Clear Labelling Task Force recommendations on ideal label formats
Friday 8 March 2002
This advice has been drawn up by an ad hoc taskforce with a wide range of expertise, experience and interests.
1. The Food Standards Agency established the group in January 2001 to advise on what it might do to improve the clarity of food labels (see Annex I for terms of reference and membership of the task force). This was a reaction to consumer research showing that many consumers find labels hard to use. Responses to a public consultation also highlighted the problem.
2. The Task Force recognised that best practice advice such as this would have only limited effect on imported foods. It considered, however, that UK guidance could have a wider influence by encouraging adoption of EU guidance and hopes that the Agency, and UK industry, will press for development of such advice.
3. Clear labels gain further value if the user has the benefit of clear advice on how to use them. The Task Force encourages the Agency to give high priority to providing consumer advice and education on food labelling. This should include advising consumers to take up any difficulties with the manufacturer or their local authority trading standards or environmental health department.
4. The group has identified three areas of difficulty - finding information, reading it and understanding how to use it. The recommendations that follow tackle each of these issues.
5. The Task Force recognised that products necessarily come in all shapes and sizes and that their labels cannot be expected to conform to a single ideal format. Its approach has been to develop an ideal format which can be used on most products, supplemented by a 'second best' to be used where size and/or shape precludes use of the ideal. It recognised that some packs could not support even the 'second best'.
6. It has not developed detailed advice on how this tiered approach should be applied in practice. The advice should, the group feels, be 'tested in anger' before any further work is done on this point.
7. In drawing up its draft advice the group has taken account of existing guidelines, particularly those published by the Institute of Grocery Distribution. These have been particularly helpful in developing the section on print size and clarity.
8. The group recognises that some groups have special needs and has tried to take this into account. It has, however, concentrated its efforts on the needs of the majority.
9. The taskforce consulted the main trade associations, LACOTS and a number of consumer groups on draft recommendations and has taken their views into account (see Annex 2 for a list of those consulted). It recommends that advice to manufacturers and enforcement authorities on clear labelling should be as follows.
Grouping information on the label
10. Group the information that consumers need to make informed purchase decisions and use food safely together. Either do this on any single face of the pack and in a recognisable border, or in the same field of vision on the pack.
11. This information consists of:
- Name of the food;
- Net weight or volume;
- List of ingredients;
- Date mark;
- Nutrition information;
- Instructions for use and/or storage;
- Customer careline information (or other information about how to contact the manufacturer, packer or seller)
Customer careline or similar information is included here because of its value to those with visual impairment.
12. Where it is not possible to group the information listed in paragraph 11 together as described in paragraph 10, group it separately as follows and provide signposts between the two groups. Present the information in each group on the same pack face or, if that is not possible, in the same field of vision.
Group A
- Name of the food
- Net weight or volume
- Date mark
- Storage instructions
Group B
- List of ingredients
- Nutrition information
- Use instructions
The customer care line information or other information identifying the manufacturer/packer/seller may be placed with either group.
13. When grouping items as recommended in paragraphs 10 and 12, bear in mind that other statutory information may also need to be given with it (e.g. declarations about the presence of sweeteners, GM, or indications of irradiation).
14. Only use signposting (directing consumers to look elsewhere on the label for information) where absolutely necessary, make sure the wording of the signpost is clear and, if signposting more than one item of information, try to put all the signposted material in the same place.
15. Do not give health marks or lot marks unnecessary prominence or emphasis, as this may tend to mislead, for example as to the origin of the food.
16. Do not hide, obscure or interrupt essential information with any other written or pictorial matter.
Format of nutrition labelling
17. Although the law only requires nutrition information when a nutrition claim is made, it is of increasing interest to consumers. Some consumers find the format prescribed in law for both voluntary and compulsory labelling difficult to use.
18. The Institute of Grocery Distribution (IGD) has issued advice on ways of improving the presentation of this information within the current rules. The taskforce has discussed ideas for improved formats and recommended that they be consumer tested.
19. In the meantime it recommends following the IGD's advice on nutrition labelling.
Presentation of ingredient listing information
Allergens
20. Always include in ingredient lists the following major food allergens, or products derived from them that may also cause problems. Do not take advantage of exemptions for compound ingredients, carryover additives or processing aids for these ingredients:
- Peanuts;
- Tree nuts (almond, brazil, cashew, chestnut, hazelnuts, macadamia nuts, pecan, pine nuts, pistachio, walnut);
- Sesame seeds;
- Cows’ milk;
- Egg;
- Fish;
- Crustacea, molluscs, shellfish;
- Soya;
- Sulphite (in concentration of 10mg/Kg or more);
- Cereals containing gluten (wheat, barley, oats, rye, spelt or their hybridised strains)
Comprehensive ingredient listing along these lines will be required in EU legislation if a proposal currently under discussion in Brussels is adopted.
21. In addition the task force would like to see a more consistent approach to devices for drawing attention to allergens to make product selection easier for sufferers and their carers. It recommends using a separate allergy information/alert panel, in the form of a “contains” box. Since not all labels will adopt this device, advice to sufferers should continue to stress the importance of checking ingredient lists carefully.
22. Use simple language, drawing on the list at paragraph 14 above, for example using 'milk protein' instead of 'casein'. The IGD has issued useful advice detailing how to do this (available at www.igd.com).
