A Qualitative consumer study related to food-type dietary supplement labelling

DETAILED FINDINGS - Part A

5  General and food-type dietary supplements  |  6  Prescribed term for ftds

5.1   Familiarity with food supplementation

All participants were aware that some foods are (increasingly) supplemented with nutrients and nutritive substances, and their awareness and knowledge is derived mainly from noticing nutrition content claims on products, as well as supportive product marketing and advertising. However there was little awareness of or familiarity with the prescribed term ‘dietary supplement’.

Many participants were confused as to whether nutrition content claims meant that the nutrient had been added to the product, or whether the food intrinsically contained that level of the nutrient, as it always had done. Participants were mostly unsure as to whether a vitamin or mineral nutrition content claim referred to a ‘new’ version of a product, or if it was a new way of labelling the same product.

Their decisions about this issue appeared to be largely guesses, based on subjective factors such as the format and wording of the nutrition content claim.   For example ‘high in iron’ was often regarded by participants as ‘new’ labelling used by the manufacturer to sell the product, which has always been high in iron. In contrast they believed that nutrition content claims like ‘with 8 vitamins’ or ‘mega vitamins’, particularly on new products, suggested that the vitamins had been added to the product.  

There was also recognition amongst many participants that there might be other products without such claims that contained similar or greater amounts of the claimed nutrient. Their view in these cases was that manufacturers of these products had simply failed to capitalise on consumers’ potential interest in health. Using claims about nutrients was viewed as a method of marketing made more appealing by an increasing focus on health and nutrition in society.

5.2   Perceptions about FTDS and how they differ from general foods

Participants viewed all food and beverage products with ‘added’ nutrients or nutritive substances as being part of the same category of ‘boosted’ (enhanced) products. Given the lack of understanding in relation to FTDS, it was extremely difficult to separate their views and attitudes about products that have been supplemented with smaller amounts of vitamins, minerals and herbs from those that would be classified as FTDS.   

Even when participants were probed by the moderator for their reactions to the supplementation of products with very high or extreme amounts of nutritive substances, their responses really reflected their broader views about supplementation in general. This is because they had no baseline or reference point to draw from with regards to ‘regular’ counterpart foods compared to those foods technically defined as FTDS.

Positive, neutral and negative perceptions

Across all groups, participants differed in their view about the supplementation of foods and beverages. Views were evenly spread and ranged from positive, to neutral to negative; however, very few held extremely positive or negative opinions.   Illustrative comments below are drawn mainly from New Zealand groups (the majority of groups were conducted in New Zealand), but are equally as representative as views expressed in the Australian groups.

Those who felt positively about food supplementation, included those who could see benefits either for themselves or for others, particularly mothers of children whose diets might be lacking in some vitamins or minerals.

These positive views were rarely held strongly . There were very few food supplementation advocates; rather these were the people who could generally see no harm in adding vitamins and minerals to foods, and assumed that there would have to be some benefit.  

“I think people are becoming more aware that it is difficult to get the balanced nutrition you need from one meal, so…we can snack on these things during the day and help to boost our intake.”  [Aust., lower SES, health conscious, 24-44yrs]

“yes, I think it’s a really good idea to get extra stuff like this into food because most people today don’t eat properly.   They know they should, but in my experience even in my diet I still don’t eat right”  [NZ, lower SES, health conscious, 45-64 yrs]

“I think the added vitamins in products are really great, especially folate and calcium because it’s something that’s really needed in diets, especially women…Because if you look at the average teenager it’s really disgusting. But if you can sneak these foods in to the foods that they eat, that they choose to eat rather than the meat and fruit and vegetables that they steer away from, they are at least going to get something”[NZ, lower SES, health conscious, 45-64yrs]

Those participants with positive views believed that supplemented foods must be ‘healthier’ than the ‘regular’ counterpart, but this did not necessarily mean the product automatically became a healthy choice. Rather, including these foods in one’s diet was seen as doing something ‘extra’ to improve your diet, and often relieved the guilt of a poor diet, or a ‘bad week’. In this regard, FTDS are regarded as a positive way to address a negative situation.

“If they were the same price then I would tend to go for the one with the extras because my diet is very bad anyway and I would say that might just make up a tiny bit for the other things that I eat so it would make a difference.”  [NZ, upper SES, less concerned about health, 45-44yrs].

“I eat really bad food and I think if I could get juice with a bit of extra this or that I’ll go for it because then I don’t feel so bad about the other food I eat” [NZ, upper SES, less concerned about health, 25-44yrs]

Those with neutral views were either not interested in food supplementation, or didn’t have enough knowledge about vitamins and minerals in order to offer an opinion.

“Also it’s like added vitamins compared to what?   It’s like, you don’t know how many were in there to start with so it could have the same amount as another brand.   It really doesn’t matter.”  [NZ, upper SES, special health needs, 18-24yrs]

Many of the participants who fell into this group were either more focused on other nutritional issues, such as monitoring the fat and sugar content of foods, or were unconcerned about the nutritional composition of their diet. For these people, vitamin and mineral content claims made little difference to whether they bought the product, and in many cases the claim would go unnoticed.

