A perspective on labelling and consumer understanding

This article presents a perspective on food additives, how consumers understand them and their labelling. It also highlights the evolution of consumer information obligations and expectations in the light of new EU Regulations.

There are likely to be many reasons why con – sumers consult food labels and the reasons probably differ according to age, education and culture. One of the few published studies was done by the Food Safety Authority of Ireland (FSAI). Three years ago, the FSAI commissioned face-to-face surveys to investigate consumers’ understanding, knowledge and attitudes to food labelling. The results1 of these surveys published in December 2009, makes interesting reading as these results are indicative of the attitudes of European consumers.

When the consumers who found food labelling informative were asked ‘Why do you read food labels?’, the reasons most often given were to look for information on nutrients, calorie content or specific ingredients. Healthy eating is a major concern for many people and this may explain why looking for nutrient information and calorie content are at the top of the list of reasons for consulting food labels. This also comes as a good justification for the update of the European food labelling rules which have recently been adopted under the new regulation2 on Food Information to Consumers.

Most food companies now place high priority on providing consumers with nutrition information on food labels to make informed dietary choices. To demonstrate this comm – itment, they voluntarily applied Guideline Daily Amounts (GDA’s) on their packs for the past few years as part of an industry self-regulatory approach. The GDA scheme delivers simple, objective per portion information, which enables consumers to make an informed choice about their food and drink intake in line with their nutritional needs, helping them to make better food choices and evaluate a product’s place in the diet.

Looking back at the reasons for consulting food labels, it should be noted that in the FSAI survey, only three per cent of people (who find food labels informative) wanted to know about the inclusion of food additives. When it comes to what is called the ‘categories’ i.e. the role or the technological function these additives perform in the final food, then consumers are even less interested. For the few consumers who are interested in knowing if a specific ingredient is used as a sequestrant, bulking agent, humectant, antioxidant or even as a stabiliser or a preservative, then this information could be made available through already well-developed digital tools (smartphones, websites). In this way, food labels would not be unnecessarily overloaded.

New regulatory requirements for Food Information to Consumers

The recently published EU Regulation 1169/2011 on the provision of food information to consumers brings a significant overhaul of the mandatory labelling requirements to be provided to the consumers, among others:

• The nutrition labelling becomes mandatory for all products and has to include the amounts of six nutrients beside the energy value (BIG 7). Until now, the minimum nutrition information to provide on a voluntary basis includes only three nutrients beside the energy value (BIG 4)
• To improve the legibility, a minimum font height has to be respected. Until now, no specific height was required
• Allergens must be highlighted
• Requirements on origin labelling could be widely extended
• Specific labelling of vegetable fats/oils; i.e. the vegetable name of the oil/fat used has to be specified

All this additional mandatory information uses up available space on the packaging, which for many labels is already very limited. It also makes the food labels more complex and will require more time for consumers to read and under – stand them. Clearly, well-developed digital tools can provide all that information and even more. Article 12.3 and 12.4 in the above-mentioned new EU regulation even foresee that criteria and modalities of application can be established to provide certain mandatory food information by other means than on the package or the label.

Current EU regulatory environment regarding the use and the labelling of food additives

According to the EU Regulation 1333/20083 on food additives, additives are defined as “any substance not normally consumed as a food in itself and not normally used as a characteristic ingredient of food, whether or not it has nutritive value, the intentional addition of which to food for a technological purpose in the manufacture, processing, preparation, treatment, packaging, transport or storage of such food results, or may be reasonably expected to result, in it or its by-products becoming directly or indirectly a component of such foods.”

So in fact, the difference between additives and other substances used to produce a food is that an additive is not consumed as such. Moreover, additives are used in minute amounts that are sufficient to perform the specific technological function for which they are intended. Food additives are chemically welldefined substances, each of them having purity criteria precisely defined by law.

The example of emulsifiers4 is a good one. Egg yolk was probably the first emulsifier ever used in food production back in the early 19th century. Because emulsifiers in egg yolk break down rather rapidly, manufacturers switched to more stable emulsifiers. Emulsifiers currently used in food production are either purified natural products (such as egg yolk used as an emulsifier in mayonnaise) or chemicals that have very similar structures to the natural products and are classified as food additives.

Safety requirements and conditions of use for food additives

The use of food additives in the manufacture, processing, preparation, treatment, packaging, transport or storage of foods is very strictly regulated. This begins with a safety approval process to ensure that each additive poses no safety concern to the health of the consumer, that there is a reasonable technological need for its use and that its use does not mislead the consumer. Hence, an E-number has been attributed to additives which have been evaluated at the European level by the European Food Safety Authority (EFSA) or, before its establishment in 2002, by the Scientific Committee for Food (SCF). Only food additives which are on the now so-called European Union List are allowed for use in foods.

Conditions for the use of food additives (maximum levels in specific food categories) have been largely updated and recently published in very detailed EU regulations5.

Labelling requirements for food additives

The first European legislation relating to labelling, the Council Directive 79/112 of 18 December 1978, introduced the concept of labelling additives with their category followed by their specific name or E-number. As mentioned earlier, category means a ‘functional class’ and covers the technological function of a given additive. The categories evolved along the revisions of the Labelling directives. At that time, it did not apply to the so-called ‘vertical’ provisions such as chocolate products. Until the adoption of the new Labelling Directive 2000/13 in March 2000 and the new Directive 2000/36 on cocoa and chocolate in June 2000, it was not mandatory to label a list of ingredients on chocolate products which means that the addition of lecithin as emulsifier, for example, was not necessarily labelled.

