Memorandum submitted by the Co-operative
Group
The Co-operative Movement comprises 45 retail
Co-operative Societies across the UK operating some 4,000 retail
outlets. The Co-operative Group is the largest Co-operative Society,
operating as a consumer owned co-operative, and comprises of a
family of businesses whose activities range from food to finance
and from farms to funerals. Food retailing is core to our activities,
providing almost half of the Group's turnover.
The Co-operative Group provides the Movement's
own label, Co-op Brand, comprising some 4,000 lines. Through the
Co-operative Retail Trading Group, an organisation of Co-operative
societies, it provides the buying and marketing function for all
these UK consumer-owned Co-operatives.
BACKGROUND
The Co-op's Right to Know policy is a commitment
to provide the facts people need to make informed purchasing decisions.
Facts about products are supplied to consumers on labels, at point
of sale, in leaflets, on our website (www.co-op.co.uk) and in
response to individual letters, e-mails or phone calls to our
freephone customer careline.
Clear labelling plays a vital role in helping
people know exactly what they are buying. The Co-op prides itself
on its clear, comprehensive and well presented labelling where
it sets the standard for the retail industry. In 1997 the Co-op
produced a code of practice for labelling and called on industry
to adhere to it. Many of the ground-breaking initiatives in the
code are now either legal requirements (QUID labelling) or subject
to FSA labelling guidelines (origin labelling, marketing terms
such as fresh, traditional, etc).
The FSA Labelling Action Plan has built on the
Co-op Code of Practice, taking it forward. We welcome their initiatives
in this field. We believe they get to the heart of what consumers
need to select appropriate products. They are constrained by EU
Labelling regulations which preclude the introduction of mandatory
approaches, leaving them to rely on industry's goodwill to adopt
guidelines.
THE NUTRITION
CONTENT OF
FOODS
The Co-op has voluntarily provided nutrition
information on pre-packed foods since 1986 which, since 1993,
has had to comply with legally prescribed formats of the EU Nutrition
Labelling directive (90/496/EEC). Having a standard format is
good from the point of view of consumers, ensuring they can compare
products from different brands. However, this puts the labelling
into a straightjacket which does not allow innovation and adaptation
to meet consumer needs. Based on textbook nutrition, it has familiarised
consumers with the names of nutrients but does not relate well
to the health messages and advice given to consumers, nor does
it put the information into context to help consumers make use
of it. Allowing a short and a long form and making the 100 gram
portion the basic information has, over time, resulted in denying
consumers key information to make healthy eating choices. Information
on the key nutrients of health messages; sugar, salt (sodium)
and saturated fats are excluded from the short format. Our research
has shown that branded products high in sugar and salt are the
very ones to adopt the short format and use only a 100 gram serving.[1]
The latter does not help consumers to readily relate what they
consume in a serving; two biscuits or ½ pack, with the detailed
information given.
To address these and other issues, the Co-op
has introduced the following adaptations into its nutrition labelling
policy:
— Full nutrition labelling (seven nutrients
and energy) on all Co-op Brands.
— Declarations on both 100 grams and
a serving on all products.
— Declarations per serving preceding
those per 100 grams in line with IGD research findings.[2]
— HIGH, MEDIUM and LOW descriptors,
based on a system developed by the Coronary Prevention Group[3]
accompanying each nutrient. This approach, unique to the Co-op,
puts the information in context for consumers. It has also been
shown in several consumer studies,[4]
most recently by the FSA,[5]
to be both preferred and to perform best.
— Salt declared as well as sodium.
Research, including our own,[6]
consistently shows that consumers are confused about the relationship
between salt and sodium. Provision of information on labels about
sodium is unhelpful since all health messages relate to salt.
— Flashes on front-of-pack show Calories,
fat and salt per serving. Other retailers have introduced this
on their healthy eating ranges. The Co-op applies it across the
Co-op Brand range.
— Guideline Daily Amounts (GDAs) for
Calories, fat and salt for the average man or woman to put nutrition
information in context in line with IGD research.[7]
— Rounding of decimal points to facilitate
calculation.
— "Eat More" roundel on front-of-pack
to encourage consumption of certain categories of food; starchy
carbohydrates (bread, pasta and potatoes) and oily fish.
— "5-a-day" logo on front-of-pack
to encourage consumption of fruit and vegetables. Although using
DoH criteria, the logo was developed by the Co-op to be more impactful
and universally applicable than that developed by DoH.
— Healthy Living range—a range
of products which meet healthy living criteria, identified by
special logo and livery as a signpost to consumers seeking the
healthy option.
In addition, we would like to implement other
measures which our consumer research shows us improves consumer
understanding of nutrition information.[8]
Although we have trialled these on-pack, they contravene current
legal requirements, so had to be abandoned.
— Re-ordering of the nutrients to give
priority to key, healthy eating information; Calories, fat, saturates
and salt.
