The British diet is too high in fats, particularly saturated fats, salt and sugar and too low in fibre. Nutrition claims such as ‘low fat’ and ‘high fibre’ on food packaging could help consumers choose a healthy diet. The Coronary Prevention Group (CPG) conducted a survey to assess whether nutrition claims in current use are helpful.
The survey found that many claims failed to meet proposed regulations issued by the Ministry of Agriculture, Fisheries and Food (MAFF). Claims were frequently selective, highlighting a desirable level of one nutrient while giving much less prominence to undesirable levels of others. Many foods claiming to be low in a nutrient were in fact high in that nutrient. Often foods making claims failed to state the actual amount of the nutrient in question (making it impossible for the researchers, let alone consumers, to verify the claims from the labels).
Claims and nutrient content were assessed against existing legislation and various proposals for control. Claims on energy, protein, cholesterol and polyunsaturated fat conformed to existing UK legislation but were not necessarily helpful to the consumer. Additional regulations proposed by MAFF would be more helpful but may not be adopted by the EC. A proposed EC Directive would establish legal definitions for all nutrition claims but current drafts would have little effect on the misleading nature of many claims and could even make the situation worse.
MAFF is urged to ensure that legislation makes nutrition claims informative, relevant and soundly based on nutritional principles. All foods making nutrition claims must have, as a minimum, comprehensive and comprehensible nutrition labelling. Recommendations are made for establishing definitions for all nutrition claims.
The UK has one of the highest death rates from coronary heart disease in the world. One of the main causes of this is our unhealthy diet. A healthier diet would include less fat, particularly saturated fat, less sugar and salt, and more fibre. Food manufacturers could help people choose a more healthy diet by providing relevant information on food packaging. In order to assess whether manufacturers do provide helpful information the Coronary Prevention Group (CPG) carried out a survey of nutrition claims – ‘high fibre’, ‘half fat’, ‘cholesterol free’, etc. – found on all foods sold in five large supermarkets. A brief summary of the findings of this survey are reported here. The full report of the results can be obtained from the Coronary Prevention Group 1.
Nutrition claims can be misleading for at least three reasons. Firstly they can be ambiguous. For example, a low fat claim on the packaging for some sausages could mean either that the product has a lower fat content than other sausages, or that sausages in general are low in fat relative to all foods. Sausages normally have a high fat content so the former meaning is more likely. However consumers are often unclear about how much fat to expect in foods2 so it is possible that they will be confused over the meaning of this type of claim.
Secondly nutrition claims can be selective. Food packets emphasise the desirable features of a food that means that negative characteristics that might offset the positive properties can be obscured. For example several breakfast cereals claim to be ‘high in fibre’ but neglect to state that they are also high in sugar and salt.
Thirdly nutrition claims can be easily misunderstood. Some claims rely on the general public’s lack of knowledge on nutrition. For example, vegetable oils often carry a low cholesterol claim but in 1984 the Government’s Committee on the Medical Aspects of Food Policy (COMA) suggested that there were insufficient grounds to recommend a reduction in the consumption of dietary cholesterol3. Low cholesterol claims exploit consumer confusion over the distinction between dietary and blood cholesterol. To reduce blood cholesterol levels people should primarily reduce their fat and saturated fat intake. Foods making cholesterol claims can be high in fat and saturated fat. Another example is when a product such as tinned carrots claim to be low in added salt but has a high total salt content.
Controls on the use of claims should help to ensure that claims are not misleading, but in the UK legislation only covers a few types of nutrition claim – energy, protein, polyunsaturated fat and cholesterol claims4. The European Community has recently passed a Directive which, when implemented in the UK, will marginally improve the labelling of foods making nutrition claims5.
Legislation for nutrition claims is therefore inadequate. This could be about to change; the European Commission is drafting a Directive aimed at harmonising claims legislation across the Community6,7.
