Food composition data use for food legislation purposes

R. Peters

Ross Peters is a Director with Flavourfresh Foods, 7 Kerrie Rd, Dundas, NSW 2117.

This review of the use of food composition data for food legislation purposes covers the following aspects: consumer expectations of food labelling (particularly nutritional and compositional labelling); the regulatory scene; labelling issues confronting the consumer, the regulator, and the manufacturer; the uses and abuses of food composition data; and a brief perspective on possible future developments.

Food labelling

Food labelling is a term that covers a broad spectrum of information, both mandatory and voluntary, that is to be found on packaged food. The mandatory information includes product name, manufacturer's name and address, country of origin, lot/batch identification, net weight, and, in certain instances, nutritional information. Additional voluntary information includes recipes, serving suggestions (pictorial representations), promotional material, product descriptions and, of course, the brand name.

Ingredient labelling is the declaration of components used to prepare food, and nutritional labelling is the declaration of certain key constituents of the food, as determined by analysis, that are significant to metabolism. Food composition data are derived from the detailed chemical analysis of a food.

Nutritional data are a sub-set of food composition data and both have a direct link with ingredient listing.

Consumer expectations

The subject of nutritional labelling of foods has been given extensive coverage in the media and the general public is becoming increasingly interested in knowing more about the food it purchases and consumes, thus needing clear, informative food labelling which is readily understood. In addition, the initiatives and activities of various government and community-based organisations have been instrumental in raising the profile of nutritional information and food composition data, eg the Commonwealth Department of Health's dietary goals and guidelines (1981) and the recommendations of the Better Health Commission (1987). However, as noted by Downer (1989), these objectives were based on limited data. The opportunity now exists to incorporate recent data to update those objectives.

To provide consumers with the opportunity to develop healthier diets by purchasing foods with known nutritional contents, clearly understood and usable information is needed on food labels. Furthermore, this information needs to be consistent with the public awareness programs being conducted by government and community-based organisations. When national data become available about Australian consumers' current level of understanding of ingredient labelling or nutritional labelling, then strategies can be planned to determine the nutritional information required on food labels, how it can be best presented, and how the purpose of the information can be lastingly communicated to all consumers in Australia, ie the dietary objectives can be matched with the label information, and with the level of consumer information.

Regulatory perspective

Ingredient labelling was introduced in 1978 as a mandatory addition to food labelling, although many manufacturers had already been providing this information voluntarily prior to 1978. The 1978 initiative saw the introduction of class names to describe food additives: mineral salts, colours, emulsifiers, food acids. In 1987 these requirements were complemented by the inclusion of the numbering system for food additives. An alternative was provided whereby the number could be substituted by the name of the food additive. The 1987 initiative also provided more detail about these class names, eg mineral salt (508), colour (160(a)), food acid (330); or alternatively, mineral salt (potassium chloride), colour (β-carotene), food acid (citric acid). The international standardisation of additive numbers and descriptions, through the Codex Alimentarius in which Australia participates through the activities of the Australian Quarantine and Inspection Service in Canberra, should assist in developing consumer awareness.

Nutritional labelling

Regulations covering the descriptive format were agreed upon in 1986 and cover any claims made relating to a food's nutritional content, eg fibre enriched, protein enriched (NHMRC 1989). Where a claim is made a table must appear describing the energy, protein, fat, carbohydrate (total and sugars component), sodium and potassium contents on per serving basis and on a 100 g (or 100 mL) basis. Similarly regulations incorporating nutritional declarations have been developed for Australian Standards: Vitamins and Minerals, and Special Purpose Foods (covering Foods for Special Dietary Uses, Low Joule Foods, Carbohydrate Modified Foods, Canned Foods for Infants and Young Children, Cereal-Based Foods for Infants and Young Children, Infant Formula, and Low Sodium and Low Salt Content Foods). In addition, cholesterol statements are prescribed for polyunsaturated oil and margarine.