Food manufacturers themselves have to determine the appropriate technological purpose for a given additive, which then has to be labelled in the list of ingredients together with its name or E-number. However, the question should be raised as to whether this information gives any benefit to the consumer. Along with most surveys, which show that consumers look for more detailed nutrition information, one should ask if informing the consumer about the technological function of the food additives remains pertinent, and still contribute to unjustifiably or unduly complicated and overcrowded list of ingredients and food labels.

Consumer perception about food additives

Food additives have always played an important role in food supply. Food additives help consumers to enjoy a variety of safe, wholesome and tasty foods all year round. They also make it possible to enjoy the convenience of food without shopping every day. Some substances like salt, baking powder, vanilla, gelling sugar and yeast are commonly used in the preparation of food at home and they are used because of their technological function. However, many people tend to think that all food additives are complex chemical compounds. Food additives perform a variety of important technological functions such as e.g. avoiding microbiological spoilage, reducing oxidative deterioration or facilitating the mixing of fat and water.

In this context, it is interesting to observe the increased transparency in recent years in communicating the importance of food additives. One example of this is the highly respected BBC TV program6 ‘E-numbers: An edible adventure’ which demystifies the usage of food additives.

Other suggestions to simplify food additives labelling

The Federation of European Specialty Ingredients Industries (ELC)7 has another proposal on how to simplify the labelling of additives:

“A number of food additives differ from each other by a minor chemical change, not easily understandable for the average consumer. The ELC proposes creating a new opportunity to allow simpler labelling for certain additives that express strong similarities, notably chemically, tech – nologically and toxicologically, i.e. it would be an option to mention them by a group name as an alternative to their specific names. For example, it should be permissible to label sorbic acid, potassium sorbate and calcium sorbate as ‘sorbates’. Another example is the labelling of phophates: ‘phosphates’ is a denomination well known by the consumer, and it is easy to identify at first sight in a list of ingredients. The ELC proposes to group phosphoric acid, orthophosphates, diphosphates, triphosphates and polyphosphates under the umbrella name ‘phosphates’. There are numerous other cases where such simplification could be made, with the following benefits: the label would be simplified and its legibility subsequently improved; the grouping of similar additives under an umbrella name would be more meaningful for the consumer; the simplification of the list of ingredients and its subsequent potential shortening would free space on the labels for the mandatory nutritional labelling, specifically on small packages; more flexibility and cost-efficiency would be offered for minor reformulation of food products without bearing the high costs of changing a label.”

Way forward

Given consumer perception and the new regulatory developments briefly described above, it would be pertinent to reconsider the need for mandatory indication of the technological function of food additive(s) in the ingredient list. This is because this way of labelling uses space in the list of ingredients without giving any further valuable information to the consumer. The EU labelling regulation defines ‘ingredient’ to mean any substance or product, including flavourings, food additives and food enzymes, and any constituent of a compound food. So food additives are considered to be ingredients as are salt and sugar which can act as a flavour enhancer and preservative. However the declaration of salt and sugar is not complemented by the indication of their function in the final product so why should then the additives be labelled with their technological purpose? By omitting the category (functional class) labelling, consumers would not be misled, as the name of the food additive would still be indicated in the list of ingredients, possibly in a simplified way as in the ELC proposal. Although food additives have been properly evaluated by the relevant competent authorities and declared as safe, consumers often think they are less beneficial than other ingredients in manufactured foods. Consumers can even be confused about the technological function of additives. The meaning of designations such as ‘sequestrant’, ‘acids’ and ‘humectants’ are certainly not obvious to understand for an average consumer.

At a time of already well-developed digital tools (smartphones, websites), is it not the right moment for all stakeholders to consider simplification of food labels by no longer mentioning the technological function of a specific food additive in the list of ingredients and, in line with article 12.3 and 12.4 of the EU Regulation2, to consider the provision of this information by means other than on the package or on the label?

References

1. FSAI, A Research Study into Consumers’ Attitudes to Food Labelling, December 2009

2. Regulation (EU) No 1169/2011 of the European Parliament and of the Council of 25 October 2011 on the provision of food information to consumers, OJ L340

3. Regulation 1333/2008 of 16 December 2008, OJ L354

4. http://www.eufic.org/page/en/page/FAQ/faqid/ difference-natural-artificial-emulsifiers/

5. EU regulations 1129/2011, 1130/2011 and 1131/2011 of 11 November, OJ L295

6. http://www.bbc.co.uk/programmes/b00tl4qk

7. Source: FLEXNEWS 05/04/2012

About the authors

Dominique Taeymans is a Regulatory & Scientific Affairs Manager at Nestec, Switzerland. He joined Nestlé six years ago and has been practicing many different aspects of food regulatory affairs for more than 20 years.

Himanshu Gupta is a Regulatory & Scientific Affairs Manager at Nestec, Switzerland. He has worked at Nestlé since 2000 and has been in regulatory affairs for the past seven years.

Grethe Humbert is a Regulatory & Scientific Affairs Manager at Nestec, Switzerland. She joined Nestlé Switzerland 16 years ago as a Regulatory Affairs Manager. She has spent 26 years in food regulation and is currently dealing with topics such as food additive regulations, allergens and product composition.