list while maintaining the current voluntary system, this may actually decrease the amount of nutrition information supplied to consumers on food labels. Manufacturers may prefer to supply no nutrition information whatsoever rather than supply extensive information about additional core list nutrients that may unfavourably portray their products. (Please refer to pp. 12 -13 for a more complete discussion of this issue.)
Second, the proposed core list insufficiently advances public health because it fails to include five key nutrients linked to chronic diseases and known to be consumed in excessive or insufficient quantities by Canadian consumers. Accordingly, we recommend that the following five nutrients be added to the core list: added sugars, folacin, vitamin A, vitamin C, and cholesterol. We respectfully submit that those nutrients constitute significant omissions from Health Canadas proposed core list and strongly recommend that they be added to the existing list for the reasons set forth below.
We acknowledge that the aetiology of dental caries is complex and the manner of consumption of sugars plays a major role in dental health. Nonetheless, consumption of sugar need not be the exclusive cause of dental caries to make added sugars qualify as a nutrient that must be disclosed on food labels.(2)
Tooth decay is not the only adverse health effect of dietary sugar. Added sugars found mainly in foods like soft drinks, cakes, candy, and cookies squeeze healthier foods out of the diet, thereby compromising intake of other essential nutrients and raising the risk of osteoporosis, high blood pressure, cancer, and other problems that could be avoided by eating healthier diets. New data from the U.S. Department of Agriculture indicate that people who consume diets high in added sugars consume lower levels of protein, fibre, vitamins A, E, C, B-6, B-12, riboflavin, niacin, folate, calcium, iron, zinc, and magnesium.(3) They also consume fewer servings of grains, fruits, vegetables, meats, and dairy products than people who consume less added sugar. In some people, diets rich in added sugars also contribute to obesity. Obesity increases the risk of diabetes, heart disease, high blood pressure, and other health problems.
A recent survey showed that 56% of Canadians are trying to reduce their intake of sugar.(4) In theabsence of a quantitative disclosure of added sugars in foods, consumers are confined to making necessarily clumsy estimates of added sugars content based on the location of sugars and other items in the ingredient list.
CSPI recommends that food labels disclose the amount of added sugars rather than total sugars because treating all sugars as equal fails to assist consumers in choosing a healthy diet. While naturally occurring sugars are chemically identical to added sugars, treating them as equal for labelling purposes provides misleading nutrition information. Added sugars are found largely in soft drinks, baked goods, candies, and other empty-calorie, nutrient-poor foods that most Canadians should eat in smaller quantities. In contrast, naturally occurring sugars are found in nutrient-dense fruits and dairy products. While fruit and low-fat dairy products appear to lower the risk of major illnesses that threaten Canadians health,(5) foods that are high in added sugars offer no known benefits. Instead, they increase the risk of health problems or replace foods that appear to reduce the risk of disease. Thus, food labels should provide information that enables consumers to distinguish the added sugars from the naturally occurring sugars.
Vitamins A and C:
Many fruits and vegetables are rich in vitamins A and C. Numerous studies suggest that a diet rich in fruits and vegetables is associated with a lower risk of several cancers.(6) Other studies have found lower rates of stroke in people who eat more fruits and vegetables.(7) This finding is supported by the recent DASH study, which found that a low-fat diet rich in fruits (as well as vegetables, low-fat dairy products, etc.) lowered blood pressure in people with high-normal levels.(8)
Unfortunately, many Canadians consume insufficient amounts of fruits and vegetables in their daily diets. Vitamin A and C disclosures would help encourage the consumption of foods containing fruits and vegetables and should thus be required.
CSPI acknowledges that dietary folate is not naturally occurring in sufficient quantities in most foods to satisfy the 400 microgram recommended daily intake to reduce the risk of neural tube defects such as spina bifida and fatal anencephaly. However, we believe that a mandatory requirement for disclosure of folate content of foods would encourage consumers to choose good sources of folate, as well as act as an effective incentive for food manufacturers to fortify their products with folate, thereby increasing its availability in the food supply. As a result, folate fortification of commonly consumed foods such as bread, cereals, and pasta would increase folate intake, which is especially important for women of childbearing age who do not take folic supplements. A growing body of evidence also indicates that folate may help reduce the risk of heart disease.
Taking a multivitamin with folic acid may be the most convenient and foolproof way to insure an adequate intake of folacin to reduce these risks. However, for the millions of Canadians who do not take supplements, it is critical that food labels disclose the folacin levels.
