Memorandum by the Biscuit, Cake, Chocolate
and Confectionery Association (BCCCA) (WP 65)
The BCCCA includes in its membership all of
the major UK manufacturers of biscuits, cakes, chocolate and confectionery
and over 70 smaller businesses, and together they account for
more than 90% of the UK sector. They employ some 60,000 people
in this country.
The BCCCA welcomed the publication of Choosing
Health. As socially responsible businesses, many with a proud
tradition of activity in their communities, BCCCA members share
the widespread concern about the increasing incidence of obesity.
For some time now they have been reviewing along with other food
sectors and with government what action they can take to help
overcome this challenge. Some of the actions which have resulted
are set out below:
— Around 80% of products already display
data on energy, protein, carbohydrate and fat, BCCCA has recommended
to its members to display these plus saturates, sugar, fibre and
sodium by the end of 2005 (with the exception of small packs for
which different arrangements are needed and those items without
nutrients).
— BCCCA members have agreed to abide
by the GMA (US) and CIAA (European) industry guidelines on promotion
of foods to children, as a minimum.
— Major manufacturers provide a range
of portion sizes for their products, and have already announced
their intention to either discontinue or redesign king-size products
to address the issue of over consumption.
— Members have agreed to support the
Automatic Vending Association's Code of Practice, which includes
providing a choice of non-branded machines and products and to
secondary schools alone. BCCCA members do not offer vending to
primary schools.
1. Will the Government be able to achieve
its objectives?
The BCCCA believes that any further action taken
by industry must be part of a wider Government programme to combat
obesity. We want to be part of the solution, but believe we can
be only just that—a part of the solution. For this reason,
we welcome the breadth of approach in the White Paper and believe
that if Government is to succeed in this endeavour then all parts
of Government must act coherently and that every stakeholder must
be involved.
Equally, the importance of personal responsibility—in
what we eat, how we feed our children, how much exercise we take
and encourage others to take—should be strongly emphasised.
We note, for example, that the NOP poll for Ofcom revealed that
food manufacturers and schools came a distant second and third
respectively to parents and other family members as influences
on children's healthy eating habits.
We agree with Government that in order to underpin
personal responsibility, consumers should have straightforward
access to accurate and helpful information about the food theyeat.
We do not, however, believe that the proposals in Choosing
Health (and as subsequentlydeveloped for consultation by the
FSA) to codify foodstuffs using over-simplistic categoriesin order
to describe the role they may play in a healthy diet will be effective
or workable.
It is important for consumers to understand
that it is not simply a matter of balance of Nutrients, within
food but how many calories are eaten and used which affects weight.
2. Are the proposals appropriate?
The BCCCA has the following specific comments
on proposals in Choosing Health.
(a) "Reverse the trend towards bigger portion
sizes"
Our customers welcome the opportunity to choose
different product formats. However, we agree that manufacturers
should make it clearer that larger formats are designed for sharing,
or for consumption over time, or for those who have a more active
lifestyle. Some major manufacturers have already announced their
intention to discontinue or re-design larger-format products.
(b) "Government will work with industry
to develop voluntary action to reduce sugar and fat levels in
different categories of food"
BCCCA members already offer a range of low-fat,
low-sugar and sugar-free alternatives. In 2003, we recommended
to members that they reduce salt in biscuits and cakes, even though
they account for less than 4% of salt in the average diet. We
welcome the acknowledgement in the White Paper that it can take
a considerable time to change the composition of foods in a way
which will gain acceptance from consumers. The White Paper also
appears to acknowledge that different categories of food will
be able to achieve varying reductions of different ingredients.
Other regulations may also constrain reductions
of some ingredients: for example, the use of artificial sweeteners
is forbidden by EU directives in biscuits and cakes; and a minimum
level of fat is prescribed by the Chocolate Directive.
(c) "By early 2006, there should be a `clear,
straightforward coding system', on the basis of which consumers
could understand `which foods make a positive contribution to
a healthy diet and which are recommended to be eaten only in moderation
or sparingly'"
The BCCCA is concerned at the implication that
a food which should be enjoyed in moderation cannot also contribute
positively to a healthy diet.
Over-simplistic labelling schemes, such as most
of those proposed for consultation by the FSA since the publication
of the White Paper, do not take into account people's different
nutritional requirements, or the fact that these products often
contain valuable micronutrients such as iron and calcium; and
do nothing to convey the fact that it is the amount eaten that
affects weight, not whether a single chocolate bar or cake has
been consumed. It is also important to eat a broad range of foods,
including those that are enjoyable.
The BCCCA has recommended to its members that
all packs (except small packs and those items without nutrients
size) should, by the end of this year, display information on
energy, protein, carbohydrate, sugars, fat, saturates, fibre and
sodium. In addition packs should display Guideline Daily Amounts
(GDAs) for calories and the contribution to the GDA per portion
of the product.
The BCCCA believes that GDAs are an objective
standard, readily understood by the public. We therefore support
the GDA option as providing accurate, accessible and clear information
to consumers.
(d) "Revised nutritional standards will
be extended to school vending machines"
The BCCCA supports the Automatic Vending Association's
Code of Practice, which also covers machines which vend our members'
products but which the member does not control. This provides
for a choice of non-branded machines and products. We also support
the integration of vending into "Food in School" health
and nutrition strategies. BCCCA members do not offer vending to
primary schools.
(e) "Restrict further the advertising and
promotion to children of those foods and drinks that are high
in fat, salt and sugar"
BCCCA members have already agreed to abide by
both US and European food industry guidelines, as a minimum. They
are recommended to have their own clearly-stated policies on promotion
to children, and major manufacturers have introduced new policies.
Industry groups will be working with Ofcom to
update the rules on broadcast advertising, sponsorship and promotion.
Ofcom itself has said that a ban on advertising to children would
be "ineffective and disproportionate" and would "reduce
choice and innovation for younger audiences".
(f) "The Government will discuss with
industry how it might contribute to funding national campaigns
to promote positive health information"
We agree with the importance of such campaigns,
but believe that nutritional labelling and even providing healthy
eating messages on pack are different from funding national information
campaigns. The BCCCA will discuss with its members and with government
whether members could provide healthy eating messages on packs
(again size and layout permitting), but health promotion and education
is a core government programme and should be paid for out of tax
revenues, which, of course, include the £1 billion of VAT
receipts from this sector of the food industry alone.
3. CONCLUSION
The average consumption of biscuits, cake and
confectionery in the UK has started to fall, after a decade of
remaining static. [123]The
lack of correlation between consumption of these products and
the increased incidence of obesity is borne out by international
comparisons. This in turn illustrates the dangers of demonising
particular foodstuffs.
Our members do not, however, support the proposals
for industry-funded public information campaigns or for severe
restrictions on advertising to all young people. What is important
is empowering consumers to make informed choices, and the BCCCA
supports those proposals in the White Paper that would underpin
consumer choice and personal responsibility.
February 2005
123 Source 2002 BCCCA; Department of Health. Back
| 