“I think there would probably be people out there that wouldn’t even know what that means they would just look at it and think ‘oh wow, that is good’ or some people would go ‘okay I don’t really know what it means it must be bad for me or something’.   They don’t know, it’s not their priority”.  [NZ, lower SES, health conscious, 18-24yrs]

“Well maybe if your diet’s lacking in those things then it’s useful but otherwise it’s not” [NZ, upper SES, special health needs, 18-24yrs]

Negative perceptions included expectations that the product would not taste as good, that it would cost more, that the food had been altered in an undesirable way, or that people could have too much of some substances without realising it.  

“…I think of lack of taste, lack of taste and something’s been added to it that I don’t know much about and I don’t really want to try my luck with that” [NZ, Upper SES, less concerned about health, 25-44yrs]

Participants’ degree of concern ranged from mild concern or frustration over the difficulty in finding the ‘plain’ packet or ‘unchanged’ product, to real paranoia about product tampering.

“are we going to have any products that are going to be left, even milk worries me, is milk real any more? What is not in it it has been boiled and skimmed.”  [NZ, upper SES, special health needs, 45-44yrs ]

Extremely negative participants (which were the exception) had a preference for what they referred to as the ‘untouched’ products, illustrated differently during the following discussion:

Moderator:  “why would you avoid the one with the added extras?”

Participant:   “because someone’s played with my food”   [NZ, upper SES, less concerned about health, 25-44yrs]

Lack of concern about over-consumption

The most widely held view was that one could not overdose on vitamins (a category term many participants used to include minerals as most made no clear distinction between the two). Others who were unsure on this issue quickly accepted this opinion without question when a more opinionated participant in their group expressed it.

The most common belief was that vitamins were water soluble, and thus would be ‘flushed out’ by the body if too much was consumed. Therefore the dominant opinion was that one could not consume too much vitamins and minerals. Whilst now and then a doubtful participant countered this view with their suspicion that the body stored some vitamins and minerals, the group was never able to resolve this issue or reach agreement. Most were not able to speculate with certainty one way or the other, and there was a general lack of awareness of the distinction between fat soluble and water soluble vitamins.

One or two participants in most groups had heard of certain effects of overdosing on particular nutrients, such as your body turning orange, or zinc and iron adversely reacting with medications. There was no accurate awareness or knowledge as to how these adverse effects were linked to specific vitamins or minerals. A small number were aware of the dangers of excessive levels of vitamin A during pregnancy.

However, in two of the groups there was a participant who gave more consideration to this issue and who then began to raise concern towards the end of the discussion about potential cumulative consumption through the day or week across a range of supplemented products. Although this view was an exception to the majority, it is illustrated below:

“I think this whole development is a concern, bread in the morning – added extras, milk, added extras, cereal – added extras, we have just talked about the morning.   We have had our daily allowance and we have taken our tablets because we are trying to look after ourselves and how risky is it that every single thing out there is selling it as the great thing to have extra and because you have got all these things with added extras you don’t know where you are going overboard.”  [NZ, upper SES, special health needs, 25-44yrs]]

5 .3   Suitable food categories for FTDS

The supplementation of foods in the general food supply was widely accepted. The majority of participants held no objection to the ‘adding’ of nutritive substances, such as vitamins and minerals to almost all food categories. A strong exception to this view was held by one or two participants in most groups, who found the proliferation of products with nutrition content claims frustrating or confusing. These participants felt that shopping was now more time consuming than ever before, because they had to sort through all the various product versions to either find the version they preferred, or the one that had not been altered at all. A small number of mainly older participants (44+yrs) felt frustrated by the fact that it was becoming increasingly difficult to find the ‘plain’ or ‘original’ version of their tried and trusted brands or products.

Over all of the groups there were no strong views either way about the increasing availability of FTDS. The researchers conclude, based on how participants responded to this line of inquiry, that they were unable to offer a strong view because they did not know the implications, if any, of including greater amounts of the nutritive substances in question.

Most participants held no objection to the offer of supplemented foods, including FTDS, in processed food categories. The one main exception, mentioned in almost all groups and supported by the majority in each of those groups, was foods marketed to teenagers and children.  

On this issue, the distinction was made between foods for children, but purchased by parents, and those purchased by children and teens themselves.   The concern was that children and teenagers were not likely to read or correctly interpret label information, and could therefore be unfairly persuaded to buy these foods.  

“For all of us, who are experienced shoppers, we know that if we want to find out about something we have to read the label, but for a teenager who has just left home and has a full time job and part time study and she’s got an hour a week to do her grocery shopping and that’s it, there is no time to sit and read the label.   And those sort of people are also going to go for the easy, the frozen dinners and that are easy to prepare.”  [Aust., upper SES, special health needs, 45-64yrs]

Of most concern were children’s foods that were eaten frequently, or in large amounts, such as children’s snack foods, where a few participants perceived that there could be a risk of overdosing on a supplemented substance.  

