Memorandum by Kellogg Company (OB 95)
INTRODUCTION
1. Tim Mobsby is Area President for Kellogg
Europe. He is British and has worked for the Kellogg Company for
over 20 years in various capacities in the UK, USA and France
including as Managing Director of Kellogg UK.
2. Kellogg's is a leading producer of ready-to-eat
cereals and convenience foods. The company markets its products
in more than 180 countries and has been active in the UK since
the 1920s. Leading Kellogg's brands include Kellogg's Corn Flakes,
Frosties, Special K, Coco Pops, All-Bran and Nutri-Grain.
3. We are aware of and share the increasing
concerns around the rise of unhealthy lifestyles, in particular
the rising incidence of obesity amongst children. In this memorandum
we comment on Kellogg's nutrition heritage and commitment to providing
high quality, safe foods that respond to changing consumer needs
and tastes, offer choice and reflect emerging learnings on nutrition
science and well-being. We welcome the opportunity to contribute
to the inquiry and aim to offer insight gained from our particular
focus and expertise in nutrition and as a major advertiser and
marketer. We offer our thoughts on what we consider to be the
proactive role and best approach for companies such as ourselves
in helping address the challenge of the rising incidence of obesity
levels. In addition, we include in the Appendices the following
information:
(1) overview of the benefits of eating
breakfast cereals;
(2) summary of the various government
and health bodies who support the consumption of cereals and grain
based foods;
(3) Kellogg's Nutrition Policy;
(4) summary of information on Colorado
on the Move and Kellogg's sponsorship; and
(5) recent research, commissioned by
Kellogg's in UK, France and Spain amongst mothers and children.
KELLOGG COMPANY
HERITAGE
4. Since its foundation Kellogg's has been
committed to nutrition and health and encouraging consumers of
all ages to improve their own health and make informed food choices.
Examples of our commitment in this regard include:
(a)
Kellogg's was the first food company to introduce
a fortified breakfast cereal, PEP, in the 1930s.
(b)
We were one of the first food companies to introduce
voluntary nutrition labelling on packaging as early as the 1940s.
(c)
We commission and support scientific research designed
to improve understanding of the role of our foods and individual
nutrients to the well-being of consumers and are proud that such
research demonstrates the positive contribution of breakfast cereals
to the diets and health of both adults and children. Such research
shows that children who eat a cereal breakfast are more likely
to meet recommended daily intakes in vitamins and minerals, have
lower fat intakes and may perform better both physically and academically.
Specifically relevant to the issue of obesity, research in France,
Spain and the UK confirms that children and adults who consume
breakfast cereals (including pre-sweetened cereals) tend to have
lower body mass index (weight to height ratio) compared to non-consumers
of breakfast cereals.
(d)
We invest considerable effort and resources in the
UK on programmes communicating the importance of breakfast and
partnering in the development of nutrition education campaigns.
Examples include:
(i) Leaflets on healthy eating as part
of coping with diabetes with the endorsement of Diabetes UK.
(ii) Kellogg's was a partner for the
British Dietetic Association campaign Weight Wise Campaign; a
three-year obesity campaign. This year the messages were targeted
at children. As part of the campaign Kellogg's produced a leaflet
in conjunction with the BDA and (along with a leading retailer)
organised supermarket tours with State Registered Dieticians.
(iii) Kellogg's sponsorships in the field
of nutrition education include the launch of the UK Breakfast
Club Awards in association with Education Extra and the New Policy
institute with backing from the Department of Health and Education.
OBESITY
5. Scientists agree that the causes of obesity
are multi-factorial and complex. Genetic, ethnic, hormonal aspects,
physiological and sociological factors can all influence the incidence
and progression of obesity. While it would be convenient and desirable
for the problem to be single-dimensional with simple actions and
initiatives able to make a difference, regrettably science does
not support that case. Both diet and physical activity have important
roles in the treatment and prevention of obesity, requiring behaviour
change which is difficult for many people. We believe a prolonged
and concerted effort involving both private and public organisations
accepting and exercising their individual responsibilities but
also acting collaboratively in a cohesive and co-ordinated manner
will be necessary to arrest and eventually reverse the rising
trend.
6. As previously noted, various factors
are associated with the increase in obesity incidence, one of
which is lack of physical activity. Increasing levels of physical
activity may have the greatest impact in slowing the increase
in obesity whilst also improving general well being. We say this
for the following reasons:
(i)
Available in home consumption data suggests caloric
intakes, including amongst children, to be stable or reducing
slightly, suggesting reduced levels of physical activity to be
the biggest factor explaining body mass index increases. Since
1994, expenditure on foods eaten outside the home has increased
in real terms by 13%, versus a 2% decline for foods eaten in home.
