Nutrition information programmes: inadequate evidence to substantiate their relevance for public health

NIPs use visual elements (logos, colours, graphics, etc.) providing summarised nutritional information for consumers on the front of the packaging, in addition to the mandatory statements featured on the back of all pre-packaged products since December 2016. Act 2016-41 on the modernisation of our health system incorporates the provisions of the European INCO Regulation and provides for the voluntary deployment of a single system at the national level to "help consumers make choices regarding energy and nutrient intakes in their diet". The Agency assessed systems, including “Nutri-repères”, “Nutri-couleurs”, “Nutri-score” (or 5C), “Health Star Rating” (HSR) and the “SENS” system.

The nutritional relevance of these NIPs was measured by its ability to reduce the incidence of diseases in the entire population, through its effects on food choices. The goal is for nutrition labelling to be more than a simple tool for the dissemination of information on the nutritional characteristics of food products and to enable consumers to fully appreciate this information in order to improve their dietary behaviour for the long term.

With this in mind, the experts first identified all the variables to be taken into account that affect the relevance of a NIP (intakes of nutrients or other substances, energy, the diet considered in its entirety, etc.). This analysis led them to consider that the systems studied, which incorporate rather indiscriminately and imprecisely the specific needs of different groups of the population, do not take into account all the diet-related variables affecting public health issues.

Secondly, the experts assessed the ability of each NIP to guide consumer behaviour, in the light of public health objectives. Few studies have been undertaken on the effects of NIPs on consumers and these have produced contrasting results, whether concerning quantitative variables (purchasing frequencies) or qualitative variables (how well the information and the nutritional quality of the purchase are understood). It has been suggested that contradictory effects may occur, such as the cognitive bias of a halo effect influencing the way consumers perceive the information and inducing inappropriate behaviour. There are currently no data directly linking the implementation of a NIP with determinants of health.

Taking these elements into account, ANSES believes that the way the examined NIPs are constructed, as regards both the variables used and the way they are combined, appears to have little relevance at the nutritional level. There is therefore no evidence to suggest that the NIPs examined have any effect in improving the choices of consumers. The Agency concludes that in the current state of knowledge, the nutritional relevance for public health of the NIPs examined could not be substantiated.

In the context of the planned regulatory deployment of nutrition labelling, the implementation of a relevant NIP therefore appears to be an accompanying measure, in the necessary continuum that includes educational initiatives, information and a regulatory framework. Given the results hoped for from the implementation of a NIP, ANSES insists on the need for regular monitoring and evaluation of the impact of whichever labelling system is chosen.

This new Opinion supplements the work published by the Agency in May 2016 on its assessment of the feasibility of calculating a nutritional score.