There was also consistent agreement, particularly in the New Zealand groups, that fresh foods should be excluded from supplementation. This included fruits and vegetables, meat and poultry, eggs and water. Consumer’s reasoning for this view was two fold: because these foods were generally un-packaged and therefore unlabelled, and because they were considered ‘natural’ foods that should (always) remain unaltered.

An isolated opinion was that supplementation should be restricted or prevented in foods that are normally consumed with other foods that inhibit their absorption, as the supplemented substance would be rendered ineffective. The example that this participant was referring to related to the interaction of Vitamin C and tea.

Another isolated concern, expressed by only a couple of participants, was that supplementation should not be allowed in ‘unhealthy’ foods, such as adding iron or calcium to chocolate breakfast cereal. Their concern was that some consumers might be misled into buying the product under the misconception that the supplementation of, in this example iron, gave that product ‘healthy’ qualities that now rendered it a ‘good’ food choice. Concern about this impact was not widespread amongst participants in this study, mainly because most felt that you would have to be ‘stupid’ to be misled in this way by such nutrition content claims. Most interested enough to raise this concern felt capable of seeing through the claim, and using the NIP to verify the overall nutritional value of the food themselves. Nonetheless, there was a low level of concern that ‘less educated’ ‘other’ consumers may not reach the same conclusion. This assessment was also expressed in the groups recruited as ‘low SES/education’ participants in this study.

The only other caveat to supporting the widespread offer of supplemented foods was if a FTDS could be harmful in some way, about which participants were unsure, in which case many felt that it should be labelled with a suitable warning or advisory statement

5.4   Use of Food-Type Dietary Supplements

Less than a dozen participants across all of the New Zealand groups, and only one in Australia, recalled having purchased any of the FTDS used as examples in the group discussion. In each of these cases, the product had been selected with disregard to the term ‘dietary supplement’, and sometimes also without having noticed the vitamin, mineral, or non-culinary herb content claim. Similarly, no consumer could determine if the supplemented products they were buying would be considered a FTDS (even after a generic description was provided by the moderator), and therefore should carry a ‘dietary supplement’ prescribed term.

No participant, either in Australia or New Zealand was deliberately buying foods because they were prompted by the use of the prescribed term ‘dietary supplement’ on the label.

Those few who were deliberately buying supplemented foods and beverages were motivated to do so because of the nutrition content claim (eg a reference to the amount of key nutrients, vitamins, minerals, or a non-culinary herbs). Use of vitamin and mineral supplemented foods was much more widespread than those with non-culinary herb supplements in the few who were deliberately buying them.  

The most regularly purchased foods were those with added nutrients such as juices with added vitamin C, milk with added calcium and margarines with cholesterol lowering elements. However, there was very low understanding as to whether or not these nutrients were at high enough levels to require labelling as a FTDS.  

A few participants in Australia and New Zealand were buying sport foods with protein and carbohydrate preparations for weight and muscle gain, usually to give to their teenage or young adult children. For these shoppers, the nutrition content claim they looked for related to protein or carbohydrate.  

The only deliberately purchased non-culinary herb supplemented products were in New Zealand, and included juice and powder products containing spirulina and another juice product which carried the nutrition content claim ‘contains Echinacea and Acerola’. Note these products are not marketed under the NZDSR therefore not required to have the prescribed term ‘dietary supplement’ – they are general foods with nutrition content claims. Only younger participants mentioned these products (ie those aged 18-25yrs). A handful of older participants (45+yrs) in New Zealand also reported having used tea products with added non-culinary herbs   such as ginseng, ginkgo and St John’s Wort.

Participants who bought ‘supplemented’ products, did not think that they were buying foods from a different category or type of food. Rather, they felt that they were just buying the product with ‘the extra health bits’, for the ‘boost’ they felt they needed that day.

However, at least half of all the participants involved in this study said they were not interested in supplementing their diet, and were not motivated by nutrition content claims. These participants were seeking to buy foods from their ‘original’ source, and were more influenced by ‘natural’ than ‘nutritional’.   This preference was illustrated by the following comment when the discussion centred around a flavoured water that was supplemented with vitamins:

“If I wanted Vitamin C I’d drink orange juice, I wouldn’t drink water.   I’d have water and I’d have orange juice, but I wouldn’t have both, not combined”.   [NZ, upper SES, special health needs, 18-24yrs]

Supplemented foods are purchased mainly for health benefits

The majority of participants in this study did not deliberately purchase supplemented foods on a regular basis.   Of those who did, there was a wide range of motivations for regularly or occasionally including supplemented foods in their diet, most of which directly or indirectly related to health benefits as follows:

• A perceived direct health benefit – to replace a known or perceived vitamin or mineral deficiency, or assist with a known illness or medical condition. For example some participants were concerned about their children missing out on certain vitamins or minerals because they do not eat particular foods or food categories, eg dairy/milk, fruit and vegetables;
  
