FOOD LABELLING ISSUES:
A Qualitative consumer study related to food-type dietary supplement labelling
July 2003
Evaluation report Series No. 6
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1 Executive Summary
2 Background and objectives
3 Methodology
4 Study Limitations and notes
5 General food-type dietary supplements
6 Prescribed term for FTDS
7 Nutrition content claims and nutritional information
8 Non-culinary herbs
9 Concluding comments about consumer education and further research
Appendix A
Appendix B
Appendix C
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A Qualitative consumer study related to food-type dietary supplement labelling
1 Executive summary
This study was conducted to gain qualitative information from consumers to assist Food Standards Australia New Zealand (FSANZ) in the future development and review of food labelling standards, codes of practice and guidelines. In particular, FSANZ has a need for information to assist in determining:
- the most appropriate criteria and conditions for making specific nutrition content claims, whilst ensuring consistency between Australia and New Zealand; and
- the possible labelling requirements for food-type dietary supplements (FTDS) from a consumer perspective.
Two concurrent studies were commissioned from NFO Donovan Research that address each of these objectives. This report deals with the findings of the second study, and explored consumer awareness, familiarity, understanding and use of FTDS. The study was also intended to assess the adequacy and credibility of information provided on the label of FTDS in relation to composition and manufacturers’ claims. Lastly, the study examined the feasibility and usefulness of additional labelling information including trigger statements in assisting product selection.
The research was conducted with consumers in Australia and New Zealand, via ten focus group discussions. Participants were selected on the basis of their level of health consciousness, in terms of their food buying, as well as demographic and geographic characteristics.
The results show that participants in this study are almost exclusively influenced by nutrition content claims rather than the current prescribed term ‘dietary supplement’, and whilst they are familiar with the concept of food supplementation, they are unable to distinguish supplemented foods that are denoted by nutrition content claims, and foods that are classified as FTDS, carry nutrition content claims and display the term ‘dietary supplement’ on the label. FTDS were viewed as one of many types of ‘boosted’ products. As a result of their low awareness and use of FTDS, most participants did not have strongly held views about them.
Overall, participants’ perceptions of FTDS and supplemented foods that are not FTDS (but carry nutrition content claims) were equally spread across positive, neutral and negative opinions. There were very few concerns about over-consumption of supplements such as vitamins and minerals, and foods that contained supplements were generally viewed as 'safe’. Many participants however were more interested in, and in some cases concerned about, distinguishing between foods that intrinsically contain particular nutrients and substances that are referred to in a nutrition content claim, and those that have been ‘added’ or supplemented during the manufacturing process. These participants wanted the label to make this distinction.
As an extension of their lack of concern about FTDS, including the supplementation of non-culinary herbs, the majority of were very open to the supplementation of foods in all processed food categories. The only restrictions, they felt, should be placed on fresh foods, such as fruit and vegetables, meat, poultry, eggs and water, and processed foods directly marketed to or for children.
Whilst the majority of participants in this study did not deliberately purchase supplemented foods, achieving real or perceived health benefits motivated those who did. These included addressing vitamin or mineral deficiencies, improving immunity and preventing illness, reassurance and relief from the guilt of a poor diet, and for extra energy. No participant had deliberately purchased a FTDS because of the prescribed term ‘dietary supplement’.
Generally FTDS were not perceived to be as effective a way of supplementing one’s diet, compared to therapeutic-type dietary supplements such as pills and capsules. Pills were viewed by most, but not all, as preferable because they are more concentrated and therefore work better, available in a controlled dose, and are easier and more convenient.
The term ’dietary supplement’, which is currently required on the label of FTDS has little, if any impact on consumers’ awareness or understanding of these foods, owing to:
- the way in which the prescribed term is displayed by manufacturers, at least on the products used in this research, which, although legible, is given low prominence and renders it “virtually invisible”; and
- a lack of information and education with regards to its meaning.
Participants described the prescribed term using a mixture of positive and negative terms, with reactions amongst New Zealand participants being more negative than those in Australia. There was general confusion regarding whether the intent behind the term was to caution consumers, or to market the product. In the end, and without information or education, there is no evidence that the current term influences consumers to use these products, if anything it is slightly dissuading.
Consumers do however want packaged food products to be clearly labelled with regards to supplements, and have a preference for more exact, and preferably quantified, claims or statements. Quantified claims, including comparative percentages or exact amounts, were favoured over other suggested alternatives for a FTDS prescribed term, including ‘food-type dietary supplement’ and ‘nutritional supplement’. The latter was seen as a highly positive statement, compared to ‘dietary supplement’, which made the product appear much more desirable.