— Putting salt not sodium content.
— Adding portions of fruit and vegetables.
— Abandoning Joules as a measure of
energy to allow space for more useful information. Research shows
consumers do not understand Joules.[9]
— Omitting protein from all labels
and declaring fibre only where relevant, so providing more space
to improve presentation and avoid confusion by overly complex
information.
Our research and proposals are described in
the attached booklet "The Lie of the Label II"[10]
[not printed].
On certain products we go further. In particular,
on alcoholic drinks, where labelling is very prescriptive, we
go beyond the law, providing:
— Ingredient lists including information
on processing aids on the advice of our Consumer Jury. This is
not mandatory on these products. The Co-op is the only brand to
include this information.
— Sensible drinking guides, repeating
the current DoH advice on sensible drinking.
— Alcohol units; units per glass and
number of glasses per bottle on spirits, units per bottle and
number of glasses per bottle on wines and units per can/bottle
on beer, as agreed with our Consumer Jury.
— Calories per standard glass/can/bottle
as appropriate.
SAFETY OF
FOODS
The safety of foods can be prejudiced if they
are stored too long, at the wrong temperatures or cooked inappropriately.
It is a legal requirement to label foods with a "use by"
date, if they are highly perishable, or with a "best before"
date where prolonged storage leads to deterioration of quality
rather than microbial deterioration. To guide consumers we include
with the date mark, on all chilled food, the advice to keep the
product in a fridge at 2 to 5°C and for frozen foods, in
a freezer at -18°C. This reminds consumers of the recommended
temperatures for fridges and freezers.
The majority of products carry cooking guidelines.
In the case of meat and poultry, under a Food Safety header, consumers
are reminded of the need to cook the food thoroughly with an indication
of how this can be judged, accompanied by other statements on
hygiene and handling, where space permits.
FOOD SAFETY
Ensure food is piping hot, an even colour throughout,
and no pink bits can be seen. Always wash work surfaces, cutting
boards, utensils and hands before and after preparing food.
Some consumers need special advice. To help
consumers allergic to particular ingredients avoid foods containing
them, the Co-op not only labels all ingredients, but highlights
the presence of nuts and eight other most common, serious allergens
(Eggs, Fish, Shellfish, Milk, Soya, Gluten, Sesame and Sulphites)
as follows:
ALLERGY ADVICE
Contains Peanuts, Fish, Milk
Because of the very serious risk of anaphylactic
shock from traces of nuts or sesame seeds, where there is the
potential for cross contamination, the allergy advice also indicates
that the product is made in a factory handling nuts and/or sesame
seeds.
The Co-op also uses labels to remind consumers
of Government advice, for example, advice to pregnant women about
the risks from consuming raw milk cheeses or from excess vitamin
A in liver, or from caffeine in coffee, tea, chocolate, medicines
and certain soft drinks.
In-store point of sale is used to highlight
similar, key messages on chilled food safety, allergy advice and
risks from consumption of pâté, cheese and raw eggs.
THE MEANS
OF PRODUCTION
OF FOODS
Like other retailers, the Co-op has a range
of organic foods which are easily identified in-store by a distinctive
logo.
All eggs are labelled to indicate whether they
are free-range or from caged hens. Indeed, it was the Co-op who
provoked the EU to introduce the term from caged hens to identify
battery hens' eggs by labelling eggs intensively produced, despite
this being illegal at the time. Eggs used in recipe products are
similarly labelled to indicate their source.
The Co-op supported the development of the RSPCA
Freedom Food scheme to improve welfare standards for animals
at all stages of the food chain. We stock poultry, meat and eggs
meeting the standards. These can be distinguished by the Freedom
Foods logo.
The little red tractor logo is carried
on a majority of fresh meat and produce, indicating it has been
grown to Farm Assurance standards. Sadly, the logo is restricted
to British produce, so although we require the same standards
from overseas suppliers, we cannot use the logo.
The Co-op recognises that consumers are concerned
about the use of pesticides. It has introduced its own code of
practice, banning some pesticides and restricting others. Such
produce is nevertheless conventionally grown. To make this clear
to consumers, packs carry the following message:
"Conventionally Grown—reducing, banning
and controlling pesticide use"
The back of pack (where room permits) will carry
the following explanation, under a Conventionally Grown header:
CONVENTIONALLY GROWN
Most produce, including that sold by the Co-op,
is grown using pesticides to help control crop damage. However,
for Co-op Brand, we ban some chemicals, control and reduce reliance
on others and encourage alternative methods.
For further information, contact our Customer
Relations Department.
Genetic modification (GM) is a concern
for many consumers who wish to avoid GM foods and ingredients.
For some, this extends to any product touched by the technology.
The Co-op's policy on GM took a lead by committing to label foods
produced using GM. We are the only retailer to label cheese when
it has been made with the enzyme chymosin produced by GM, making
it suitable for vegetarians. Such cheeses are clearly labelled:
"Made using genetic modification and so
free from animal rennet".