Trans fats and saturated fats are more important determinants of serum lipid levels than dietary cholesterol. However, that conclusion should not lead Health Canada to ignore dietary cholesterol any more than it should ignore cigar smoking as a health hazard because cigarette smoking is associated with a greater risk of cancer. In fact, Nutrition Recommendations... A Call for Action, a report published by the authority of the Minister of National Health and Welfare in 1992, acknowledged the importance of dietary cholesterol. In discussing the link between elevated blood cholesterol and heart disease, the report states: Dietary cholesterol, though not as influential in affecting levels of blood cholesterol, is not without importance.(9)
The evidence that dietary cholesterol raises blood cholesterol is incontrovertible. A recent meta-analysis of well-controlled clinical studies indicate that adding two egg yolks to a daily diet would raise blood cholesterol by 10.8 mg/dL.(10) Even a lower-quality meta-analysis financed by the egg industry show that two egg yolks a day would raise blood cholesterol by 9.5 mg/dL.(11) Furthermore, studies in primates indicate that dietary cholesterol may promote atherosclerosis by mechanisms other than raising blood cholesterol.(12)
A recent survey shows that 62% of Canadians are trying to reduce their intake of cholesterol.(13) But without nutrition labelling, it is virtually impossible for most consumers to identify high- or low-cholesterol foods or estimate their cholesterol intake. Other experts consulted by Health Canada during the summer of 1998 recommended adding cholesterol. We join them in recommending that cholesterol be added to the core list of nutrients.
Can you share any educational insights regarding the nutrients on the new core list?
To help educate consumers, Health Canada should produce educational materials summarizing current scientific knowledge about the health effects of the core list of nutrients. Such materials should be made easily available to all consumers by broadly distributing them through a variety of ways, such as physicians offices, grocery stores, and on the Internet.
However, even the best educational materials will be useless if the labelling system remains voluntary; many food labels will continue to provide only limited or no nutrition information. In that case, consumers may feel that any nutrition education efforts have limited applicability. However, if consumers are provided with comprehensive nutrition information on all food labels, they will be more interested in learning about the core list nutrients. Simply requiring nutrition information on all food labels will itself increase interest in nutrition.
We also urge Health Canada to carefully consider the way in which trans fatty acids should be declared on the nutrition label. Since consumers may assume that the amount of saturated fat listed on the label includes all of the heart-unhealthy fat in a product, we recommend that Health Canada consider including trans fatty acids in the definition of saturated fatty acids for nutrition labelling purposes.
As an additional matter, we would like to stress that attaching health claims about manufacturer-selected nutrients to product labels will not usefully advance consumers knowledge about the importance of nutrients. Health claims often give an exaggerated impression of the healthful properties of a single food and distract consumers from the benefits of eating a balanced diet. Moreover, experience in the U.S. and Japan the only two counties that currently permit health claims shows that such claims are difficult to regulate and are often made with inadequate pre-market approval and declining standards of scientific substantiation.
Accuracy of Nutrition Labels:
CSPI urges Health Canada and the Nutrition Labelling Advisory Committee to establish strict requirements to ensure the accuracy of the quantitative information provided on nutrition labels. We suggest that the nutrition information provided on labels vary by no more than 10% from the actual amounts of nutrients found in a sample of the food offered for sale. If variances greater than 10% are permitted, this will likely undermine the publics confidence in, and therefore use of, all nutrition labels.
CSPI is concerned about the enforcement of nutrition labelling rules. Measures should be taken to ensure that adequate enforcement procedures and resources are available to properly monitor compliance with nutrition labelling laws and regulations and compel remedial action where violations are found. Evidence of inaccuracies in nutrition information could undermine consumers confidence in nutrition labels as a source of reliable information and, by extension, diminish the considerable potential public health benefits of this effort.
Some nutrition labels currently used (especially on cereal boxes and special dietary beverages) have
become difficult to read because they contain too much nutrition information (as many as 28
nutrients are reported on some cereal boxes). Often, some of the nutrients reported are not cause
for public health concern because the vast majority of Canadians already consume them in
appropriate quantities. A brand of food with a long list of nutrients may give the misleading
impression that it is more nutritious than a similar brand with a shorter nutrient list. We therefore
propose that companies be prohibited from reporting nutrition information beyond the core list,
unless they can demonstrate that the additional nutrient(s) is related to the prevention or
management of a disease that is of public health significance.