Qualitative consumer study related to nutrition content claims on food labels
Results - Part C
14 ' Lite' and ' Light' claims
13 ‘ No added ’ claims
13.1 Background and context
Consumer groups have expressed concern about consumer confusion with ‘no added sugar(s)’, ‘unsweetened’ and ‘no added salt/sodium’ claims. ANZFA (now FSANZ) recommended in the Draft Assessment Report for P234 that a disclaimer should be placed on the label in conjunction with the claims to draw attention to the natural sugar or salt/sodium content of the product. 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.
Key finding: The ‘no added sugar’ claim was the most familiar of the three 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. It was also clear that ‘unsweetened’ meant the product had no artificial sweeteners, as well as no added sugar. Consumers 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 with special health needs felt that disclaimers were unnecessary, as they already use the NIP as needed. Others however responded positively to the disclaimer ‘contains natural salt/sugar’ because it removed the ambiguity by clarifying whether the product was sugar or salt ‘free’. |
13.2 Familiarity with and use of ‘no added’ claims
‘No added sugar’ and ‘unsweetened’ claims were looked for on canned fruit, juices and cordial. ‘No added sodium/salt’ claims (referred to as ‘no added salt’) were sought on chips, baked beans, and canned vegetables.
Everyone was familiar with all three types of claims, however the ‘no added sugar’ claim was the most regularly looked for. The ‘unsweetened’ claim was sometimes distinguished as being taste-related (a less sweet taste) rather than nutrient-related, and as such, was looked for on foods that were to be used as ingredients in meal preparation where the desire for a less sweet or sweeter flavour was driving the choice of product.
13.3 Understanding and credibility of ‘no added’ claims
In all but one group the meaning of ‘no added’ was unequivocally understood to mean that the product had only ‘natural’ sugar or salt, with nothing added.
“whatever is there is there, but they haven’t actually added anything”[Aust, lower SES, special health needs, 45-64yrs]
This was seen to be analogous with ‘natural juice’.
It was also widely understood amongst consumers in this study that ‘no added’ claims did not imply that the product had ‘none’ of the nutrient in question. There was however an underlying feeling, not expressed openly, that these products would be ‘low’ in the claimed nutrient, certainly lower than products that did not carry a ‘no added’ claim, and most probably healthier as well.
The researchers speculate that this ‘underlying’ expression of uncertainty may well be more concrete than participants were prepared to acknowledge in the discussions. Once again drawing on the previous quantitative research [1] , almost one third of consumers (28%) said that the ‘no added sugar’ term meant that the food contains no sugar, another third (30%) said that it contains small amounts of sugar, and only 38% said that it could be either a low, medium or high sugar food (the correct response).
In the group discussions on this issue quite a few participants were prepared to tolerate relatively high amounts of sugar in fruit products that carried a ‘no added’ claim, and in one case described below, defended the amount of sugar in the product, against the claim.
“it is probably the same if you canned them yourself”[Aust, lower SES, special health needs, 45-64yrs]
“like fruit juices, even natural fruit juices have a fair bit of sugar in them”[Aust, low SES, highly health conscious, 24-44yrs]
“all fruit has at least some sugar in it, but they haven’t put any extra in during the canning”[NZ, lower SES, special health needs, 45-64 yrs]
However, one New Zealand group were more uncertain than all others as to the true meaning behind ‘no added’ claims, and there was much more disagreement about whether the claim meant the food contained the claimed nutrient at all. The uncertainty was raised by a couple of consumers citing examples of canned foods that carried a ‘no added’ claim, but declared an amount of the nutrient in the NIP, or the ingredients list.
A different but isolated query was whether the ‘no added’ claim referred to just the food itself, such as the corn in ‘no added salt’ canned corn, or whether it also included canning and packing agents such as brine which they felt would have an impact on the salt content and salty flavour of the end product. In this case there was uncertainty as to where the line was drawn in terms of claiming to not have added a particular nutrient.
At the same time 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’.
