Provision of background information
31) Standards must be supported by adequate information
in addition to that shown on the product itself. Labels themselves
can convey only limited information. Excessive information on
a label risks distracting from the core message, or discouraging
consumers from considering the label at all. The British Retail
Consortium noted that:
A contradiction was highlighted in a number of studies;
whereby consumers support the inclusion of the maximum amount
of label information, yet regularly claim to feel confused or
overloaded by the information provided.[40]
In general, the level of information that is appropriate
to be included on the label itself varies with the product. For
instance, Marks & Spencer believes that signposting (the use
of simple logos) is easier for their consumers to understand and
therefore more effective,[41]
given the number of products on display and the nature of grocery
shopping. Conversely, labels for products where, in general, more
time is taken over a purchase, (such as white goods or vehicles)
can offer more detailed information.
32) Most consumers are likely to be satisfied
with the information provided on the product itself. A small minority
of curious or committed consumers may wish to seek out further
information about a label's operations, principles and standards.
This information should be publicly available to those who seek
it. This is especially important for complicated or opaque processes,
as in the case of green energy tariffs. Mr Steve Smith, from Ofgem,
told us:
You have [green energy] schemes which are much harder
for customers to understand where people are saying: 'we'll take
the money and we'll put it in some sort of investment fund and
we will invest it in other environmental improvements'.[42]
Although it would be very difficult to explain on
a label itself the more exact use of these additional funds, it
is essential that information is available online (and on request)
that explains to consumers the structures and processes that underpin
a label's claims. Primary responsibility for providing the necessary
background information for a labelling scheme should reside with
the label owner. The
Government should require certification schemes to make public
information explaining the structures, standards and methods behind
the label; ensuring that consumers can have confidence in the
audit and inspection processes that underpin the claims a label
makes. The Government should also set standards and guidelines
for the levels and categories of information to be provided by
any business that seeks to promote its operations and products
through a third-party labelling scheme.
Reviewing labels
33) The vehicle emissions label was revised recently
in order to make it more accessible for consumers and relevant
to the concerns of consumers.[43]
Some of the evidence we received highlighted a need for similar
evaluation and remodelling, notably in the area of energy labelling
for freezers and refrigerators, where improvements in energy efficiency
have led to confusingly-named A, A+ and A++ bands.[44]
Ofgem worked towards labelling guidelines and templates for the
marketing of green electricity tariffs when it became apparent
that existing labelling attempts were poorly understood,[45]
especially the distinction between 'low-carbon' and 'renewable'
energy.[46] Ofgem told
us that energy suppliers had welcomed this intervention to improve
transparency and coherence in the labelling systems they used.[47]
Labels
need to be regularly reviewed and adapted to ensure they keep
up with changes in the market and adequately reflect consumer
concerns. We welcome the Government's involvement in remodelling
the vehicle emissions label, and we urge it to maintain a programme
of regular reviews across its own labelling portfolio. The Government
should also identify areas where non-government labels are in
need of review, and should place pressure on the label owners
to undertake regular reviews.
34) Some environmental labels identify the highest-performing
products in a particular field. The most successful example of
this kind of label is the Energy Saving Trust's Energy Saving
Recommended (ESR) certification. This label takes the form of
a simple logo, complementing the more complex A-G white goods
label by identifying at a glance the highest-performing products.
The ESR label has been successful in helping consumers to differentiate
between the high numbers of top-rated products in the white goods
market.[48] But the need
for such labels may indicate a shortcoming in the primary labelling
system. The EST told us that their ESR logo is successful because
it communicates a clear message 'at-a-glance'[49]
but the colour and letters on the A-G label should have the same
effect. The ESR label was a UK response to sluggish revision of
the A-G label by Europe. The
Government's priority should be to resolve shortcomings in existing
labelling schemes, rather than introducing extra labels to compensate
for deficiencies.
37 Ev 1 Back
38
Q 309 (Mr Ryder) Back
39
Ev 60 Back
40
Ev 138 Back
41
Ev 13 Back
42
Q 202 Back
43
Ev 96 Back
44
Ev 114 Back
45
Ev 72 Back
46
Q 203 Back
47
Q 194 Back
48
Ev 54 Back
49
Ev 58 Back