In 2000 about 230 calories (11.6 %) came from foods eaten outside
of the home.
(iii)
Physical exercise has many benefits beyond simply
burning calories such as raising HDL cholesterol levels and building
stronger bones and muscles.
7. In observing this we do not underestimate
the challenges of bringing about such behavioural change. This
should not dissuade the effort, rather reinforce the view that
it will require a sustained, consistent and collaborative effort
on all sides.
8. We believe and support the view that
changes to diet will be necessary to accompany increased levels
of physical activity. We also support the view that habits as
adults are strongly influenced by those established in childhood
hence the importance that children are encouraged to eat a balanced
diet. We support the focus of current dietary guidelines which
recommend decreased consumption of fat to be replaced with increased
consumption of carbohydrates of cereal, vegetable, fruit and other
plant origins.
9. We believe the food industry can and
should play an important and pro-active role in helping both promote
higher levels of physical activity and promote good nutrition
such that consumers make informed food choices.
ADVERTISING AND
MARKETING
10. We are aware that advertising and marketing,
particularly that directed at children, attracts a lot of focus
and attention as being a perceived causal factor contributing
directly to the problem of obesity. We believe this to be an over-simplification
of a very complex issue.
11. Advertising has been and continues to
be an essential and integral component of Kellogg's approach to
business, it encourages competition and is a necessary tool in
a free market economy. For consumers of all ages advertising provides
information and encourages innovation. Through our advertising
we seek to inform consumers of the benefits of our foods, promote
their purchase and build preference for our brands.
12. Breakfast cereals are a mature category.
Volume is and has been essentially static for some time. Pre-sweetened
children's cereals are similarly static. The strong emphasis on
TV advertising within the breakfast cereals category is explained
by the following:
(i)
Breakfast cereals are a true mass market product,
with household penetration approaching 100%. It is also one of
the few food categories where the main purchaser of the product,
normally mothers, are willing to let their children ask for a
particular brand.
(ii)
Frequency of consumption, particularly amongst children
is relatively high (five to six times per week). Children of all
ages thrive on variety and novelty (the average home has four
to six cereals in the store cupboard) meaning a wide range of
cereals are advertised.
(iii)
Snacks foods and soft drinks are purchased (at least
sometimes) by the end user, including by children, and can be
stimulated by availability and visibility in convenience stores.
Similarly meals and snack meals have presence "on the street".
Conversely, breakfast cereals are consumed almost exclusively
in the home and purchased almost exclusively by the household
provider. Put simply, the breakfast cereal category relies heavily
upon TV advertising and has fewer options to secure exposure than
other food forms which are more portable, designed for occasions
other than breakfast, and which are often consumed outside the
home.
13. As responsible advertisers, we believe
that the current legislation on advertising to children provides
the necessary conditions for protecting them and ensuring that
advertising is not only fair, honest and truthful, but also takes
account of the limited life experience and particular sensibilities
and vulnerabilities of children.
14. Kellogg's works responsibly within the
existing self-regulatory and statutory codes and indeed goes further.
Our advertisements directed at children almost invariably depict
situations involving physical activity. The number of inquiries
about advertising received by the Kellogg's Careline—a free
phone service—are negligible.
15. Suggestions to ban advertising of all
or certain food products to children we believe to be misplaced
and not supported by the facts:
(i)
In Quebec (a province in Canada), where advertising
to children is banned, the incidence of obesity is no lower than
in other developed countries. The situation is similar in Sweden.
(ii)
Banning advertising in children's programming ignores
the reality that much of children's TV viewing is of adult programming.
(iii)
Banning of advertising on certain products pre-supposes
that there is a direct causal link between advertising and obesity.
There is no scientific substantiation for such an assertion.
WHAT CAN
BE DONE
TO COMBAT
OBESITY
16. As we make clear above, obesity has
many causes and any solution will require a collaborative effort
involving all stakeholders. For it's part, Kellogg's can and will
continue to:
(i)
Offer choices and nutrition information to our consumers.
Continue to identify ways in which we can more strongly promote
increased levels of physical activity and adoption of a balanced
diet.
(ii)
Provide comprehensive nutritional labelling on our
products and provide information to allow informed food choices.
(iii)
Consider emerging science and learnings as well as
consumer perceptions when developing and reformulating our products.
(iv)
Continue to increase our practice of collaborating
with nutrition experts, health and Government authorities, charities
and various industry and consumer groups in developing and pursuing
communications and educational programmes to promote the importance
of a balanced diet together with regular exercise.