Every group decided fairly quickly that ‘unsweetened’ and ‘no added sugar’ did not mean the same thing, and were clear that ‘unsweetened’ meant the product had no artificial sweeteners, as well as no added sugar [3] . In contrast, they felt a product with a ‘no added sugar’ claim could still be artificially sweetened. One confectionary product provided as an example for the group discussion carried the term ‘sugarless’ on the back of the pack, as well as a ‘sugar free’ claim on the front. This term was viewed initially by the group as adding further confusion, because it added yet another sugar term, which had an unclear definition, although the group quickly agreed that it implied the product, had no sugar at all. However they did believe that it was artificially sweetened .
The NIP is used less to verify ‘ no added ’ claims
Consumers were generally 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. Those who were more trusting of claims in general felt they would rely solely on the ‘no added’ claim to make a product decision. Nonetheless many participants, and particularly those with a special health need, did report having used the NIP at some stage to gain further information. This was often when a ‘no added sugar’ claim was used in conjunction with an ‘in lite juice’ or ‘in natural juice’ or ‘in clear juice’ type statement.
‘ Light ' juice vs ‘natural ’ juice
The terms ‘light juice’ and ‘natural juice’ were discussed in the context of ‘no added sugar’ claims. The term ‘light juice’ was ambiguous and participants were unable to agree whether the claim implied less or more sugar than ‘natural’ juice. One isolated view was that the claims differed in the type of sugar that was in the product – natural sugar versus another type of sugar.
“I want to know what is in the light juice’ [Aust, low SES, highly health conscious, 24-44yrs]
Others found the term ‘natural’ juice more appealing than ‘no added sugar’ because they felt it inferred that there were no artificial additives or preservatives in the food. There was a feeling amongst these participants that preserved foods would have reasonably high levels of some sort of preserving agent, and that if they were low in sugar, it must be high in either salt, or chemical preservatives.
One way in which ‘no added sugar’ claims were regarded as potentially misleading was when they are wrongly assumed to indicate a low sugar product, when the product still contains a high amount of intrinsic sugar. One participant, who was a person with diabetes, referred to having been given ‘no added sugar’ jam, which on closer inspection he discovered was not a suitable product for him.
There was some frustration from a few cynical participants as to where the term ‘natural salt’ came from.
13.2 Views about disclaimers for ‘no added’ claims
Three potential disclaimers were explored:
1. ‘see Nutrition Information Panel on back’;
2. ‘Contains natural sugar(s)’ / ‘Contains natural salt/sodium’; and
3. ‘Contains natural sugar(s) – see panel on back’ / ‘Contains natural salt/sodium – see panel on back’.
Inquirers and consumers with special health needs felt that disclaimers were unnecessary, as they already use the NIP as needed. The disclaimers that made a reference to the NIP were deemed least necessary. One view was that claims were advertising, and therefore it wasn’t up to the manufacturer to qualify its claim on the front of the pack.
“I think it is good they have the panel, and the ingredients listing. That is enough information.”[Aust, low SES, highly health conscious, 24-44yrs]
Others however responded positively to the disclaimer ‘contains natural salt/sugar’ because it removed the ambiguity by clarifying whether the product was sugar or salt ‘free’. They felt strongly that it should appear on relevant products that carry a ‘no added claim’.
Participants felt that a disclaimer in this context would need to be of adequate font size and colour so that it is noticed and can be easily read by shoppers who do not take their glasses with them to the supermarket. They also believed that the font size and colour of the disclaimer would need to depict equal importance as the ‘no added’ claim itself, but would not necessarily have to be the same size.
[1] Food Labelling Issues: Quantitative Research with Consumers. FSANZ Evaluation Report Series No 4
[2] Food Labelling Issues: Quantitative Research with Consumers. FSANZ Evaluation Report Series No 4
[3] The definition of ‘no added sugar’ is regulated by clause Al(10) of the Food Standards Code, which prohibits the claim unless the food contains no added sugars as defined in Standard Kl, and no added honey, malt, malt extract or maltose. The definition of ‘unsweetened’ is the same as that for ‘no added sugar’ in addition prohibiting the claim unless the food contains no added artificial sweetening substance and no added sorbitol, mannitol, glycerol, xylitol, hydrogenated glucose syrup or isomalt.
14 ‘Lite ’ and ‘Light’ claims
14.1 Background and context
A qualitative consumer study commissioned by the then ANZFA (2001) indicated that people were sceptical of ‘lite’ claims. There was confusion over the meaning of ‘lite’ and how it related to other claims such as ‘free’. 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.