There are various proposals for this proposed legislation including those published by the Ministry of Agriculture, Fisheries and Food8, 9 and the Coronary Prevention Group 10. The survey aimed to assess the effect of these proposals on claims as currently used and whether they would make them more or less misleading to the consumer.
METHODS
Five medium sized supermarkets were visited and approximately 30,000 foods scanned for nutrition claims. Details of the wording of all claims and of the foods on which such claims were found were recorded. The nutrition content of foods making claims was obtained from the nutrition labelling.
A nutrition claim was defined as an explicit reference to the content of protein, carbohydrate (including sugar), fat (including polyunsaturates, monounsaturates, saturates and cholesterol), fibre, salt and energy. Vitamin and mineral claims (other than for salt) and implied nutrition claims, such as ‘light’, ‘lean’ and ‘diet’, were not recorded.
Each food making a claim was compared with a similar food not making a claim. The nutrition content and other details were recorded for a similar food located on a nearby shelf or were obtained from McCance and Widdowson’s “The Composition of Foods” and related Tables 11,12.
The nutrient content levels of foods making claims were banded into ‘high’ ‘medium’ and ‘low’ by a scheme developed over several years by the Coronary Prevention Groupl3. Unless otherwise stated these definitions are used throughout this report when referring to the actual, as opposed to claimed, nutrient content levels of foods.
RESULTS
The Nutrients Referred to in Nutrition Claims
629 nutrition claims were collected. Table 1 shows these claims classified by the nutrient to which they refer. It shows that fat claims are the most frequent type of nutrition claim (30% of all claims). This reflects the view that the most important dietary change that people need to make in the UK is to reduce their fat intake. However, given the UK Government’s dietary recommendations, some nutrition claims were unduly common. The 1984 COMA Committee suggested that there were insufficient grounds to recommend a reduction in dietary cholesterol3 yet 4% of claims were cholesterol claims. Some claims are unduly rare – saturated fat claims on food packets could be used to help people change the type of fat they eat as opposed to the total amount of fat, yet they only constituted 6% of claims.
Table 1. Frequency of nutrition claims by specified nutrient
| Nutrient | % of all claims | Main types |
| Energy Protein Carbohydrate Sugar Fat Saturated fat Polyunsaturated fat Monounsaturated fat Cholesterol Salt Fibre MiscellaneousTOTAL | 17 1 0 18 30 6 4 1 4 7 10 2100 | x% calories, low calorie high protein N/A No added sugar, low sugar Low fat, x% less fat Low in saturates High in polyunsaturates High in monounsaturates Low in cholesterol No added salt, low salt High fibre Enriched with glucose |
Types of Foods Making Nutrition Claims
Generally it was foods in which the consumer might expect to find a particular nutrient that made claims for that nutrient. For example, 82% of foods making a ‘reduced’ fat claim and 26% of low fat claims were for foods that were high in fat by CPG criteria.
Some foods rarely if ever carry a relevant claim. For example breakfast cereals which were low in salt were never found to carry a low salt claim, even though many breakfast cereals are high in salt. Cakes, biscuits and confectionery rarely carry a low or reduced fat claim even though they are often high fat foods ll. Foods which nutritionists recommend should be a major part of a healthy diet – particularly fruit and vegetables – hardly ever carry a nutrition claim.
As well as the amount of the nutrient referred to in the claim other nutritional characteristics of foods which made claims were investigated. Many examples of selective claims were found. A breakfast cereal claiming to be ‘very high in fibre’ was high in salt and sugar, a pate labelled ‘less than half the fat’ was high in saturated fat, and so on.
Table 2 shows the nutritional breakdown for foods making a fat claim. It shows that only 34% of foods making such a claim were high in fibre, 70% were high in salt, 62% were high in saturated fat and 19% were high in sugar.