(v)
Support and contribute to informed review of food
advertising codes to ensure they take account of current consumer
attitudes and trends. Also continue our support of media literacy
programmes such as Media Smart and other programmes to encourage
children to engage with the media in a positive way.
(vii)
In light of the current concerns about obesity, we
are going to review our products, labelling and advertising to
see whether there are changes in our current approaches which
should be made in order to be more even more responsive to current
concerns.
17. In order for Kellogg's to commit hearts,
money and resource on these areas and be confident we have the
continued freedom to communicate our brands and their benefits
in the way we do currently, there are important criteria to consider:
(i)
A more restricted regulatory and legislative environment
would limit the ability of companies such as ourselves to work
in partnership to resolve the current health challenges.
(ii)
There needs to be a greater acceptance and understanding
of the commercial needs facing businesses and how through mutual
co-operation and collaboration in educational campaigns and other
initiatives, we can impact consumer understanding and behaviour.
It will only be through the collaborative efforts
of all stakeholders involved in society in a prolonged and concerted
effort involving both private and public organisations working
together that any true progress can be made in helping combat
the challenges of obesity. Kellogg's is committed to continue
to do whatever it can to assist in such an approach.
November 2003
APPENDIX 1
BENEFITS OF
EATING BREAKFAST
CEREALS
Nutrition research confirms that children and
adults who eat breakfast, including cereals, have diets which
are lower in fat and higher in carbohydrate, in line with the
recommendations of leading health organisations across the world.
Consumers of fortified breakfast cereals have higher vitamin and
mineral intakes and improved nutritional and health status.
Examples of scientific literature to support
this include:
On average adults eat one 30g serving of breakfast
cereals each day. National Diet and Nutrition Survey: adults
aged 19-64 years (2002).
On average children eat one 30g serving of breakfast
cereals each day. National Diet and Nutrition Survey: young
people aged 4-18 years (2000).
People who eat breakfast tend to be slimmer
than those who skip breakfast. Gibson & O'Sullivan (1995).
Breakfast cereal consumption patterns and nutrient intakes in
British schoolchildren. Journal of Royal Society of Health 115
(6): 366-370.
People who eat breakfast regularly are less
likely to be overweight than those who skip breakfast.
Haines et al (1996). Trends in breakfast
consumption of US adults between 1965-1991. JADA 96: 464-470.
The more often you eat breakfast the more likely
you are to be slim. Summerbell CD et al (1996) Relationship
between feeding pattern and body mass index in 220 free-living
people in four age groups. Eur J Clin Nutr 50:513-519.
People who eat breakfast cereals tend to be
slimmer than those who either skip breakfast or eat meat and eggs
for breakfast. Cho S et al (2003) The Effect of Breakfast Type
on Macronutrient Intakes and Body Mass Index (BMI) of Americans.
J Am Coll Nutr. 22:296-30.
Both body weight and body shape are healthier
among those who eat breakfast cereals compared to those who don't.
Bertrais S et al (2000) Contribution of ready-to-eat cereals
to nutritional intakes in French adults. relations with corpulence.
Annals of Nutrition and Metabolism 44: 249-255.
Overweight children are more likely to skip
breakfast than their normal weight peers. Ortega et al (1998)
Differences in the breakfast habits of overweight/obese and normal
weight schoolchildren. Int J Vit Nutr Res 68: 125-132l.
Skipping breakfast means that important nutrients
are missed which are not made up during the rest of the day. Cho
S et al (2003)The Effect of Breakfast Type on Macronutrient Intakes
and Body Mass Index (BMI) of Americans. J Am Coll Nutr. 22:296-302.
High blood cholesterol levels are associated
with increased risk of heart disease. Research has shown that
adults who eat ready-to-eat breakfast cereals have a lower cholesterol
levels than non-consumers. A similar trend has also been shown
in schoolchildren. Preziosi et al 1996. Serra Majem and Aranceta
Bartrina, (2000). Desayuno y equilibrio alimentario. Estudio enKid.
Masson.
Fortified Breakfast cereals are a major source
of B vitamins in UK children's diets, providing 21% thiamin and
riboflavin, 16% niacin, 18% B6 and 22% folate. National Diet
and Nutrition Survey: young people aged 4-18 years (2000).
One fifth of girls aged 11-18 years have very
low riboflavin intakes and are likely to be deficient in this
vitamin National Diet and Nutrition Survey: young people age
4-18 years (2000).
Breakfast cereals provide one tenth of the fibre
in the diet of young people in the UK. National Diet and Nutrition
Survey: young people aged 4-18 years (2000).
Fortified foods such as breads and breakfast
cereals provide almost one third of children's calcium intakes.
