In the short time left, I would like to focus on two proposals that we would discourage the committee from pursuing.
The first is mandatory menu and menu board labelling. I'm sure committee members are familiar with Bill C-283. The stated purpose of this private member's bill is to address obesity. This is a very resource-heavy approach for both government and industry that we believe would ultimately be unworkable and ineffective. Governments have studied menu and menu board labelling many times and rejected it for practical and well-thought-out reasons, most notably in the context of allergens. Governments recognize that a manufacturing environment cannot be equated to a food service environment, and mandated labelling would only give allergy sufferers a false sense of security.
Similarly, it would be almost impossible, even for branded chains with a high degree of standardization, to provide menu board and menu labelling that would be complete, accurate, legible, reliable, and enforceable. This is because of the frequency of menu changes and supplier substitutions, the prevalence of customized meal choices, the range of flavour and size options for menu items, and the critical role of menus and menu boards in the ordering process and speed of service.
The following slides explain the realities of the restaurant environment and the challenges involved in providing accurate and complete nutrition information that meets the needs of customers. In the interest of time, I won't go through each one, but I would be pleased to address the factors in the Q and A session.
For now, let me jump to slide 39 and draw your attention to the dangers of taking an overly simplistic approach to nutrition information. The sponsor of this bill would say, “It's not that complicated. I just want you to give the customer an idea of the calorie count.” But is it really empowering consumers to make healthy choices if the calorie count is off by more than 50%, depending on the dressing or topping or beverage or side dish the consumer chooses?
A labelling requirement focused on calories over other nutritional considerations can be misleading and may not result in the most nutritious choices. For example, if a teenager were to buy a beverage based on calorie count, she would choose several types of soft drinks and an iced tea over a glass of 1% milk or a chocolate milk. Focusing on calories could also lead a consumer to choose a small doughnut over a multi-grain bagel.
The focus on calories could have other unintended negative effects on children, including conflicts between parents and children centring on food.
Most importantly, there is no evidence that calorie labels would have any effect on people's eating habits or on obesity levels. Dietitians of Canada reference a European heart network study to highlight some key gaps in using nutritional labelling as a population health strategy for improving the eating habits of Canadians.
The resources required to try to implement menu and menu board labelling would be huge and ongoing for both industry and government. The committee must think carefully about the cost and undetermined benefits when considering such a solution.
The other proposal that I will touch on briefly is the recommendation to remove sales tax from restaurant or retail foods that are deemed to be healthy, and perhaps add some taxes to foods that are less healthy. You might think that food service operators would jump at the chance of getting a tax break on the fastest growing component of their menus. As Jill mentioned earlier, developing and promoting healthy menu items is a growing trend, and CRFA has been complaining for years about the unfair application of sales tax to food in Canada.
Meals purchased in restaurants are subject to the GST as well as provincial sales tax in most jurisdictions, while food purchased in grocery stores is tax exempt. However, using the tax system as a tool to modify consumer behaviour on the basis of nutrition would be a logistical nightmare for restaurant operators. For example, an item high in fat may contribute essential fibres and nutrients, while an item low in fat may provide few nutritional benefits. What would a counter person charge a customer who ordered the whole wheat thin-crust vegetarian pizza and then asked for double cheese and bacon? Singling out any food item in a restaurant for special tax treatment ignores the human reality that foods are eaten in combination, and health and nutrition depends upon balance as well as moderation.
To conclude, Mr. Chairman, the food service industry recognizes the seriousness of the obesity problem and the need for multi-faceted solutions that include food service. The CRFA supports greater government intervention and involvement in nutrition and active lifestyle awareness and education programs. Restaurants provide a great distribution point for consumer information, and our members have a sincere desire to be part of such a program.
Please work with us to develop and test effective, workable approaches to encourage Canadians to adopt healthy, active lifestyles.
Thank you.