Although this study did not focus on nutrition content claims, discussion about these was unavoidable given participants’ lack of distinction between foods with nutrition content claims and FTDS with both nutrition content claims and the prescribed term. Nutrition content claims were mostly viewed as a marketing ploy used by manufacturers to persuade a consumer to buy a product. They were treated with scepticism, but not deemed to be untruthful. Rather they were regarded as telling just one part of the story about a product’s nutritional value, and are verified by many consumers using the Nutrition Information Panel (NIP). There was no perception, based on these findings, that nutrition content claims transform a product to being automatically ‘healthy’, however some participants acknowledged that the claim may elevate its perceived healthiness – that is the product is perceived to be ‘healthier’ but not necessarily ‘healthy’.
Understanding and reactions to ‘source of’ claims (‘source of’, ‘good source of’ and a potential new claim ‘excellent source of’) were explored. Most participants concluded that all three terms were relative, that is ‘good source of’ inferred larger amounts of the source nutrient than ‘source of’. However there was no awareness that these terms have a regulated definition based on the % Recommended Dietary Intake (RDI) that they contribute (note that not all source claims are defined by RDI eg dietary fibre). All three terms were considered to be highly subjective, and most participants in this study expressed a high level of scepticism about what they implied, regarding them mostly as purely marketing.
Reactions to three potential labelling elements were explored:
1. A trigger statement which directs consumers to the NIP;
2. A statement cautioning consumers against regarding FTDS as ‘magic bullets’ – ‘this product should be consumed in the context of a healthy, balanced diet’ and
3. An additional column in the NIP - % Daily Intake.
None of these elements were particularly well received or supported. Most participants felt that there was no need for such statements, and that in the case of supplements it was up to the consumer to evaluate whether the product was suitable for them. Most felt capable of doing this using the NIP. There was least support for the cautionary statement (2) because it was generally viewed as either obvious, condescending, or meaningless.
Familiarity with food products supplemented with non-culinary herbs was much lower than vitamin and mineral FTDS, and the number of participants who reported using these foods was also very low. Perceptions about adding herbs to foods were either positive or neutral; there were no strong objections or concerns. Compared to vitamin and mineral FTDS, there was much less interest in quantified claims and most felt that content claims such as ‘contains…’ were sufficient.
Throughout the conduct of this research there emerged a need to inform consumers about labels and label information, and an increasingly obvious need for consumer education on how to use and interpret labels. Consumers’ current level of information and understanding about supplementation and nutritional information is such that the pre-condition for informed choice, that underpins the rationale for many labelling requirements, is not being met. Adding further information on food labels to reflect the addition of nutrients or herbal components of foods will not be meaningful to consumers unless they are also educated about the meaning behind that information, and how to use it.
2 Background and objectives
2 .1 Background to the research
Food Standards Australia New Zealand (FSANZ) is an independent bi-national organisation that has the role, in collaboration with other organisations, to protect the health and safety of the people in Australia and New Zealand through the maintenance of a safe food supply. FSANZ was responsible for developing the Joint Australia New Zealand Food Standards Code (the Code), a component of which contains food labelling requirements for manufacturers, in order for consumers to make informed decisions about food products that are available. The Code came into effect in December 2002.
Prior to the introduction of the Code, FSANZ commissioned NFO Donovan Research to conduct a large qualitative and quantitative research project to investigate and quantify consumer awareness, knowledge and understanding of permitted food labelling elements [1] .
As part of FSANZ’s responsibility to develop and review food standards, codes of practice and guidelines, FSANZ also has a need for information to assist in determining:
Given the recent emergence of FTDS onto the market over the last few years, there is little literature available in relation to labelling and consumer behaviour to inform FSANZ decision-making. As such FSANZ engaged NFO Donovan Research to conduct qualitative research to examine consumers’ awareness, understanding and use of FTDS. The study was also intended to assess the adequacy and credibility of information provided on the label of FTDS in relation to composition and manufacturers’ claims. Lastly, the study examined the feasibility and usefulness of additional information including trigger statements and disclaimers in assisting product selection.
2.2 Issues of interest about food-type dietary supplements [2]
FTDS represent a growing sector of the global food market. They present a number of regulatory complexities as New Zealand and Australia have different systems in place to regulate these foods. At present, the Code does not contain provisions for foods that are positioned as FTDS. As a result FTDS cannot be produced, or imported into, and sold in Australia. Many such products however are currently eligible to be manufactured in, or imported into New Zealand under the New Zealand Dietary Supplement Regulations 1985 (NZDSR). By virtue of the Trans-Tasman Mutual Recognition Arrangement (TTMRA) these products can be exported from New Zealand to Australia.