National Diet and Nutrition Survey: young people aged 4-18
years (2000).
One in eight boys and one in four girls aged
11-14 years have very low calcium intakes and are likely to be
deficient in this mineral. National Diet and Nutrition Survey:
young people aged 4-18 years (2000).
Breakfast cereals encourage the consumption
of milk. Eating a cereal breakfast with milk is an effective way
to increase calcium intake, which is an important mineral for
children and teenagers for the development of strong bones and
teeth. Nicklas et al (1998). Am J Clin Nutr; 67 (suppl): 757S-63S.
Iron deficiency anaemia is the most common nutritional
problem in the Western world, most commonly affecting infants,
children and young people and women of child bearing age. Almost
half of young people aged between 11-18 years eat very low levels
of iron and so are likely to be deficient in this mineral. National
Diet and Nutrition Survey: young people aged 4-18 years (2000).
Fortified breakfast cereals provide one quarter
of total iron intakes among young people. Fortified breakfast
cereals are the single biggest source of iron in the young persons
diet, providing more iron than meat and meat products, breads,
or vegetables. National Diet and Nutrition Survey: young people
age 4-18 years (2000).
Breakfast cereals provide just 7% added sugar
intake in a child's diet, compared to 14% from biscuits, buns
and cakes, 33% from drinks, 21% from confectionery and 6% from
milk and milk products. National Diet and Nutrition Survey:
young people aged 4-18 years (2000).
No health effects, other than an association
with dental caries, have been conclusively shown to be related
to sugar consumption. There is no direct connection between the
intake of added sugars and obesity. Am J Clin Nutr 2003; 78
(suppl): 814S.
Data show that high fat and low carbohydrate
or low sugar intakes are associated with higher incidence of overweight
ie sugar may be protective against obesity. Am J Clin Nutr
2003; 78 (suppl): 814S.
APPENDIX 2
THIRD PARTY
ENDORSEMENT OF
READY-TO-EAT
BREAKFAST CEREALS
A. UK's Food Standard Agency Public Website
(In total there are 20 references to breakfast cereal)
"breads and cereals should make up about
one-third of the diet".
Carbohydrate
"Aim to eat plenty of starchy foods—or
complex carbohydrates—each day, such as cereals, pulses
and potatoes".
Your growing child—"fortified
breakfast cereals as source of vitamin D, iron:
— weaning food, foods for toddlers,
women—pregnancy—fibre, iron, folic acid, vit D. men—carbohydrate;
and
— getting the balance right, healthy
eating, getting physical, increasing fibre, iron, losing weight".
Importance of Breakfast
"Is it really important to have breakfast?
It's often said that breakfast is `the most important meal of
the day' but many of us find it hard to find the time to have
breakfast before heading off to work or school".
"And some people choose to skip breakfast
because they believe it will help them to control their weight".
"But more and more studies show that the
importance of breakfast is not just a myth—eating breakfast
can have a range of beneficial effects including helping to maintain
a healthy body weight".
"To go to school or work without breakfast
affects concentration and energy levels throughout the day. This
is because by the time we wake up the last meal we ate was many
hours ago so our blood glucose is low"
B. Organisations who support dietary changes
towards grain based foods
American Dietetic Association
Diabetes Association (USA/Canada/UK)
American Health Foundation
American Institute of Cancer Research
Canadian Cancer Society
Deutsche Gesellschaft fur Ernahrung (Germany)
Europe Against Cancer
Food and Agriculture Organization (FAO)
Food and Nutrition Bureau (Netherlands)
French Health Education Committee
German Society for Nutrition
Health and Welfare Canada
Imperial Cancer Research Fund (England)
Japanese National Cancer Center
National Academy of Sciences
National Cancer Association (Denmark)
National Institute of Nutrition (Italy)
National Nutrition Council of Norway
National Food Agency (Scandinavia)
National Food Council (France)
National Heart Association (Denmark)
National Institute of Nutrition (Italy)
National Research Inst. of Diet and Nutrition
(France)
Swedish National Food Administration
US Department of Agriculture, FDA
World Health Organization (WHO)
APPENDIX 3
KELLOGG COMPANY
AND COLORADO
ON THE
MOVETM
The Kellogg Company is a founding member of
the University of Colorado Friends of the Center for Human Nutrition
that launched "Colorado on the MoveTM" as the first
statewide obesity prevention program in the US in October 2002.
With the help of funds from its members, the program has been
evaluated in schools, worksites and communities. From the beginning,
the program has been committed to continuously improving the health
and quality of life of people. The message has been simple, "walking
just 2,000 steps more every day can help prevent a number of important
health concerns and stop weight gain". More importantly,
the Colorado on the MoveTM initiative is an easy, achievable,
and fun way to address an important health concern.
