• About FDF
• Our Priorities
• Members list
• News
• Policy Briefings
  • Competitiveness
  • Food Safety and Science
    • Food Chain
    • Food Ingredients
    • General Food Law
    • Labelling
    • Nanotechnology
    • Nutrition
      • Dietary Fibre
      • Folic Acid
      • Nutrient Profiling
      • Trans Fatty Acids
    • Residues and Contaminants
  • Health and Wellbeing
  • Sustainability
• FDF Responses
• The Industry
• Events
• Publications
• Campaigns
• FAQs
• Polls

Nutrient Profiling

Policy Position

Nutrient Profiling in General

FDF is fully supportive of helping consumers of all ages choose healthy lifestyles, part of which involves choosing a nutritionally balanced diet to suit their individual needs. However, we believe that using a universal nutrition profiling model (i.e. a profiling scheme which applies to all foods across all categories) to judge whether individual foods are ‘healthy’/ ‘high in fat, salt or sugar’ (HFSS) may not be an effective way of achieving this objective. As EFSA has alluded to, it is difficult to come up with a science based universal nutrition profiling scheme which ‘attempts to distil a product’s nutrient composition into a single score'.

FSA defines nutrient profiling as "the science of categorising foods according to their nutrient composition". But FDF is not entirely convinced that nutrient profiling is a science.

FDF has developed at set of scientifically based profiling principles, which we believe should be considered when developing a nutrient profiling model:

1. it should have a clear and unambiguous objective for tackling a clearly defined end point, e.g. obesity, blood pressure, heart disease, etc...
2. it should consider all nutrients (not foods) relative to the objective, appropriately balanced according to their expected impact on the defined end point, based on a high standard of scientific evidence
3. if designed for a defined population should be based on the average within that population (e.g., bodyweight, activity level)
4. it should consider actual consumption patterns, taking account of amounts typically consumed and may include frequency
5. it should be capable of identifying significant differences in nutrient composition within and between foods, thereby encouraging appropriate reformulation or new product development appropriate to the objective
6. it should be understandable by those expected to comply but does not necessarily have to be understood by consumers
7. should be sufficiently robust, as a rule, so as to avoid the need for exemptions
8. it should avoid absolute adjectival parameters in its design or execution e.g. ‘healthy', 'unhealthy', 'good', 'bad', etc.
9. it can be category based scheme if appropriate for the objective
10. it can use thresholds, algorithms, or some other numerical system provided they levels are based on generally accepted scientific evidence and any comparative impact on individuals foods is proportionate.

Background

a) FSA’s Model for use by Ofcom

• The approach used in developing the model is questionable because it is circular: it starts from a list of foods, subjectively labelled as ‘good’ and ‘bad’; moves on to devise a scoring scheme which reflects that assessment; then validates the scoring system against the original list.
• The approach adopted by FSA is a subjective judgment of the perceived nutritional value of a product. It only looks at a very narrow snapshot of a product’s nutritional value and classifies some foods which are major contributors of important nutrients, such as cheese and breakfast cereals, as ‘unhealthy’.
• It is the combination of foods eaten, the frequency of consumption and portion size that is important in achieving a balanced diet; none of these factors is considered. Although the scoring system is based on GDA bands, the final scores do not bear any real relation to percentage GDAs nor any other public health measure; it seems to have been designed to ensure certain foods, deemed to be high in salt, fat and sugars, did not pass.
• If reduced fat, salt and/or sugar products cannot be advertised, because both the ‘regular’ and the alternative product fail the FSA model, it will restrict opportunities for manufacturers to highlight the benefits of such alternative choices and thereby serve to discourage innovation.

In March 2005, the Government’s Food and Health Action Plan committed FSA to publishing nutritional criteria as a basis for advising Ofcom on restrictions on the advertising to children of foods high in saturated fat, salt and sugars (HFSS).

As a first step, FSA established an expert group in 2004 comprising nutrition scientists, dietitians, food industry (including FDF), consumer organisations and policy makers to oversee the development of its model. FSA refined and tested the model against a wide range of foods and consulted on the revised model. FSA also took on board the advice from SACN, and before the consultation period was over, decided to make further alterations to the model which effectively widened the net over which processed foods would be deemed to be ‘unhealthy’. The final model, with the additional changes, was endorsed by the FSA Board on 13 October 2005. It classified individual foods as ‘high in saturated fat, salt or sugar’ by taking into account the energy, saturated fat, total sugar and sodium; as well as the amount of protein, fibre, nuts, fruit and vegetables in a product.

In February 2007, following two periods of consultation, Ofcom published a statement on new rules relating to TV advertising of food and drink to children. Ofcom’s final statement concludes that, ‘it is appropriate and necessary to adopt restrictions intended to reduce significantly the exposure of children under 16 to HFSS advertising’.These restrictions are now in place, meaning no HFSS food/drink advertisements are now permitted in and around TV programmes of appeal to children under 16. HFSS advertising is defined by FSA’s nutrient profiling model.

b) European Profiling Model for Nutrition and Health Claims

Nutrient profiles are also being considered for the purpose of restricting the use of nutrition and health claims on foods that contain high levels of fats, sugars and salt – if a product fails one of the nutrient profiles then the product will not be allowed to bear any health claim. A nutrition claim will be permitted provided that a claim about the failing nutrient is displayed with equal prominence on the label.

FDF believes that the nutrient profiles will prove to be an obstacle for innovation particularly for categories that have been severely restricted or completely excluded from the possibility of making health claims.

The EU model was expected in January 2009, however this deadline has been significantly delayed and we continue to wait for agreement at the EU level.

top