FA0132 Baseline for Evaluation of EU FIC (Food Information to Consumers) labelling
Defra
FA 0132 Baseline Evaluation of EU Food Information for Consumers
(FIC) Labelling: Final Report
This research was commissioned and funded by Defra. The views expressed reflect the research findings
and the authors’ interpretation; they do not necessarily reflect Defra policy or opinions.
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FA0132 Baseline for Evaluation of EU FIC (Food Information to Consumers) labelling
Baseline Evaluation of EU Food Information for
Consumers (FIC) Labelling: Final Report
Prepared for:
Defra
Food Policy Unit
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17 Smith Square,
London
SW1P 3JR
Prepared by:
Anthesis Consulting Group The Future Centre, 9 Newtec Place, Magdalen Road, Oxford, OX4 1RE
E-mail: [email protected]
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www.anthesisgroup.com
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April 2016
Report written by:
Nicola Jenkin, Jennifer Wilson, Oscar Benjamin & Graham Kelly
Contributors:
Sue Clegg and Vicky Grinnell-Wright
Quality Assurance
Reviewers:
Nicola Jenkin, 10th July 2014
Report approved by:
Ben Tuxworth
Signature ……………………………………………………………..
FA0132 Baseline for Evaluation of EU FIC (Food Information to Consumers) labelling
Table of contents
1. Project Overview ............................................................................................................................................. 1
1.1 Project aims and objectives ......................................................................................................................... 1
1.2 Project Scope .............................................................................................................................................. 1
1.3 Project Limitations ....................................................................................................................................... 2
2. Food Labelling in the UK ................................................................................................................................. 4
3. Methodology & Tools ...................................................................................................................................... 5
3.1 Phase One: REA ......................................................................................................................................... 7
3.2 Phase One: Method Output Summary ............................................................................................................. 9
3.3 Phase Two: Primary Research ....................................................................................................................... 10
4. Baseline Findings: Impacts on Consumers .................................................................................................. 18
4.1 Country of origin/place of provenance labelling ............................................................................................. 18
4.1.1 Rapid evidence assessment (REA) Findings .............................................................................................. 18
4.1.2 Consumer Survey Findings ......................................................................................................................... 20
4.1.3 Accompanied Shop Findings ....................................................................................................................... 24
4.1.4 Conclusion ................................................................................................................................................... 26
4.2 UK 2013 Front of Pack Nutrition Scheme....................................................................................................... 26
4.2.1 Rapid evidence assessment (REA) Findings .............................................................................................. 27
4.2.2 Consumer Survey Findings ......................................................................................................................... 28
4.2.3 Accompanied Shops Findings ..................................................................................................................... 34
4.2.4 Conclusion ................................................................................................................................................... 36
4.3 Allergen labelling ............................................................................................................................................ 36
4.3.1 Rapid evidence assessment (REA) Findings .............................................................................................. 38
4.3.2 Consumer Survey Findings ......................................................................................................................... 39
4.3.3 Accompanied Shop Findings ....................................................................................................................... 42
4.3.4 Conclusion ................................................................................................................................................... 45
4.4 Additional EU FIC ingredient labelling requirements ...................................................................................... 46
4.4.1 Rapid evidence assessment (REA) ............................................................................................................. 47
4.4.2 Consumer Survey Findings ......................................................................................................................... 47
4.4.3 Accompanied Shop Findings ....................................................................................................................... 53
4.4.4 Conclusion ................................................................................................................................................... 55
FA0132 Baseline for Evaluation of EU FIC (Food Information to Consumers) labelling
4.5 Conclusion: Impacts on Consumers ............................................................................................................... 55
5. Impacts of the EU FIC regulation on Food Business Operators ................................................................... 57
5.1 General awareness of the EU FIC regulation ................................................................................................. 60
5.1.1 Rapid Evidence Assessment ....................................................................................................................... 60
5.1.2 Business Survey Results ............................................................................................................................. 60
5.1.3 FBO Awareness: Prompted & Unprompted ................................................................................................ 61
5.1.4 FBO General EU FIC Awareness: FBO Characteristic Breakdown ............................................................ 64
5.1.5 Large Corporation Interview results ........................................................................................................ 64
5.1.6 Conclusion ................................................................................................................................................... 65
5.2 Preparedness to meet the EU FIC requirements ........................................................................................... 65
5.2.1 Rapid Evidence Assessment ....................................................................................................................... 65
5.2.2 Business Survey Results ............................................................................................................................. 66
