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 From Hong Kong's Information Services Department
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December 18, 2003
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Food labelling beneficial to health
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I believe we all subscribe to the view that nutrition information is extremely valuable and important to the consuming public for they may choose to obtain their daily food products wisely and in a way that would not be detrimental to their health and would promote their future healthy development. It is also clear to me that most members would also agree that a system of nutrition information labelling would also enable us to deal with misleading nutrient-related claims effectively in order to protect public health.

 

Nutrient refers to any substance normally consumed as a constituent of food which provides energy or is needed for growth and development and the maintenance of healthy life, or a deficit of which will cause characteristic bio-chemical or physiological changes. While undernutrition is not a major public health problem in Hong Kong nowadays, chronic degenerative diseases such as coronary heart disease, diabetes and certain types of cancer are major public health problems. Although the causes of these diseases are often multifactorial, an imbalanced diet is one of the important causes. In fact, the World Health Organisation reported that dietary factors are estimated to account for approximately 30 per cent of cancers in industrialised countries. These diet-related diseases are important public health problems in many parts of the world including Hong Kong.

 

Food labels are an important communication channel whereby consumers can obtain specific information on individual food products, thus providing nutrition information on food labels is an important public health tool to promote a balanced diet. A balanced diet can also help lower the risk of those diet-related diseases.

 

A positive impact

Overseas experiences have shown that nutrition labelling can have a positive impact on food consumption patterns, save healthcare costs and human lives. For example, in the US, the cost-benefit study of a nutrition labelling scheme commissioned by the Food & Drug Administration estimated that if consumers changed their consumption practices as a result of nutrition labelling, the benefits associated with the reduction in risk of cancer and coronary heart disease ranged from US$4.4 billion to US$26 billion over a period of twenty years. Similarly, Agriculture & Agri-Food Canada and Health Canada calculated that the reductions in the direct and indirect costs associated with cancer, diabetes, coronary heart disease and stroke would be about CAD$5 billion in Canada over the next twenty years. In Australia and New Zealand, it is estimated that 320 to 460 lives could be saved each year with the introduction of mandatory nutrition labelling due to reduced risk in diet-related diseases.

 

In recent years, there is clearly a global movement towards the labelling of nutrition information. Various places have developed their labelling scheme on nutrition information based on the principles and recommendations of the Codex Alimentarius Commission (Codex). The European Union and Singapore have adopted the approach that nutrition labelling is voluntary unless with nutrient-related claims. On the other hand, the US, Canada, Australia, New Zealand, Japan and Malaysia have taken the approach to require mandatory nutrition labelling. We understand that countries currently adopting the voluntary approach including countries of the European Union are taking active steps to move towards a mandatory nutrition labelling regime.

 

Increasing demand for nutrition data

In 2002, we completed a feasibility study on nutrition labelling. In the course of conducting the feasibility study, we reviewed the local situation and international practices on nutrition information on food labels. We have also kept a close watch on new developments in food manufacturing methods and sales patterns. We note that there is an increasing demand for information about nutrients containing in food intended for human consumption so that consumers can make important choices that may have a bearing on their health conditions.

 

Although many pre-packaged foods sold in Hong Kong carry nutrition labels, there is no uniformity in the way that nutrient information is presented on food labels. This is because the existing legislation in Hong Kong does not impose any specific requirements on nutrition labelling, and there is no legal definition on nutrient or standard such as 'high' or 'low' of a particular nutrient. Hence, consumers may find the nutrition information provided on the food labels variable, difficult to comprehend, and sometimes misleading.

 

As part of the Government's ongoing efforts to protect and enhance public health, we believe that the time is now right for us to introduce a nutrition labelling scheme in Hong Kong with the aim of (1) facilitating consumers to make healthy food choices; (2) encouraging food manufacturers to apply sound nutrition principles in the formulation of foods which would benefit public health; and (3) regulating misleading or deceptive labels and claims on nutrients. It is for this reason that we have recently issued a public consultation document setting out our proposals on the detail components of the labelling scheme on nutrition information for pre-packaged food products sold in Hong Kong.

 

A phased introduction

In our consultation document, we propose to implement a mandatory nutrition labelling for pre-packaged food products by phases through legislative amendments to the regulations made under the Public Health and Municipal Services Ordinance (Cap 132). In Phase I, nutrition labelling is required for pre-packaged food products with nutrient-related claims only. Pre-packaged food products without nutrient-related claims may provide nutrition labelling on a voluntary basis in accordance with the specified requirements.

 

In Phase II, nutrition labelling will be required on all pre-packaged food products sold in Hong Kong, except for those pre-packaged food products exempted from the requirements. Examples of exempted items include: food packed in a container of which the aggregated surface area is less than 100 square centimetres; fresh fruits and vegetables; and food sold at a catering establishment for immediate consumption. We also propose to establish a set of local Nutrient Reference Values (NRVs) for nutrition labelling purposes by making reference to those recommended by Codex and other countries.

