Monday, October 30, 2017

Food Industry Furious With Health Canada's Front-of-Package Plans

If Health Canada takes Chile's lead, we too might see Frosted Flakes boxes change from looking like those on the left to looking like those on the right.
When industry is furious with a government proposal it's a safe bet that proposal is likely to affect their sales, and so when I learned that the food industry was incensed by Health Canada's front-of-package plan proposals (Aric Sudicky, a final year medical resident who was rotating through our office at the time, watched the recent roundtable style consultation hosted to discuss the implementation of what will be a Canada wide front-of-package program, via teleconference and reported to me that industry was none too pleased), I wanted to learn more.

Now this post isn't going to delve into whether or not those are the best 3 targets for front-of-package symbols, instead I want to focus on the lobbying and machinations of industry.

First though, a tiny bit of background.

In creating a new front-of-package symbol for Canadian consumers, what Health Canada doesn't want is a program that emphasizes so-called positive nutrients as 50 percent of Canadian package fronts already have those (put there by the food industry directly to help sell food), or one that requires a second step of thinking to interpret (eg studying the nutrition facts table) as that has been shown to lead to misunderstanding, or a hodgepodge of programs (as more than 150 front-of-package labeling programs have already been documented in Canada) .

What Health Canada does want is a single, standardized system, that involves a prominent symbol, that's consistently located, that doesn't require nutritional knowledge to understand, to help consumers identify products with high levels of nutrients that Health Canada deems are concerning to public health, that by itself provides the required interpretation for its meaning. Such a system would be consistent with the core recommendations made by the U.S. Institute of Medicine.

Breaking it down further, what Health Canada wants is a system that conveys simple to understand information, rather than one that presents data requiring interpretation.

Further still?

Health Canada wants warnings.

In their recent meeting, Health Canada presented their wants to food industry stakeholders, as well as the evidence they feel supports them, and invited them to submit their thoughts and suggestions for a symbol to fit Health Canada's 4 design principles:
  1. Follow the "high-in" approach
  2. Focus only on the 3 nutrients of public health concern (sugar, sodium, and saturated fat)
  3. Be 1 colour (red) or black and white; and
  4. Provide Health Canada attribution
As to what this might look like, here are some mockups put together jointly by the Canadian Cancer Society, Canadian Medical Association, Canadian Public Health Association, Diabetes Canada, Dietitians of Canada, and the Heart and Stroke Foundation.

Given that warning symbols aren't likely to be good for business, I was curious as to industry's response to the ask.

Suffice to say, industry is indeed unhappy.

The Retail Council of Canada wants Health Canada to implement instead an instruction for consumers to turn products around and study their nutrition facts tables, and they don't want Health Canada's name mentioned on the symbol. They are apparently worried that including Health Canada's name on the symbol might be misinterpreted as a government endorsement which in turn would lead consumers to eat more of the products with the warning labels. They're also apparently simultaneously worried that if the symbol utilized is already recognized to be a danger symbol, it could lead consumers to believe there is a food safety risk, and that if used, children, accustomed to seeing these symbols on foods, might lead them to think that cleaning supplies with danger symbols are safe to consume.

The Food Processors of Canada used bold to point out that, "the meeting didn't agree to anything", and that, "Health Canada has lost its way on the obesity issue". They think that what's needed is more public education, not a front-of-package warning program.

The Canadian Beverage Association expressed their, "deep concerns", and that though they were happy to have been included in the meeting, their definition of "deep and meaningful dialogue" with industry should include a process whereby industry participants would all discuss and agree upon what the program would entail.

Food and Consumer Products of Canada also wanted to express their disappointment that they weren't provided the opportunity to be more directly involved in crafting the proposal's criteria and their concerns about "the integrity and transparency of the consultation process". They sent a second note expressing their hope that the criteria still have room to evolve and that their preference is for traffic lights as they believe, "information – good and bad – builds on consumer literacy".

Dairy Farmers of Canada expressed their concern that the proposed warning system lacks the nuance required "to distinguish between nutrient-dense and nutrient poor foods" (sweetened milk will likely be slapped with a high in sugar warning), and that they'd be happy to support, especially, "if coupled with exemptions for nutritious dairy products", those programs that would provide data for consumers to study and interpret (like for instance the Facts Up Front program illustrated below).

There was however, one response from industry that was heartening. It was from Nestlé, whose representative reported being, "a little embarrassed" by how industry presented their views during the roundtable, and, "that Nestlé is not fully aligned to some of the comments that were made by some of our trade associations, and a few of us are feeling very frustrated."

Whatever comes of all of this, one thing's for sure. The food industry's near uniform opposition to Health Canada's proposed front-of-package warning label criteria is strong indirect evidence in support of their utility, as for the food industry, salt, sugar, and fat are the drivers of profitability and palatability, and they'll oppose anything they worry might limit their use.

So kudos to Health Canada for sticking to their guns, and also for honouring their pledge to make this process transparent by sharing with me industry's responses.

(and if you clicked on any of the industry letters to read, this is the post roundtable letter from Health Canada to which they're all referring).

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