  
• Prevention - to improve overall immunity or prevent illness, particularly to prevent colds and flues in winter;
  
  
• Conditioning – a broad desire to be ‘healthier’ and/or a belief that one ‘should’ try to consume foods rich in vitamins and minerals and/or that these substances are ‘good for you’, without any real understanding of why.   This was viewed as ‘topping up’ a reasonably good diet rather than replacing known deficiencies for enhanced well-being and sustained ‘wellness’;
  
  
• Reassurance - to overcome, or relieve guilt from a self-reported poor diet;
  
  
• For extra energy - described as a ‘boost’ or ‘pep up’ when feeling low, via vitamins in drinks, protein powders, and non-culinary herbs in teas.

FTDS are not as effective as pills and capsules

The groups were divided in their preference for supplementation via pills or FTDS, but the overall conclusion in every group was that pills, capsules and powders are a more effective way of taking supplements; however not necessarily a ‘better’ way. Therefore, a participant’s preference for supplementing vitamins and minerals through pills versus food depended on whether needing to address a known deficiency drove the supplementation, or if it was more a preventative measure to avoid a deficiency.

“I think it probably is more efficient if you’ve got a really deep deficiency or something…but if you’re just wanting to be healthier then it’s probably better to eat it in your food…”  [NZ, upper SES, special health needs, 18-24yrs]

Pills and capsules were regarded as having other specific benefits, intrinsically linked to being ‘more effective’:

• Pills are more concentrated and so they work ‘better’, or they are better ‘value’ for money

“Pills are more concentrated, or at least you would think so.”  [Aust., lower SES, health conscious, 24-44yrs]

“The levels are a lot lower though.   Yes, you’d have to drink a ton of that orange juice to get as much calcium as you would in a wee tablet.”[NZ, lower SES, highly health conscious, 45-64yrs]

“Like if the doctor says to you oh your iron is low then you think pills are going to give it to you straight away whereas if you have a piece of meat it’ll give me a little bit and the juice will give me a little bit but not as much as the pill gives me.”  [NZ, upper SES, less concerned, 25-44yrs]6

• You are able to monitor and control the dose, and pills tell you exactly how much you’re getting

“Well if you’re taking a tablet or capsules and you know what you’re getting where as with the food and that you don’t know how much you’re getting…”[NZ, lower SES, health conscious, 45-64yrs]

“And if it’s a multi vitamin you’d take two pills each morning and it says it replaces half of your needs, so you know it does.   Where as here you’ve got to get your calculator out and your pen and pencil and sit there for hours trying to figure it out.   So it’s a healthier way, I feel, of taking them because you know exactly what you’re getting and in what dosage”[NZ, upper SES, special health needs, 18-24yrs]

This advantage is more a perceived expectation, as no participant was trying to monitor how much they are or should be getting from supplemented foods.

• Pills are regarded as easier and more convenient

“well, it’s more convenient though and I mean you just pop the pills down, you don’t have to munch through an apple or something like that”  [NZ, upper SES, special health needs, 18-24yrs]

However, taking pills was seen to have some disadvantages. For those participants for whom natural ingredients were a consideration, taking pills was seen as another form of “artificial” foods. However, participants concerned about this issue are unlikely to look for supplemented foods, for the same reason.  

Others felt that choosing supplemented foods was a more “holistic” way of ensuring a diet is balanced, with supplemented foods offering nutritional worth as well as the supplement. For this reason, achieving good nutrition from supplemented foods was seen as a more cost-effective (not necessarily cheaper) way of getting supplements.

“The pills only do one thing, the food does a whole lot of things.”  [Aust., lower SES, health conscious, 24-44yrs]

“You have to eat food anyway, whereas buying the pill is something different, something extra.”  [Aust., lower SES, less concerned about health, 45-64yrs]

Participants with these opinions were very open to having FTDS available, and described them as a ‘nicer’ and ‘more natural’ way to supplement one’s diet.

6.1   Awareness of the term ‘dietary supplement’

In order to understand whether consumers notice FTDS labelling, and to explore the language they use to describe these products, a simulated shopping task was undertaken. At the commencement of the group, participants were asked to look at five pairs of food and drink products and were asked to note any differences or similarities between the pairs. Each pair included a FTDS product (labelled with the term ‘dietary supplement’), together with a regular counterpart food.

Participants were slow to note that some of the products were supplemented, with some groups, particularly the ‘less concerned about health and nutrition’ groups (1^st mention of this group in the results), unable to identify these foods. When participants were specifically asked if they had noticed that some products had something “added”, many were able to correctly identify vitamins and minerals that had been added. When given an opportunity to talk about what was different or special about these products the initial focus was on the nutrition content claims on the products, such as comparative claims (eg. ‘reduced’, ‘increased’ and ‘less than’ claims) and ‘free’ claims about fat, cholesterol and sugar, rather than the supplemented substances.