5.2.3 Large Corporation In-depth Interviews ........................................................................................................ 70
5.2.4 FBO General EU FIC Awareness: FBO Characteristic Breakdown ............................................................ 70
5.2.5 Conclusion ................................................................................................................................................... 70
5.3.1 Rapid Evidence Assessment ....................................................................................................................... 71
5.3.2 Business Survey Results ............................................................................................................................. 71
5.3.3 Large Corporation Interviews ...................................................................................................................... 74
5.3.4 FBO perceptions concerning ease of implementation of the EU FIC regulation: FBO characteristic
summary ............................................................................................................................................................... 74
5.3.5 Conclusions ................................................................................................................................................. 75
5.4 Opportunities associated with the EU FIC regulation changes ...................................................................... 75
5.4.1 Rapid Evidence Assessment ....................................................................................................................... 76
5.4.2 Business Survey Findings ........................................................................................................................... 76
5.4.3 Large Corporation Interviews ...................................................................................................................... 77
5.4.4 Conclusions ................................................................................................................................................. 78
5.6 Wider food label issues explored .................................................................................................................... 78
5.6 Conclusion: Impacts on Business ................................................................................................................... 79
6 Research summary and conclusions ............................................................................................................ 81
6.3.1 Consumer research EU FIC baseline and hypotheses for future research................................................. 89
6.3.2 Business research EU FIC baseline and hypotheses for future research................................................... 93
Bibliography .......................................................................................................................................................... 97
FA0132 Baseline for Evaluation of EU FIC (Food Information to Consumers) labelling
Table of figures
Figure 1 EU FIC Baseline Methodology Structure 6
Figure 2 Qualitative analysis process summary 17
Figure 3 Use of regional food labels 24
Figure 4 Allergy and intolerance sufferers reported ease of use on new EU FIC allergy labels 42
Figure 5 Consumer prompted and unprompted awareness of wider EU FIC requirements 48
Figure 6 FBO awareness of EU FIC regulation requirements 61
Figure 7 Summary of FBO activities to prepare for the EU FIC regulation 67
Figure 8 FBO ease of implementing the EU FIC regulation 72
Figure 9 FBO perceptions of areas for financial investment to meet EU FIC requirements 73
List of tables
Table 1 Accompanied shop participant sample summary by region ............................................................... 11
Table 2 In-store & in-home participant sample split ........................................................................................ 12
Table 3 Consumer survey participant sample summary ................................................................................. 13
Table 4 FBO survey participant sample summary .......................................................................................... 14
Table 5 In-depth interview business sample summary ................................................................................... 15
Table 6 Regional prompted awareness for COOL .......................................................................................... 20
Table 7 Regional COOL confidence and understanding in food content ........................................................ 21
Table 8 Regional use of COOL ....................................................................................................................... 22
Table 9 Recall awareness of UK 2013 FoP Nutrition Labelling....................................................................... 29
Table 10 General awareness of UK 2013 FoP Nutrition Labelling .................................................................. 30
Table 11 UK 2013 FoP nutrition information contribution to consumer confidence and understanding ......... 31
FA0132 Baseline for Evaluation of EU FIC (Food Information to Consumers) labelling
Table 12 UK 2013 nutrition label contribution to healthier consumer choices ................................................ 32
Table 13 Information looked for when purchasing food and drink .................................................................. 33
Table 14 Unprompted awareness of allergen information per diet demographic............................................ 40
Table 15 Prompted awareness of allergen information per diet demographic ................................................ 40
Table 16 EU FIC Allergen changes contribution to allergen suffers changes in confidence and understanding
......................................................................................................................................................................... 41
Table 17 Regional prompted awareness of wider EU FIC requirements ........................................................ 49
Table 18 Wider EU FIC requirements contribution to consumer confidence .................................................. 50
Table 19 Wider EU FIC requirements contribution to consumer understanding ............................................. 51
Table 20 Consumer use of 'Other' EU FIC labelling information ..................................................................... 53
Table 21 FBO detailed awareness of EU FIC allergy changes ....................................................................... 62
Table 22 FBO awareness of EU FIC requirements ......................................................................................... 63
Table 23 FBO preparedness to meet EU FIC requirements by activity .......................................................... 67
Table 24 FBO suggestions on the most effective communications for future EU FIC messaging .................. 68
Table 25 Summary of FBO suggested information sources to deliver future EU FIC messaging .................. 69
Table 26 Consumer EU FIC Baseline & hypotheses for future research ........................................................ 89
Table 27 Business research EU FIC baseline and hypotheses for future research ....................................... 93
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FA0132 Baseline for Evaluation of EU FIC (Food Information to Consumers) labelling
1. Project Overview
1.1 Project aims and objectives
In October 2011 the EU passed Regulation No. 1169/2011 on the provision of food information to
consumers (EU FIC Regulation). This regulation requires member states to modify existing food labelling
regulations, with the aim of:
1) Enabling consumers to make more informed choices;
2) Increasing the safe use of food; and
3) Ensuring the free movement of legally produced and marketed food.
