Qualitative consumer study related to nutrition content claims on food labels 

Results - Part B

8   Comparitive claims

9   ' Free' claims

10  ' % Fat Free ' claims

11  Cholesterol claims

12  Carbohydrate and protein claims

Comparative nutrition content claims are those claims that compare a food with a similar food or class of foods such as ‘reduced’, ‘increased’ and ‘less than’.

Participants used the moderator’s showcard and real product examples as references during the discussion, as well as examples they recalled from their own experiences.

8.2   Familiarity with comparative claims

Consumers in this research were highly familiar with the various comparative claims included in this study. Everyone in every group recognised each of the examples and most had selected products at least partly based on a comparative claim. For most consumers use of comparative claims, as with most nutrition content claims, is not usually pre-meditated. Whilst consumers who are highly health conscious or shopping for special health needs are deliberately attentive to nutrition content claims, for most their use of them is spontaneous and ad hoc.

On the whole, ‘reduced’ claims were associated with sugar, salt and fat, ‘increased’ claims were most commonly associated with calcium, and ‘low’ claims were linked to fat and salt.

8.3   Use of comparative claims

More than any other type of nutrition content claim, comparative claims were described by consumers as ‘just a guide’, and required verification by using the NIP because the comparative claim terms were regarded as too generic to be useful in their own right. The process of verification was described by consumers as ‘getting more information’ and involved one or a more of the following:

– either finding out exactly how much of the nutrient in question was present in the product (using the NIP as a stand alone tool);

– comparing the product’s NIP with the NIP of another ‘original’ product that made no such claim (how much lower is low);

– comparing the product’s NIP with the NIP of another product that makes the same claim (is this ‘low’ as low as ‘that’ low?).

Consumers were more likely to use these claims in the third way, described above, if they were very interested in nutrition, or were highly health conscious.

8.4   Comparisons with reference foods

In this regard, many consumers are looking to make comparisons with a reference food, and many struggle to find the most appropriate reference food. For some, the most appropriate reference product is a similar product by another brand, for others it is another product in the same range.  

Most consumers could not recall having noticed any labelling that provides a comparison to the reference food, either via an extra column in the NIP, or a statement on the label which compares to the reference foods, such as ‘30% reduced fat when compared to [brand] tasty cheese’ and ‘contains less than half the fat and 20% more protein than standard full cream milk‘. There were no available examples of the NIP column for reference foods; however when the reference food statement was brought to their attention, using a ‘reduced fat’ milk example, many participants felt this information was useful and valuable, and it was viewed as being quicker by those participants who did not wish to invest a lot of time reading NIPs. On balance however, amongst those interested in making comparisons, the ‘standard’ NIP was still regarded as more helpful and, for some, more believable for making comparisons between a ‘reduced’ product (eg milk) and a reference product (eg full fat milk) because one could hold the two NIPs side by side and directly compare the values in each NIP.

Often the process of verification is also one of self-education and inquirers use claims and NIPs to teach themselves and make decisions about products that are acceptable to them. Once the claim is verified, and the product is ‘tried and proven’ based on its nutritional value, taste and price, the claim is then used to quickly identify the same product again for a repeat purchase. Yogurts, cereals and canned foods were common product examples.   

However, some resent having to further investigate the claim, as illustrated by the following conversation between a number of participants.

“when they are not being specific on what the difference is why not have it on the front of the packaging that it is 10% reduced, why do I sort of have to turn to the back?”  [NZ, lower SES, special health needs, 25-44yrs]

Moderator:   “How do you feel about having to do that?”

Participants:

“annoyed.   You should be able to just see it.   It should say, like you said, it should just be there”

“stamped on the front”

“so you don’t have to turn it around and stand there for half an hour looking at each one”

“the printed matter is probably boring to the manufacturer they would probably rather have it pretty on the front where we want just the words on the front”[NZ, lower SES, special health needs, 25-44yrs]

More attention is paid to, and involvement invested in, comparative claims that refer to a consumer’s significant nutrient.   If the claim is made about a nutrient other than the significant nutrient, or one that is lower down on their list of significant nutrients, the product may well still be noticed and examined initially in response to the claim, but will be assessed primarily on the significant nutrient rather than the claimed nutrient.   In this context, inquirers begin to look for and assess nutrient trade-offs, and are not led by the claim alone.   For example, a consumer who is unconsciously or consciously most influenced by fat content may well notice a ‘low salt’ claim on a product, pick up that product for it’s suggested health benefit, but from there on make a decision to purchase based on fat rather than salt content.

8.5   Understanding of comparative claims

Each of the three comparative claim terms was discussed in turn and then in the context of other claims using the terms ‘low’, ‘high’, ‘lite’ and ‘diet’.  

The perception amongst most participants, in all groups, was that a comparative claim implied that the product was healthier than the ‘original’, but not necessarily healthy or a better choice. There was a high level of scepticism about these terms in all groups, and a great deal of confusion between these and the other terms. Most were not able to reach agreement as to whether a product was a healthy choice if it carried a comparative claim. At the root of consumers confusion is their search for a health recommendation rather than reference to a reference food.

