On 28 July 2009, the Food Standards Agency (FSA) launched a consultation on its draft recommendations on saturated fat and added sugar reductions, and on portion size availability for biscuits, cakes, pastries and chocolate confectionery. The consultation addresses three different elements of the Saturated Fat and Energy Intake Programme: encouraging increased accessibility to smaller food portion sizes; encouraging more promotion and increased uptake of healthier options; and encouraging voluntary reformulation of mainstream products to reduce saturated fat and energy.
It is important to note that changing recipes to improve the nutritional content of manufactured foods is only one aspect of the solution to a very complex issue and that biscuits, cakes and pastry can be part of a healthy and enjoyable diet if consumed in moderation. The baking industry provides its consumers with information about the food they enjoy, and there is widespread commitment across different sectors to continue to develop better information provision, including clear and reliable back-of-pack nutrition information and, where appropriate, front-of-pack GDA labelling which also includes information on calories and saturated fat.
Variety is the spice of life
Consumer demand for product variety is part of what drives industry. Consumers are aware that different products are appropriate for different eating occasions. The sheer variety of products on the market allows them to choose what they want, on occasions that are appropriate for them. For example, a thickly coated chocolate or rich cream-filled biscuit might be more appropriate to serve to guests at a dinner party, or to have as an occasional treat, than to have daily dunked in tea at elevenses.
It is vital that regulators remember that although saturated fat reductions are possible, it is important to address the issue of reformulation in a more rounded way, ensuring consumer choice remains available. The implementation of recommendations that are too strict across the board would result in the undesirable cheapening of products and a move towards more uniform and less varied offers. An example of this is the 5% reduction recommendation for non-plain biscuits, which can only be achieved by reducing the amount of creams and/or coatings, as well as reformulating the dough.
Despite the FSA’s recommendations, it will be up to individual companies to assess what is possible for each of their products. This will depend on the technical challenges and solutions available and, most importantly, on what is compatible with maintaining consumer satisfaction, brand integrity and remaining competitive.
The calorie reduction challenge
The FSA consultation contains the following draft recommendation: "[Every saturated fat] reduction should be accompanied by a calorie reduction unless a technical case can be made that this is not achievable." This recommendation fails to recognise that alternative fat blends used to reduce saturated fat content will still contain, gram for gram, the same calorific value as the original saturated fat used making this recommendation impossible to achieve. The reduction of calories, therefore, needs to be recognised by the FSA as an additional challenge to be tackled via a different approach to saturated fat reformulation.
One way to reduce calories in fine bakery products is to use intense sweeteners and fat replacers. This means manufacturers would need additional time and resources to explore the availability, suitability and consumer acceptance of replacement ingredients an unrealistic task in the proposed timescale.
In addition, the use of intense sweeteners, regulated by Directive 94/35/EC, is not permitted in fine bakery wares unless for special dietary purposes. Therefore, changes would need to be made to ensure that manufacturers have the flexibility to use intense sweeteners as part of their reformulation strategies, if they decide to do so. Recent engagement with FSA officials on a proposed extension of the use of sweeteners in bakery and confectionery did not result in the support required at EU level to modify the legislation (see BB, 28 August).
Costs and timing
The costs associated with reformulation should not be underestimated, as companies have learnt through their experience with trans fat reductions. Some companies have already been able to deliver impressive saturated fat reductions for some of their lines, but this has only come about from considerable investments over a period of years rather than months, to allow for the technical challenges to be resolved and for the costs to be absorbed rather than passed on to consumers. The time-scale proposed by the FSA delivery of 10% reductions for plain biscuits and pastry and of 5% reductions for non-plain biscuits by 2012 does not appear to be realistic. Research and development, the implementation of new recipes, sourcing of new ingredients, changes in equipment and processes, all generate increases in production costs. Furthermore, there can be significant costs associated with the failure of some products with regard to consumer acceptance.
Many of the companies manufacturing BCCC products are SMEs and will find it even more challenging than larger companies to invest in major equipment changes. Another consideration is that a large number of biscuits and cakes consumed in the UK are imported and so would not necessarily be required to comply with the FSA-proposed recommendations, which would clearly disadvantage UK firms.
How would consumers know about the changes?
The Health and Nutrition Claims Regulation (EC) 1924/2006 could also, unwittingly, reduce the incentive to reformulate by restricting opportunities to make claims on-pack. This is particularly pertinent in relation to the legality of ’X% reduced’ claims. Manufacturers under-taking reformulation often cannot achieve reductions of 25-30% the current minimum conditions to make a claim on certain nutrients for technical or consumer acceptability reasons. The Food and Drink Federation is working closely with the FSA to ensure that such claims are included in the annexe, as a failure to do so would mean that claims such as "10% less saturated fat" would become illegal on 20 January 2010.
Although the FSA has stayed well away from calling its voluntary recommendations "targets", we believe they have taken an approach that is too prescriptive. We do welcome the initiative to address saturated fat reductions as a means of helping consumers stick to healthier diets, and we certainly want, as an industry, to be part of the solution to the state of the nation’s health. However, much more flexibility is needed to ensure that companies can move at different paces towards healthier products and also to ensure that the variety of products enjoyed by consumers is preserved.
Clear commitments by individual companies and technical support to smaller businesses are more likely to work than any list of percentages.
l Comments should be sent to the FSA by 3 November 2009