A short history of labelling in the UK...
1996
Added requirements to packaging include amount of ingredients, storage and origin
2000
The EC issues a directive setting out the compulsory information required on labelling
2006
Sainsbury’s, Waitrose, Asda and Co-op back government traffic-light scheme. Tesco prefers GDAs
2007
FDF launches a £4m campaign to promote GDAs; FSA agrees nutritional criteria for its traffic-light labels; and Asda introduces a combined traffic-light and GDA system on its own-label produce
2008
In January, the EC proposes mandatory front-of-pack GDAs and a 3mm font for nutritional information. Six months later, the FSA backs industry concerns over EC proposals and calls for “broader view of clarity”. Next month, the EC debates concerns voiced by EU member states. No decision expected until new year
Labels are there to help consumers make informed choices – but how many can they realistically handle, and does their presence damage brand image, asks Alison Clements1996
Added requirements to packaging include amount of ingredients, storage and origin
2000
The EC issues a directive setting out the compulsory information required on labelling
2006
Sainsbury’s, Waitrose, Asda and Co-op back government traffic-light scheme. Tesco prefers GDAs
2007
FDF launches a £4m campaign to promote GDAs; FSA agrees nutritional criteria for its traffic-light labels; and Asda introduces a combined traffic-light and GDA system on its own-label produce
2008
In January, the EC proposes mandatory front-of-pack GDAs and a 3mm font for nutritional information. Six months later, the FSA backs industry concerns over EC proposals and calls for “broader view of clarity”. Next month, the EC debates concerns voiced by EU member states. No decision expected until new year
It takes approximately four minutes and 16 seconds to read every word printed on a box of Mr Kipling Lemon Slices. Front- of-pack information includes a Guideline Daily Amounts breakdown and a visual ‘tick’ feature stating ‘No artificial colours or flavours’, as well as the familiar Mr Kipling styling and product shot.
On the back, ingredients are listed alongside allergy advice, nutrition information, another GDA table, a quality guarantee, and recycling information for the carton, tray and film. Once further space has been taken up with barcode, best-before data, storage advice and company information, the much-loved slogan Exceedingly Good is literally squeezed into a corner. Digesting half the contents would be quicker.
And the amount of labelling could soon become even harder to stomach. Next month, the European Commission’s proposals to make GDA labelling on front of packs obligatory in two years time and introduce a 3mm minimum font size for all nutrition information will be hotly debated at a series of high-level discussions in Brussels.
“I can see a future retail environment dominated by packaging covered in large messages,” despairs Don Williams, director of Pi Global. “It’s a future where the brand message has become completely marginalised, and the poor old consumer is struggling to make any meaningful brand choice at all.”
Moreover, warn experts, there are so many labels that they run the risk of undermining – or at least diluting – any serious health claims being made. So can anything be done at the 11th hour to stop the relentless proliferation of food labels?
Over the past 40 years, a plethora of new front-of-pack labels have gradually been introduced including assurance schemes such as the Organic Standard logo in the 1970s and more recently the new-look Red Tractor in 2007 (see over).
Though they all have their merits, they’ve made food and drink packaging look increasingly crowded and they are not the only additional adornments packaging has had to accommodate.
A raft of voluntary and mandatory labelling regimes have been introduced over the past couple of years as obesity and healthy eating issues have come to the fore (see right). Many retailers and manufacturers have made a very visible commitment to either the traffic light or GDA camps when it comes to nutrition labelling, with Asda raising the stakes last year when it added a combination of traffic-light and GDA labelling to the front of more than 1,000 own-label products.
The upshot is that there is now more labelling on food and drink packaging in this country than elsewhere in Europe. Back of pack has certainly become a pretty crowded fixture. And now, the EC’s proposal to make front-of-pack GDA information mandatory raises the prospect of a similarly cluttered scenario where it really matters – the customer-facing, brand-displaying product ‘shop window’.
Label overload?
Red Tractor (UK farm assurance)
Owned by Assured Food Standards, it denotes food produced by the alliance of farmers, processors, retailers and distributors
Organic Standard logo (Soil Association)
Food carrying the logo has met the strict environmental and animal welfare standards laid down by the Soil Association
Freedom Food (RSPCA)
The label is awarded to products that come from animals reared on farms inspected to RSPCA welfare standards and are traceable from farm to fork
Quality Standard mark (Eblex)
Guarantees beef and lamb was born, raised and slaughtered in England, and raised on a farm belonging to a recognised farm assurance scheme
LEAF marque (Linking Environment And Farming)
Awarded to farmers who embrace an environmental and socially responsible way of farming to ensure sustainability
Whole Grains stamp (US Whole Grains Council)
On trial at Morrisons, the two-tiered scheme (100% Stamp and Basic Stamp) guarantees that all or at least half of the product’s grain ingredients are whole grains
Further labelling requirements, particularly front of pack, could be counter-productive, believes the Food and Drink Federation. “We support the EC’s stated vision to simplify labelling but regret that within the proposals there’s no real attempt to reduce the amount of information required on the label,” says a spokeswoman. Red Tractor (UK farm assurance)
Owned by Assured Food Standards, it denotes food produced by the alliance of farmers, processors, retailers and distributors
Organic Standard logo (Soil Association)
Food carrying the logo has met the strict environmental and animal welfare standards laid down by the Soil Association
Freedom Food (RSPCA)
The label is awarded to products that come from animals reared on farms inspected to RSPCA welfare standards and are traceable from farm to fork
Quality Standard mark (Eblex)
Guarantees beef and lamb was born, raised and slaughtered in England, and raised on a farm belonging to a recognised farm assurance scheme
LEAF marque (Linking Environment And Farming)
Awarded to farmers who embrace an environmental and socially responsible way of farming to ensure sustainability
Whole Grains stamp (US Whole Grains Council)
On trial at Morrisons, the two-tiered scheme (100% Stamp and Basic Stamp) guarantees that all or at least half of the product’s grain ingredients are whole grains
Brand designers warn that extra front-of-pack information would crowd out the brand, making it harder for consumers to spot their favourite products. “Shoppers recognise the brands or items they want from three or four feet away and that is where the front of pack is doing its work around shelf standout,” says Williams. “Generally, consumers take a nanosecond to recognise the product they want, which is why branding is so important. Smothering pack fronts with confusing bits of information risks camouflaging the brand. If a customer is interested in the health aspects of a box of cereals, they will turn it over and find what they need to know.”
