Health Committee on Feb. 21st, 2007

[Fred Schaeffer]

With regard to the two questions addressed to me, one was on whether we would put a colouring system on top of the current nutrition facts table. I'll address the question more broadly, and you can come back if you don't like the answer.

Perhaps the question behind the question is, can we at some point improve the nutrition facts table? I'm a CEO, so I'm a believer in continuous improvement. There's nothing in the world that can't be improved upon.

I think the question is this. What's the right way to improve things over time? How do you improve it over time? Where do we want to spend our time and energy between now and then?

I personally believe that in the short run we should spend our time and energy on educating people on what the nutrition facts table says today and on how to read it today, rather than spending time, energy, and resources educating or thinking about something else. It's only been in the market for a couple of years, a year and a half, or a year and a few months. It's early in the cycle. I would say we should stay the course.

In terms of how we deal with the multi-regional regulations, I can tell you that it's a challenge. I believe it is in some ways an impediment to trade, depending on what some of the regulations are and how regional they become. It takes considerable time, energy, and resources. Again, those are resources that in my mind could be put towards other things, such as improving the health properties of our products.

Running a corporation or a government is all about making choices. We can choose to continuously redesign our labels or we can choose to continually improve the quality of our products and the nutritional profile of our products. It's hard to choose everything and do it well all at once.

[The Chair, Conservative, Rob Merrifield]

I'm sorry, your time is finished.

Mr. Boshcoff.

[Ken Boshcoff, Liberal, Thunder Bay—Rainy River, ON]

Thank you very much, Mr. Chair.

I have questions about the cost of changing labels. But right from the beginning, perhaps CFIA could tell us this. When we deal with imports or specialty shops, what restrictions or guidelines do they have for English, or French, or something else? Are they compelled to follow the same rules as Canadian food producers?

[Debra Bryanton]

Yes, thank you. The regulations apply to domestic and imported food products, and so they apply equally to imports. We work with importers as the responsible party for bringing the foods into Canada. We have been working to first educate them on the requirements for nutrition labelling and to improve compliance as it relates to inclusion of the nutrition facts table on their products.

Some of these companies would be considered to be in the smaller category. The uptake by the larger companies was very good. We found that for the first phase of the implementation of the nutritional labelling regulations there was good uptake, and for the most part, the nutrition facts tables are being used. For some of the smaller companies, which include some of the smaller importers, we expect there will be a greater effort on our part to make sure these products are in compliance with Canadian regulations.

[Ken Boshcoff, Liberal, Thunder Bay—Rainy River, ON]

Thank you.

Perhaps Mr. Jeffery could answer the first question, which would be the cost of producing standardized, uniform labels. Would that be oppressive to the nation or the economy?

Maybe Mr. Schaeffer could tell us a little about how often labels are turned over, when you add an Olympic logo, congratulations to some type of program, or those kinds of things.

I'm leading towards the question of what would be a reasonable time for us to come up with a label that was standardized in terms of its health perceptions, so that we could go with the Heart and Stroke Foundation, or at least with a label that people would really recognize and that the government could actually endorse, according to the Canada's Food Guide.

Please answer.

[Bill Jeffery]

To respond to the first question, the metric for deciding what course of action to take from a public policy perspective should always be what's the public health benefit, not just in terms of reducing the loss of human life, but also financial savings and less strain on the public health care system and on economic productivity.

The evidence concerning the benefits of mandatory nutrition labeling that we have currently demonstrated is that it's a fabulously efficient way for producing public health benefits, at least as far as cost goes. So I think there's great potential for having some kind of traffic light system, and I would hate to think that the decision to not go down that road, even to research its feasibility, was dictated by management philosophy instead of the likelihood of having some public health benefit.

[The Chair, Conservative, Rob Merrifield]

I wonder if Mr. Schaeffer would like to answer your question about the cost of labelling.

[Fred Schaeffer]

Industry studies, orders of magnitude: circa $150 million when we went to MNL, mandatory nutrition labeling. Regarding packaging, I don't know if that's roughly equivalent with—

[Janet Beauvais]

Yes. When we implemented the nutrition labeling regulations, we were required to do a detailed business cost impact, and it was in the order of $260 million over three years, although to add a logo would probably cost about half, because companies wouldn't have to do the analysis of the nutrients.

[Ken Boshcoff, Liberal, Thunder Bay—Rainy River, ON]

But companies do that as a matter of routine--you know, “This is the year 2000 and it's our hundredth anniversary”, or “This is the best beer possible”, and those kinds of things.

[Fred Schaeffer]

To that I would say there are several “I'll try not to bog you down in the quagmire of technical details on packaging” kinds of packaging changes. They're what we call single plate changes, where you need to change an ingredient because it's no longer available or you've chosen to use another ingredient. That's one type of change, and it's very inexpensive, very quick, and happens relatively frequently.