Key findings: 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 did not know what 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 majority of consumers 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 were felt to be important, and would increase both participants understanding of the ‘light/lite’ claim, and its credibility. |
14.2 Familiarity with and use of ‘lite/light’ claims
‘Light/lite’ claims were recognised by all participants, and were regarded as widely used by manufacturers, particularly on products such as cheese, yogurt, milk, cereals, icecreams, canned fruit, crisps, olive oil etc.
These claims were used frequently by participants, at least to initially pick up a product before examining the NIP.
14.3 Attitudes towards and understanding of ‘lite/light’ claims
Attitudes towards ‘lite/light’ claims depended on a participant’s level of interest in and awareness of labelling in general. Inquirers were overwhelmingly negative towards these claims, viewing them as ambiguous, misleading, confusing and/or outright ‘trickery’. Many consumers were least trusting of this claim, compared to all others. The views of many of these participants had been informed by ‘expose’ type television programs and magazine articles that talked about the ambiguity of the meaning of the claim. However less well-informed or label-educated consumers regarded ‘lite/light’ claims as an attractive and easy way to identify a healthier version of the product. Most of these consumers assumed that the claim referred to macronutrients such as sugar and fat.
However, by far the majority of participants were uncertain, and many were confused, about what the ‘lite/light’ term referred to. The following conversation indicates the lack of consensus amongst consumers in this study typically felt.
“it is everywhere, but what does light mean?’
“low calorie”
“low fat”
“low in alcohol?”
“low in sugar”
“but when it is on a product it doesn’t mean it is light in all of the above, it might be light in one of those particular things”[Aust, lower SES, special health needs, 45-64yrs]
In several other groups both in Australia and in New Zealand, participants discussed the example of ‘lite/light’ olive oil, which they had each initially assumed to mean ‘light in fat’ but had later found out meant light in colour. Other examples where ‘light’ was now known to refer to colour included soy sauce and fruitcake.
In the absence of any clarity as to the meaning of the ‘lite/light’ claim, most consumers would assume that the claim referred to the nutrient in the food that most needed reducing, and the default assumption was that ‘lite’ referred to fat.
“I feel like I’ve been conditioned that L I T E is referring to fat”
Quite a few participants, and particularly those in the older age group 44-65yrs objected strongly to the spelling of ‘lite’ and deliberately avoided products that carried this claim. The term, spelt this way, was viewed as meaningless, and exacerbated the consumer’s frustration with what they felt is an already ambiguous term.
There was a general view in the groups that the term ‘light/lite’ should not be allowed to stand alone, and that it made much more sense when it was accompanied by a comparative claim, such as “has less fat than our normal icecream”.
14.4 Impact of disclaimers for ‘ lite/light ’ claims
The majority of consumers were wholeheartedly in favour of the use of a disclaimer, which identifies the nutritional or non-nutritional characteristic of the food to which ‘lite/light’ refers. It was agreed that such a disclaimer must appear in conjunction with the claim, and examples used and endorsed were ‘light in colour’, ‘light in fat’, ‘light in energy’.
The addition of such disclaimers was felt to be important. Participants believed disclaimers would increase their understanding of and trust in the ‘light/lite’ claim.
In order to notice and use a disclaimer the groups felt that it would need to be in a font and colour that made it equally as noticeable as the claim, though they did not feel that it was absolutely necessary that it had to be the exact size and colour of the claim.
The implication of permitting a smaller or less distinct font/graphic for the disclaimer, compared to the ‘lite’ claim itself, is that consumers will need to be informed about the introduction of the disclaimer so that they know to look for it. Once again, the design elements of the disclaimer should bear in mind that many consumers do not shop with their glasses.
15 ‘ Diet ’ 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.
Key finding: This claim was viewed as the least trustworthy and most ambiguous of all claims, and mostly irrelevant to consumers. It was also used least, and was 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. |
15.1 Familiarity with and use of ‘diet’ claims
The ‘diet’ claim was viewed as the least trustworthy and most ambiguous claim, and irrelevant to most consumers. Of all the nutrition content claims examined in this study, it was least used because it was associated with weight loss products and therefore only useful for people who are on weight loss ‘diets’.
