Joint memorandum by the Food and Drink
Federation and the National Farmers' Union (WP 55)
The organisations contributing to this response
are the Food and Drink Federation (FDF) and the National Farmers'
Union (NFU). They represent the food production and manufacturing
sectors of the food industry.
FOOD AND
DRINK FEDERATION
The FDF represents the UK food and drink manufacturing
industry, the largest manufacturing sector in the UK. Its members
are food and drink manufacturing companies, large and small, and
trade associations dealing with specific food and drink sectors.
The UK food and drink manufacturing industry:
— has a gross output of over £66
billion, accounting for 14% of the total manufacturing sector;
— employs some 500,000 people, representing
around 13% of the UK manufacturing workforce;
— exports around £9 billion of
food and drink, over 60% of which goes to EU;
— members imports around £18 billion
of food and drink, of which 64% comes from EU; and
— members buys two-thirds of all the
UK's agricultural produce.
NATIONAL FARMERS'
UNION
The NFU represents the farmers and growers of
England and Wales. Its central objective is to promote successful
and socially responsible agriculture, while ensuring the long
term viability of rural communities.
It is the largest farming organisation in the
UK, representing around three quarters of the full time commercial
farmers in England and Wales. The sector employing 550,000 people,
has a total turnover (value produced) of £15.5 billion.
INTRODUCTION
Both FDF and NFU welcome the White Paper and
its overall aim of improving people's health and lifestyles. However,
as the delivery plan (including the Food and Health Action Plan)
has not yet been issued, it is difficult to answer some of the
specific questions in your Inquiry's terms of reference and, at
this stage, to understand how success will be measured. In this
response, we have therefore concentrated on areas of the White
Paper which are of the most immediate relevance to the food and
drink manufacturing industry.
The White Paper sets out a process of discussion,
negotiation and action by a number of stakeholders. It is important
to recognise that the food industry can only act within its area
of competence and expertise. We therefore welcome and support
the partnership approach and, along with the rest of the food
chain, will work to achieve the White Paper objectives to:
— help motivate people to be healthy;
— ensure a wide provision of products
and services to help consumers adopt healthy diets and lifestyles;
and
— provide clear information which will
help consumers make healthy choices for themselves and their families.
FDF and NFU are pleased that success is acknowledged
in the White Paper and examples given (such as the FDF Manifesto).
As far as achieving national dietary targets, it is important
to recognise that gains have already been made. For example, the
population target for total fat intake has been achieved. It will
be important to assess how such successes were achieved and to
build on them. (For example the fact that most people now drink
semi-skimmed milk has played a significant part in bringing down
fat levels in the diet). We hope that the eventual White Paper
delivery plan will not disregard lessons to be learnt from such
successes.
We should also like to see measurements made
on health improvements so that cost effectiveness of the White
Paper proposals can be estimated. This will be the only way of
checking that the recommendations are appropriate and that delivery
methods are clear, in relation to the White Paper proposals. We
see the establishment of a robust dietary survey programme as
an essential tool for evaluation. We are currently involved in
discussions with FSA on what kind of dietary survey would be feasible
as a replacement to the National Diet and Nutrition Survey (NDNS).
COMMENTS ON
AREAS RELEVANT
TO THE
FOOD MANUFACTURING
INDUSTRY
Food Labelling, "Signposting" and Nutritional
Profiling
Our two organisations see no value, and some
dangers in simplistic and subjective systems of labelling/signposting,
especially if it is based on some kind of profiling scheme. For
real behaviour change to take place, consumers need to understand
and "own" a system of labelling. There is little rationale
or value in a system which labels foods in a narrow subjective
way, such as a traffic light type of scheme which labels foods
as "eat sparingly", "in moderation", etc.
Trying to distil the overall nutritional value of a single food
into one "signpost" is unscientific and potentially
misleading.
The food manufacturing and farming industries
support the development of a "Guideline Daily Amount (GDA)"
scheme, based on government targets for population nutrient goals.
Such a scheme will allow consumers to see how much of which key
nutrients are present in a portion of the particular food and
able to compare this with the recommended levels of that nutrient
for a day (the GDA). Such a GDA scheme would also allow consumers
to assess objectively the nutritional value of each food product
in their own diet.
FDF and NFU are preparing detailed comments
on the profiling model developed by FSA for submission by the
25 February deadline questioning its scientific validity and value
to consumers.
Food Advertising and Marketing
— Two important principles are stressed
in the White Paper—the need for information and the role
of individual choice. For both choice and information to be maximised,
advertising and other forms of consumer communications should
not be unjustifiably restricted. This is because advertising communicates
product benefits to consumers and is a key feature of a market
economy. Without it, consumers would not become aware of the availability
of products, and be able to exercise effective choice. Manufacturers
would also have little incentive to meet different consumer tastes
or needs if they were unable to communicate value-added benefits
to them.
— Mandatory codes on advertising, as
currently in existence, can react quickly to specific issues and
are more flexible than legislation. They need to be evidence-based
and regularly reviewed. FDF and NFU, along with the rest of the
food chain and advertising industries, is committed to working
with Ofcom and Government on an evidence-based review of the codes,
as well as discussing the whole range of concerns relating to
advertising to children.
Changes in Food Composition and Portion Sizes
— We agree that consumers should have
choice. Being able to choose a lower fat or sugar option, as well
as the original option, is important from the point of view of
taste as well as health: dietitians agree that it is inappropriate
for all consumers to have a low energy dense diet.
— An increase in the range of lower
fat and sugar products must go hand in hand with activity to motivate
consumers to purchase and eat these foods. Industry will not be
able to increase the range of these foods if consumers do not
buy them.
— As set out in FDF's Food and Health
Manifesto (not printed), our industry is committed to exploring
new approaches to portion sizes.
Public Health Education Campaign on Obesity
— The food chain and advertising organisations
wrote to the Prime Minister in May 2004 offering to participate
in a Government-led campaign of public education on healthy eating
and lifestyle. This offer still stands and we await Government's
response.
Public Procurement
It will be important that Government both sets
an example and takes the opportunity to make a substantial contribution
by ensuring that the £1.8 billion spent on public procurement
of food and drink products supports the aims of the White Paper.
CONCLUSION
FDF's Food and Health Manifesto sets out our
industry's commitment to working with FSA and Government on more
informative nutrition labelling; and to working with Government
and Ofcom on tightening the advertising codes, particularly in
relation to children, within competition law.
Both food manufacturers and farmers, along with
the entire food chain, are committed to playing their role and
look forward to clarifying the detail of White Paper proposals;
discussing ways forward; and implementing co-ordinated policies.
THE UK FOOD
AND DRINK
MANUFACTURING INDUSTRY
Our industry is socially responsible and has
been so from its founding years. Examples include the Quaker traditions
of Rowntree and Cadbury's and the vast number of current community
projects that industry supports.
Food safety is the number one, non negotiable
priority for food and drink manufacturers and we work closely
with the safety and regulatory authorities to bring that about.
We have a role to play in tackling problems
of obesity and non-communicable diseases in society and believe
the best approach is to help encourage consumers to adopt a balanced
diet and healthy lifestyle.
February 2005
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