Undoubtedly, there is nowadays a growing sentiment towards food and its effects on health.
People are worried about health risks related to certain foods.
In practice, the selective approach that is prevailing, focuses exclusively on nutrition, putting aside other considerations – culture, sociology, genetics, environment, employment, economics and internal market – that are also crucial part of the equation.
The main problem behind this discussion is that ‘per se’ there is no coherent debate at all, and each of the stakeholders (both public and private) is more interested in emphasizing its own point and discarding the others, than in finding the way to make progress through cooperation. Because, do not forget, all the actors share the same objective: to make a virtuous circle between food and health in order to improve healthier lifestyles of the consumers, and no single entity can tackle the challenges of nutrition and health-related issues alone.
It is now time to build trust and effective cooperation at the EU level.
This is in fact what Farm Europe has been promoting in the context of the Global Food Forum, which was held in Milan last October, with one of the workshops dedicated to this issue.
In the past weeks, various debates held in Brussels gave us the opportunity to hear from the Commission some messages that could open the door to a new way of thinking, which is much in line with what has been discussed during the Global Food Forum.
The first one relates to the debate on how to improve a more balanced diet without focusing too much on specific nutrients. This is indeed a key issue to address, as we tend to focus the attention on ‘good/healthy’ and ‘bad/unhealthy’ products individually, by considering specific nutrients in food (i.e. salt, saturated fat or added sugar), while the key point is to think about eating patterns and dietary factors, which can imply a variety of foods with healthy nutrients. The concept is straightforward: no single product (or nutrient), taken in isolation is a choice, thus variety is key in a healthy diet and all foods bring different nutrients to the mix.
The real challenge is how to drive people to a healthier lifestyle and, precisely, how to communicate it in the most effective and responsible manner.
This is actually what seems to be the main struggle within the food industry, which is totally aware of the decisive role it can play in guaranteeing the nutritional quality of products, not only with respect to salt, saturated fat levels and energy content, but they are also committed to increase positive nutrition. The concept of positive nutrition relates to offering products with an improved nutritional composition.
Secondly, the Commission foresees the need to think about the actual legislative framework (General Food Law Regulation), and how it can be improved and eventually extended to other areas, in close cooperation with Member States and the participation of the relevant stakeholders, taking into account the current trends and needs.
It seems clear that Europe needs a broad general framework and to simply come out of the mist on nutrition and health domains. This general framework should prevent inter alia the risks of fragmentation of the internal market that we face with the endless list of national, regional or local initiatives already in place.
Third, something has to be done with the “apparent erosion of public trust in our science – based system“. Fully agree. The lack of a minimum consensus on food and nutrition critical issues leads directly to misunderstandings, consumer confusion and wrong decision making. And this includes the need to rethink how can we reinforce EFSA as the reference for excellence in science and food.
Fourth, the need to improve communication. In this world of information overload, “information, misinformation, prejudices, opinions , truths, half- truths and un-truths compete for attention”. Rigor and better communication of science are needed so that people can be better informed about issues and risk management decisions.
This is absolutely true, and a big malaise of our model. We need to separate science from opinion, and as media are the way to translate science into public opinion, it is from the outmost importance to give them tools to better do their job.
The reliance on nutritional communication of health benefits should be definitely improved.
Fifth, innovation. “A constant challenge is to find the best way to continue to empower consumers to improve their health, while, at the same time, leaving flexibility for the food industry to innovate”. In this context, how the industry can formulate better products through non-legislative approaches is another point that can be improved. Moreover, we think that stronger efforts on research and innovation getting the links of the food chain working together – and not only the industry – should help to improve healthier habits and ways of consumption.
However, in order to do that, the food chain needs the help of public authorities if we want to pass innovations to consumer and improve their perception on food. This because there is a huge difference between what consumers believe is good and what is perceived as good.
All the points raised here are very much in line with a new way of thinking about food and health, which should aim at bringing together the interested parties and trying to get a common, balanced approach in working together against NCDs, whose high prevalence in Europe is of serious concern.