“they might make you think subconsciously that they are healthy for you.   You just don’t know, is it reduced within the healthy guidelines?”  [Aust, low SES, highly health conscious, 24-44yrs]

‘ Reduced ’

‘Reduced’ was generally understood to mean lower than the regular or ‘original’ version.  

Generally consumers were more sceptical about this term than ‘low’, but found it difficult to distinguish between the two terms. There was no understanding that the use of this term was regulated with maximum content conditions, and that there were therefore ‘boundaries’ around the use of the ‘reduced’ claim. Many participants were dissatisfied with the degree of ambiguity around this term, and felt that it was difficult or impossible to know how much the product had been reduced by unless it stated the % reduction as part of the claim.  

“I wonder what it is reduced in comparison to.   Is it less than previously?    Or less than the tin next to it?[Aust, low SES, highly health conscious, 24-44yrs]

“well someone’s ‘reduced’ may not be half as much reduced as someone else’s…you could have ten brands that all say reduced, but they could be reduced to ten different extents”.[Aust, lower SES, moderately health conscious, 45-64yrs]

The obvious confusion over how the term ‘reduced’ differs to a ‘low’ claim confirms the findings of the previous quantitative research [1] , where nearly half of the consumers interviewed (46%) said that the ‘reduced in salt’ term meant that the food contains less salt compared to a similar food labelled ‘low salt’, and a further 26% said that the term meant that the food contains the same amount of salt. Only 11% said that the ‘reduced in salt’ term meant that the food contains more salt compared to a similar food labelled ‘low salt’ (the correct response).

There was a clear preference for ‘% reduced’ claims (on the front of the package) compared to general ‘reduced’ claims, accompanied by the reference statement on the back of the package. ‘% reduced’ claims were useful to consumers wanting to lower their intake of a particular nutrient in order to make a healthier choice, many of whom felt that they did not need to know how much of the nutrient remained in the product, or did not know how to find out.

However more active inquirers preferred even more information, so that the claim would say ‘reduced from X% to Y%’.  

“I am a little cynical about the claims but I still notice them”

Moderator – “what is the cynicism about?”

“well you can reduce something from 80% to 75% fat and that is still reduced so I kind of want to know more”[NZ, upper SES, highly & moderately health conscious, 45-64 yrs]

“It is a claim that makes you quickly scan the shelves and you might see ‘reduced’ and that will be okay to buy it but in actual fact when you think about it, it’s not actually saying anything is it”

Moderator – “How come it is not telling us anything?”

“because it is not quantifying”

“and it is not saying what it is comparing it with”[NZ, upper SES, highly & moderately health conscious, 45-64 yrs]

These consumers were capable of using the NIP to ascertain exactly how much of the nutrient was present, but had developed their capacity to do this because they found the current claims unhelpful.  

Amongst some, there was an expectation that in order to reduce a nutrient, something else has been added to replace it, which then makes the product undesirable. These products were perceived to have been ‘altered’ and to now have increased preservatives, ‘nasty chemicals’, or ‘added stuff’ in order to address the taste imbalance of lowering or removing the claimed nutrient. These concerns applied as much to ‘low’ and ‘free’ claims as they did to ‘reduced’ claims.

“I worry about what they’ve replaced it with.   I think it would be artificial, your sweeteners and things”[NZ, lower SES, special health needs, 25-44yrs]

“you trust that they are taking sugar out, and fat out, but you don’t trust what they are putting in it”  [Aust, low SES, highly health conscious, 24-44yrs]

‘ Increased ’

Generally consumers were less familiar with the term ‘increased’, associating it with micronutrients such as calcium, protein, iron, and fibre. This claim was less salient and less important to consumers because they were associated with nutrients much further down on their list of ‘significant’ nutrients. This claim was deemed relevant to shoppers who had special health needs, or young children at risk of particular nutrient deficiencies.

The term was interpreted to mean ‘added’ or ‘enriched’ and, unlike ‘reduced’ and ‘low’ claims, it was generally understood that the food was not intrinsically (or ‘naturally’) high in the increased nutrient when it carried an ‘increased’ claim.

‘Increased’ claims carried none of the negative connotations associated with ‘reduced’ claims with regards to product alteration and the addition of other substances in order to compensate for poor taste.   

Consumers were less sceptical, and less opinionated generally, about the ‘increased’ claim, mainly because of an underlying assumption that manufacturers would not want to increase something unless it made the product a better choice, or because it was of less interest to them.

Participants were less inclined to comment on the healthiness of a product carrying an ‘increased’ claim, because healthiness was viewed as being, primarily, to do with the fat, sugar or salt content of a food and the ‘increased’ claim was never used in association with these nutrients.

‘ Less than ’

Consumers were also much less sceptical of ‘less than’ claims, when they were used in a quantified context, such as ‘less than 5 g of sugar’.  For some, the quantification negated the need to refer to the NIP, especially when the claim involved a consumer’s significant nutrient.

A quantified ‘less than’ claim elicited much less scepticism and cynicism than ‘reduced’ claims because they were regarded as far less ambiguous or confusing.

8.6   Distinguishing between comparative claims and other claims

After the three comparative claim terms had been discussed independently, consumers were asked how they differed or compared to other nutrition content claims such as ‘low’ and ‘high’, ‘lite’ and ‘diet’. To generate discussion, participants as a group, completed a word sort task where they were asked to differentiate the claims according to the amount of an example nutrient they contained. Fat, and sometimes also salt and sugar were used as the examples.