The time taken to notice the term ‘dietary supplement’ on the label was remarkably different between the Australian and New Zealand groups. In all but one of the New Zealand groups at least one and sometimes a few participants spontaneously mentioned the term when probed by the moderator for product differences. There was no Australian group which spontaneously noticed the term (when probed), so it had to be pointed out to the group. It is unclear whether this was because the New Zealand participants were unconsciously more aware of this term, or simply more attentive during the group task. This difference may reflect the greater length of time that FTDS have been available in the New Zealand market. Overall, New Zealand participants did not appear to be any more familiar with the term ‘dietary supplement’ than did their Australian counterparts.  

The FTDS products did prompt recall of other specific FTDS products, which had been noticed and sometimes purchased. This only occurred in the New Zealand groups, amongst younger and health conscious participants. Overall though, recognition of these types of FTDS was not widespread.

6.2   Understanding of the term ‘Dietary Supplement’

Participants on the whole were not familiar with the prescribed term ‘dietary supplement’ as it pertains to FTDS. On its own, the term was associated with therapeutic-type dietary supplements, such as vitamin pills, and/or weight control or weight gain powders and bars. Again when considered in isolation, there was no general agreement as to whether the term referred to products which are consumed in addition to the ‘usual’ diet, or products which replace foods in the ‘usual’ diet. In the context of FTDS, the term was clearly associated as having vitamins or minerals ‘added’, or foods being ‘boosted’ in vitamins or minerals.  

In its current form, the use of the prescribed term ‘dietary supplement’ on the label of FTDS had little, if any impact on consumers’ awareness or understanding of these products. This was a result of two equally important factors:

• the way in which the term is displayed by manufacturers at least on the example products used in this research, which, although legible, is given low prominence; and renders it “virtually invisible”; and
  
  
• a lack of information or education for consumers as to its meaning, or how the term distinguishes FTDS from other foods carrying nutrition content claims.   At present consumers do not distinguish between them.

Even after a full discussion, most participants were unconcerned that the prescribed term referred to amounts of nutritive substances in higher amounts than those in other products permissible as general foods and carrying nutrition content claims. The ‘higher levels’ that the prescribed term relates to had little relevance, particularly for the majority who were unaware of or unconcerned about the amounts of these substances in products with nutrition content claims, or ‘regular’ counterpart foods.

Participants described the prescribed term ’dietary supplement’ using a mixture of positive and negative terms:

• Boosted;
• Something extra or added;
• Something not in your diet;
• Supplementing your diet;
• For diets lacking;
• Meal replacement;
• Diet product, for weight loss
• Healthier;
• Better for you (but not necessarily good for you);
• No longer natural;
• Tampered with;
• Altered;
• Tastes bad.

Whilst the positive connotations associated with the term were more widely held, and made by participants across all the groups, the more negative connotations (referring to tampering, product alteration, and being no longer ‘natural’) came mostly from the New Zealand groups, and also the ‘health conscious’, and ‘special needs’ groups in Australia.

One group wondered whether the term ’dietary supplement’, meant that some foods “have” dietary supplements in them, such as juice with extra vitamins, and other foods “are” dietary supplements, such as meal replacements. This confusion was consistent with other groups, where the term ’dietary supplement’ was seen to describe both foods with added ingredients, and meal replacement foods.

“I’d actually be confused if I saw…’dietary supplement’. I’d be confused as to whether the product itself was a dietary supplement, or whether it contains something that is generally perceived to be a dietary supplement, like a vitamin or a mineral.” [Aust., upper SES, special health needs, 45-64yrs]

When probed in greater detail, participants in every group were unsure and could not agree whether the term referred to foods which were or should be additional to one’s usual diet, which was their rational interpretation of the word ‘supplement’, or instead of foods in one’s normal diet, ie replacing a meal or food. After considerable thought and discussion on this issue the most consistent conclusion was that whilst the term is probably intended to mean ‘in addition to’, in reality “many” consumers would use these types of foods to replace meals or foods. The “many” consumers who it was speculated would use FTDS in this way were rarely the participants in this study, but rather ‘other’ consumers, particularly ‘other’ young people and uneducated shoppers

Participants were not clear about the ‘dietary supplement’ term. For the product examples shown to the groups, the prescribed term was located on the front of the pack or bottle and it tended to be treated with the same level of distrust or scepticism as nutrition content claims.  [Readers should refer to the Nutrition Content Claims report [1] for more information about how consumers regard what is on the front of the pack as ‘advertising’ and what is on the back of the pack as ‘the truth’].   Participants also observed spontaneously that the term was much smaller than the nutrition content claim, and in comparison to the claim much more difficult to find. The majority of participants concluded that the prescribed term was only used because it had to be, otherwise manufacturers would make more effort to display it. Their reasoning was that manufacturers had deliberately minimised the size of the prescribed term in relation to the nutrition content claim, because it was less important to them (the manufacturer) and therefore by logical progression, only present because it must be important to ‘someone else’, such as the government or a regulatory authority.