The General Food Law Regulation has almost 15 years, and is close to be of legal age. A comprehensive policy evaluation is under way to assess whether the regulatory framework for the food and feed sector is fit for purpose and whether it properly addresses current trends and needs. REFIT is the word, and we think that what we have heard in the last weeks are promising steps in the positive direction. Let’s keep the right pace.
The strong interest and participation to a very lively discussion between speakers and audience showed the necessity of having such a debate. The issue is quite complex, intriguing and critical. We had the chance to tackle the debate from different perspectives: speakers and attendees included politicians, scientists, media, regulators, industry representatives, consumers.
The following main issues emerged from the discussion:
The EU uses science to support decision-making across a wide range of policy areas. Scientific evidence can be used to help identify potential risks, protect citizens and use resources more wisely, as decisions and actions are taken. However, we are far from an ideal world: the relationship between science and decision-making is not easy, and not always straight-forward. Decisions are not always based on science and science does not always provide clear answers. One area where this is the case is nutrition policy.
Several questions need to be asked:
How can we improve the exchanges between science and policy-making, when aiming to improve diets and people’s health?
Is scientific evidence properly considered in nutrition policy and measures taken to improve people’s diets?
Do we need more scientific evidence for a more effective nutrition policy?
“If you take obesity, there is no one-fits-all recipe” (Prof. Agostoni). Everybody agrees that policy decisions should be based on sound scientific basis. Nevertheless, “the lack of harmonized methodology in many cases represents a limit in building scientific evidence (…) More tests/pilots need to be tried before they are developed at global public level.” (Prof. Fattore).
What about the role of the Media?
In recent times, we have seen many cases of scientific communication escalating in the media and causing uncontrolled and unjustified reactions in the public opinion (i.e. E. Coli crisis, horse-meat scandal, glyphosate, red meat case etc.). This puts an enormous pressure on decision makers, so much so that the “precautionary principle” is often replaced by the “chance principle” (MEP Ayuso)
Media are not scientists. They rely on information provided by authoritative sources (i.e. EFSA, WHO), but it is not always easy. Sometimes there is no scientific consensus (i.e. the recent “red meat” case). “Science may not be unanimous, meaning that there may be more than one answer” (Emsden, Journalist). At the same time, “media are also private companies that need to sell, therefore they will look at controversial news” (Simon, journalist).
Industry is almost absent from the debate, but it could play an important role in communicating, both with consumers and decision makers. Recent examples support this evidence: the debate on renewal of glyphosate in the European Union, IARC decision on meat, the WHO debate on the relationship with industry representatives…
Conclusions and food for thoughts:
Clearly, there is a problem. Decisions are not always based on science, or science does not always provide clear answers; in addition, communicating science is not straightforward and can have repercussions on consumers’ perception of reality.
This is why more cooperation and engagement among all interested parties is needed. We need to seat together and build a new collaborative approach based on solid, common and agreed principles and ethics.
More in particular, a common comprehensive agreed framework is needed to facilitate the interaction and relations between Science, Media and Decision Makers in order to develop sound and science-based nutrition policies.
“Common platforms to share ideas and best practices are needed” (MEP Delahaye).
The debate was open, frank and constructive. We will continue working on this important issue, looking for fresh ideas. Comments and cooperation from all interested stakeholders are, of course, always welcome.
COMMENTS ON THE DUTCH PRESIDENCY EU CONFERENCE ON FOOD PRODUCTS IMPROVEMENT.
Earlier this year, the Dutch Presidency brought together representatives of Member States, International Organizations and European stakeholders, in order to discuss (about) one of the most controversial issues (apart from taxes) in the fight against obesity: reformulation of food products.
The Dutch Presidency has been working hard in order to reach a final agreement on the “Roadmap for Action on Food Improvement” that was presented during the Conference, and even if the result has not been as successful as planned, it builds at least on what has already been achieved.
The whole exercise deserves some comments.