23. Where separate allergen information is given you may wish to refer consumers to the ingredient list for more detailed information about the composition of the product and the presence of particular allergens.
Additives
24. The Task Force recognises that scientific names for additives (and some other ingredients) are difficult to understand. It believes that more work on this issue is needed and that little of value can be done without changing the law.
Print size and clarity
25. Do not hide, obscure or interrupt product information with any other written or pictorial matter. Make sure that all product information is easily visible and clearly legible.
26. Ideally use a font size of 10 point for the essential information in paragraph 11 wherever possible. If this is not possible, the absolute minimum for this information should be 8 point.
27. Where it is necessary to consider which information to give in 10 point and which in 8 point because of space limitations, priority should be given to retaining the name of the food, the date mark and the list of ingredients in 10 point and as much of the other information as is possible.
28. Where packs are physically too small or of a shape which cannot support 10 point type size it is paramount to address other factors. These will include ensuring that non-essential information (neither statutory nor in paragraph 11) doesn't take up unnecessary space, the type colour and font, and the layout of the label.
29. Use simple sans serif fonts with a good 'x' height and avoid ornate fonts or distracting effects, like shadowing.
30. Use the normal weight of the font for standard text, and bold for emphasis.
31. Do not use all upper-case letters or underlining for emphasis.
32. Only use italics for isolated words - do not use them for large blocks of text, or for small font sizes.
33. Use the 'range left' format, and avoid hyphenation and justified text.
34. Print essential information in black type on a white background. If this is not possible, make sure there is a good tonal contrast between the type (which should be dark) and the background (which should be light).
35. Avoid 'reversing out', except possibly for headings in a large font size (at least 12 point). In any event, only use it for white type on a black background.
36. Do not place images behind text ('watermarking').
37. Avoid the use of green and red together - it can be difficult to decipher. Strong colours work better than pastel shades.
38. Be careful when wrapping text around images - it can be difficult to read. In any case, always make sure the left-hand edge of the type is kept straight, and that wrapping the text doesn't produce a line length that only consists of two or three words.
39. Metallic and shiny surfaces make reading difficult. Try to use a matt-finish printing surface.
40. Simple icons can help direct consumers to information ('signposting'). This can be particularly useful for cooking instructions (for example, pictures of a frying pan, oven and microwave). But make sure the icons will be easily recognisable.
41. It is important to ensure that numerals are distinct. The numbers 0, 3, 5, 6 and 8 can easily be misread in certain typefaces.
42. White on black should be avoided for fonts of less than 12 point unless excellent print resolution can be achieved. Dark text on a light background should be used for text less than 12 point.
43. Adopt a consistent format when presenting information like nutrition labelling on a range of products to make it easier for consumers to identify and locate.
Increasing the printable area on pack
44. Give the essential information described in paragraph 11 top priority when designing labels. If you find it hard to follow this advice on ideal formats, consider the following ways of making more space available :
- Reducing space used for branding and claims
- Increasing the label size, but don't obscure sight of the product where this is important to consumers
- Using inside label space for information which does not govern choice, like detailed recipes
- Using a different type/style of label.
Clear Labelling Task Force, January 2002
Annexe 1/Terms of Reference
1. To review the ease with which consumers are currently able to obtain information of concern to them from food labels.
2. To identify particular sources of difficulty, having regard to all types of consumers, including those with special needs.
3. To make practical recommendations for improvement, including any changes needed in food labelling legislation; and guidance to industry on possible non-statutory measures that would be of benefit to consumers.
Members
Charles McDonald (Chair)
Glasgow City Analyst
Dermot Ryan
Royal National Institute for the Blind
John Wild
Campaign for Plain English
Ralph Blanchfield
Institute of Food Science and Technology
Mona Patel
Consumers' Association
Sam Miskelly
General Consumer Council of Northern Ireland
Tony Wheale
Ealing Council
David Pearce/Catherine Humphries
British Retail Consortium
Valerie Saint
Food and Drink Federation
Andrea Meaning/Sandra Morton
Basic Skills Agency
Pippa Martlew
Jones Knowle Ritchie
Observers
Hilary Neathey
Food Standards Agency (Wales)
Pamela Reid
Food Standards Agency (Scotland)
Secretariat
Rosemary Hignett
Food Standards Agency
Keith Gregory
Food Standards Agency
List of Consultees
David Reading
Anaphylaxis Campaign
Rachel Kenningham
British Retail Consortium
Irene Mackay
Coeliac Society
Sue Davies
Consumers' Association
John Caseley
FAC Secretariat
Michael Hunt
Food and Drink Federation
Tim Lobstein
Food Commission
Maeve Bell
General Consumer Council for Northern Ireland
Penny Viner
Health Food Manufacturers Association
Sue Gatenby
Institute of Grocery Distribution
Les Bailey
LACOTS
Sue Dibb
National Consumer Council
Patience Purdy
National Council of Women
Elizabeth Hogben
National Farmers Union
Janet Graham
National Federation of Consumer Groups
Ben Savill
National Federation of Women's Institutes
The Secretary
Proprietary Association of Great Britain (PAGB)
Charlie Powell
Sustain
Clear Labelling Task Force Members (listed at Annexe 1)
Tom Robinson
FSA Northern Ireland
Pamela Reid
FSA Scotland
Hilary Neathey
FSA Wales