As a natural progression from this discussion participants then sought to clarify the intent behind a prescribed term. There was much confusion and no agreement about whether the term ‘dietary supplement’ was intended as an identifier, a warning or cautionary statement for consumers, or if it was indeed supposed to be another ‘selling point’ like the nutrition content claim.  

“I take it to be a warning, though up until 10 minutes ago I would have taken it as a motivator.”  [Aust., lower SES, health conscious, 24-44yrs]

“because if it’s a warning type thing they make it a warning or an attention rather than just…because I think having a dietary supplement is sort of like, perhaps we’re better and you should buy ours becauseit’s better for you when it may not be any better than another product on the shelf’  [NZ, upper SES, special health needs,18-24yrs]

In the context of it being a warning,, participants could not understand why it was so small and difficult to read, and were thus at a loss to determine why the term was there at all.

“Maybe the manufacturers think because it’s got a negative connotation to it maybe it’s not something they want to be pointing out to everyone”  

“but like she said, it might suggest that it’s bad, but because they’re obligated to put it on they do it in the littlest writing when they really don’t want to put it on…”  [NZ, upper SES, special health needs,18-24yrs]

“it depends on what they intend to do with this dietary supplement or what ever they put on it, or whether it’s across the board or not.   What’s the intention?   Is it to tell us that it has been altered in which case just bring it to our attention, not a warning”  [NZ, upper SES, special health needs,18-24yrs]

It was clear that the participants were not only prepared to be led by government or the food industry on the issue of cautioning them about moderate to high amounts of substances in foods, but they expected to be fully informed about potential adverse effects and/or groups at risk. In several groups, the issue of food safety in regards to food supplementation was raised spontaneously by a group participant, and the moderator pursued the topic for a short amount of time. The underlying assumption amongst all participants in the groups where this topic was raised was that there are ‘authorities’ that regulate and monitor the amount of additives in foods, including nutrients, vitamins, minerals and herbs, and that they rely on such authorities to protect the public from any health risks with regards to supplementation. There was a common understanding that food on the market is unquestionably safe, instances of product recalls and product tampering aside.  

For consumers generally it does indicate that there is a need for clarity and education on this issue.

The term ‘dietary supplement’ is more dissuading than persuading

After discussing participants’ understanding of the term ‘dietary supplement’, the moderator probed for their views on how appealing the term was. Responses were varied. Initially, most participants jumped to the conclusion that it was a ‘selling point’, although most did not find such a claim personally relevant or motivating for themselves.

After some consideration, the interpretation by the majority was that it was not a motivator to purchase a product carrying that label (assuming it could be readily seen from the supermarket shelf). Some who reached this conclusion felt strongly that they would indeed avoid a product carrying such a term, because of the connotations it brought for them about product ‘tampering’ or ‘reduced taste’ or ‘no longer natural’. For others who were uninterested in food supplementation and paid no attention to vitamin and mineral claims anyway, the term would have no impact. Others again would avoid products with the term because they associated it with weight loss or ‘dieting’ products:

“dietary – that’s what it is.   Dietary to me says hungry.   I’ve got to starve my body”[NZ, lower SES, health conscious, 45-64yrs]

Participants did not offer any views about the usefulness of the term because they were still fairly unclear as to its purpose, and the ‘category’ of FTDS had, for most, low personal relevance.

6.3   Views about the need for a term ‘dietary supplement’

A definite desire for regulated ‘supplement’ labelling

The importance of the public being made aware of supplements in foods was raised spontaneously by all groups. This was seen as the main reason for having specific labels on foods, whether they be a nutrition content claim or a prescribed term, such as ‘dietary supplement’ (participants do not differentiate between the two).  

“well, we’re buying it, we should know what’s in it”  

“they should definitely be telling us that there’s something added”  [ NZ, upper SES, special health needs,18-24yrs]

However, in no group was awareness of the term ’dietary supplement’ high enough to serve this role. All participants missed the point of, or a need for, the prescribed term enabling them to distinguish between FTDS, other supplemented products, and ‘regular’ counterpart foods. This was mainly because participants appeared to be unable to make judgments about the relative levels of vitamins and minerals in products with nutrition content claims like ‘contains’, ‘source of’, and ‘good source of’

“I didn’t realise that it was a requirement to put the dietary supplement on there when they increased it, it…should be advertised so you are aware that when it says dietary supplement it is because this product has been increased…they should advertise that at x percentage it has to have dietary supplement put on there, because it is above the recommended amount.”  [Aust., upper SES, special health needs, 45-64yrs]

Almost all participants, and particularly New Zealanders, had an underlying desire to ‘know what’s added to their food’. One participant, who was, indicative of the common view, commented that“there’s a big difference between containing it and adding it”.  There were a number of reasons for this attitude, some of which have been mentioned earlier in other contexts. These are summarised below.

