Evaluation report Series No. 5
This study was conducted to gain qualitative information from consumers to assist FSANZ in the future development and review of food labelling standards, codes of practice and guidelines. In particular, FSANZ has a need for information to assist in determining:
- the most appropriate criteria and conditions for making specific nutrition content claims, whilst ensuring consistency between Australia and New Zealand; and
- the possible labelling requirements for food type dietary supplements (FTDS) from a consumer perspective.
Two concurrent studies were commissioned from NFO Donovan Research that address each of these objectives. This report deals with the findings of the first study, which explored consumers’ familiarity and use of eight different types of nutrition content claims. The study was also intended to explore the feasibility and usefulness of disclaimers in assisting consumers’ trust and understanding of such claims. Lastly, the study examined whether other forms of nutrition information on the label, such as the nutrition information panel (NIP) are used in conjunction with nutrition content claims.
The research was conducted with consumers in Australia and New Zealand, via ten focus group discussions. Participants were selected on the basis of their level of health consciousness, in terms of their food buying, as well as demographic and geographic characteristics.
The results show that many consumers in this study are highly engaged in reading and investigating nutrition content claims. Most participants fell into one of three ‘types’ of shoppers, when it comes to using nutrition content claims: ‘inquirers’, ‘believers’ and ‘non-users’. The majority of consumers were inquirers; however consumers in this largest group varied in the amount of effort they put into claim inquiry, and the appropriateness of the decisions based on their inquiry.
Claims in general
Nutrition content claims can provide the impetus or permission to pick up a new product; a quick way to find the product again during repeat purchase; and/or quick way to avoid the product, because it is considered to be of inferior taste or quality to the ‘regular’ version. Such claims are used as a guide when assessing a product for the first time, rather than taken at face value. The majority of consumers voluntarily made a clear distinction between information on the front of the pack (advertising) and on the back of the pack (the facts). Nutrition content claims on the front are usually verified, via the NIP on the back, to determine whether the claim is ‘correct’ and/or to assess the nutritional value of the whole product. However price, taste, and a consumer’s intended use for the product can over-ride any health and nutrition benefit.
Most consumers in this study had an underlying level of scepticism and cynicism about nutrition content claims and the intention of manufacturers in using them. It was widely assumed that nutrition content claims should not be trusted, implicitly, and that manufacturers are using claims to persuade them to buy a product, rather than simply inform them about the product.
Although the use and verification of a nutrition content claim can be a highly involved process, it is usually done only once for each particular brand and product, after which the claim is either trusted or accepted and then used to identify the product as a suitable selection for repeat purchase, or it is avoided because it failed to offer an acceptable taste trade-off.
Comparative Claims – ‘reduced’, ‘increased’ and ‘less than’
Research participants were highly familiar with the various comparative claims included in this study. More than any other type of nutrition content claim, it was felt that comparative claims required verification by using the NIP. This was because the comparative claim terms were regarded as too generic to be useful in their own right. For most consumers in this study comparative claims implied that the product was healthier than the ‘original’, but not necessarily a healthy or better choice. There was a high level of scepticism about these terms in all groups, and a great deal of confusion between these and other terms common to them, such as ‘low’, ‘lite’ and ‘diet’. The ‘reduced’ claim was understood to mean lower than the ‘normal’ version. Generally consumers were more sceptical about this term than ‘low’, but found it difficult to distinguish between them. The claim ‘increased’ was less familiar to consumers, because it is usually associated with nutrients of less significance to them. Consumers were much less sceptical about ‘increased’ and ‘less than’ claims, as long as they were used in a quantified context.
All consumers in this study were familiar with ‘free’ claims, which they are using more extensively. In comparison to comparative claims, ‘free’ claims are viewed much more favourably, because they are not making any sort of comparison to any other food, and are viewed as more helpful and more definite than claims like ‘reduced’ or ‘low’. All participants came to the unanimous decision that ‘free’ should mean ‘zero’, although some felt it was unlikely that this was how manufacturers used the term. There was also universal agreement that ‘free’ should be based on absolute absence and not nutritional insignificance. 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.
‘% Fat Free’ Claims
All research participants were familiar with ‘% fat free’ claims, which, like ‘free’ claims, they are also using more extensively. Consumers felt even more positively towards these claims than they did about ‘fat free’ claims, because they were more definitive and therefore viewed as more reliable. The most commonly raised limitation of ‘% fat free’ claims was that the claim does not immediately reveal how much fat is in the product. Very few consciously looked beyond the percentage to think about the amount of fat they would be consuming from the product. The majority of participants felt that a percentage ‘fat free’ below 90% was misleading and should not be permitted.