As reported earlier, consumers across all groups had difficulty distinguishing between the terms ‘reduced’ and ‘low’, and many also were confused as to how ‘less than’ (unquantified) and ‘lite’ differed from these terms. No group could reach 100% agreement about which of these terms would contain the most or least of an example nutrient.   In most groups, the exercise appeared to increase consumers’ confusion and frustration with the terms. Generally consumers agreed that it was difficult to make judgements about the terms without referring to the NIP. Some became quite frustrated with the task as they felt it was an impossible task.

“words don’t mean anything until you look at the panel”[Aust, lower SES, moderately health conscious, 45-64yrs]

Some specific findings are reported below.

Low

In the general unstructured discussion, the term ‘low’ was used by participants interchangeably with ‘reduced’, and initially most perceived these terms to mean the same thing. Only after more focused discussion and the word sort exercise, did most groups agree that ‘low’ probably inferred more of a reduction than ‘reduced’.

As with the ‘reduced’ claim, many participants did not feel that the presence of a ‘low’ claim made the product a better choice, or that it was the lowest version or brand available. Most were familiar with having to use the NIP to compare with another product in order to ascertain the best choice for them.

“but you always compare it with the subject next to it.   Like if it’s low fat cheese, you pick it up and look at that one and then you look at the other one and often it is actually higher in some cases”[NZ, upper SES, highly & moderately health conscious, 45-64 yrs]

In a couple of groups participants sought clarity about whether ‘low’ meant that the product was ‘naturally’ (intrinsically) low in the claimed nutrient, or if it meant it was now low because it had been reduced in that nutrient. This distinction then became a suggested point of differentiation between the ‘low’ and ‘reduced’ claims. That is, for many people ‘low’ claims relate to products intrinsically low in the claimed nutrient, while ‘reduced’ products are ones that have been altered to contain lower amounts of the claimed nutrient.

The majority of consumers also recognised that a manufacturer’s use of a ‘low’ or ‘reduced’ claim was voluntary, and therefore one product carrying a ‘low’ (or ‘reduced’) claim could still be higher in the claimed nutrient than another product not labelled with a ‘low’ claim. For this reason the usefulness of these claims was regarded as fairly limited.

‘ Lite ’  and ‘ Diet ’ vs ‘ increased ’ and ‘ low ’

Consumers were also very familiar with ‘lite’ and ‘diet’ claims, and reactions to them are discussed in detail in sections 14 and 15. In comparison to the other claims, consumers across all groups were most cynical about the ‘lite’ claim. There was a high level of awareness that ‘lite’ could refer to many different things (a nutrient, colour, texture etc). ‘Lite’ was considered to be the most misleading of all claims. As well, many consumers, particularly those in the 45+ age groups strongly objected to the spelling of the word ‘lite’ and reported that they deliberately avoided buying products that carried the claim.

There was therefore much disagreement, within and across groups, as to how ‘lite’ and ‘diet’ differed from ‘low’, ‘reduced’ and ‘less than’. Most could not suggest how the terms could be distinguished from each other. Whilst some participants felt the terms inferred that they contained the least amount of a nutrient (compared to other terms such as ‘low’ and ‘reduced’ and ‘less than’), others felt as strongly that it could contain the same amount or more, and others again felt there was no way of knowing. Whilst the terms ‘lite’ and ‘diet’ are not classified as comparative terms, most consumers felt that the only way of correctly interpreting these claims would be to compare with another product that did not carry the claim.  

High vs increased

Consumers initially found it difficult to distinguish between these terms, and until the focus group discussion had not given this comparison any thought. Once again they used the terms interchangeably. When pressed on this issue by the Moderator it was assumed that a food labelled with a ‘high’ claim (eg high in fibre) would probably contain more of the nutrient compared to a product labelled ‘increased’ (eg ‘increased in fibre’); however consumers had no confidence that their assumption was correct. The discussion also raised the question as to whether ‘high’ meant ‘naturally’ high or whether it also included foods that had added fibre, whereas ‘increased’ clearly inferred that fibre had been added to the product during manufacturing.

8.7   Relative differences compared to the reference food

Consumers were quite adamant that products carrying any of the claims discussed earlier should differ significantly from their ‘regular’ counterparts. There was strong agreement that reductions in particular, but additions as well, of only small amounts should not be permitted under these claims. However most did not believe that this was currently the case, indeed many participants felt that that products currently claiming ‘reduced’ or ‘low’ could in fact be only reduced by quite tiny amounts.

“Technically they could (reduce it) by anything, by point one.

Moderator: Do you think that happens?

“Yes, I think it happens all the time.” 

The acceptable relative difference between a food carrying a comparative claim and the reference food varied between participants; however there was most agreement for a difference of about 25% or one quarter less or more than the ‘regular’ food.   Differences of less than 10% were deemed unacceptable.

8.8   Trust and credibility of comparative claims

Compared to some other nutrition content claims such as ‘free’ and ‘% free’ and ‘no added sugar’, consumers were highly sceptical about comparative claims, particularly ‘reduced’. They were not deemed to be trustworthy, where trust implies ‘reliability’ – very few consumers in this study felt that they would rely on a comparative claim when purchasing a product for the first time.  