1. To make informed decisions about ‘natural’ sources of vitamins and minerals.  
   
   “I’d like to know the source of the vitamins and minerals and whether they are chemically made or a naturally derived product”  [NZ, lower SES, health conscious, 45-64yrs] 
   
   Although some New Zealand participants were extremely keen to know whether the dietary supplement was derived from a ‘natural’ or ‘chemical’ source, their interest was in seeking reassurance as to the ‘naturalness’ of the product. No participant interested in dietary supplement sources had any knowledge from where any nutritive substances in other supplemented foods were derived.
   
   
2. To easily identify foods with high levels of nutrients. This would be particularly useful for parents who had children who did not or could not eat certain foods, such as milk, in which case juice and biscuit products fortified with calcium would be helpful. Need to state that participants mentioned this otherwise it sounds like your opinion.
   
   
3. To assist people who have particular allergies or food intolerances by informing them of the presence of allergens such as nuts and gluten. Only a dozen people mentioned this and they also said they always relied on the ingredients listing to check whether nutrients of concern were present, and did not rely solely on nutrition content claims or allergen declarations. This point illustrates consumers’ tendency to confuse supplementation labelling with other labelling issues such as allergen declarations.
   
   
4. The desire to avoid overdosing on supplements. This was only a strongly held concern by one or two people in a few groups, the majority were unconcerned about cumulative intake of vitamins and minerals.   The ‘unconcerned’ belief was that it was not possible to overdose on vitamins and that the body ‘flushes them out’ if you have too much.

“you can’t overdose on vitamins, not that I know of, your body just gets to a certain level and then it just off loads what it doesn’t need, you can’t stockpile them, other things you can stockpile in your body.    You can’t store them, it just off loads them”  [NZ, lower SES, health conscious, 18-24yrs]

Most people did not have enough information or interest in vitamin and mineral consumption to worry about overdosing, or to ascertain at what level of consumption, and what specific vitamins or minerals, one might overdose on. When those concerned about overdosing were prompted, no one was monitoring their intake of such nutrients to avoid overdosing.   The only people paying attention to levels of these nutrients were those with specific health concerns (eg. low potassium diet).  

Most consumers wouldn’t need the term ‘dietary supplement’ on the label if   nutrition content claims were more meaningful.

Arising from the ambiguity about the intent of a prescribed term, and how it might distinguish FTDS from other products, was a lack of perceived need for one.  

Keeping in mind the inability amongst most participants to distinguish between FTDS and other supplemented products, and their lack of understanding regarding the potential impact of consuming FTDS, the majority of participants felt that nutrition content claims were all that was needed to draw one’s attention to the supplementation of that product. Most participants shared this view, across all groups, but for different reasons. Those least interested in vitamin and mineral composition felt no personal need for a prescribed term, and assumed that nutrition content claims with the NIP were sufficient information for others. Another view was that consumers could and should take responsibility for what they did with that information – whether that meant disregarding it, avoiding the product, or seeking further clarification of what it meant.Those most interested in the nutritional composition of their food felt that the presence of the NIP negated any need for the term ‘dietary supplement’ on the label.

“If you’ve got, on your label with added vitamins and minerals or what ever like that one there that’s got Vitamin B and Iron added, you don’t also need to add that it’s a dietary supplement.   Because the fact that you’ve added it already means that”  [NZ, lower SES, health conscious, 45-64yrs]

“No, it doesn’t need to say ‘dietary supplement’ as well.   It’s already told us what it’s got in there and you’ve got your nutritional information on it there.   If you’re truly interested you can look”  [NZ, lower SES, health conscious, 45-64yrs]

“they already write on it that it’s got something added anyway, so why do they have to put ‘dietary supplement’ on it?”  [NZ, upper SES, special health needs, 18-24yrs]

6.4   Location of the term ‘dietary supplement’

A further conundrum arising around the issue of FTDS labelling is where best to position or place a FTDS term so that it is most effective. Based on participants’ views about the low visibility of the examples of the term used in this study, if there is deemed a need to caution consumers about FTDS products, such a statement must be on the front of the package, and preferably close to the nutrition content claim, so that it is noticed by shoppers.   However, in order for a prescribed term to gain recognition it will need to be sufficiently more noticeable for consumers to readily identify the product.

The findings of this research indicate that most consumers make a clear distinction about the credibility between information on the front versus the back of the package. On this basis, the researchers conclude that co-location of the term with the nutrition content claim runs the risk that the prescribed term will be dismissed as ‘advertising’ or regarded to be of dubious credibility, depending on the consumers level of overall suspicion and their familiarity with other nutrition content claims. To be given ‘automatic’ credibility, the prescribed term should logically be located with the other ‘trustworthy’ information on the back of the package, such as the NIP.

To overcome this, the format of the present term would need to be distinctively different from a nutrition content claim, but at the same time sufficiently noticeable. Alternatively, or additionally, informing or educating consumers about what a chosen prescribed term means or infers, and how it is different to a manufacturers content claim, could go a long way to resolving the question of position.