Any time you're trying to redesign the real estate of your package and you want to move things around on it, this usually requires getting a packaging and design firm and relaying that entire package. This would be a second and much more expensive level of change.

Then regarding the point raised by Health Canada, if that's also required by supported nutritional analysis, it has third-party validations, and it's sent out to labs, that is yet another layer.

So not all changes are created equal is the message I would leave with you, and the more space and more analysis you require, the more costs you incur.

[The Chair, Conservative, Rob Merrifield]

Thank you. Your time is gone.

Mr. Batters.

[Dave Batters, Conservative, Palliser, SK]

Thank you very much, Mr. Chair.

Thank you to all of you for taking time out of your busy schedules to enlighten this committee today.

To Health Canada, do you conduct ongoing evaluations of the mandatory nutrition labels that are currently in effect to determine their effectiveness? Also, how do you test their effectiveness?

As a bit of a preamble, I have to confess that I don't ever read the nutrition labels. I find it quite complicated. This is something that probably should be taught in our schools as a mandatory part of education. It should be taught to grade 3 students or below. I simply don't ever remember being taught that, and I've never used it in my life.

Given that, do you test for effectiveness, and how do you assess that effectiveness?

[The Chair, Conservative, Rob Merrifield]

Just for the information of the committee and those listening, Mr. Batters applies that same principle with eating cookies here too.

[Some hon. members]

Oh, oh!

[Dave Batters, Conservative, Palliser, SK]

And I grew up on McCain Pizza Pops.

[Janet Beauvais]

Health Canada is fully committed to evaluating the impact of the nutrition labelling regulations once they're more fully in place. As I've mentioned, the implementation date was December 2005, which was just a little over a year ago, so it's premature to be doing a full evaluation at this point in time. We haven't yet designed the evaluation, but we fully intend to do it. And with the launch of the food guide, there'll be even more education around healthy eating and reading nutrition facts panels.

[Dave Batters, Conservative, Palliser, SK]

Have there been concerns or complaints expressed regarding the existing mandatory nutrition labelling? And if yes, have they come from consumers; have they come from industry?

And maybe our industry representatives can comment on that. If there have been concerns, how will they be addressed? Or will you be addressing them?

[Janet Beauvais]

From Health Canada's perspective, the types of complaints we generally receive are concerns from the public about the nutrient profile of such a product or another product. They're concerned, basically, that it's maybe not a healthy food, or things of that nature.

I'll ask CFIA to speak perhaps more to other types of complaints. We don't tend to receive many.

[Debra Bryanton]

Because of the complexity of the nutrition labelling regulations, there was a lot of discussion with industry, not just with the manufacturers but also with the packaging organizations. There was a full commitment to moving ahead with nutrition labelling requirements. It was more a question of the “how to” and the “when”. Industry, of course, was quite interested to know when we would be taking aggressive compliance action on products.

Earlier I mentioned that we hadn't moved ahead with prosecution. It's that we haven't had a situation that would lead to prosecution as of yet. So although we would follow up, to the point of prosecution, we have not had a reason to do it at this point. We don't get many complaints on the need for nutrition labelling.

[Dave Batters, Conservative, Palliser, SK]

Mr. Schaeffer and Ms. Brown, and Ms. Dombrow, do you, from your perspective, like the labels? Are you okay with the labels—just quickly?

[Sally Brown]

Yes.

[Fred Schaeffer]

Yes.

[Dave Batters, Conservative, Palliser, SK]

Thank you.

I have one more line of questioning. Recent literacy and numeracy surveys in Canada have shown that about half of the Canadian population lack sufficient skills to understand the current food labels. I'd like to think I could understand them; I just choose not to look at them. Food companies have suggested that their symbols and logos take the confusion out of nutrition for consumers and enable them to make specific dietary changes. What evidence exists about the effectiveness of these different colour symbols in communicating nutrition information? Would these suffice? Or do we need the nutrition facts labels as well?

That's question number, I guess: are the symbols enough, or do we need the nutrition facts labels as well?

And with the proliferation of competing symbols and logos from different companies, is there greater confusion among consumers with all these symbols? Should we be striving to develop a uniform system that is simpler than the current labelling system?

That will finish my questions, once they're all answered, Mr. Chair.

[Sally Brown]

I could start, maybe, Mr. Batters.

We believe the nutrition facts table is essential, and the Health Check logo is meant to complement it, not replace it.

With respect to your second question, you don't need, we believe, exclusivity in the label; there could be all sorts of checks. But they all should be based on the same criteria. If they don't want the Health Check label on, then put on a label that says the same thing. The public thinks it's saying the same thing, so make the criteria the same. They then can pay for their own reformulation and put on a PepsiCo label. But it should be based on the same criteria that the Health Check one is, which is based on Canada's Food Guide.