Table 2. Other nutritional characteristics of foods making a fat claim
| Nutrient | Low | Medium | High | No. of claimswhere sufficient data |
| Protein Carbohydrate Sugar Fat Saturated fat Sodium Fibre | 15% 49% 62% 33% 7% 19% 63% | 20% 50% 19% 24% 31% 11% 3% | 65% 1% 19% 43% 62% 70% 34% | 183 180 21 185 45 27 32 |
The Wording of Nutrition Claims
A nutrition claim can suggest a desirable content of a particular nutrient in various ways. 75% of nutrition claims used adjectives – ‘high’, ‘low’, ‘less’, ‘rich’, ‘no’, etc. – but 25% of claims used numerical descriptions – ‘14% fat’, ‘half fat’, ‘10% less fat than the previous recipe’.
Numerical claims
Numerical descriptions of nutrient content were most commonly used for fat and energy. 54% of energy claims and 41% of fat claims were numerical claims. At first sight numerical claims are objective descriptions of the nutrient content but they can often be misleading.
For example one prepared meal claimed to supply ‘450 calories’ (450kcal or 1907kJ per serving, around one fifth of the average adult’s energy intake). Although this claim was technically accurate, eating this product may not help significantly in a weight reducing diet. Similarly a brand of chopped ham claimed to have ‘10% less fat than the previous recipe’ while having a fat content of 20g/100g fat (70kJ/100kJ; 5.6g/serving). This claim could be taken to imply that eating this product could help to reduce fat intake. One normal portion of this food constitutes around 10% of a person’s daily energy requirement. Eating a normal serving of the fat-reduced product rather than of the previous product would lead to a reduction in that day’s fat intake of 0.6g. This represents approximately 3% of the average recommended reduction in fat intake from 88g to 70g fat per day.
Adjectival claims
Adjectival claims can be divided into three basic categories, shown in Table 3.
Table 3. The wording of adjectival nutrition claims
| Claim type | Examples | % of all nutrition claims |
| Absence claimsAbsolute claimsRelative claims | no added sugar, salt freelow fat, very low fat, high fibre, source of fibrelower fat, reduced fat, more fibre | 16%48%9% |
Adjectival claims are often ambiguous. In only 2% of cases was it clear from the wording of the claim that ‘low fat’ meant that the food was a low fat food rather than that the food had a reduced fat content.
Adherence to Current Regulations
Energy, protein, polyunsaturated fat and cholesterol claims are covered by the 1984 Food Labelling Regulations4 – 27% of claims in current use are of this type.
Energy, protein and polyunsaturated fat claims must be accompanied by a declaration of the nutrient referred to in the claim and 100% of such claims did carry such a declaration. The Food Labelling Regulations do not require cholesterol claims to be accompanied by a declaration of the cholesterol content; only 30% of such claims did declare it.
Claims for energy, polyunsaturates and cholesterol must also be accompanied by other labelling information. For example a low cholesterol claim must be accompanied by a statement that the food is low in saturates (even though they are not generally low in saturated fat by MAFF or CPG criteria). 100% of these claims conformed to these additional labelling requirements. Claims that are regulated must also conform to compositional requirements, for example foods making a high protein claim must have protein content of more than 12kJ/100kJ. 100% of the claims conformed to these requirements.
171 energy, protein, polyunsaturated fat and cholesterol claims were investigated, all of which conformed to the Food Labelling Regulations.
One way of making a claim for cholesterol, protein, energy and polyunsaturated fat which is not apparently covered by the Food Labelling Regulations is to word it as a numerical description of the nutrient content. 54% of calorie claims were numerical claims and 83% of these could not have made a low calorie claim under the existing regulations.
The Effect of New EC Legislation
When the new EC Labelling Rules Directive5 is implemented in the UK, all foods making nutrition claims will have to meet certain labelling requirements.
All foods making a nutrition claim will have to declare the content of the nutrient referred to in the claim. Table 4 shows that 70% of cholesterol claims, 70% of salt claims and 65% of sugar claims currently fail to do so.