“I’d still read the label to see where it (the fat/salt/sugar) is coming from…I wouldn’t trust them”[Aust, lower SES, moderately health conscious, 45-64yrs]

However, consumers did not regard these claims as unbelievable, where believable implies ‘truth’. Most acknowledged that the claim ‘reduced’ truthfully implies that the product contains less of the claimed nutrient than its ‘original’ counterpart. However, these claims were viewed as providing incomplete information, which can then be misleading if taken at face value. Most of these claims were viewed as misleading because of their perceived ambiguity, which is assumed to be deliberate on the part of manufacturers who are just trying to sell their product.  

“I think it can be misleading sometimes too though because I mean I have seen it where people have real problems with weight issues so they tend to go for the low or the reduced because they think fat, but if they actually looked at the back   they would see the carbohydrates have been shot right up, it is actually worse for them than if they had gone for the ordinary thing, so it can be misleading”[NZ, lower SES, special health needs, 25-44yrs]

“It is just trying to lure you to it that it is better than something else but you don’t know what the something else is”[NZ, lower SES, special health needs, 25-44yrs]

“it is basically a sales point because if you actually had time to sit and compare one packet with the other you would probably find there is no difference anyhow”[NZ, lower SES, special health needs, 25-44yrs]

However, whilst most consumers in this study were concerned and even angry about the vagueness of these claims, there was no indication that they themselves were being misled by manufacturers. Most have learned to moderate their behaviour, by using the NIP, to make decisions about the value of comparative claims. Their concern over the misleading nature of these claims was for ‘other’ less able shoppers who were unable to use NIPs.  

9.1   Background and context

Examples of ‘free’ claims include; for example ‘fat free’, ‘sugar free’, ‘cholesterol free’, ‘gluten free’. After the pilot group the ‘gluten free’ and ‘lactose free’ claims were excluded from the scope of this study for two reasons: firstly because they have a public health and safety issue which other ‘free’ claims don’t have; and secondly because in the pilot group their perceived importance overwhelmingly overshadowed discussion about other ‘free’ claims such as ‘fat free’, ‘sugar free’ and ‘cholesterol free’.   These claims are permitted under certain circumstances in the Code of Practice on Nutrient Claims in Food Labels and in Advertisements in Australia (see Appendix D). In contrast to gluten and lactose claims, trace amounts of the nutrient (e.g. 0.15g of fat per 100g of food for a ‘fat free’ claim) are allowed because they are nutritionally and physiologically insignificant.  

Participants used the moderator’s showcard and real product examples as references during the discussion, as well as examples they recalled from their own experiences.

9.2   Familiarity with and use of ‘free’ claims

All consumers, in all groups were familiar with these claims, which are being used more extensively by them. They were most commonly recalled being on dairy foods and breakfast cereals, and to a much lesser extent salad dressings, confectionary, jars of salsa, and fresh produce such as kiwi fruit and avocados.

In comparison to comparative claims, ‘free’ claims were viewed much more favourably, because they are not making any sort of comparison to any other food, and were viewed as more helpful and more definite than claims like ‘reduced’ or ‘low’, and therefore less confusing or misleading.  

“This was the one I trusted the most, because if it says that it is not comparing itself with something else.   It is not ‘a little bit better’ or what ever.”  [Aust., Upper SES, moderately health conscious, 25-44yrs]

“I would buy fat free and sugar free against ‘reduced’ because I haven’t got time to read all the labels on the end and to me I would have to say that free is better than reduced.”[Aust, lower SES, moderately health conscious, 45-64yrs]

When confronted with a ‘free’ claim on a product they haven’t seen or bought before, most consumers felt that they would be initially attracted to the product and inclined to pick it up. ‘Free’ claims were regarded as quicker and easier to use, particularly for only moderately health conscious and those who are less ‘active’ inquirers. These consumers wanted to be able to use a ‘free’ claim without having to use the NIP as well.

“I want to believe that [points to fat free claim’ has no fat in it and that [point to sugar free claim’] has not sugar in it …and [other participant’s name] was saying that   should read the packet but I think there is no need, because that to me says something.”[Aust, lower SES, moderately health conscious, 45-64yrs]

9.3   Using the NIP for verification

There were, however, just as many consumers who sought to verify the claim as there were consumers like those discussed above, who took a ‘free’ claim at face value. Verification was done by using the NIP to compare the amount of the claimed nutrient with another product that does not make the same claim, or by looking for nutrient trade-offs. Those who verify the claim were more likely to be highly health conscious consumers, those with special needs and/or ‘active’ inquirers. These consumers were more sceptical of ‘free’ claims and actively looked for nutrient trade offs, such as high amounts of sugar or carbohydrate on products such as yogurt and lollies that carry ‘fat free’ claims. In a typical group, half the participants would investigate and verify ‘free’ claims in this way, another quarter would have some suspicion of a trade off but would not have investigated, and the remaining one or two participants would have trusted the claim without further thought or investigation.   

The following conversation was highly typical of consumers’ reaction when the moderator introduced a confectionary product, in this case marshmallows, carrying a ‘fat free’ claim.

