Memorandum submitted by Tesco
1. INTRODUCTION
1.1 We are grateful for the opportunity
to submit written evidence to the Environmental Audit Committee's
inquiry into environmental labelling. By way of response to the
questions set out in the inquiry's terms of reference, we set
out below what we see as the fundamental principles that should
underpin a successful system of environmental labelling.
2. THE POWER
OF CONSUMERS
2.1 Consumers have a fundamental role to
play in tackling climate change and responding to other environmental
challenges. In the case of climate change, this is because they
control around half the emissions through their own actions and
because, properly empowered in a dynamic market, they will stimulate
business to innovate low-carbon products and services. The same
applies to other environmental challenges.
2.2 The huge growth in sales of organic
food is testimony to the fact that people will make greener choices
if we give them the right information, opportunity and incentive.
By expanding our range and promoting organic products through
green Clubcard points and point of sale information, buying organic
has become much more mainstream, with one in three customers putting
at least one organic item in their trolley. We now have over 1,200
own brand organic products and our organics business is growing
twice as fast as our main food business.
3. CONSUMERS
WANT INFORMATION
ON THE
ENVIRONMENTAL IMPACT
OF PRODUCTS
3.1 Our customers are increasingly aware
of green issues and tell us they want our help to do more in the
fight against climate change. Some 71% of consumers think they
are not doing all they could to tackle climate change and one
in three claim simply not to know enough about what they could
do to help stop global warming.[15]
3.2. They tell us that one of the barriers
to going green is a lack of information about what they can do.
3.3. Our research shows that customers would
welcome clear information and labelling on the environmental impact
of products, with over half saying more information would help
them make greener lifestyle choices.
4. INFORMATION
EMPOWERS CUSTOMERS
TO ACT
4.1. Information is a powerful tool in driving
behaviour change, empowering individuals to take action.
4.2. Our experience with nutritional labelling
shows that giving customers the right information is the best
way to get them to change their behaviour.
4.3. Nutritional labelling provides a powerful
example of what might be achieved with effective, specific and
targeted environmental labelling. By moving the nutritional advice
from a small, mathematically-complex box on the back, to a simple
Guideline Daily Amount key on the front, we saw sales swing dramatically.
For example, prawn mayonnaise sandwiches saw a sudden drop in
sales while those of the healthy living alternative increased.
In the eight weeks following the introduction of front of pack
GDA labelling on a frozen beef stroganoff ready meal (salt GDA
46%) sales fell by 46% as customers shifted to healthier alternatives.
These sales patterns also led to rapid product reformulation;
if a manufacturer was able to remove salt, fat and calories from
their product, it was in their interest to do so. In fact, as
a result of this reformulation, over the past 12 months salt levels
have been reduced in over 500 products.
5. THE ROLE
OF GOVERNMENT
IS TO
HELP EMPOWER
CONSUMERS
5.1. Government should recognise the potential
for consumers, properly empowered, to deliver change and support
businesses in helping consumers make green choices.
5.2. This will be more effective than regulating
for change which risks introducing inefficiencies into the market
and stifling consumer action.
5.3. In terms of environmental labels, we
believe that the role of government should not be to impose any
particular model but, where necessary, to facilitate their development
and to ensure that the claims are verifiable and robust.
6. LABELLING
SHOULD BE
SIMPLE, INFORMATIVE
AND NOT
MISLEADING
6.1. In order for a label to be effective,
the information it provides must be clear, concise and easy to
understand.
6.2. The success of a labelling scheme will
depend upon customers' ability to understand and feel comfortable
using the labels. Labels should focus on information that is easy
to understand and apply and should not overwhelm consumers with
excessive data.
6.3. It is for this reason that we do not
believe a single environmental label is the right approach. This
risks being overly-complicated, not only to agree and develop
but more importantly to present, and of therefore having limited
impact in driving behaviour change.
7. LABELLING
IS ONLY
PART OF
THE SOLUTION,
EDUCATION AND
INCENTIVES ALSO
HAVE A
VITAL ROLE
TO PLAY
7.1. Labelling can be a powerful tool for
customers but not on its own. It must be supported by education
to help customers make proper use of the information.
7.2. Our front of pack nutritional labelling
has enabled customers to make healthier choices but the information
we gave our customers in store, through leaflets and online empowered
them to use the information on the labels effectively.
7.3. Information and education must also
be accompanied by incentives to make greener choices more attractive
as we know these can play a powerful role in changing customer
behaviour. For example, by giving our customers green Clubcard
points for every carrier bag that they do not use, we have saved
over one billion bags. Similarly by halving the price of energy
efficient bulbs we have quadrupled their sales. We have also just
launched a new interactive website for customers called Greener
Living. This is designed to be a fun and informative way to help
our customers be greener and will be followed early next year
with a new Greener Living range including products like energy-saving
light bulbs, recycled bin liners and an energy-saving eco-kettle.
8. CARBON LABELLING
8.1. We believe the biggest public policy
challenge we face is that of climate change and that clear information
about the carbon cost of the products will enable customers to
make effective green choices.
8.2. Customers want us to develop ways to
take complicated carbon calculations and present them simply.
8.3. We are therefore working to develop
a universally accepted and commonly understood measure of the
carbon footprint of every product we sell. This will allow customers
to compare the carbon footprints of products as easily as they
compare price.
8.4. We will be working with the Carbon
Trust to measure the carbon footprints of 30 of our own brand
products taken from a range of categories including tomatoes,
orange juice, potatoes, light bulbs and detergents.
8.5. This will bring us a step closer to
providing the type of information customers need to make greener
choices based on good science. Mapping the carbon footprint of
these products will yield invaluable data that will benefit all
those retailers and producers who are working towards combating
climate change. It will also give us important information on
how measurement can work in a simple, cost effective way when
applied to a wide range of products.
8.6. We do, however, recognise that it will
take time to create a commonly accepted and universally understood
carbon labelling programme. As an interim measure we have therefore
put an aeroplane symbol on all air-freighted products. We appreciate
that food miles are a crude measure and that a product grown abroad
and flown here may have no higher carbon footprint than a product
grown out of season in a heated greenhouse in Europe. However,
air freighting is generally deemed as having a detrimental impact
on the environment and the label is therefore an important first
step in arming consumers with the information they need to make
greener choices. We are also reducing our reliance on air transport
overall by restricting it to less than 1% of our products. That
said, there is clearly a strong international development case
for trading with developing countries. Therefore, within this
1 per cent there will be a bias in favour of developing countries.
October 2007
15 Penn, Schoen & Berland Associates, November
2006. Back
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