Whilst many Food Business Operators (FBOs) have already made changes to labels, most provisions of
the Regulations apply from December 2014.
The primary aim of this research was to establish a baseline against which the effect of changes brought into
effect by the EU FIC regulation could be tracked. The project team used both qualitative methodologies
(accompanied shop/in-home observations and in-depth qualitative interviews) and quantitative research
methods (consumer omnibus and business survey) to create a snapshot of UK FBOs (retailers and
manufacturers) and consumers’ attitudes and behaviour in relation to food labelling, and their preparedness
for implementation of the EU FIC regulation in 2014.
Project objectives were to:
Critically assess and summarise the existing evidence base surrounding both consumer and
business view of food labels, and their awareness of the changes required to existing food label
structures to meet EU FIC regulation requirements;
Explore and summarise consumer understanding of food label information and changes in
purchasing decisions following the first wave of food labelling changes in line with the EU FIC
regulation requirements;
Explore and identify any barriers and opportunities for the businesses involved in rolling out the
new labelling changes, along with identifying their information requirements; and
Provide a baseline and methodology that can be used for subsequent evaluations of the
penetration of the new EU FIC labelling.
1.2 Project Scope
The following project boundaries were agreed.
1.2.1 Geographical Regions
Defra’s initial research brief was to create a baseline for assessing the impacts of the EU FIC regulation
changes on businesses and consumers in England. Early on in the study, this scope was extended to
include Scotland, Wales and Northern Ireland, referred to throughout this study as ‘regions’. The project
delivery timeline could not be extended, so instead the research used smaller sample sizes, and more
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limited primary research took place in each of the additional regions. The approach is explained further in
Appendix V.
1.2.2 EU FIC Regulation Changes
EU FIC regulation changes identified for investigation were selected on the basis of their potential for
significant impact on both consumers and FBOs. The five areas chosen were:
Country of origin/ place of provenance labelling;
Voluntary front-of-pack nutrition labelling;
Food allergen labelling and information;
Labelling of vegetable oil, including palm oil; and
Quantitative indication of ingredients (QUID), including meat content and added water
declarations.
1.2.3 Priority Products for assessment
The EU FIC regulations identified above were assessed on five illustrative products:
Minced meat;
Unprocessed meat (e.g. poultry, lamb, goat, swine);
Dairy (e.g. yogurt, cheese, milk);
Ready meals; and
Cereals and biscuits.
These products were selected as a representative sample of products found in UK shoppers’ baskets
(WRAP, 2013). All were pre-packed: non-prepacked foods, such a minced meat bought from a butcher,
were excluded.
1.3 Project Limitations
A number of evidence gaps have been detailed within the main report, with implications for further study.
1.3.1 Overarching Project Limitations
The study was limited by time and scope, where possible gaps identified in the REA (the first research
stage) were addressed using the primary research techniques used within this project (i.e. surveys and
participant observations). A summary of the main limitations to be taken account of when reviewing this
research are set out below.
1) The project was commissioned in January 2014, midway between the introduction of the new
regulations and when they apply. As a result, the research team were unable to collect a baseline
sample in the truest sense as FBOs have begun to prepare to meet the first regulation deadline
of 13th December 2014. Different FBO retailers and manufacturers are at different points in their
journey of compliance, a factor which is reflected in the different levels of label change
penetration within the market place found during this research project.
2) To incorporate a wider geographical scope for review (Scotland, Wales and Northern Ireland as
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well as England) within the limited time constraints of the original project brief, sample sizes for
surveys and accompanied shops were smaller for the additional regions. Results from these
areas are therefore only indicative of consumer behaviour in these regions, rather than robust
predictors. Greater confidence would depend on these regional research samples being
increased.