Unfortunately, there is little consistency in the prescribed formats for nutritional information for these foods, particularly within the Special Purpose Foods category. Carbohydrate Modified Foods require a percentage composition of the key components and an energy statement per 100 g; Formula Dietary Foods require a statement of the energy content consumed per day as well as the proportions of protein, fat and carbohydrate in the food; Infant Formula requires a table of 28 components expressed per 100 mL as reconstituted; Low Sodium Foods may also have their sodium and potassium contents expressed in millimoles as well as milligrams per 100 g. This situation could obviously lead to confusion in the consumer's mind.

Labelling issues

Who needs the information?

Every consumer, every man, woman and child in Australia, has a need for information about the nutritional value of food consumed. This need has become more important and more complex as more is known about the composition, the metabolic value and the potential hazards of food, and, more importantly these days, there is an infinitely greater choice of foods to consume at our finger tips.

What does the nutrition label mean?

An example of the current confusion may exist in the consumer's minds if they are intending to purchase food to satisfy publicised needs to achieve a healthier, more balanced diet is given by sample labels for protein enriched bread shown in Table 1. Bread A has more protein, but more sodium, less sugar and less fat than Bread B. Both breads are described as “protein increased”, but for a consumer with a strong interest in purchasing the appropriate bread for developing a healthier diet, the choice is not particularly straight-forward based on the information presented on the label. Does the sodium content have precedence over protein content, or a lower fat content? Or should bread be considered a component of a broader menu for a daily diet, or a weekly diet, or a life-time diet? And therefore, does it matter if there are slight differences in compositional data of this component food? The critical point is, how can the consumer assimilate the nutritional information presented to them on this one food? There are many more product comparisons that would be equally relevant.

Labelling of sugar content

Sugar labelling has been a subject of contention for some time. Should sugars be labelled as “added sugars” or as “total sugars”? A number of natural, unprocessed foods contain simple sugars, such as lactose in milk, and fructose and sucrose in fruit. However, these sugars are not perceived as constituting health problems for the average consumer. Indeed, general advice is to increase the consumption of fresh fruit for its mineral, vitamin and fibre content. Sugars in whole fruits are not believed to be damaging to teeth or other aspects of metabolism because the way in which nature ‘packages’ sugar tends to reduce sugar contact with teeth and may delay its absorption into the blood (Anon 1987). Furthermore, the sugar content of fruit can be highly variable depending upon the cultivar and stage of maturity. Further, from a nutritional point of view, the energy intake, often dependent upon the total sugar intake, will be important in any dietary consideration. If total sugars are to be the preferred form for labelling, then most fruits and many vegetables could be designated as being high in sugar content. This would be factually correct, but would require substantial educational input to the population to explain this apparent anomaly.

Labelling of salt or sodium content

Salt has been used as a method of preservation since recorded time. However, the relevance of salt to hypertension and its subsidiary side-effects is becoming well documented and well publicised. The public health concern arises through the addition of salt to foods rather than from that naturally present in foods. Whilst the total sodium content of foods should be given on a label in quantitative terms (g salt or sodium per 100 g of food), some have argued that millimoles of sodium (or sodium chloride) can be better integrated into a dietary objective.

Dietary fibre

Dietary fibre has been a widely used term in the past decade. In recent years there have been substantial developments in our understanding of the term, the composition of dietary fibre, and its physiological effects on the body. Traditionally, the term fibre has been loosely applied to those components of the plant cell wall which escape digestion by the enzymes of the human intestine. More recently, a stricter chemical definition has been developed which refers to non-starch polysaccharides, thereby eliminating minerals, lipids and lignins from consideration as fibre (Anon 1987). All non-starch polysaccharide components escape digestion in the human small intestine, moving on to the colon. This definition of fibre could satisfy those who are concerned with regulatory aspects including scientific accuracy, and those concerned with nutritionally meaningful definitions. However, it is becoming evident that the full meaning of dietary fibre is yet to be unravelled. Manufacturers are bound to label food according to regulations, but is the information on the label meaningful to the consumer in terms of needs, and metabolic effect?