Similarly, we are endeavouring to respect consumers'
wishes by eliminating GM from the feed of food producing animals;
meat, fish, milk and eggs. Where we are successful, this is clearly
stated on-pack with reference to non-GM feed.
In the case of eggs we have also removed the
colourant added to feed to enhance the colour of the yolk. Both
issues are communicated by the roundel shown on the packet.
ETHICAL CONSIDERATIONS
The Co-op believes it is wrong for the majority
of the world's citizens to be condemned to a life of poverty and
firmly advocates the protection of human rights for workers in
all countries. The two main ways of tackling the issues are Ethical
Trading (also known as sound sourcing) and Fair Trade.
The two approaches are complementary.
Ethical Trading is primarily aimed at
ensuring basic human rights and a safe and decent working environment
for employees of supplying producers and manufacturers. The approach
therefore covers the vast majority of our suppliers and, as such,
does not require special labelling.
Fairtrade seeks to guarantee a better
deal for the world's disadvantaged growers and small-scale producers.
Aimed primarily at marginalized independent growers and producers
in the world's poorest countries, fairtrade ensures they receive
payment that exceeds the market place norm and includes an additional
premium to support producer programmes.
The Co-op has pioneered the development of fairtrade
in the supermarket sector, being the first retailer to develop
and launch an own brand fairtrade product. Our ultimate objective
is to bring Fairtrade into the mainstream. We have fairtrade products
in more stores than any other retailer, improving consumer access.
A distinctive livery, together with the Co-op
Fair Trade logo and the FAIRTRADE Mark, readily identify products
in the Co-op Brand range which meet the criteria of the Fairtrade
Foundation.
We have also pledged to include Fairtrade ingredients
in products wherever we can. In order to qualify for the Fair
Trade branding at least 20% of the total must comprise Fairtrade
or Fairly Traded ingredients. Such products carry the FAIRTRADE
mark but not the Co-op Fair Trade logo. Each Fairtrade or Fairly
Traded ingredient is identified in the ingredient list. A line
below will identify the percentage of Fairtrade or Fairly Traded
ingredients.
INGREDIENTS
(greatest first): Sugar, Fairtrade Cocoa Butter,
Skimmed Milk Powder, Milk Powder, Fairtrade Cocoa Mass, Crisped
Rice (70%), Butterfat, Emulsifier (Lecithins—Soya), Flavouring.
MILK CHOCOLATE CONTAINS COCOA SOLIDS 32% MINIMUM
AND MILK SOLIDS 27% MINIMUM
32% FAIRTRADE INGREDIENTS
Where there are some ingredients that are not
Fairtrade or Fairly Traded, the amount is always repeated under
the product name, eg:
Fairtrade Cranberry Sauce
Contains 20% Fairtrade Sugar
Uniquely among supermarkets the Co-op has run
a national TV campaign dedicated to the support of fair trade,
in addition to awareness building adverts in national press and
magazines.
SUMMARY
The examples above provide a flavour of the
way the Co-op uses labelling, in particular, to make consumers
better informed about the nutritional content of foods, how to
handle and consume foods safely, how foods have been produced
and where good labour practices are used. Further examples are
provided in the attached leaflets [not printed] and can be found
on our website; www.co-op.co.uk
19 April 2004
1 NOP Consumer Research conducted 1,061 face-to-face
interviews with a representative sample of the UK population.
Completed July 2002. Back
2
Voluntary Nutrition Labelling Guidelines to Benefit the Consumer-Voluntary
Nutrition Research Findings, IGD, February 1988. Back
3
"Just Read the Label: Understanding nutrition information
in numeric, verbal and graphical formats". The Coronary Prevention
Group, Alison Black and Michael Rayner, 1992, London, HMSO. Back
4
"Just Read the Label: Understanding nutrition information
in numeric, verbal and graphical formats". The Coronary Prevention
Group, Alison Black and Michael Rayner, 1992, London, HMSO; The
Consumers' Association, The Ministry of Agriculture, Fisheries
and Food, National Consumer Council "Consumer Attitudes to
and Understanding of Nutrition Labelling", British Market
Research Bureau, 1985. Back
5
Nutrition Label Testing, Food Standards Agency, November 2003. Back
6
NOP Consumer Research conducted 1,061 face-to-face interviews
with a representative sample of the UK population. Completed July
2002. Back
7
Voluntary Nutrition Labelling Guidelines to Benefit the Consumer-Voluntary
Nutrition Research Findings, IGD, February 1988. Back
8
NOP Consumer Research conducted 1,061 face-to-face interviews
with a representative sample of the UK population. Completed July
2002. Back
9
NOP Consumer Research conducted 1,061 face-to-face interviews
with a representative sample of the UK population. Completed July
2002. Back
10
Lie of the Label II, the Co-operative Group, August 2002. Back
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