3) The EU FIC requires changes in allergen labelling, and a representative sample of users of this
labelling was identified and surveyed. If a more detailed analysis of impacts of EU FIC allergen
regulation changes is required then the sample size should be increased. The positive effect of
labelling on this group suggests that this is an area worthy of further research.
1.3.2 Method Limitations
Outlined below is a summary of the limitations of each of the research methods used:
Rapid Evidence Assessment: The effectiveness of an REA depends on the primary search terms
used to collect evidence. These terms are what makes the process time efficient, and determine the
quality of evidence collected. If the search terms are ineffective in identifying secondary data, the
method and its output become invalid. To mitigate against this a list of secondary search terms were
developed, but effectiveness of both lists of search terms cannot be measured objectively and,
therefore there is some risk in the use of this method.
In addition to this the evidence base for the topics of assessment within the REA vary significantly
with the evidence base surrounding consumer purchasing decisions and use of food labelling being
much more advanced than that of the evidence base surrounding the EU FIC regulation. Therefore
there is the risk that the REA may be able to provide a solid foundation for some elements of this
research and not others. To overcome this all evidence/knowledge gaps identified by the REA will
attempt to be plugged using the multiple primary research methods.
Participant Observations: The research project used pre-agreed participant recruitment criteria
aimed at ensuring the correct number and diversity of participants. Criteria included variables such
as life stage, purchasing motivation, shopping mode (i.e. in-store/online) and spend. In combination,
these criteria were sometimes hard to meet, and as a result, some samples had to be adjusted to
yield sufficient numbers. For example there are fewer senior online shoppers, and so the online
shopper sample was adjusted to include more family shoppers.
An additional methodological limitation that is present for both participant observations and the
subsequent survey methods outlined below is the presence of the observer effect. In the research
community the observer effect is known by many titles and is defined as a form of in-field response
when a researcher’s cognitive bias (e.g. their awareness of the main purpose of the
research/experiment) causes them to unconsciously influence the participants of an experiment. To
overcome this methodological barrier the research team utilised a double blinded experimental design
for all elements (observations and surveys) of the primary research of this project. The double blinded
experimental design overcame the observer bias as neither in-field researcher or participant were
informed of the true aim of the research (i.e. the assessment of food label use and EU FIC regulation
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FA0132 Baseline for Evaluation of EU FIC (Food Information to Consumers) labelling
awareness) until the conclusion of their participation. Therefore at the research induction each
participant and researcher were informed that the purpose of the research was to understand why
people shop the way that they do, and only afterwards where all parties informed of the true purpose.
Consumer Survey: An omnibus survey was the chosen as the delivery vehicle for the consumer
survey as it is a cost effective and efficient way to reach a large number of participants. Omnibus
survey companies cannot however guarantee that the sample size criteria of survey customers will be
met by the survey they choose to be part of. As a result, additional survey work may be required to
meet sample criteria.
Business Survey: Only one person responded to the business survey on behalf of each business,
but their responses are taken as representative of their employer, regardless of whether they have a
formal role in relation to the EU FIC changes. There is therefore a risk that their responses are not an
accurate account of the true situation at the business.
Business Interviews: Seven in-depth qualitative interviews were conducted with both FBO retailers
and manufacturers. Those that participated were deliberately chosen for their high level of awareness
of the EU FIC and were therefore much more prepared for the changes ahead than the FBO survey
sample, introducing potential biases within results. Additionally the findings which draw on evidence
from the 7 in-depth interviews with businesses are limited by the small sample size, but they provide
interesting insights from big businesses
2. Food Labelling in the UK
Food information and labelling legislation in the UK is largely set at an EU level. Its role is to:
1. Set clear requirements for food business on what information they must give consumers, and
how to present it; and
2. Help consumers understand what food label information they can expect to be provided with
when purchasing food e.g. name of food, use by or expiry date, necessary warnings and storage
instructions etc.