 

Although many nutrients are important for individual health, it is considered that nutrients of public health significance should be identified and recommended for listing on the nutrition label. We recommend the mandatory listing of 10 parameters on the nutrition label of pre-packaged food. These 10 parameters are "energy" plus "nine core nutrients". The nine core nutrients are protein, carbohydrate, total fat, saturated fat, cholesterol, sugars, dietary fibre, sodium and calcium.

 

The core nutrients for labelling have been selected having regard to the public health significance of these nutrients, and after having reviewed the ten leading causes of deaths and leading morbidities in Hong Kong. In drawing up the list, reference was also made to the Codex Guidelines, information from other nutrition labelling programmes worldwide and the findings from a local market survey.

 

Nutrient declaration

In our proposals for nutrients for which a claim is made, we have also taken reference to the Codex Guidelines which required declaration of the amount of nutrients for which a claim is made. Furthermore, where a claim is made regarding the amount of and/or the type of carbohydrate, the amount of total sugars should be listed. The amounts of starch and/or other carbohydrate constituent(s) may also be listed. Similarly, where a claim is made regarding the amount of and/or the type of fat or the amount of cholesterol, the amounts of saturated fat, monounsaturated fat and polyunsaturated fat and cholesterol should be declared. The Guidelines also required nutrients to be expressed in absolute amount in metric unit, per 100 g (or per 100 ml) of food. If the package contains only a single portion, nutrients may be expressed in absolute amount in metric unit per package.

 

We have also taken reference to the Codex Guidelines for the use of nutritional claims in 1997. These guidelines laid down the appropriate criteria for making nutrient content claim, nutrient comparative claim and nutrient functional claim. In essence, nutrient content claim should only be made when a specified maximum or minimum level of a particular nutrient is present. Nutrient comparative claim should only be made when the reference to is clearly identified and a specified amount of difference in the amount of that particular nutrient is present between the comparison foods. Nutrient functional claim should only be based on scientific substantiation. I should not talk about the details proposed in the document but refer members to the consultation document.

 

2-year grace period proposed

To allow sufficient time for the trade to prepare for the changes, including re-packaging, and taking into account the wide variety of foods that will be affected and the shelf-lives of a large variety of pre-packaged food products, we propose that a two-year grace period would be allowed before implementing Phase I of the proposed labelling scheme; and that Phase II (mandatory nutrition labelling) would be implemented three years after the implementation of Phase I. A two-year grace period is considered necessary in Phase I as a large number of food products will be covered by the proposed labelling scheme, and it will take some time for the trade to replace their products with labels not meeting the new requirements that are already in the market. A grace period is also necessary for Phase II as the number of food products affected will increase markedly from Phase I to Phase II, of which some of them are products of small manufacturers and traders, and many of these products do not have readily available nutrition information.

 

Many members have spoken about the implementation timetable of our proposal. We will certainly consider the views expressed very carefully and discuss with the trade to see if there are likely to be any insurmountable difficulties. What is important is that we seek to strike a right balance between the consumers' interests and the trade's ability to comply with the new regulatory regime and strive for what is achievable and practicable without sacrificing the overall interest of the community.

 

I would also like to briefly explain why foods for infants and young children and other foods for special dietary uses are not included in the proposed nutrition labelling scheme. In considering and determining the scope and requirements of our proposed nutrition labelling scheme, we have taken into account local public health concern of the general population and the Codex Guidelines on nutrition labelling which are not applicable to these foods. The reason is that these foods are targeted at subgroups of the population with special dietary needs which are very different from that of the general population. It is also international practice that their labelling requirements are dealt with by separate sets of guidelines and standards. We will consider the need to introduce nutrition labelling requirements covering these products at a later stage.

 

Public feedback welcome

I am very grateful for the views expressed by members today. Our existing regulatory system, plus the proposed additional measures set out above to regulate nutrition information on food labels should meet many of Members' concerns. We invite the public and the trade to comment on our proposal so that it can meet the public health needs of our community. The public consultation period will end on 31 January 2004.

 

We will consider carefully the views from the members of the public and the trade in response to our consultation exercise before we make a firm decision on the way forward. We will also conduct a Regulatory Impact Assessment to evaluate the overall costs and benefits, including the potential benefits of lowering the overall health costs to the whole community. Whilst we are mindful of the cost implications to the food industry, it must always be remembered that our responsibility to protect public health is of paramount importance.

 

(This was Secretary for Health, Welfare & Food Dr Yeung Eng-kiong's speech to Legislative Council members on December 17, on the Government's food labelling proposals.)

Secretary for Health, Welfare & Food Dr Yeung Eng-kiong