Another major gripe with the EC’s impending labelling overhaul is the proposed 3mm minimum font size for nutrition information.
This concern is echoed throughout the industry. Though the FSA been a long-term advocate of traffic lights rather than GDAs, it does not oppose the addition of nutrition information front of pack per se. However, it is concerned about the minimum font size proposal, which it fears will be impractical and cost millions to comply with.
One supermarket has submitted calculations to the FSA showing that to alter labelling on the 145 million sandwiches it sells annually would create 72,500 kg of additional packaging. This would cost £1.15m, and require an investment of £3.12m for new labelling equipment.
“Small stores stocking smaller pack sizes with smaller facings will struggle to meet these demands,” adds one supermarket own-brand designer.
As far as on-pack information goes, the FSA believes there are other ways to improve overall labelling clarity than prescribing a minimum font size, such as improving the contrast between print and background. Others question whether extra information should be put on packs at all.
“On a Coca-Cola fixture you’re likely to have six packs across the shelf,” points out Paul King, retail director of design consultancy Vivid Brand, and formerly a design manager at Tesco.
“Does nutritional information need to be displayed six times at the point of sale? Couldn’t some of the info currently on packs go on to the shelf edge or on to a leaflet or be downloaded from a company website? Surely there are other options beyond cramming the same message on to every front of pack.”
This would allow the packaging to do its primary job of selling the product, argues King. If consumers really are serious about reading up on nutrition, the origin of ingredients or carbon footprints, they’re more likely to do that at home than in the aisle anyway.
“I think the leading brands will really start to kick up a fuss about front of pack GDAs,” he predicts. “Their brand is their big asset and if the brand is compromised and sales are threatened, they’re not going to sit back and take it.”
Brand owners are reluctant to comment, but retailers have already demonstrated how open they are to using shelf-edge and take-away leaflets to educate their customers.
A Waitrose spokeswoman says the chain uses a number of methods to provide information to customers in store. “This includes leaflets on such things as where our meat comes from, sustainable fish, or on schemes such as our Waitrose Foundation, helping the lives of the South African farmers who grow our fruit,” she says.
“We also produce leaflets on matters such as traffic-light labelling on our foods, or 5-a-day. And we communicate to customers in-store through our customer magazines.”
Such leaflets may offer a practical solution when it comes to information relating to alcohol products, suggests The Portman Group, which feels that front-of-pack messages signalling a wine’s low-calorie credentials, for instance, undermine sensible-drinking advice.
Despite its reservations about the size of font used, the FSA believes front-of-pack calorie labels could be beneficial to consumers in certain categories, including beers, wines and spirits.
“Clear and easy-to-read product information is an important way of helping consumers to exercise informed choices about what they eat,” says Stephen Pugh, its head of general food labelling and marketing terms.
“This is often vital, for example, for those with food allergies that could be potentially fatal. The most effective way of displaying this information is on the label itself and this is what consumers expect. The current EC proposal on labelling doesn’t rule out alternative methods for displaying information, it is just that they are often impractical for a significant number of consumers.”
Williams agrees that on-pack labelling plays a vital role, but reiterates his point that too much of it is counterproductive, especially front of pack.
“Once the item is picked up and handled, the shopper will be in a position to read nutritional information and trust marks, by which time it’s not essential for the information to be on the front, or in particularly large print.”
He’d like to see bureaucrats develop a clearer understanding of how consumers behave at point of sale when there’s so much “visual noise”.
In the meantime, he says, “brand owners must tailor pack design more carefully to their target audience, think about who is really information-hungry, and stop throwing out irrelevant information that isn’t meeting consumer needs or allowing the pack to work as the powerful sales aid it should be.”
Having passed on a dossier of information to the government in time for next month’s debate in Brussels, the FSA says it’s now up to UK ministers to present the industry’s concerns.
The outcome of the EU debate on food labelling will not be known until the new year. For now, labelling will continue to test the creative skills of designers –and the reading skills of consumers.
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