Moderator  “why are we laughing?”

“because of the sugar in there.   I would look in there and see if it was saccharin or sucryl or something that was a replacement and then I would buy it if it was”

Moderator  “how do we feel about them putting fat free on things which are high in sugar like that one?

“one of those roll your eye things”

Moderator– “what does that mean?”

“the whole thing is that that is not a fatty product and we all know that so we are not stupid and you are making it look good but come on!”

“well it wouldn’t make me think ‘oh it’s fat free I’ve got to buy it’, I would be quite sceptical about what is actually still in it”

“It is a ploy to try and get you to buy it, what are they hiding?   People think they can eat that without guilt”.[NZ, lower SES, special health needs, 25-44yrs]

9.4   Understanding of ‘ free ’ claims

Across and within all groups there were only slightly varied reactions to what ‘free’ meant:

Nothing, not a trace

Nothing added

Nil

None whatsoever

Zero

Absolutely none

Free should always mean zero

Every group came to the unanimous and unequivocal decision that ‘free’ should mean ‘zero’ or ‘nothing, not a trace’, although many felt it was unlikely that this was how the term was used by manufacturers. Those who were more sceptical had seen evidence to support this on NIP labels in the past. Others, who had trusted implicitly that ‘free’ = zero, were surprised and disappointed to hear that the ‘free’ term has been used for products that contain small amounts of the claimed substance.

“free says nothing, there’s no sugar and there’s no fat”[Aust, lower SES, moderately health conscious, 45-64yrs]

Their views about the ‘correct’ definition of ‘free’ were based on their literal interpretation of the word, as well as their awareness that this claim is also used for substances that are potentially harmful to some consumers, such as wheat/gluten, peanuts and sugars (lactose).  

‘ Sugar free ’ is more ambiguous

Views about ‘free’ also differed for fat compared to sugar. Whilst ‘fat free’ claims were viewed as more straightforward, some consumers were highly distrustful of ‘sugar free’ claims because it was felt that ‘free’ did not mean the product was free of other sweeteners or hidden types of sugar. This view was based on participants’ recollections of having used the NIP to verify the claim and having found the product to contain an amount of sugar, and other experiences of having referred to the ingredients list in their verification process, such as the example described below.

“sugar can be many other ingredients, it can be sucrose, fructose, sugar itself, so if you’re saying it’s sugar free, yes it’s got no sugar but lo and behold it’s got fructose, sucrose and what ever, which is still sugar…this states categorically sugar free, so I wouldn’t expect to find any of that”[Aust, lower SES, moderately health conscious, 45-64yrs]

By contrast, no one in the study raised similar concerns about types of fat, and it was assumed that ‘fat free’ meant the product was free of all types of fat.

Insignificant amounts of nutrients are significant!

When the issue of nutritional ‘insignificance’ was introduced into the discussion, most participants accepted that for nutrients such as fat, sugar and cholesterol, small amounts such as 0.01g or 0.05g were virtually insignificant and certainly not harmful. Whilst a couple of participants in each group felt that leaving small amounts in a ‘free’ product was a result of the manufacturer being lazy or untruthful, by far the majority acknowledged that it was very difficult for manufacturers to remove 100% of the nutrient and that trace amounts left in the product was probably unintentional on the part of the manufacturer.

Nonetheless, there was universal agreement that the use of the ‘free’ claim should be based on absolute absence and not nutritional insignificance. Similarly, the use of different definitions of ‘free’ for nutrients such as fat and sugar compared to substances that can have harmful effects, such as gluten and lactose was viewed as unacceptable. It was consistently advocated by participants that manufacturers shouldn’t be able to claim ‘free’ unless they could guarantee it was free, and that they should be made to use another term or claim, such as using a percentage, if they wished to indicate very small amounts.  

However, rather than favouring a new alternative word or statement to indicate trace amounts, such as ‘very low’, ‘traces of’, ‘minimal amount of’, ‘virtually nil’ etc consumers preferred that the exact amount be included in the claim – such as 1% fat or ‘less than 1% fat’. The alternate suggestions, such as ‘traces of’ were viewed as being more of an ‘escape clause’ or disclaimer than a claim, and were not favoured because they were felt to be too inexact, and therefore must be trying to hide something.

In most groups consumers were confused about whether a ‘free’ claim inferred that the absence of the nutrient was a result of it having been reduced in processing (such as yogurt) or whether the claim should also include products that have never contained the nutrient, eg fat in kiwi fruit, cholesterol in avocados, fat in marshmallows, and salsa. The inclusion of the latter products added to consumers’ cynicism of the ‘free’ claim, particularly when it was used on fresh produce.

Only a small number of consumers in the whole study were aware that a manufacturer is required to declare the amount of the nutrient in the NIP when a ‘free’ claim is made; however all fully endorsed this requirement, including consumers who did not use NIPs. It was felt that such a requirement was both helpful and useful for consumers, but was probably also necessary for ‘less reputable’ manufacturers who would otherwise put ‘free’ claims on products that were not necessarily free. The more cynical participants thought that this had probably been happening anyway, and were surprised and pleased to learn of the declaration requirement for packaged foods. Inquirers did however acknowledge that for most ‘free’ claims they looked at, the quantified amount of the nutrient could now be found in the NIP and they made the comment that NIPs with the most ‘significant’ nutrients were becoming more widespread and on packaged foods.