Labelling of fat content in food

Through media advertising, consumers are becoming more aware of the need to monitor intake of polyunsaturated fats, mono-unsaturated fats and cholesterol. As knowledge increases so do the concerns for various aspects of fats and fat-soluble components of our diet. The point comes through again, do we have the necessary information to provide consumers with a clear understanding of their dietary needs?

Uses and abuses of food composition data

There may be need to adopt a “helicopter” viewpoint in addressing the issues surrounding food labelling, so as to avoid the divisions among the many groups, each with a well planned agenda to achieve defined objectives, though often with a narrow perspective. The public is being bombarded with bits and pieces of information concerning their diet and the opportunity to abuse food compositional data then arises. The abuse may take the form of selective promotion of key nutritional groups in isolation from the broader perspective of a balanced diet. The reverse also applies in the case of negative claims. The manufacturer must respond to the changing food information environment and provide pertinent statements or data that will maintain or develop market share for certain products.

Table 1. Nutrition labels for two types of protein enriched bread (per 100g)

* serving size 29.6 g
** per slice 28.0 g

The drive for healthier food has seen the description “natural” debased to a point where it is difficult to know whether it really has the meaning the public expect. The term “all natural” is often used to indicate that the ingredients used to prepare the product are natural. However, in an instance where a product is highlighted as “all natural” but its ingredient statement lists potassium chloride and calcium chloride, is the claim “all natural” justified? These particular substances exist in nature, but many may not be satisfied that they are natural. The critical issue is the need to have clear understanding among consumers of the contribution to the diet of ingredients and additives approved for use in food, and their relation to the nutritional goals for Australians.

The future for nutritional advice on food labels

The issues surrounding information presented to consumers through labels, advertising and publicity are complex. The need to know more about the food we eat is undisputed. The problem lies in how to convey the necessary nutritional information in a form that is readily understood and that can be assimilated into the wider perspective of better health and well-being, bearing in mind that the ultimate choice is that of the consumer. The difficulty with a numerical tabulation of nutritional data on labels is that the consumer not only has to understand the units in which the nutrient is expressed, but then has to collate the information on several nutrients depicted in different terms, eg kilojoules, grams, milligrams, millimoles. If this has been achieved, consumers can then choose the brand of food which conforms most closely with their wishes. But then the consumers somehow have to integrate information on all their food purchases if they wish to maintain their diet in accordance with established guidelines. The integration of such information has been recognised for some time, both internationally and in Australia, and has led to the statement that there is no such thing as an unhealthy food and that the balance of food choices is the key to an appropriate diet.

This leads to the opportunities for the future. Perhaps the pictorial representation of nutritional information, as is being developed in the UK, has merit. However, it may be more pertinent at this moment to determine what Australians currently understand with respect to food, nutritional and compositional labelling and what consumers want to and need to know. Such a survey would need to be appropriately detailed to cover the spectrum of the Australian population, and structured in such a way that the gaps in understanding can be identified, and future regulations, public awareness campaigns and advertising guidelines developed accordingly. Access to considerable food data is now possible but there may be little benefit in presenting such data through food labels unless consumers can clearly understand them and appropriately collate and assimilate the information against dietary objectives. There needs to be a national approach to address all the issues to reduce the potential for misunderstanding and abuse of food data. Meanwhile, there is a real risk that consumers will become totally apathetic towards the nutritional information prescribed by regulation on food labels.

References

Anon. 1987. Nutritional labelling of foods: a rational approach to banding. London: The Nutrition Advisory Committee, The Coronary Prevention Group.

Better Health Commission. 1987. Towards better nutrition for Australians. Canberra: AGPS.

Commonwealth Department of Health. 1981. Dietary guidelines for Australians. J. Food Nutr. 38: 111–9.

Downer, A.H. 1989. Dietary goals, guidelines and guesswork. Food Aust. 41: 916.

National Health & Medical Research Council 1989. Food Standards Code. Canberra: AGPS.