When an energy, protein, carbohydrate or fat claim is made, the food will have to make a declaration of the energy, protein, carbohydrate and fat content (on a per 100g basis) – this is called Group 1 nutrition labelling. Table 4 shows that 88% of such claims currently make such a declaration. When a sugar, saturated fat (or other fat subclasses, including cholesterol), salt or fibre claim is made, the food will have to declare the four main nutrients plus saturated fat, sugar, salt and fibre – a Group 2 declaration. Table 4 shows that around 20% of such claims currently make such a declaration.
The new Directive will improve the labelling of foods making claims but it is still inadequate. If the consumer is to assess the validity of claims the nutritional labelling of foods should be comprehensive. For example, only 24% of foods making a fat claim declared the saturated fat content; this would not need to change following the implementation of the new Directive, so even for foods claiming to be healthy on the basis of their total fat content it will often be impossible to assess whether they are high or low in saturated fat.
In 1987 MAFF published voluntary guidelines for nutrition labelling which recommended that nutrition claims should be accompanied by a declaration similar to EC Group 2 labelling14. Table 4 shows that only 17% of foods made a Group 2 declaration and that 14% of the similar foods without claims made such a declaration. In other words foods making nutrition claims were no better labelled, despite the 1987 Guidelines, than foods not making claims. This is an example of the failure of voluntary guidelines to ensure the effect intended by Government. The Coronary Prevention Group considers that nutrition labelling should be mandatory for all foods and there should be one specified format similar to Group 2 labelling.
Table 4. Nutritional labelling offoods making nutrition claims
| Nutrient | Claim nutrient declared by (%)* | Group 1 declaration made by(%) | Group 2 declaration made by (%) |
| Energy Protein Sugar Fat Saturated fat Polyunsaturated fat Cholesterol Salt FibreAll claimsSimilar foods | 100 100 35 100 100 100 30 30 97 87N/A | 94 100 95 95 60 64 63 87 98 86 89 | 19 13 9 10 20 25 26 9 361714 |
| * Percentages in this column exclude absence claims |
The Effect of Proposed Regulations
The EC is currently proposing a Directive to regulate the use of nutrition claims in other ways; there are at least two drafts in circulation 6,7. MAFF have indicated that they will urge the EC to adopt controls similar to those of the 1984 Food Labelling Regulations4 and to proposals published in 1989 for new regulations to control fat, saturated fat, sugar, salt and fibre claims8. The Coronary Prevention Group has produced proposals of its own for the control of nutrition claims 10.
These proposals deal mainly with the composition of foods making nutrition claims. The effect of these proposed compositional controls on current nutrition claims was assessed. Table 5 summarises the results for absolute and relative adjectival claims.
Table 5. Percentage of nutrition claims which met proposed criteria
| 1. Absolute claims (low/high) | ||||
| Criteria | ||||
| MAFF | EC1 | EC2 | CPG | |
| Energy Protein Fat Saturated fat Polyunsaturated fat Cholesterol FibreAll claims, excluding energy | 100 100 56 3 100 100 93 65 | 100 0 50 18 61 20 3540 | 93 0 75 26 61 20 3853 | NC 100 42 0 100 100 8558 |
| 2. Relative claims (lower/higher) | ||||
| MAFF | EC1 | EC2 | CPG | |
| Energy Fat | 90 88 | 80 47 | NC NC | 55 24 |
| NC = No Criteria given For details of the Criteria see Refs. 4,8,6,7 and 10 or the Full Report1. |
Absolute claims
There are two types of compositional criteria for absolute claims. MAFF and CPG specify that all foods making the claim must meet absolute criteria, whereas the current draft EC proposals require the foods to have a nutrient content higher or lower by a given amount than a similar food. So for low fat claims there are the following proposals:
MAFF: The fat content must be less than 5g/100g and less than 5g/normal serving.