Helpful or misleading?

There was a great deal of disagreement in most groups as to whether ‘fat free’ claims were helpful or confusing when they were placed on foods which have never contained the claimed nutrient, such as ‘fat free’ marshmallows or other confectionary items; and foods that were felt to have a substantial nutrient trade off, such as ‘fat free’ diet yogurt that they had assessed was higher in sugar than most other yogurts. In most groups a few participants took strong objection to claims being used in this way, because they felt it was misleading ‘other’ consumers into thinking they were buying a product that was healthier than it actually was. At this point in the discussion, one or two other participants in these groups admitted to using claims in this way, and a couple admitted to having inferred that ‘free’ claims meant that they could eat that food in virtually unlimited amounts.  

The extent to which this claim was viewed as unhelpful or misleading depended on the product example. In the case of confectionary, some felt the claim was still useful as it helped to identify a ‘better’ choice in an ‘unhealthy’ or ‘treat’ food category. However in the yogurt example, where the product may be consumed more frequently as a ‘staple’ food, there was more widespread concern that people could be eating this food for its ‘fat free’ qualities, and be completely unaware that it is much higher in sugar than ‘standard’ yogurt.

10  ‘ % fat free ’ claims

10.1 Background and context

In the Draft Assessment Report for P234 (Criteria and conditions for making nutrition content and related claims), ANZFA (now FSANZ) recommended that ‘% fat free’ be permitted if it meets the requirements for ‘low fat’ claims. Please refer to Appendix D for CoPoNC criteria related to this nutrition content claim.

The examples of ‘% fat free’ claims used in this study were ‘100% fat free’, ‘99% fat free’, ‘98% fat free’, ‘97% fat free’, ‘96% fat free’ and/or ‘94% fat free’.   Participants used the moderator’s showcard and real product examples as references during the discussion, as well as examples they recalled from their own experiences.

10.2  Familiarity with and use of ‘% fat free’ claims

All consumers, in all groups were familiar with these claims, which like ‘free’ claims, are being used more extensively by them. They were most commonly recalled being on yogurts, milks, frozen meals, salad dressings and rice crackers. Its wide use was particularly due to the fact that fat is the most commonly observed nutrient.

10.3  Attitudes towards and understanding of ‘ % free ’ claims

Consumers in all groups felt positively towards ‘% fat free’ claims, even more so than they did about ‘fat free’ claims, because they were more definitive and therefore viewed as more reliable.  

“…like for me, if they give a percentage, that is measurable, very clear cut, quantifiable statement.”[NZ, upper SES, highly & moderately health conscious, 45-64 yrs]

Generally participants felt that if a manufacturer was prepared to state a percentage of fat free there was less room for ambiguity because the company was required to be honest in this declaration. The majority of participants therefore felt that one was least likely to be misled by a ‘% fat free’ claim, so it was consequently viewed as helpful and useful. Others felt that a percentage-based claim gave the product, and the manufacturer, more credibility.

“that one to me with the percentage is actually saying that they have done their homework and gone that extra step to actually finding out for you the consumer how much really is in there.   So yeah, something that is saying that to me that they have gone that little bit further and they have made the effort to back themselves up”[NZ, lower SES, special health needs, 25-44yrs]

Another benefit of ‘% fat free’ claims was that they made comparison between products much easier than comparative claims.

Limitations and confusion

The most commonly raised limitation of ‘% fat free’ claims was that the claim does not immediately tell the consumer how much fat is in the product. Cynical consumers questioned why a manufacturer was telling them how much of a nutrient wasn’t there, instead of how much was, however most acknowledged the marketing advantage of a high ‘% fat free’ claim.  

Only those most ‘active’ inquirers were making reverse calculations when they looked at a ‘% fat free’ claim, to ascertain the actual % fat of the product.   Whilst many participants had broadly understood that 99% and 98% ‘fat free’ claims are lower in fat than 96% and 94% ‘fat free’ foods, only highly experienced or informed inquirers (one or two consumers in most groups) viewed a ‘94% fat free’ claim as having approximately twice as much fat as a ‘97% fat free’ claim.  

In this way, most consumers were looking for high numbers in ‘% fat free’ claims, such as ‘99% fat free’; very few consciously looked beyond the percentage to think about the amount of fat they would be consuming from the product.

The researchers hypothesise that some, if not many, inquirers are overly confident about their ability to accurately verify a ‘% fat free’ claim in terms of its relative fat content.   This hypothesis is partly informed by the findings in the previous quantitative research [2] , where three quarters of consumers (75%) said that the ‘94% fat free’ term meant that the food was a ‘low fat food’, where as only 16% correctly described it as a ‘medium fat food’ (as defined in the Code of Practice on Nutrient Claims in Food Labels and in Advertisements).

Some consumers were confused by or sceptical about ‘% fat free’ claims because they did not know or did not trust how the percentage fat is calculated.  