Prior to the new EU FIC regulation, The Food Labelling Regulation 1996, set out the primary regulations
governing the labelling of foods within England, Scotland and Wales. This regulation requires that all food
stuffs are marked or labelled with the following:
‘Subject to any exemptions, these regulations require that pre-packed food stuffs are marked or labelled
with…
1. Name of the food;
2. List of ingredients;
3. Quantity of certain ingredients or categories of ingredients;
4. Appropriate durability indication;
5. Special storage conditions or conditions of use;
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6. Name and address or registered office of either or both of –
i. of the manufacturer or packer; or
ii. a seller established within the European Community.
And in certain cases:
7. Particulars of the place of origin of the food or place of provenance; and
8. Instructions for use.’
N.B indication of net weight is needed under the Weights & Measures Act 1985.
A similar law applied to Northern Ireland. The new EU FIC regulation 1169, introduced in 2011, has
extended the scope of labelling requirements to cover food information at all stages of the food chain in
order to bring rules on general and nutritional labelling into a single regulation to simplify and consolidate
existing labelling legislation.
The premise of these changes is that through the consolidation of food labelling information, the interests
of consumers and businesses will be better served. The EU anticipates that the EU FIC will work to:
1. Assure that consumers are not misled to a material degree;
2. Aid consumers in making healthier choices;
3. Enable consumers with food allergies to make informed and safe choices;
4. Enable food business operators to bring new and innovative products to the market;
5. Provide consumers with accurate, clear and easy to understand food information; and
6. Support appropriate business implications and behavioural changes to adapt to the new
legislation (Defra, 2014).
Please refer to Appendix I for the EU FIC regulation implementation timeline and requirements.
3. Methodology & Tools
This research project was conducted in two phases (see figure 1) adopting a mixed method approach.
Desk based research was conducted in phase 1 and was subsequently followed by primary research in
phase 2;
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FA0132 Baseline for Evaluation of EU FIC (Food Information to Consumers) labelling
Figure 1 EU FIC Baseline Methodology Structure
Phase One used secondary data sources identified through a Rapid Evidence Assessment1 (REA)
process to provide an overview of:
a) The current evidence about consumer use and understanding of labels, and business awareness
and understanding of the EU FIC label changes, and
b) Guidance provided to facilitate the transition to the new EU FIC labels.
Phase Two focused on utilising primary research methods to gather evidence of:
a) The understanding and interactions consumers have with food labels whilst shopping in-store or
online, and
1 An REA is defined as the systematic review, search and critical appraisal of existing research. They aim to be rigorous
and explicit in method and thus systematic but make concessions to the breadth or depth of the process by limiting
particular aspects of the systematic review process (Civil Service, 2011).
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FA0132 Baseline for Evaluation of EU FIC (Food Information to Consumers) labelling
b) Investigating what businesses expect or report the impact of EU FIC changes to be on their
businesses.
The research methods established utilised both qualitative (in-depth interviews and participant
observations) with quantitative method techniques (consumer and business surveys) to create a diverse
evidence base which could be interrogated to provide statistically significant figures, but also a narrative
which could provide a contextual background to findings. The individual methods used are summarised in
more depth below.
3.1 Phase One: REA
Phase One used a Rapid Evidence Assessment (REA) process to identify consumer and business a)
opinion of food labels, and b) level of interaction with existing food labels in both an in-store and online
setting. The REA consisted of two core elements:
1. A standard REA secondary evidence search; and
2. A condensed in-depth review and analysis of core literature.
The REA process that the team followed for this project was made up of six stages, as illustrated in figure
two. A summary of each stage can be found below:
Figure 2 REA process overview
The first stage of the REA process requires fundamental methodological principles to be established, 1)
purpose and 2) source inclusion criteria. As the REA is the first research method used within the project
the REAs purpose was clear, to establish an existing evidence base upon which a hypothesis could be
formed and identify any existing evidence gaps that might be able to be plugged by the second phase
primary research methods to be applied within the project.
The second principle of source inclusion criteria was developed in collaboration with the Defra and FSA
steering group. The source inclusion criteria established confirmed the variety, age and source of the
evidence parameters. The full list of source inclusion criteria are outlined below:
1. The age of food label and consumer decision making literature reviewed should range from 2009
to the present date (using Food Safety Authority of Ireland: a research study into Consumers
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Attitudes to Food Labelling 20092
as a benchmark for literature inclusion and exclusion
parameters).
2. Additional literature sources (specifically sociology and psychology) must span a thirty year
period (1984-2014).
3. Evidence sources to span a variety of mediums such as academic journals, government
publications, official research institutions, market intelligence agencies, retailer and manufacturer
publications and wider media such as newspaper articles, blogs and press releases.