Overall, very few consumers paid any attention to cholesterol claims. Those most attentive to these claims were consumers with a special interest in cholesterol or heart disease, or those in the upper age group 45-64yrs. Participants in this study that did have special health needs associated with cholesterol or heart disease demonstrated a fairly good capacity to assess cholesterol and other claims, using the NIP to evaluate the suitability of the product for themselves. Most used the NIP to assess the amount of saturated fat in the product and based their product choice on this information. 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 is deemed ‘reliable’ is ‘cholesterol free’.
Carbohydrate and Protein Claims
Most participants reported to pay little attention to carbohydrate and protein claims, and do not regard foods carrying these claims as being of interest ore relevance to them. 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.
‘No added’ Claims – ‘no added sugar’, ‘no added salt’, ‘unsweetened’
The ‘no added sugar’ claim was most familiar to consumers, compared to ‘no added salt’ and ‘unsweetened’ claims. The meaning of ‘no added’ was unequivocally understood to mean that the product had only ‘natural’ sugar or salt, with nothing added. It was also widely understood that ‘no added’ claims did not imply that the product had ‘none’ of the nutrient in question. Research participants were far less sceptical of ‘no added’ claims than most other claims, and use of the NIP to verify ‘no added’ claims was therefore less necessary. ‘Inquirers’ and those consumers with special health needs felt that disclaimers, that made reference to the NIP or to the presence of ‘natural sugar or salt’, were unnecessary for ‘no added’ claims. However other consumers responded positively to the disclaimer ‘contains natural salt/sugar’ because it removed the ambiguity by clarifying whether the product was sugar or salt ‘free’.
Light/lite’ claims were widely recognised and used within their perceived limitations. ‘Inquirers’ were overwhelmingly negative towards these claims, viewing them as ambiguous, misleading, confusing and/or outright ‘trickery’. Most consumers in this study did not know what characteristic or nutrient the claim referred to, and by default would assume that it referred to the nutrient in the food that most needed reducing, in most cases fat. The overwhelming majority of consumers in this study were in favour of a disclaimer that identifies the nutritional or non-nutritional characteristic of the food to which ‘lite/light’ refers. The addition of such disclaimers was felt to be important, and would increase participants’ understanding of the ‘light/lite’ claim, and its credibility.
This claim was viewed as the least trustworthy and most ambiguous of all claims, and mostly irrelevant to consumers in this research. It was used least, and was mostly associated with weight loss products and therefore deemed useful only for people who are on weight loss ‘diets’. Most consumers had strongly negative views about this claim.
Additional Disqualifying Criteria
Overall, the concept of additional disqualifying criteria was not well supported. Apart from one or two ‘inquirers’ in each group, who strongly agreed with the concept of disqualifying criteria, the majority of participants felt that the two examples used in this study were unnecessary. Consumers on the whole felt capable of deciding for themselves whether a product was an overall healthy choice for them. Whilst disqualifying criteria relating to the claimed nutrient was seen by some participants as important or reasonable, this view was far from widespread. The rationale for disqualifying products that are high in a nutrient other than the one they have made a claim about was not well understood, and universally not supported.
A Need for Education
This study has identified a need to inform and educate consumers about nutrition content claims. Consumers are looking for standardisation and agreed meaning behind the various words and terms used in content claims. They are confused and frustrated because there is no common consumer understanding of terms such as ‘high’, ‘low’, ‘reduced’, ‘source of’, ‘light’ etc. There is also no awareness or understanding that there are ‘rules’ around the use of nutrition content claims, and that most nutrition content claims do have meaning that is commonly understood by manufacturers.
In some cases participants were overly and unnecessarily critical of manufacturers and nutrition content claims because they were unaware that recommended standards and limits are applied, through the current Code of Practice on Nutrient Claims in Food Labels and in Advertisements. Most have assumed the terminology and wording of nutrition content claims is haphazard and ad hoc, determined by what is popular, and therefore most attractive to manufacturers rather than consumers.
In addition, regulatory authorities may wish to give consideration to the advantages (and disadvantages) of consumers’ current distinction between information on the front and back of food packages, as this will have implications as to where new labelling requirements should be positioned.
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