CPG: The fat content must be less than 15kJ/100kJ.
EC1: The fat content must be at least 60% less (by weight) than in a similar food or a previous recipe.
EC2: The fat content must be at least 50% less (by weight) than in a similar food or a previous recipe.
Table 6 shows the proportion of low fat claims which met the four proposed compositional criteria and the percentage of claims meeting those criteria that met the other criteria. Table 7 shows the fat content of low fat claims and of those claims that met the four criteria.
Table 6. Low fat claims that met proposed criteria
| Criteria | % of claims which met one criterion | % of these claims which met remaining criteria | |||
| MAFF | CPG | EC1 | EC2 | ||
MAFF CPG EC1 EC2 | 56 42 50 75 | (100) 100 73 62 | 76 (100) 65 49 | 64 76 (100) 67 | 82 86 100 (100) |
Table 7. Mean (± S E M) fat content of foods making low fat
claims and of those which met the criteria (N = 89)
| Criteria | g/100g | g/serving | kJ/100kJ |
All Claims MAFF CPG EC1 EC2 | 11.5 (1.2) 1.2 (0.1) 0.9 (0.1) 6.9 (0.7) 10.4 (1.1) | 2.7 (0.3) 1.0 (0.1) 0.8 (0.1) 1.7 (0.2) 2.4 (0.3) | 32.6 (3.2) 9.1 (1.0) 4.6 (0.5) 25.3 (2.7) 29.6 (3.2) |
Tables 6 and 7 illustrate the main differences between the two basic systems of controls for absolute claims. Table 6 shows, for example, that although a similar proportion of low fat claims met the MAFF and the first EC version, the two systems differ in the type of claims they allow: more than a third of low fat claims which met the MAFF criteria failed the EC1 criteria and vice versa.
Table 7 shows that absolute criteria such as MAFF’s or CPG’s mean that the average fat content of foods which met the criteria was much lower than where the criteria are relative, as in the two EC versions. Many low fat claims which met the MAFF and CPG criteria would not be allowed under the current EC proposals – for semi-skimmed milk, some yoghurts, baked beans and pulses, for example – because the similar food has a similar fat content.
Relative claims
For relative claims the criteria proposed by MAFF, the EC and CPG differ in the percentage reduction in the claimed nutrient from a similar food that they require. The MAFF criteria require a reduction of 25%, the EC criteria 30% and the CPG criteria 50%.
CPG argues that controls on relative fat claims should prohibit their use when the percentage reduction is too small to make any appreciable difference to the consumer’s fat intake 10. MAFF consider the percentage reduction should be at least 25% and suggest that ‘A higher figure would exclude some products which could not technically achieve such a cut without changing their nature but which could contribute significantly to dietary change8,9. Table 5 shows that only 24% of lower fat claims did not achieve the 50% reduction required by the CPG criteria. These claims were mostly for foods such as spreads, which did achieve a 50% reduction in other cases.
Absence claims
16% of nutrition claims were absence claims (e.g. ‘no salt’). 77% of these were for sugar, 18% for salt and 5% for fat. It was not possible to assess whether these claims met criteria proposed by the MAFF and EC6,7,8 because the foods making these claims did not give the content of the claim nutrient. It was clear, however, that some at least of the claims were misleading. For example foods which claim to have no added salt can have a relatively high total salt content. One brand of tinned carrots had a salt content of 0.1g/100g (12g/10MJ), high in salt by CPG criteria.
CONCLUSION
It was shown that many nutrition claims on food packaging are
- ambiguous; for example, sausages labelled ‘low fat’ could lead people to believe that this was a product low in fat, as opposed to a high fat product with marginally less fat than other sausages
- selective; for example, 70% of low fat claims were for foods high in salt
- easily misunderstood; for example, 4% of nutrition claims were low cholesterol claims, but a diet high in fat, particularly saturated fat, not dietary cholesterol, is the main cause of high blood cholesterol.