4. All sources gathered during the REA to be documented via a detailed tracker with content, quality
and robustness scores applied to each source, on a scale of one to five.
REA Search Strategy
After agreeing the REA parameters the research team conducted the evidence search over a period of
three weeks. For each search that was conducted detailed information on the source was captured for
documentation purposes
In total for this research project 449 documents in all. A sample from the documentation sheet used by
the research team can be found in appendix 1.1.7.
Refining the REA search results
After the collation of all recorded resources the research team were required to filter the evidence in a
systematic manner based on predefined inclusion and exclusion criteria agreed by the FSA and Defra
project teams to create a smaller more relevant pool of evidence to be reviewed in more depth.
Phase One Screening: The first step of this process was to simply review the collated evidence research
and corroborate this against the source inclusion parameters for all evidence (see above for full list).
Once all evidence has been reviewed against these criteria and a revised evidence list created phase two
screening could commence. This first phase of screening reduced the evidence to be reviewed from 449
to 221.
Phase Two Screening: The evidence list was then filtered to identify the final list of literature sources for
further review. The phase two filtration criteria consisted of a content applicability score and a source
quality score, using a scale of 1 (low) to 5 (high) for each. Sources that were academic peer-reviewed
journals scored 5, trusted industry literature (e.g. Defra, Food & Drink Federation sources) scored 3-4 and
other grey literature, depending on source (e.g. a news article 2, blog 1) scored 0 – 3. To further filter the
sources and create a list for more in-depth review, the top scores (a maximum of 10) across both criteria
(content and quality) were cross-referenced with search areas to rank those with the highest applicability
2 http://www.fsai.ie/assets/0/86/204/9f8b5edc-565e-4f10-8c0f-7015f742da09.pdf
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selected for review. All resources ranked above a score of 6.5 were crossed-checked by a second
researcher to ensure that subjectivity of quality and content applicability were not introduced into the
assessment of literature sources. The phase one 221 sources were re-ranked to produce a shortlist of
158 documents for thorough review based on their phase two scoring.
The documents for detailed review were predominantly made up of peer-reviewed academic journals and
literature from established institutions such as Defra, The Food Standards Agency and the European
Commission which ensured that the core secondary evidence utilised within this project was robust and
had a sufficient amount of academic rigour. Low ranking sources (i.e. those which scored below 6.5 and
were made up of less robust sources e.g. grey literature) were not reviewed or included within the
literature assessment, as the project team felt that only the most robust sources should inform the
baseline. For an example of the more detailed review process applied, refer to Appendix IV Conducting
the REA. Additionally please refer to appendix 1.1.8 for an example of the audit documents required for
an REA.
3.2 Phase One: Method Output Summary
The REA indicated that none of the reviewed research adequately assesses or explores the implications
of the changes that the introduction of the EU FIC regulation might have on the food labelling landscape.
Instead the literature assessed explored what the changes were, providing guidance on different
elements of the EU FIC changes. This was particularly true of sources from industry or governmental
bodies such DEFRA, The Food Standards Agency and the European Commission. Academic and peer-
reviewed literature tended to focus more on:
1) Consumer interaction with and the effectiveness of FoP nutrition labelling;
2) Consumer use of nutrition labels; and
3) How specific shopper categories respond to/use food labels differently (for more detailed information
on the outputs of the REA please refer to the Impacts on consumer in chapter 4).
Specifically, the REA identified core data gaps relating to the use of all five prioritised FIC information
changes for consumers:
1. Country of origin/ place of provenance labelling.
2. Voluntary front of pack nutrition labelling.
3. Food allergen labelling and information.
4. Labelling of vegetable oil, including palm oil.
5. Quantitative indication of ingredients (QUID) including meat content and added water
declarations.
The detailed findings of the REA are summarised within the impact on consumer chapter.
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3.3 Phase Two: Primary Research
The REA highlighted a number of evidence gaps. To address these gaps primary research was
undertaken, combining qualitative observations and surveys. This work was focused on two groups:
Consumers: (1) accompanied shops; (2) in-home observations; and (3) consumer surveys.
Businesses: (1) in depth interviews and (2) a survey.
An overview of the research methods and rationale is provided below.
