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How important is consistency of look? Explain.

A standardized format will make it easier for consumers to learn how to read nutrition labels and compare different products. When comparing two or more products, a consumer should be able to align the nutrition information panels and easily compare the corresponding nutrients in the same sequence and the same size typeface to select the most healthful product.

A uniform appearance will also help communicate the impression that the nutrition information being provided is regulated and is therefore reliable — and not merely marketing information. If consumers do not have confidence in nutrition labels, they will be less likely to use them.

To what degree should any of the graphic elements be prescribed?

The graphic elements (border, font, spacing, colour, panel shape) should be prescribed to the greatest extent possible to ensure a consistent appearance and maximize readability. Different size variations of the graphic elements could be prescribed to accommodate different product label sizes.

Currently, some nutrition labels are very difficult to read. In some cases, the print is very fine or small, contrasts little with the background, or is placed in an inconspicuous location. The National Institute of Nutrition's 1992 report concluded that consumers want labels with increased size, colour, and contrast; standardized formats; and easier-to-read terms.(14) Legibility is a concern for many consumers, especially for those over 65. Forty-four percent of grocery shoppers (including 70% of seniors) find the writing on packages too small to read.(15)

In a recent survey, of the 30% of Canadians who rarely or never use nutrition information on food labels, 21% complained that they are too hard to read, 19% said that there is too much variation in format from one product to another, and 23% said it takes too much time to read.(16) Nutrition information must therefore be presented in a standardized, easy-to-read format that is simple to locate on the label. Nutrition labels should use sufficiently large type-face with an adequate contrast between printing and background so that consumers (particularly elderly consumers and others with impaired vision) can easily read it. Consumer survey research should be used to guide the formulation of a standard graphic element.

Moreover, maximum consistency of graphic representation will also facilitate efforts designed to promote effective use of the new nutrition label. If manufacturers are free to make stylistic modifications to the nutrition label, the usefulness of educational materials designed to teach consumers how to read and interpret those labels may be impaired. Product comparisons would also be more difficult if different graphic designs were used by competing manufacturers. Furthermore, the failure to prescribe graphic elements would make enforcement more difficult.

Which panel title is better for consumers? Why?

CSPI believes that either panel title — “Nutrition Information” or “Nutrition Facts” — would be acceptable. However, we believe that only one title should be used to reduce possible consumer confusion.

Is providing the number of servings per package useful? Why?

Providing the number of servings per package is useful for several reasons. First, it helps consumers visualize the actual size of one serving. For example, if the serving size of a 1.89 litre carton of juice is 240 mL, it may be difficult for consumers to visualize how large one serving is unless they are told that there are eight servings in the entire carton.

Disclosing the number of servings per package is also useful in comparing products whose package volume is the same, but whose weight is significantly different. For example, rice cereal and whole wheat cereal may be packaged in boxes of similar size. However, because of weight differences, the rice cereal will contain significantly fewer servings per box. Declaring the servings per package allows consumers to easily compare the economic value of the two cereals. Without this disclosure, consumers may incorrectly assume that the numbers of servings per box are equal or have to perform complex calculations to determine the number of servings per container.

As an additional matter, we wish to emphasize that permissible serving sizes, wherever possible, should not be expressed as ranges. We recognize that some foods of the same type — such as cookies - vary in size and weight and that serving sizes will necessarily vary from brand to brand. However, the serving sizes of foods such as peanut butter, margarine, and vegetable oil should not be allowed to vary across brands. For example, the recommended serving size for peanut butter is 15-30 grams. As a result, Kraft Peanut Butter uses a serving size of one tablespoon, while President's Choice Peanut Butter uses a serving size of two tablespoons. To compare nutrition information between those two products, consumers must double the numbers listed on the Kraft label or halve the numbers listed on the President's Choice label.

To rectify this problem, serving sizes should be standardized among similar food products where possible and reflect the amount of food people actually eat. Standardization makes it easier for consumers to make nutrient comparisons among foods and ensures that companies do not use an unrealistically small or large serving size to favourably portray the nutritional composition of their products.

Does it matter which order of presenting nutrients is selected? Why?

The sequence of nutrients should be the same for all nutrition labels to make it easier for consumers to locate particular nutrients on the label, make nutritional comparisons among different products, and facilitate educational efforts. Four factors should be considered in determining that sequence.

First, some consumers may assume that the order in which nutrients are reported reflects their importance. Therefore, the order in which nutrients appear should account for this perception. Where possible, nutrients should be reported in order of most important to least important from a public health perspective. For example, saturated fat should be listed before iron because problems associated with saturated fat are more widespread in the population and are linked to incidence of life-threatening coronary heart disease and cancer. Non-core list nutrients may be reported underneath the core list.

Second, nutrients that have related health effects should be reported together. For example, fat, saturated fat, trans fat, cholesterol, and sodium should be reported together. This makes it easier for consumers who are concerned about cardiovascular health to focus on those nutrients.

Third, nutrients that are components of other nutrients should be reported together. For example, fibre and added sugars should be reported as a subset of total carbohydrates.

Fourth, vitamins and minerals (except for sodium) should be grouped together.

We propose the following sequence for reporting the nutrients we have recommended:

          total fat
          saturated fat (including trans fatty acids)
          total carbohydrate
          added sugars
          vitamin A
          vitamin C

What are the educational challenges and solutions for the way nutrients are declared?

Nutrients should be declared both in absolute amounts (i.e., the actual amount of the nutrient in a serving) and in relative amounts (i.e., a percentage of a reference standard of a daily intake).

Expressing nutrients only in absolute amounts is not meaningful for most consumers. Without a context, consumers will not know if those amounts are high or low. For example, a consumer might assume that a food containing five grams of saturated fat per serving is low in saturated fat, or that a food containing 100 mg of sodium is high in sodium.

When the United States Food and Drug Administration examined that issue, it found that many Americans could not specify the recommended intakes for nutrients such as sodium, even when those interviewed indicated that the nutrient was important to their health and that they were concerned about their intake of the nutrient.(17) The same is likely true for Canadian consumers. Putting those numbers in context allows consumers to better assess the food's nutritional value and understand how the nutrients fit into their total daily diet.

A recent survey also supports the declaration of nutrients in both absolute and relative amounts. The survey found that Canadians regard nutrition information expressed as both “grams” and “%RDI” as more useful in describing the nutrient content of a food than the provision of “gram only” information.(18)

We would also like to note that consumers may misinterpret the meaning of missing nutrition information. All food labels should be required to disclose the amounts of all nutrients in the core list, even if those values are zero. 73% of respondents in this survey support requiring such disclosures.(19) Nutrients in the core list should not be removed from the nutrition panel simply because they are not contained in a food.

Which of the two bilingual formats do you prefer? Why?

Both bilingual formats may pose minor difficulties. “Example A” is easier for English readers, but requires Francophones to locate nutrition information by reading from right to left. “Example B” requires unnecessary additional reading for both French and English readers. Francophones must read the English nutrient name before seeing the French equivalent, while Anglophones must read French nutrient names before scanning across to see the quantitative amount of that nutrient. Health Canada may consider conducting additional consumer research to determine which style is most effective for both Anglophones and Francophones.

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