Claims generally complied with existing legislation but the findings suggest that the legislation is failing to ensure that nutrition claims help consumers to choose healthy foods. The MAFF proposals would do more to help but may not be adopted by the EC. The proposed EC legislation, in its current form, is unhelpful and could even make the situation worse. Legislation is necessary as the survey showed that the food industry has not responded well where MAFF has relied on exhortation to improve matters. For example, more than two thirds of foods making sugar, salt or cholesterol claims failed to comply with MAFF guidelines that they should state the content of the nutrient referred to in the claim.
RECOMMENDATIONS
- The Coronary Prevention Group urges MAFF to review existing and proposed legislation for nutrition claims to ensure that nutrition claims are made more informative, relevant and based on nutritional principles. CPG’s nutritional banding system13, which is based on WHO recommendations and is in line with the recent WHO report, “Diet, Nutrition and the Prevention of Chronic Diseases”15, could be extended to cover nutritional claims. Such a scheme would include the following points.
- Absolute nutrition claims (whether numerical or adjectival) should meet absolute criteria, set separately for each nutrient and applying to all foods. For example a low fat claim should only be made where the food has a fat content of less than 15kJ/100kJ.
- Relative claims should only be allowed where consumption of the product has a significant effect on nutrient intake. For example a reduced fat claim should only be made where the food has a fat content which is 50% less than a similar product.
- Nutrition claims should always be accompanied by comprehensive and comprehensible nutrition labelling.
7. REFERENCES
1. Coronary Prevention Group (1991). The Regulation of Nutrition Claims. Full Report CPG: London.
2. Consumers’ Association (1989). Consumers and Food Claims. An in-depth analysis of consumers’ attitudes and reactions to claims on food labels. Consumers’ Association: London.
3. Department of Health and Social Security (1984). Diet and Cardiovascular Disease. Committee on Medical Aspects of Food Policy Report of the Panel on Diet in Relation to Cardiovascular Disease. HMSC): London.
4. Food Labelling, Descriptions, Etc. The Food Labelling Regulations 1984. Statutory Instruments 1984/1305.
5. Commission of the European Communities (1990). Council Directive of 24 September 1990 on nutrition labelling of foodstuffs. 90/496/EEC.
6. Commission of the European Communities (1989). Proposal for a Council Directive on the approximation of the laws of the Member States relating to claims made in the labelling, presentation and advertising of foodstuffs for sale to the ultimate consumer. III/B300/89-EN.
7. Commission of the European Communities (1990). Draft Commission proposal for a Council Directive amending Directive … / … /EEC on the approximation of the laws of the Member States relating to the labelling, presentation and advertising of foodstuffs. SPC/104/90-EN.
8. Ministry of Agriculture Fisheries and Food. Food Advisory Committee (1989). Nutrition Claims in Food Labelling and Advertising. MAFF: London.
9. Ministry of Agriculture Fisheries and Food (1991). Food Advisory Committee Report on its Review of Food Labelling and Advertising 1990. HMSO: London.
10. The Coronary Prevention Group (1990). Memorandum to the Commission of the European Communities concerning proposals for a Council Directive on the approximation of the laws of the Member States relating to claims made in the labelling, presentation and advertising of foodstuffs for sale to the ultimate consumer. CPG: London.
11. Paul AA, Southgate DAT (1978). McCance and Widdowsons’s: The Composition of Foods.4th ed. HMSO: London.
12. Crawley H (1988). Food Portion Sizes. HMSO: London.
13. Coronary Prevention Group (1990). Nutrition Banding. A scientific system for labelling the nutrient content of foods. CPG: London.
14. Ministry of Agriculture Fisheries and Food (1988). Guidelines on Nutrition Labelling (Revised January 1988). MAFF: London.
15. World Health Organisation (1990). Diet, Nutrition and the Prevention of Chronic Diseases. WHO, Geneva.