“it doesn’t really matter whether it says 99 or 94, it still means that it is in there, there could still be heaps of fat, as you said, how do they work out that percentage, are they just going by how much is in that bottle of mayonnaise?”[NZ, lower SES, special health needs, 25-44yrs]

Price / fat trade off

When choosing between ‘% fat free’ products, consumers were often making a price/’% fat free’ trade off, particularly between products that were perceived to be more closely fat free, such as those that are 94% or more fat free. For example if the ‘99% fat free’ product was a lot more expensive than the ‘97% fat free’ product, they would choose the ‘97% fat free’ version. However, if price was equal they would select the product that had less fat, no matter how much less it contained. In this regard, a product with a ‘99% fat free’ claim was deemed better than a product that was ‘94% fat free’.

10.4  Minimum standards for ‘% fat free’ claims?

Overall, participants were divided in their view about minimum amounts for ‘% fat free’ claims. Most had to think about the question for some time before they were able to offer a recommendation, demonstrating that this was not an issue that they had given any thought to previously, or that had concerned them in the past.

The majority of consumers felt that a ‘% fat free’ claim below 90% was misleading and should not be permitted. However about a third of participants, had no strong feeling that a minimum was necessary at all. These consumers regarded any percentage as a legitimate ‘% fat free’ claim as the percentage spoke for itself and they, as the shopper, could decide from the declared percentage if they wished to buy the product. For some of these participants, it was felt that there could be no appropriate minimum limit, as it would depend on the product’s initial or intrinsic fat content. It was suggested, for example, that some cheeses labelled ‘ 70% fat free ’ may well be a useful claim for consumers, as it pointed out a healthier choice, where as ‘90% fat free’ on milk would not be viewed as a good choice relative to other milks.

Another suggestion was making the minimum standard an amount significantly lower than the reference food in that product range. This would mean that milk, for example, should not be able to carry a ‘96% fat free’ claim as ‘regular’ milk is normally 4% fat, but that 98% and 99% ‘fat free’ claims would be permissible in this case.

10.5 Views about disclaimers for ‘% fat free’ claims

The benefits of using a disclaimer such as ‘this is a low fat food’ in conjunction with a ‘% fat free’ claim were explored.  

Whilst most consumers understood the intent behind such a disclaimer, and did not object to it, it wasn’t viewed as particularly necessary or useful by inquirers who already knew that a ‘% fat free’ claim did not always mean the product was low fat. In their view, most people are able to work out for themselves whether the product is low fat, by using the NIP to compare products.

At the root of this view was the assumption that the term ‘low fat’ is a relative and highly subjective term, that only makes sense in comparison with other foods which may be ‘lower’ or ‘higher’ in fat.   There was no awareness that the term ‘low fat’ is defined around a regulated amount of fat. Therefore, for believers or less informed inquirers, a disclaimer statement was also of little use, because the term ‘low fat’ is not well understood.

Therefore for such a disclaimer to be useful, consumers would need to be firstly educated about its introduction and what the disclaimer actually means.   Many consumers foreshadowed that unless they knew to look out for such a disclaimer, they probably would dismiss it as more manufacturer advertising, and would not assume that a food that did not carry a disclaimer was not a low fat food. As well, the researchers observed from the discussion that the format and size of the disclaimer would need to be strictly prescribed, otherwise it probably would not be noticed by consumers at all.

11.1   Background and context

Current scientific evidence suggests that greater emphasis should be placed on reducing the intake of saturated fats, rather than dietary cholesterol as a strategy to reduce coronary heart disease. ANZFA (now FSANZ) therefore proposed in the Draft Assessment Report for P234 that cholesterol claims (‘low in cholesterol’, ‘reduced in cholesterol’, ‘cholesterol free’) be prohibited, in order to avoid confusing consumers. This study therefore focuses on consumers’ attitudes towards and their perceived usefulness of these claims. Please refer to Appendix D for CoPoNC criteria related to this nutrition content claim.

Participants used the moderator’s showcard and real product examples as references during the discussion, as well as examples they recalled from their own experiences.

11.2  Familiarity with and use of cholesterol claims

Only consumers with a special interest in blood cholesterol or heart disease, or those in the upper age group 45-64yrs paid any attention to cholesterol claims. Whilst quite a few other participants were familiar with the various cholesterol claims, most dismissed or paid no attention to them whilst shopping.   In the context of a consumer’s ‘significant nutrient(s)’ cholesterol is very much a low or no-priority for most. This was particularly true for younger participants, who felt that watching one’s dietary cholesterol was not important until much later in life. Amongst younger participants there was no obvious understanding of the difference between blood and dietary cholesterol.

Amongst those consumers in the study that did have special health needs associated with blood cholesterol or heart disease, there was a high level of label-education and capacity to use the NIP to evaluate products. Our study included people with newly diagnosed cholesterol-related conditions, as well as those who had been monitoring cholesterol for a number of years. Whilst all were familiar with cholesterol claims, very few based their product assessment and selection solely on these claims. Most used the NIP to assess the amount of saturated fat in the product and based their product choice on this information.

11.3 Understanding of cholesterol and coronary heart disease

Across all groups in which cholesterol claims were discussed, everyone understood that cholesterol in food was ‘bad for you’ and most participants had a vague awareness that blood cholesterol had something to do with fat. There was a general view that foods that are low in cholesterol are also low in fats.  