First of all, concerning the name. Technically speaking, the traditional word used for the reduction of levels of salt, fats and added sugars has been “reformulation”, but maybe the Dutch diplomats chose the new term of “product improvement” in order to ease the debates. However, this does not really matter.
The point is that during many years, public authorities at international, European and national level have insisted on the need for reformulate products as a way to make “the healthy choice the easy choice”, as the Dutch Minister of Health specified, as well as using it as a new approach to stimulate the production of healthier food.
This is not that simple. Reformulation is not the panacea, and it makes us confront with certain limits. Think about a product like Olive Oil. Its health benefits are unrivalled. However, it also contains plenty of calories. Another interesting example in this regard is Ham. Much salt is needed to make it, preserve it and get the flavor out of the product. Or let’s consider also a sweet product without sugar. We could convene on the fact, that in the end, the reduction of salt, fats and sugars has its own limits in terms of production, palatability, conservation and security.
To sum up, not all the food products can be reformulated or at least, it is not an easy process to manage. It should also be highlighted that, the producer has to put on the market what the consumer demands.
Regarding the last point, it may be noted that many sectors have made a serious effort to place “light”, “reduced-fat” or “zero-fat” products on the market.
However, in a food market with fierce competition, if you do not want to fall behind your competitors, any action has to be deeply analyzed.
There are also solid reasons behind any change to make. If we accept the idea that it is not the product itself, but the diet that needs to be balanced, how can we explain the concept of reformulation?
Maybe these are some of the questions behind, and explain why only some sectors – soft drinks, snacks, margarine, chocolate and a few others – have actively committed to codes of conduct, aiming at reformulating their products.
Moreover, it has to be noted, that most of the effort already spent comes from the industry side. Retail sector and farmers still lag behind, and this is definitely something that deserves a reflection. On the one hand, the importance of Private Label cannot be neglected all over the European countries, where figures are often close to 50 % of total sales. On the other hand, farmers are supplying the raw materials that are directly involved in the issue. This means that if no real food chain strategy is envisaged and all the links are not involved in any solution, a real danger exists.
It is worth recalling the comments made by Commissioner Andriukaitis during the Amsterdam Conference. In that occasion, the Commissioner said that reformulation would not be sufficient and also mentioned that together, taxation, marketing, advertising, education, reducing accessibility to unhealthy food and awareness-rising could help to achieve a healthy choice.
Not all the Member States signed the Roadmap. Civil society, industry and retailers were in favour, while producers did not sign it. Consumers considered it not ambitious enough, whereas some health organizations were in favour. As usual, no consensus has been reached.
To conclude, reformulation can help the agri-food sector, whenever possible, to show its commitment against obesity and avoid other kind of restrictive and imposed measures. However, even more important than that, a movement in the food chain to act united could be key.
Abstract: On October 26, 2015 the WHO’s International Agency for Research on Cancer has announced that it has added processed and red meat on its list of carcinogenic substances. Only three decades ago, read meat was categorised as one of the most valuable foods in most states’ nutritional guidelines. Now it is apparently a risk to human health.
This discussion paper aims to shed light on the question regarding whether such classifications of regulatory bodies are mere outlier cases, or are part of a wider trend towards increasingly viewing the agri-food chain under the sole perspective of public health and neglecting cultural, economic and leisure aspects of food consumption. A closer look soon reveals the increasing dominance of public health rationales when regulating food.
References from the United Kingdom or Ireland show that alcohol and certain food categories are increasingly treated as hazardous products, like tobacco, proposing “risk management tools” such as labelling standardisation, incl. Health Warning standards, advertising restrictions, taxation and price measures.
Consequently, the question is to what extent the EU agri-food chain can be part of the solution, and what can it contribute to balance the debate in order to include economic, cultural and behavioural effects of regulation in the equation? Finally, this paper aims to provide food for thought inter alia, as to how impacts ofregulation on consumer behaviour can be measured in a more comprehensive way, and what the European contribution should be to this issue.