6.5   Reactions to alternative terms, and other suggestions

In addition to the current prescribed term, FSANZ also wished to explore consumers’ reactions to two alternative prescribed terms: ‘food-type dietary supplement’ and ‘nutritional supplement’, as well as suggestions for any other alternatives.

The term ‘food-type dietary supplement’ evoked similar reactions to the current term, particularly in regard to its association with dieting.   It was not considered a suitably different alternative, and was less favoured because it was considered too wordy and thus confusing.  However it should be noted that almost all participants framed their responses around an assumption that any term should make the product more appealing, rather than less appealing.

“it’s so non-specific. It’s no more specific than ‘dietary supplement’. People would say food type, what do they mean by that and so they would stand there for a few minutes and then think about it and then think 'I will avoid that one’ ”  [NZ, upper SES, special health needs, 25-44yrs]

One or two participants in some groups acknowledged that the term was suggestive of there being other types of dietary supplements, but even fewer made the connection that the term might be trying to distinguish between therapeutic-type supplements, such as pills and capsules. A few speculated that perhaps the term was trying to differentiate FTDS from meal replacement and weight loss products. Only a few participants in total felt that the term brought more clarity because it related directly to food, and these people failed to see the point of such a differentiation.  

Another very small number of participants felt the term carried positive connotations, with the word ‘food’ suggesting the product was more desirable or ‘better’ than a ‘regular’ counterpart product.

Substantially different meaning inferred from ‘nutritional supplement’ compared to ‘dietary supplement’

In contrast, the term ‘nutritional supplement’ was seen as a highly positive statement , which participants initially preferred. Their immediate and spontaneous reactions were directly responding to the substitution of the word ‘dietary’ for ‘nutritional’. Although this positive reaction was received in every group, it was most strongly and consistently expressed amongst those in a New Zealand group of lower SES, health conscious participants, aged 45-64yrs. Whilst these participants were in agreement, their responses were expressed for several different reasons, as is illustrated in the comments below:

“diet has negative connotations where as nutrition has good vibes”  

“if it was changed to nutritional I’d buy it…because it sounds good. Dietary to me just honestly says someone’s on a diet.” 

“if you’ve got kids you don’t want to put dietary because you don’t put your kids on diets. But nutrition is big for kids.” 

“the word nutrition itself is positive. It’s a word that’s used a lot in the media and by your doctor. It’s nutrition this or it’s nutrition that …it’s got a positive tone about it”. 

“to me that [nutritional supplement] doesn’t’ say ‘watch out’. If that’s the intention of the manufacturer, then to me it doesn’t’ say ‘watch out’. That is a good effect…” 

The majority opinion, based on initial spontaneous reactions, was that the use of this term made the product a good buy.

However, not every participant was strongly in favour of the term ‘nutritional supplement’. A few had some reservations that the term might in fact be misleading or deceptive:

“you feel you are adding something to your body but that can be deceptive because you may not be”  [NZ, upper SES, special health needs, 25-44yrs]  

For some more health conscious participants who dwelt on this term longer than the majority, it lost some of its initial favour. Like all of the suggested terms, the word ‘supplement’ has negative connotations, implying additives or ‘unnatural’ ingredients.

Nonetheless, the term ‘nutritional supplement’ is far less likely than ‘dietary supplement’ to evoke a ‘cautionary’ reaction, although the latter still does not communicate this as effectively as it may be intended by some.

Other suggestions - A preference for a more exact labelling system

It is apparent that without education as to what the term ‘dietary supplement’ refers to, the term will be rarely used, and would not serve any purpose either as a product identifier or as a caution.

Participants interested in nutrient supplementation or in monitoring the composition of the foods they eat were all in favour of regulated labelling for any added nutritive substances, regardless of the amount in which they had been added. As well, ‘disinterested’ participants strongly endorsed the availability of this information in a quick, user-friendly format, for those who might want to know at some stage. However, participants did not distinguish a greater (or lesser) need for accurate, easy to interpret ‘additive’ labelling for FTDS compared to other products with nutrition content claims.  

What participants desired was an easy way to interpret how much of any ‘added’ nutrient or nutritive substance is in the food available to them. What would be most useful to consumers is a graded or quantified ‘supplement’ label for all vitamin and mineral fortified foods and beverages, that positioned the food in question relative to other foods. Suggestions included classifications using a low to very high scale, a numbering system, colour codes or graphical symbols.   For example, rather than just label the product as a ‘grade 3’ it should be labelled as ‘grade 3 out of 5’, or a middle shade of blue, on a scale of light blue to dark blue. Essential to providing this would be an information or education program that explains to consumers how to recognise and interpret the labelling ‘system’.

A percentage of the recommended daily intake (RDI) was the most preferred labelling ‘system’, as it was seen as an easy way to evaluate how much of a nutrient you should have in a day. Views about RDIs are reported in more detail in section 7.

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