The level of understanding about the difference between dietary and blood cholesterol, and the relative importance of blood cholesterol, fat and saturated fat in relation to coronary heart disease varied depending on a consumer’s information source. Those that had been advised to lower their cholesterol by a GP or dietitian were well informed, and familiar with the concepts of ‘good and bad fat’, and ‘good and bad cholesterol’. Saturated fats were regarded as the ‘bad’ fats, polyunsaturated and mono-unsaturated were ‘good’ fats, and a few of these participants had a sketchy knowledge that omega-3s were also ‘good’. They had clearly been informed about how dietary cholesterol impacts on blood cholesterol, and some referred to terms such as ‘HDL’ and ‘LDL’ or ‘the lowering cholesterol’ but no one was able to explain to the group exactly how it all worked.

Nonetheless, most of these consumers understood how to use the NIP to assess a product as a ‘good’ or ‘bad’ choice, and their assessment was usually determined based on the amount of saturated fat in the product. For these consumers, cholesterol claims, or amounts of cholesterol declared in the NIP were secondary, if not superfluous.  

For the remainder of blood cholesterol-conscious consumers, their knowledge was much less accurate, and their reliance on cholesterol claims was greater.   Some of these participants had a vague understanding of ‘good’ and ‘bad’ cholesterol, but not much more.  

11.4 Attitudes towards and usefulness of cholesterol claims

Consumers with medically diagnosed cholesterol conditions found fat claims, and saturated fat information in the NIP of more use than cholesterol claims.   Amongst these participants, as well as those who are cholesterol-conscious, the only cholesterol claim that was deemed ‘reliable’ is ‘cholesterol free’.   ‘Reduced cholesterol’ and ‘low cholesterol’ claims were viewed as roughly the same thing, and just advertising, whereas a ‘cholesterol free’ claim was assumed to reliably indicate that the product contained no (zero) cholesterol.

A few participants were concerned that cholesterol claims give the consumer a false sense of security. They cited examples of people they know who have inferred from the claim that the product is now ‘healthy’ and can be consumed much more liberally.  

“sometimes it leads you astray.   I know my Dad has a cholesterol problem and Mum buys low cholesterol rah rah rah and you’ll see him, and he’ll use twice as much cause it’s healthy for him…sometimes I wonder if it’s giving people that false safety net.”[Aust, low SES, highly health conscious, 24-44yrs]

The range of cholesterol claims could be reduced, if not removed entirely

When it was suggested to participants that fat and saturated fat information might be more useful than cholesterol claims, there was a strong but mixed reaction.

Those with diagnosed cholesterol and heart disease conditions agreed, and confirmed again that they already pay limited attention to cholesterol claims, and base their decisions on the saturated fat information in the NIP. For this group of consumers, the removal of cholesterol claims would not matter, although they felt it would be advisable to inform the medical and dietetic professions, who advise consumers on how to read labels, if such a change was introduced.

Those who are regular or infrequent dietary cholesterol ‘watchers’ did not support the removal of cholesterol claims. These consumers tended to rely more heavily on such claims, and did not understand the importance of saturated fat, rather than dietary cholesterol, in preventing heart disease. However, these consumers still found the range of cholesterol claims confusing, and did not know how to distinguish between ‘reduced cholesterol’, ‘low cholesterol’ and ‘cholesterol free’ claims. For this group of consumers, one claim only would be preferable, and the ‘cholesterol free’ claim was deemed most useful.

There is a smaller group of consumers who would be frustrated and confused by the carte blanche removal of cholesterol claims, as it would be interpreted as yet another change of mind about what is and isn’t good and bad for you. These people felt that nutrition information and dietary recommendations are changing constantly, and were exhausted and angered by having to always keep up with new label information and health regulations. These people repeatedly drew on the butter/margarine debate as an example, as well as ‘cholesterol free’ claims on avocados.

Others again, who were not cholesterol ‘watchers’ themselves, were concerned that the removal of cholesterol claims would disadvantage those who did monitor their cholesterol intake. People who did not use cholesterol claims themselves nonetheless assumed that these claims are important to others, and afford a great deal of trust to them.

12  Carbohydrate and protein claims

The examples for carbohydrate and protein claims used in this study were the terms ‘high in’, low in’ and ‘source of’. Please refer to Appendix D for CoPoNC criteria related to this nutrition content claim. Participants used the moderator’s showcard and real product examples as references during the discussion, as well as examples they recalled from their own experiences.

Although carbohydrate and protein claims were not viewed as the same thing, both were associated with sports and energy drinks and powders. They were considered only relevant or applicable for people who had significantly greater energy or body weight needs, such as athletes and body builders.

A couple of participants, in different groups, reported having bought protein powder products for themselves or their teenage children, because they felt they were under weight. Most however either ignored these claims, or avoided them because they felt they should be getting adequate protein and carbohydrate from their diet. There was no interest, across the groups, for foods that made specific claims in either of these nutrients.

There was an indication, based on the comments of one or two participants in a couple of groups, that an increase in carbohydrate claims would result in consumers, and particularly parents, paying more attention to the sugar information in the NIP. These consumers made an assumption that energy drinks and other high carbohydrate foods could also be high in sugar, and they would therefore would be inclined to assess the NIP to ascertain what proportion of total carbohydrates were made up of sugar.