Thanks, Garth.
I'm going to focus on nutrition disclosure in restaurants, since it dominated one of your previous sessions. We do appreciate the opportunity to clarify the industry's position on this very important subject.
First, you should be aware that CRFA is in discussions with Health Canada and individual provinces about a national policy framework for nutrition disclosure. Included in your package are the guiding principles informing these discussions. One of the challenges for both government and industry is ensuring that this initiative will have the desired impact on the food choices and ultimately on the health of Canadians.
A recent witness acknowledged that “The evidence that menu labelling will influence people's eating habits is not conclusive”, but went on to say that “most recent studies have found significant, though modest, effects”. I haven't seen any studies that have found significant effects. I can cite many studies that have found weak, inconsistent, or no effects. Most recent studies, based on real-world experience, not hypothetical, show no impacts.
A study in the current issue of the American Journal of Preventive Medicine tracked purchasing behaviour at a fast food chain before and after calorie posting was regulated, comparing sales between a chain establishment within and adjacent to the regulated jurisdiction over a 13-month period. It found that the regulation had no impact. Trends in transactions and calories per transaction did not vary between the control and intervention locations after the law was enacted. A study released just this week in the International Journal of Obesity came to the same conclusions.
Because the evidence to date is inconclusive, Health Canada is planning a think tank on nutrition disclosure at the end of March that will bring together academics, NGOs, industry, and governments. One of the objectives is to identify research gaps, needs, and opportunities.
From the industry's perspective, the objectives of a nutrition disclosure policy framework are, first, to provide consumers with meaningful nutrition information so they are able to make informed choices that reflect their individual dietary and lifestyle needs; second, to help consumers make healthier food choices that will improve their health.
Building on CRFA's voluntary nutrition information program, a national nutrition disclosure framework would include the consistent, prominent, and visible display of nutrition information for standardized menu items in store, prior to point of sale. The manner in which this information is displayed may vary, depending on the individual restaurant's unique environment, but must meet the test of being visibly prominent and available at point of sale.
Some examples of how restaurants may prominently display nutrition information include: wall poster, menu insert, brochure stand, computer kiosk, etc. Technology is changing the face of society and the way we interact and consume information. Nutrition information is no exception. Many CRFA members are developing new electronic applications so that customers can view nutritionals simply by pointing their BlackBerry or their iPhone at the menu or menu board. This is already operational in some chain restaurants in Canada.
So CRFA is opposed to the oversimplified provision of single-nutrient information, such as the posting of calories, for several reasons.
The first reason is the difficulty of presenting the information in a way that is meaningful to consumers. Restaurants offer menu choices in multiple varieties, flavours, and options for customization. This makes it impossible to fit nutrition information on menus and menu boards in a way that is accurate, complete, legible, and enforceable. A sandwich, a pizza slice, a burger can vary in caloric content by a margin of 50%. Customers may have thousands of options that aren't listed on the menu, and this is the reason so many chain restaurants use nutrition calculators on their websites. Jurisdictions in the U.S. that have mandated calorie posting allow broad ranges of calories on their menus that aren't permitted in Canada.
Second is the singular focus on calories, rather than on nutrition and balance. This approach delivers a mixed message to consumers. For example, a small serving of milk will show more calories than a small soft drink; a yogurt with granola will show more calories than a bag of chips; a flax seed bagel will show more calories than a cookie. And it should be noted that Weight Watchers, which has helped millions of people throughout the world lose weight, uses a point system based on fat, carbohydrates, fibre, and protein—not calories.
Third is the shifting public policy concern about posting information on menus.
Over the years, the industry has been faced with public policy initiatives requiring posting on menus and menu boards of specific allergens, fat, trans fats, calories, and, most recently, sodium. Recognizing the normal shifts in public health concerns, we are amenable to a policy that highlights specific nutrient information on calories and sodium in our nutritional information in an effort to draw particular attention to them at this time. The industry is concerned about the precedent of requiring specific information per menu item on menus and menu boards.
To conclude, CRFA is interested in working with government on a made-for-Canada national policy framework that will ensure that Canadians have meaningful information for making healthy choices when they visit their favourite chain restaurants.
In the interests of time, I'm going to provide clarification on our positions on trans fats and sodium during the Q and A.