Food is above all a source of life. But, apart from that, food and beverages do much more than simply providing humans the fuel for survival. It offers culture, tradition, one of the most important sources of economic activity, employment and innovation in Europe; it is choice, friendliness, variety…
In the last decades, science has shed light on what we eat, and has shown that food is a critical factor for human health. Particular importance has been given to its relationship with Non-Communicable Diseases (NCDs) like obesity, cholesterol, diabetes, cancer, coronary diseases and others related, making diet a priority for public health.
Public authorities all over the world have tried to curb problems related to nutrition – not only through public health, but also via society, economics, finance and politics- through different initiatives.
The most significant, recent, worldwide initiative has been the “Global Strategy on Nutrition, Physical Activity and Health” from the World Health Organization (WHO) approved in 2004. Seven years later, United Nations signed the “Declaration on prevention and control for Non Communicable Diseases” providing both a set on recommendations and action plans to guide and influence national policies against harmful effects of food and drink on human health.
Having in mind this global framework, the European Union has developed its own initiatives in four main areas:
Legislation: Even if health is not a fully European policy, the E.U. has the objective of ensuring a high level of human health protection in the definition and implementation of all Union policies and activities. At the same time, Internal Market and Consumer Protection are the basis for regulations in different areas such as labelling and food information to consumer, nutrition and health claims, advertising;
Cooperation with stakeholders, through the E.U.platform for Health and Physical Activity and the European Alcohol and Health Forum in order to share best practices, information, data and research, etc;
Coordination with national authorities. Initiatives like the Committee on National Alcohol Policy and Action (CNAPA), to encourage cooperation and contribute to policy developments;
Support to education programs via the €150 million School Scheme Fund included in the Common Agricultural Policy, focusing on the distribution of fruits, vegetables and milk to children in the EU.
Finally, at national level, Member States are not lagging behind regarding such initiatives, and even go further, offering a wide variety of measures ranging from legislation, to self- regulation codes, taxes, prohibitions… Sometimes going far beyond the common European framework and thus affecting the internal market.
“A short review of the stakeholders may give us a brief idea of the intensity of the debate – and its polarisation”
The issue of food and health has gained importance on the European political agenda, and, at the same time, is a rather sensitive topic. All stakeholders take active part in the debate, attempting to influence and pass through their visions and positions to the different institutions.
A short review of the stakeholders may give us a brief idea of the intensity of the debate -and its polarisation.
The media: in general terms, messages and opinion published around food and drink are mostly negative. Diseases, economic burden, inequality, pandemics… all are issues very often linked to food and beverages in the media, transmitting a somehow distorted vision –or at least unbalanced reality-, which damages the public image and credibility of the whole food chain. There is only one exception: when it comes to gastronomy, it seems that people perceive food and beverages as something positive, enjoyable, and attractive. There is a measure of separation between public and personal perceptions.
Science: nutrition has exploded in recent years, making food, its composition, and its effects on health an area of special interest for science. On the contrary, other areas of research, like genetics or the influence of physical activity, or even others like environment, do not attract the same level of interest. It seems clear that good evidence – based policy making depends – at least in part – on good research and evidence. But sometimes it happens that science is mixed with politics, making it harder to reach a consensus on core issues, and contributing to confusion amongst consumers.
Economic sectors: the whole food chain is affected by this issue, from production to industry, to distribution and Horeca. They all take part in the production of food and beverages which are to be consumed by the population, at home or out. Many different initiatives are in place – self-regulation codes, voluntary agreements, information and education campaigns, voluntary labeling schemes, physical activity programs, research funding…-, and continue to undergo development. The industry side is the most active link of the agri-food chain in this sense, even if sometimes their efforts are not fully recognised or are surrounded by scepticism.
NGOs and activists: consumer organisations and other NGOs have been traditionally relatively active when it comes to the food sector, but the issue of food and health has attracted its interest and participation in the public debate to an even greater extent. But the “newcomers” are the activists, working individually or in coalitions, with rather new and aggressive communication techniques in search of a place and erupting with extreme proposals, the effectiveness of which have not been proven.