In 2002, Kellogg Company funded "Families
on the Move" with Dr Hill. The objective of the study was
to determine if adding an extra 2,000 steps to your day and regularly
eating ready-to-eat breakfast cereal would help prevent weight
gain in families with at least one overweight child between the
ages of 10-12 years old. The 14-week study found (yet unpublished)
that this program to increase walking and eat more ready-to-eat
breakfast cereal helped people to lose body fat and reduce their
body mass index (BMI). Perhaps, more importantly, it helped to
prevent weight gain in children.
Kellogg Company's legacy is based on the philosophy
that people can improve their health by changing their eating
habits. The challenge is to meet nutritional needs from fewer
calories at a time when physical activity has declined. Fortified
breakfasts cereals are nutrient dense foods that can help consumers
meet their dietary requirements while limiting their energy intakes.
APPENDIX 4
BELIEFS AND
INFLUENCES ON
CHILDREN'S
EATING HABITS
Research presented at the European Nutrition
Conference in Rome (October 2003) shows that the biggest influence
on the eating habits and food choices of children was their mother.
This new study highlights the central role that
mothers play in helping to shape the eating habits of children.
It also indicates that health promotion professionals may need
to have a better understanding the practical barriers to healthy
eating that mothers face in busy day to day family life.
The study[20]was
conducted by the HPI Research Group on behalf of Kellogg's in
UK, Italy and Spain to explore the attitudes of children (aged
7-11), mothers and health professionals towards food and healthy
eating.
One of the most significant findings is in all
countries children's attitude towards healthy eating always mirrors
those of their mother.
The results clearly showed that from a child's
point of view, the main carer (usually the mother) is seen as
the most trusted and most frequent source of information about
food and nutrition.
Children are far more likely to believe what
they learn about nutrition in school if this is supported by beliefs
and actions of their mother in the home.
"How do you know that this is good for
you? My mummy says so." UK boy aged eight.
Children who eat with their mother or parents
are more likely to eat a wider range of foods and enjoy a balanced
meal including vegetables and fruit than those who eat alone or
just with brothers and sisters
Italian mothers place much more emphasis on
setting a good example during family meals compared to those in
Spain or the UK. Italian children also have a much more positive
attitude to foods like boiled vegetables, that are disliked by
children in the other two countries
Mothers themselves under-estimated the extent
of their influence on children's eating habits. Practical and
lifestyle pressures are reasons given as barriers to being a good
role model for healthy eating. Lack of time, especially for working
parents and a desire to avoid conflict with their children was
given as reasons to compromises over meal composition.
The study also indicates that in all three countries
health professionals often do not understand the daily challenge
mothers face in feeding their families. Few practical ideas were
offered to help mothers to encourage healthy eating at mealtimes,
or on how to persuade children to try new or disliked foods.
Health professionals did not believe that mothers
have either the knowledge or skills to teach her children good
habits, but were unable to come up with solutions to providing
mum with the information that she needs. Therefore greater insights
by health professionals in the realities of family life would
aid communication of health eating messages to parents.
S Stork and[21]RJ
Fletcher: Knowledge, Attitudes, Food Preferences In Relation To
Health Perceptions Of European Children, Their Mothers And Selected
Health Professionals; Difference and Similarities Within And Across
Countries.
RESEARCH DETAILS
The research was commissioned by Kellogg's and
conducted by HPI Research Group in the UK, Spain and Italy in
Spring 2002. The research involved 11 peer groups of children
(aged 7-11 years), four peer groups of mothers and in-depth interviews
with healthcare professionals (5 per country).
APPENDIX 5
KELLOGG COMPANY'S
NUTRITION POLICY
Kellogg Company's practices can be summarised
as follows:
1. The acceptability of our products in
flavour, texture and appearance is essential if they are to make
any nutritional contribution.
2. Essential nutrients are restored to products
at the levels that existed before processing whenever feasible,
assuming the level in the pre-processed grain is high enough to
make it a significant dietary source.
3. Products are fortified with added nutrients
and at higher levels than existed before processing in keeping
with the following considerations:
(a) The nutrient intake of the population.
(b) How specific products are used by the
consumer.
(c) Technical feasibility.
4. Educating consumers on the importance
of good nutrition is a continuing program. Through advertising,
product packages, educational materials, and publicity, we shall
continue advertising the public on the value of a good breakfast
and a balanced diet.
5. All Nutritional information is carefully
reviewed for accuracy by a professional nutritionist to assure
the consumer factual information about our products.
20 HPI Research Group, UK. Back
21
Kellogg Europe. Back
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