At present there is no definition for FTDS in the Code. The NZDSR define ‘dietary supplement’ as ‘any amino acids, edible substances, foodstuffs, herbs, minerals, synthetic nutrients, and vitamins sold singly or in mixtures in controlled dosage forms as cachets, capsules, liquids, lozenges, pastilles, powders, or tables, which are intended to supplement the intake of those substances normally derived from food’. There are a number of definitions for FTDS from both domestic and international sources but not one that is generally accepted. Definitions are important however, as they segregate and identify various types of foods.
FTDS differ from conventional foods in that they are supplemented with nutritive substances such as vitamins and minerals (in amounts higher than those currently permitted in the Code) and non-culinary herbs. The NZDSR require FTDS to be labelled as ‘dietary supplement’. Although the purpose of this term is not explicitly stated it is used by enforcement agencies and/or possibly consumers to identify these products. Concerns have been raised in response to FSANZ’s Proposal P235 Review of Food-Type Dietary Supplements (P235) Initial Assessment Report that consumers may infer from the classification of FTDS (as ‘dietary supplements’) that these products have enhanced health properties and/or benefits, compared with general purpose foods which may contain vitamins and minerals in smaller amounts. This study investigates this issue. It also explores consumers’ responses to the notion of FTDS being extended to more conventional type (staple) foods such as milk, breads, cereals etc because concerns were expressed by public health professionals in response to P235 that the use of FTDS in any foodstuff may conflict with general healthy eating advice including national dietary guidelines.
Vitamins and minerals were identified by FSANZ as a topic of particular focus for this research. Generally, vitamins and minerals are the most common supplemented ingredients of FTDS. They are usually added in amounts that represent moderate to high proportions of the recommended dietary intake (RDI). It is unclear as to whether consumers are cognisant of any potential adverse reactions associated with the consumption of excess amounts of certain vitamins and minerals such as Vitamin A. In addition, some concerns have been raised by health professionals in response to P235 in relation to consumers adopting a ‘more is better’ approach in making FTDS choices.
Non-culinary herbs were also identified by FSANZ as a topic of particular focus for this research. FSANZ is aware of the proliferation of FTDS containing non-culinary herbs such as echinacea and ginseng available in the market place. There is also increased consumer interest in seeking ‘natural’ remedies. There was a divergence of views among stakeholders with respect to the use of non-culinary herbs in FTDS in response to P235. In particular, a number of submitters raised concerns about inappropriate usage, insufficient safety data and lack of efficacy.
A key feature of FTDS is nutrition content claims. FSANZ is therefore interested in consumer reactions to and understanding of ‘source of’ claims, including the currently allowed terms ‘source of’ and ‘good source of’, as well as a potential new term ‘excellent source of’.
In an effort to minimise consumer confusion in relation to nutrition messages about diet and health, FSANZ is also seeking information to assess the feasibility of additional labelling elements on the label of FTDS to assist consumers in making informed food choices. Therefore the study examined consumer reactions to three potential additional labelling elements, which are detailed in Section 7.3
2.3 Research Objectives
The overall objective of the research project was to explore how consumers perceive and use FTDS labels when purchasing food products.
The specific objectives for the FTDS research activity are listed below:
- How FTDS are described and whether consumers can distinguish between food- and therapeutic-type dietary supplements by the way in which they are presented and labelled;
- Whether consumers can distinguish between FTDS and similar ‘regular’ counterpart foods;
- The use by consumers of compositional and nutritional information on labels and how they relate this information to FTDS labels;
- Whether consumers use the claims made on FTDS (currently available in the marketplace) in choosing products ; and
- Whether other information that may appear in the labelling of these products eg. advisory statements assists consumers in making informed choices.
This study was conducted at the same time as a qualitative investigation of nutrition content claims, the results of which are reported under separate cover [3]
[1] Food Labelling Issues: Quantitative Research with Consumers. FSANZ Evaluation Report Series No 4
[2] The term ‘dietary supplement’ is currently prescribed under the New Zealand Dietary Supplements Regulations 1985 (part 1, general requirements, clause 5
[3] A Qualitative Consumer Study Related to Nutrition Content Claims on Food Labels. A Report to FSANZ, 2003
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