The new transparency policy embraced by the European institutions has opened the way to this new group of stakeholders, even if they raise some doubts about its representativeness amongst the other groups of civil society.
“It is questionable whether health arguments can be assumed
to supersede other (fundamental) rights”
International Organisations continue working on new proposals. One of the most active is WHO,
which recently produced a document on “Sugar intake for adults and children”, and is preparing another one on childhood obesity.
The OECD has been also very active, especially on the side of alcohol, with its recent paper “Tackling Harmful Alcohol Use”, with the collaboration and support of the FAO and WHO, thus showing a new feature of cooperation between international organisations that will be a growing trend in the next future.
Back to the European Union, several issues are on the table and provoking lively debates. On the regulatory side, application of Regulation 1169/2011 on Information to Consumer via national schemes, like the UK traffic lights system, raises the question of compatibility with EU Law. Nutritional profiles, as conceived by Regulation1924/2006 haven’t seen the light -after six years-, and the European Parliament is divided, with a high number of Members asking the Commission to withdraw this model due to its lack of scientific basis, possible discriminatory effects, and potential dangers to the international market. Similarly, the Danish “fat tax” was unilaterally removed by the local authorities, and subject to an investigation opened by the EC for its possible anti-EU law effects.
With the EU placing great emphasis on the importance of the Intellectual Property Rights (IPRs) – the protection of intellectual property rights is an essential element for the success of the Single Market , not only for promoting innovation and creativity but also for developing employment and improving competitiveness – and some of the proposed public health measures potentially undermining this protection, it is questionable whether health arguments can be assumed to supersede other (fundamental) right.
Finally, it is worth mentioning that twenty public health organisations recently resigned from the European Alcohol and Health Forum, in protest against the European Commission’s refusal to submit a new alcohol strategy.
“In the EU, the most active level is the national one”
But, as it has been said before, the most active level is the national one. Several examples are worth mentioning in order to gain a better idea of what is at stake.
France: the draft “Loi Santé” is due to be voted on in the plenary session of the National Assembly in the coming weeks. Its chapter on prevention puts together tobacco, alcohol, and food, with special provisions for each of the sectors heading generally for further restrictions.
Ireland: A Parliament Committee on Health and Children backed last June the government´s approach to introduce a minimum unit price (MUP) for alcohol, as well as other measures like a “social responsibility levy” to capture some of the profit that may arise from introducing a MUP to fund awareness and addiction programs, health warnings on alcohol packaging with similar rules to those controlling tobacco labels, bans on the advertising of either retail discounting or multi-buy alcohol promotions, etc.
Scotland has already voted in similar laws, but they are being fought through the EU Court of Justice after challenges from the Scotch Whisky Association and several major wine-producing countries and Associations. In the General Advocate’s opinion a member State can impose a minimum price, which restricts trade and distorts competition, only if this system is superior to an alternative measure (increase taxation)
Latvia has become the latest EU country to ban trans fats, joining ranks with Austria, Hungary, and Denmark. The prohibition will enter into force in 2018, for both domestically produced and imported food. In the same line, but on a voluntary basis, BEUC, EPHA, CPME, EHN and four major food companies have sent a letter to the Commission requesting a legislative limit to TFAs in food.
“The European food chain is facing one of its most important challenges, if not the greatest it has seen”
There is no doubt that the European food chain is facing one of its most important challenges, if not the greatest it has seen.
In search of a solution, many theories have been applied, from the “Nanny State” –prohibition, taxes and minimum unit pricing, restrictions to advertising and communication- to self-regulation measures –EU pledge, voluntary measures on reformulation, warnings,…- and new proposals like behavioral science –“nudge theory”. But one thing seems clear, and that is that “business as usual” is not the right way to overcome the challenge.
Amongst others, some questions need to be answered if the food chain wants to be not only part of the problem, but also contribute to the solution. In order to participate and enrich the debate, Farm Europe will propose in the coming weeks key questions to be answered to have a coherent and efficient policy in Europe with regard health and labelling.