Deborah Chen | Is evidence being ignored in front-of-package labelling

On behalf of the academic and non-governmental organisations (The Heart Foundation of Jamaica, Diabetes Association of Jamaica), members of the National Mirror Committee (NMC), we are very concerned about recent developments in relation to Final Draft CARICOM Regional Standard for the labelling of pre-packaged foods.

We write in relation to two articles published in The Gleaner on June 11 titled ‘Label resistance’ and ‘Front-of-package warning labels – CARICOM can either follow science or protect private interests’. We wish to note the anomalies in voting procedures and lack of evidence-based decision-making.

For the past three years, Jamaica and the rest of the Caribbean have been in discussions to update the standard. Each country is now required to vote on the final draft of the standard which includes a black, octagonal front-of-package (FOP) warning label to be placed on food packages. The FOP will indicate to consumers when a product is ‘high in’ sodium (salt), fat and sugar. It is a primary tool for educating consumers of the diet-related risks linked to non-communicable diseases (NCDs). In Jamaica, that vote is determined by the NMC, which comprises various stakeholder groups. This process is facilitated through the Bureau of Standards Jamaica (BSJ).

As stated in The Gleaner article, a vote was held on March 30, 2021, to meet the stipulated deadline of March 31, 2021. The outcome was a majority vote in support of the standard. Subsequently, stakeholders were called to an emergency meeting on June 4, 2021, to discuss a finalised position on the standard. However, in an uncharacteristic turn of events, a re-vote was facilitated which enabled some stakeholders to change their vote. The previous national position was therefore seemingly changed to reflect a rejection of the standard.

We are not aware of any procedural allowance for a ‘confirmation’ of vote or a ‘re-vote’, so this seems highly unusual. We therefore request transparency in the events leading up to and during the meeting.

AT A DISADVANTAGE

Jamaican consumers are already at a disadvantage without mandatory, easy-to-understand nutrition labels. Overwhelmingly, the scientific evidence is in favour of the proposed ‘high in’ FOP labels; showing it safeguards and supports public health, and helps Jamaican consumers identify healthier products. This evidence must take precedence over private-sector interests.

Existing evidence refutes the arguments that including multiple options for FOP labels is in the best health and economic interests of consumers. It has been proven several times over in the literature that utilising multiple FOP labelling systems only serves to confuse consumers. Moreover, findings from a recent study in Chile (2021) indicate that these regulations have not influenced the long-term patterns of employment or wages in the food and beverage sector one and a half years after implementation.

Best practice dictates that the standards development process must be evidence-based, and data-driven policies must be implemented. Existing science provides no justifiable reason for opposing the black octagon high in’ FOP label. This FOP label outperforms all other FOP labels that were considered. The industry-endorsed Guideline Daily Amounts (GDA) is not effective and generally regarded as unhelpful and confusing for consumers.

In fact, a recent randomised control trial conducted by the Ministry of Health and Wellness of Jamaica, the University of Technology, and the Pan American Health Organization demonstrated that, when compared to other front of package labelling systems, the black, octagonal warning label performed best in allowing Jamaican consumers to correctly identify healthier products versus those high in sugar, salt, or saturated fat. This study adds to robust scientific evidence accumulated in other countries of the Americas, which concluded that the black, octagonal FOP is the most informative and effective in helping consumers make healthier choices.

Additional recent evidence include:

• In Chile, children were able to identify products by seeing these labels.

• Mandatory FOP labels on sugar-sweetened beverages in the United States would reduce obesity prevalence by 3.1 per cent in five years.

• A modelling study from Mexico showed that FOP warning labels could prevent 1.3 million cases of obesity (a 14.7 per cent reduction in prevalence) and save US$1.8 billion ($1.1 billion in healthcare costs and $742 million in indirect costs).

EVIDENCE-BASED DECISIONS

In the June 11 article, Andrés Constantin wrote, “the private sector has also already had the opportunity to weigh in on FOPWL (front-of- package warning labels). When CROSQ (CARICOM Regional Organization for Standards and Quality) first began considering the matter in 2018, the revision of the 2010 Regional Standard for Labelling of Pre-Packaged Foods underwent several rounds of consultations, including with the private sector.” For policy development, decisions must be evidence-based, using objective information. The evidence substantiating the benefit of the ‘high in’ FOP labelling system was shared freely, and various stakeholders reinforced this need to add credibility to the standard. To clarify, all parties to the NMC had the opportunity to provide input and review the process. The proposed change to the national position that objects to the standard in its current form therefore implies a rejection of the overwhelming evidence in support of protecting the nation’s health.

As stated by Constantin, “To be clear, the private sector can have a seat at the table. But having a seat doesn’t mean licence to manipulate research and distort scientific evidence. Instead, any serious private-sector attempt to meaningfully participate in the FOPWL process should begin by abiding by established international standards, particularly those relating to scientific evidence in policymaking.”

Jamaica and the rest of the Caribbean continue to struggle with the overwhelming health, social and economic burdens of overweight/obesity and NCDs. These diet-related NCDs cause almost 80 per cent of deaths in Jamaica annually. COVID-19 deaths are higher among persons with NCDs. For this, we continue to support the ‘high in’ model using the black octagon and reiterate that an effective, evidence-based FOP label system must be adopted in Jamaica as part of a multifaceted approach to addressing NCDs and obesity in the region.

With the COVID-19 pandemic at the forefront of the country’s public health agenda, urgent action to protect consumers and secure healthier food environments must be prioritised. As this was initiated and put forward by governments across the CARICOM region, it is important at this point for the Jamaican Government to provide clarification on the national position in relation to front-of-package warning labels and its benefit to public health. A productive population must be a healthy population. We must put the health of Jamaicans first.

Deborah Chen is the executive director of The Heart Foundation of Jamaica. Send feedback to jctc@heartfoundationja.org.