Front-of-pack labels are a matter of contention between industry and campaigners in markets across the world. In the final section of the management briefing on nutrition labels, Ben Cooper looks at a key point of the debate – whether or not a label should interpret nutritional value for consumers in the form of a symbol or a colour.


Wherever the issue of front-of-pack labelling has been debated in recent years, the question of whether a system should be interpretive or non-interpretive has been central to the discussion, and has been a consistent point of difference between the food industry and public health groups.

Put simply, the industry prefers non-interpretive systems. The arguments presented for that position are various but some would suggest that primarily food companies object strongly to the idea of a system which would define products as unhealthy. A cross or a red light is perceived by some as tantamount to a health warning on their products. The industry’s position on questions of diet and health and obesity is that there are no unhealthy foods, just unhealthy diets.

Public health professionals, on the other hand, argue that a simple mark on a product that warns consumers of a high content of a nutrient to limit, such as sugar, salt or saturated fat, is a perfectly justified public health measure, particularly in light of rising obesity rates in so many countries. 

Food producers suggest they know what their consumers want and need and that interpretive systems are a simplistic tool, which can brand as unhealthy foods which if consumed in appropriate proportions can be part of a balanced diet. And so the debate goes on.

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Interpretive versus non-interpretive approach
In the space of a few years there have been extended debates over FOP nutritional labelling in the UK, in the US and in Australia, and in each of these markets the issue of whether the FOP label should be interpretive or not has been the chief bone of contention.
Interestingly, while industry has taken a differing view from consumer organisations and health campaigners on the issue, it has also found itself at odds with the conclusions of research or reviews commissioned by government public health agencies.
The US
The debate currently taking place in the US is the most recent case to point. A report by the Institute of Medicine (IOM), which was commissioned by Congress, recommends an interpretive system.
The IOM could not be clearer. It concludes that “it is time for a move away from front-of-package systems that mostly provide nutrition information on foods or beverages but don’t give clear guidance about their healthfulness, and toward one that encourages healthier choices through simplicity, visual clarity, and the ability to convey meaning without written information.”
The IOM says that the nutritional rating would be “graphically displayed on packaging as check marks, stars, or some other icon”. Interestingly, the report does not specifically mention traffic lights
An IOM spokesperson told just-food that the research had concentrated on the question of whether there should be some form interpretive symbol on the pack, rather than going into the question of what that symbol should be, which it believes should be a subject for further investigation by the FDA. In other words, the IOM’s work was very focused on the specific question of whether a system should be interpretive or not.
In Australia, the results of the Blewett Review of food labelling were even more specific. Not only did the review come out in favour of an interpretive system but it specifically recommended a ‘multiple traffic lights’ approach.
The industry in Australia is following a voluntary guideline daily amounts (GDA) approach, whereby nutritional values are represented as a percentage of recommended daily intake, known as DIGs (daily intake guide). The fact that the government has put the Blewett recommendation regarding traffic lights ‘on hold’ has been characterised by campaigners as bowing to corporate pressure.
The UK

In the UK, food producers back use a guideline daily amounts (GDAs) though food retailers have generally opted on their products for this to be combined with a colour coding or ‘traffic lights’ element.
It is fair to say that the debate over FOP labelling in the UK has subsided over the past year or so. There are two principal reasons for this and both stem from the change of government in 2010. This resulted in the Food Standards Agency (FSA), the body that had been pushing the agenda on FOP labelling, losing its responsibility for nutrition-related aspects related to food. It is now solely concerned with food safety and its other responsibilities have passed to the Department of Health.
At the same time, through its Public Health Responsibility Deal, the incoming government has taken a more permissive view towards industry action. Leaving aside the issue of whether public health debates should be viewed in adversarial terms, industry is now in the ascendant, and enjoying considerable influence over the policy agenda.
Before the FSA lost its responsibility for nutrition-related food policy, its final position on FOP labelling, published in March 2010, which had been reached following extensive stakeholder consultation and consumer research, was that GDAs should be used in combination with either traffic lights or the words ‘high, medium or low’, and should ideally have all three elements. Campaigners viewed this as something of a compromise as the FSA’s research carried out the previous year had come out strongly in favour of traffic lights. Nevertheless, it was another official position supporting the idea of an interpretive element.