Thank you, Mr. Chair.
Since, like some of the other members of the committee, I'm a repeat attender, I'll dispense with the introductory comments about the Centre for Science in the Public Interest beyond saying that we have 100,000 subscribers to our newsletter and we don't take funding from industry or government.
Current mandatory nutrition labelling regulations for prepackaged foods were predicted by Agriculture and Agri-Food Canada to reduce the burden of diet-related disease by approximately 4% by producing $5 billion in cumulative economic benefits in the coming two decades at a non-recurring cost of about one-fifth of 1% of food sales for a single year during the phase-in period. By our calculations, that's a 2,000% return on investment.
The impact of the new mandatory nutrition labelling rules has not yet been formally assessed in Canada. While cause and effect relationships are difficult to establish, American consumer research has shown that many consumers use the U.S. Nutrition Facts panel, and that nutritional labelling use is associated with healthier diets. That said, the effectiveness of nutrition facts labelling could be amplified in Canada by supplementing the labels with information such as a front-of-package traffic light system that requires fewer mathematical calculations and less time to interpret.
Such a system would also provide stronger incentives for food companies to reformulate their products to benefit from a healthier designation. Of course, nutrition label information that is now mandated by regulation in Canada, coupled with sensible nutrition criteria, would serve as the basis for the symbol designations. The use of a symbol could accommodate the menu space limitations that appeared, for instance, to underlie the restaurant industry's opposition to menu labelling provisions in Bill C-283 in November 2006.
The appeal of the front-of-package nutrition symbols is that they translate key nutrition information now in small print on food packages into easily recognizable universal symbols. This is even more important for chain restaurant foods where fine print is often available only on corporate websites, if at all.
Front label symbols that alert consumers to the healthfulness of foods: “We must make the healthy choice the easy choice” is a slogan popularized by the World Health Organization and used by the Minister of Health, Tony Clement. By simply glancing at the front label of a food package, consumers could immediately know roughly how healthful a food is.
In the absence of a Health Canada endorsed traffic light labelling system, food companies and others have developed their own front label symbols to indicate that a particular product is healthful, or at least better than some other foods. Indeed, some companies see consumers' confusion about how to structure a healthy diet as a marketing opportunity and use symbols to designate more healthful items to encourage shoppers to buy those products.
Existing symbols include PepsiCo's Smart Spot, Kraft's Sensible Solution, President's Choice's PC Blue Menu, and General Mills' Goodness Corner. These private systems all allow manufacturers to effectively promote their healthier products to consumers, but on the basis of self-chosen nutritional criteria. While those programs may be useful, they may also be deceptive, and because they have differing and sometimes weak criteria, taken together they may end up being more confusing than helpful to consumers.
For instance, according to The Globe and Mail nutrition columnist, Leslie Beck:
Packages of Kraft Dinner, President's Choice Rice Chips, Gatorade and Diet Pepsi are stamped with “good for you” decals, but health foods they're not...And many products would not meet the Heart and Stroke Foundation's nutrient criteria. According to Carol Dombrow, nutrition consultant for the Heart and Stroke Foundation, roughly 50 per cent of PepsiCo's Smart Spot products, for example, would not meet Health Check criteria.
The United States Institute of Medicine, in its report, Food Marketing to Children and Youth: Threat or Opportunity, stated:
While representing an important step to draw attention to more nutritious products, the array of categories, icons, and other graphics, as well as the different standards employed by these companies may introduce some confusion, particularly for young consumers, thereby raising the need for developing and regulating standard and consistent approaches...The FDA has not yet fully explored its potential role for providing leadership and experience to food companies in order to develop and enforce an industry-wide rating system and graphic representation on food labels that is appealing to children and youth to convey the nutritional quality of foods and beverages.
Action by Health Canada would bring consistent and reliable information to the marketplace and help consumers choose more helpful diets. A significant amount of U.S. research has already pointed to the potential value of front-of-pack nutrition and symbol systems, and last November the Select Standing Committee on Health of the British Columbia legislature recommended that its own government “develop warning labels alerting consumers to high fat, sugar, and salt foods, such as a red-amber-green system, and/or a calorie-load-per-serving system”.
You heard testimony earlier in the week about the U.K. signposting system. There are two other systems that I think merit the committee's attention. One is called the Swedish keyhole system. It identifies more healthful food choices within particular food categories like pizza, cheese, margarine, and so on. The approach differs significantly from the U.K. system of traffic lights, which calls for the use of colour-coded symbols, green, yellow, and red, on all foods, not just those that are relatively healthful within a specific food category.
The Swedish system, while useful, does not identify which foods are less healthy, and since 1989 the Swedish national food administration has allowed more nutritious foods within particular food categories to be labelled with a green keyhole system. One major Swedish retailer, ICA, has used the keyhole system and reports that in 2003 and 2004 sales for keyhole products rose by over 15%.
There is also one promising private system in the U.S. that merits special attention, the Hannaford Brothers supermarket chain star designation system. It established the star system for processed foods, in which some products receive no stars, one, two, or three stars, on a shelf marker next to the item price or on a sign. One star indicates a good choice, two stars indicate a better choice, and three stars indicate the healthiest choice. One advantage of this approach is that it is not binary but allows Hannaford to depict a gradation from less to more healthy. On the other hand, one may question the particular criteria and cut-offs used.
In the end, three-quarters of products sold received no stars because they're not especially healthful, as explained in a point-of-sale brochure. Such products as General Mills' Count Chocula, Cookie Crisp, and Trix cereals do not qualify for any of Hannaford's stars because of their high sugar content, yet those cereals carry the American Heart Association's heart check logo--as distinct from the Health Check logo here--on their labels because they are low in fat and cholesterol. Such inconsistent messages can only confuse consumers.
In conclusion, Health Canada should conduct a study of front-of-label nutrition traffic light systems by soliciting comments from scientists, health and communication experts, industry, and consumers on how best to rate and communicate to consumers through the use of symbols on food packages the nutritional quality of foods. It should also engage in consumer research to identify the program that would best help consumers choose healthful diets. Work already completed by the Food Standards Agency in the United Kingdom, the U.S. Food and Drug Administration, the Swedish government, supermarket chains, food manufacturers, and the Heart and Stroke Foundation and others could help inform this effort. Once Health Canada identifies the appropriate nutrition criteria and symbols, with explanatory words if necessary, it could determine whether the system should be voluntary or mandatory, although we strongly favour a mandatory system. Health Canada should also determine whether company and non-profit labelling programs that are inconsistent with the official labelling program are misleading and should be ended.
Thank you.