The most top of mind example of a ‘diet’ claim was diet soft drinks such as ‘diet coke’ Many consumers also recalled having seen a diet yogurt product when it was introduced by the moderator.
15.2 Understanding of ‘diet’ claims
Most consumers had strongly negative views about this claim, mainly due to:
- an association that diet foods taste bad; and
- ambiguity about what the claim means.
The intention behind the claim was very much viewed as trying to make one feel better about the food choices they make that carry this claim:
“it means it’s gotta be better for you than coke”
“low fat is just reduced the amount of fat in it, or taken the fat out, whereas diet generally substitutes artificial sweeteners”
“to me, it might not even mean fat, you might be talking about sugar content. To me, diet means reduced sugar content” [Aust, upper SES, moderately health conscious, 25-44yrs]
Depending on the product category, diet meant different things. In soft drinks, ‘diet’ implied it was low calorie, had artificial sweeteners, but could possibly have some sugar in it, though less than the original product. In yogurt, it meant artificial sweeteners and less milk or fat.
However, many viewed it as a ‘nothing’ term, and similar to ‘light’ in terms of its ambiguity.
“to see diet on a can, it doesn’t mean anything to me, it is just a marketing ploy, what does it mean?” [Aust, upper SES, moderately health conscious, 25-44yrs]
Others viewed the term as being ‘old’ because it was non-specific, as opposed to more detailed claims such as ‘% fat free’ claims.
“you don’t’ see diet products around much any more, they are tending to be a lot of more specific, you know with their 99% fat free or that kind of thing., so I think they are realising people want more information, they want specifics on the box”.[NZ, upper SES, highly & moderately health conscious, 25-44 yrs]
16 Disclaimers and qualifying criteria
16.1 Background and context
Nutrition content claims provide indications about the level of a nutrient or energy in a food. They do not describe the overall nutritional value of a food. Participants in an ANZFA (2001) commissioned qualitative study were aware that a food might be low or high in a claimed nutrient or energy, but that the food may also contain undesirable levels of other nutrients. For example, some consumers recognised the concept of a fat/sugar trade off. The issue therefore arises as to whether any or all nutrition content claims should have disqualifying criteria. ANZFA (now FSANZ) recommended in the Draft Assessment Report for P234 that disqualifying criteria should be applied to fibre claims, to prevent manufacturers from making them if their product contains too much fat. This study explores the merit of disqualifying criteria more broadly.
Key finding: Overall, the concept of disqualifying criteria was not well supported. Apart from one or two very active inquirers in each group, who strongly agreed with the concept of disqualifying criteria, the majority of participants felt that disqualifying criteria were unnecessary. Consumers on the whole felt capable of deciding for themselves whether a product was an overall healthy choice for them. Disqualifying criteria were seen as important and reasonable when they were closely related to the claimed nutrient. However, the notion of 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. |
16.2 Views about disqualifying criteria
Overall, the concept of disqualifying criteria, other than for ‘lite’ claims, was not well supported or understood. There was, however, a range of views on this issue, which varied depending on the product and the criteria being considered.
Initially, many participants liked the idea of disqualifying criteria, and thought that they would help people who don’t read labels, because they would be more straightforward.
“it totally demystifies it, makes it completely clear”[Aust, low SES, highly health conscious, 24-44yrs]
More cynical participants felt that claims implied the foods were healthy, and that therefore people should be protected with disqualifying criteria that related to all nutrients, not just the claimed nutrient.
“Most people splash 100% fat free salad dressing all over the food not realising that the salt content is so high. They shouldn’t be able to make that claim so blatantly obvious when something else on the back is so high.”[Aust, lower SES, special health needs, 45-64yrs]
In each group there was one or two very active inquirers who strongly agreed with the concept of disqualifying criteria, which they felt would prevent less active inquirers and believers from being mislead by a content claim. Whilst these inquirers were very aware of nutrient trade-offs, they felt many other shoppers would not be so attentive, and would judge a food only on the content claim while not being aware that the product may well be less healthy in another way.
However after some thought, the issue of applying disqualifying criteria became quite complicated for most participants, as they struggled to understand how foods would be classified as warranting or not warranting disqualifying criteria. Many objected to the idea of classifying foods as ‘healthy’ or ‘unhealthy’ (in another way) and felt this was an impossible objective because people differ on how they wish to judge the ‘healthiness’ of a food. Within each group, participants were all looking for different things, and for different reasons. For example, one person was mostly concerned about salt, one about sugar, one about fat, while others were not concerned about fat or sugar in ‘treat’ foods (such as chocolate and biscuits), but they closely monitored their fat intake from ‘daily’ foods (like dairy and cereals).
The majority of participants didn’t feel that one claim suggested the product was healthy.
“If it said “low in carbohydrates”, I’d say that was the only claim they can make, I wouldn’t expect it to relate to any other claim.”[Aust, upper SES, moderately health conscious, 25-44yrs]
Although it was not a majority view, there was an expectation amongst quite a few participants that products were now labelled with all the health benefits they could offer, and so one could expect a product to be less healthy in a particular nutrient compared to similar products that made positive content claims. Therefore, there was no assumption, at least amongst the consumers in this study that a low fat claim meant the product was also a positive choice in terms of its sugar and salt content.
“If it is also low in fat, it would say it, they would shout it loud and proud.”[Aust, upper SES, moderately health conscious, 25-44yrs]
“I would expect them to label all the good things, I would never assume.”[Aust, upper SES, moderately health conscious, 25-44yrs]
In the end, the majority of participants decided that as long as there was enough information on the package to evaluate the claim, that was enough.
“That’s the consumer choice, it goes back to that.”
“It should be up to you to read it…to read Coco Pops, and disregard whatever, fat free or whatever, and then have a read of what is actually in it. You should be informed enough to know that advertising is purely to get people.”
“I guess the individual consumer, I think they do have to take responsibility, as long as the information is there and in a readable format…and I think you know if there is no fat then they are replacing it with sugar in most cases.”[Aust, low SES, highly health conscious, 24-44yrs]
Many participants also raised the question of how they would know if disqualifying criteria were introduced. Informing and educating consumers about the ‘hidden’ rules and regulations around labelling was felt to be very important. Many participants, at the conclusion of the group discussion, felt that they had learned a lot about interpreting and comparing content claims, and their guidelines. They wondered why consumers, as a whole, weren’t informed about what they had learned at the group, and felt it would make label reading and product choice easier.
16.3 Boundaries for disqualifying criteria
Although broadly speaking, consumers did not strongly support the idea of disqualifying criteria; they were more objectionable to having criteria on foods which they knew were less healthy but purchased nonetheless. This included ‘treat’ foods such as chocolates, sweets and lollies, biscuits and chips.They felt that these foods are generally eaten in small amounts, and less frequently. Content claims are therefore rarely looked for to make a ‘healthier’ choice as the decision to eat a less healthy food has already been made. Products carrying content claims in these categories are usually associated with a taste trade off, which is rarely worth the health benefit.
With the exception of ‘lite’ claims, which consumers strongly felt needed ‘qualifying’ criteria (rather than disqualifying criteria), there was no particular content claim that consumers felt was more in need of disqualifying criteria than any. Participants were most familiar with fat, salt and sugar trade offs, however the ‘undeclared’ trade off was seen to apply equally as likely to each of the content claims addressed in this study.
Because of the amount of information and range of content claims that had to be covered in this study, the topic of disqualifying criteria could not be addressed in great detail. Much of the discussion on this topic was taken up with explaining to consumers what disqualifying criteria meant, and how they would work. It is therefore difficult to draw conclusive findings about the support for, and dissenting views about disqualifying criteria. However it can be assumed that consumers saw no obvious need for such criteria and felt, on the whole, that they were capable of deciding for themselves whether a product was an overall healthy choice for them. Whether their self-confidence in their capacity to do this correctly is warranted cannot be speculated from this study. It is recommended by the researchers that further small-scale research, dedicated to this topic, be undertaken before final recommendations are made.
16.4 Reactions to specific disqualifying criteria
Reactions to two alternate types of disqualifying criteria were explored:
- disqualifying criteria that apply to nutrients or energy which relate to the claimed nutrient (e.g. limiting the saturated fat content permitted in a food when a nutrition content claim is made about fat);and
- disqualifying criteria that apply to nutrients or energy which don’t appear to relate to the claimed nutrient (e.g. limiting the fat content permitted in a food when a nutrition content claim is made about sodium);
Keeping in mind that man