3.3.1 Consumer: Accompanied Shops & In-home Observations
Accompanied shops and in-home observations were both used to assess consumers’ physical interaction
with food labels whilst shopping, in-store and online. It is important to caveat findings as indicative rather
than directly comparable because the participants were not the same individuals as responded to the
survey. Nevertheless, this research helped uncover indicative differences between what people claim
they do in surveys, and what they actually do.
The aims of this research approach were to:
Explore consumer attitudes to and interaction with food labels in different situations (i.e. in-store
and online).
Record relevant food label and EU FIC aspects of a consumer’s experience and the processes
by which purchasing decisions are made.
Find evidence about behaviours and interactions with food labels which participants may not be
aware of, and/ or able to verbalise.
Researchers shadowed3 consumers and conducted in-store and in-home interviews
4 while participants
conducted their ‘main weekly food shop’. For more information on the protocols adopted refer to Appendix
II Qualitative Observations A1.6 Observation Protocols.
In all, 64 accompanied shops (see table below) and 26 in-home observations (in England alone) were
3 Researchers followed and observed pre-recruited participants both in-store and in-home to observe their interaction
and use of food labels. During the observation process researchers made comprehensive notes and asked participants
ad-hoc questions to illicit their thoughts and opinions.
4 The project team mitigated against observer bias by adopting two mitigation actions (1) following a detailed
accompanied shop and in-home observation protocol; and (2) utilising the think out loud technique in the field to illicit
detailed participant responses.
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conducted.
Accompanied Shop Locations Number conducted
England 28
Scotland 12
Wales 12
Northern Ireland 12
Table 1 Accompanied shop participant sample summary by region
Smaller sample sizes were used in the regions because of research time restrictions and as such the
findings are not robust but they are indicative. The recruitment criteria used for this project were the
following:
1. Life stage e.g. pre-family, family, post family, senior (a summary of the accompanied shop and in-
home recruitment to this criteria is below in table 2);
2. Purchasing motivation (food allergy and or intolerance);
3. Products purchased (mandatory minimum of one illustrative product outlined in section 1.2.3);
and
4. Basket spend (mandatory minimum of £50).
The choice to use the above sampling criteria above was driven by the need to accurately identify ‘main
shoppers’. Taken together, these criteria ensure that a spread of typical UK main shopper profiles and
activities are captured.
Recruitment criterion Assessment metric In-store (64) In-home (26)
Life stage
Pre-family 12 5
Family 12 5
Post Family 12 5
Elderly (65+) 12 3
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Purchasing motivation
Allergies 8 4
Food intolerance 8 4
Table 2 In-store & in-home participant sample split
*N.B All participants had to have a minimum basket spend of £50 and purchase a minimum of two of the
illustrative products.
To deliver a balanced participant pool of main shoppers a set number of participants were required to
meet each of the above recruitment criteria (i.e. four participants per life stage and purchasing motivation).
Overall there was a 70-30 female to male bias of participants. Our experience from previous studies is
that main shoppers within a family or post-family life stage are predominantly female (PLMA, 2013).
Recruiters recorded low levels of online shopping amongst the senior (65+) sample base, confirming
existing evidence on online shopper demographics (ONS, 2013). As a result, recruitment for in-home
observations was biased towards families. For recruitment criteria used please refer to Appendix V.
Accompanied shops and in-home observations lasted between 45 and 90 minutes and each observation
began when a participant began shopping in-store or online. During observations, participants were
asked to ‘think out loud’5 to explain their purchasing decisions. For more detailed information on the
accompanied shop and in-home observation methodologies see Appendix V.
3.2.2 Consumer Omnibus Survey
Building on the insights gained from the accompanied shops and in-home observations, a consumer-
focused survey was undertaken to gather further insights into consumer opinions, understanding,
behaviours and confidence levels in relation to both the existing and new food labels.
Similar to the focus of the accompanied shops and in-home observations, only main shoppers were
interviewed in the consumer survey, the sample sizes for which were:
5 ‘Think out loud’ is a technique used by the research team to illicit responses from participants during accompanied
shops and in-home observations. For a more detailed overview on the technique please refer to appendix V.
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Region Main Shopper Sample Size
England 1,254
Scotland 138
Wales 132
Northern
Ireland148
Table 3 Consumer survey participant sample summary
An Omnibus survey was used to collect consumer insights as this was deemed the most time- and cost-
effective way to access a representative sample base. A bespoke Omnibus survey will also allow Defra to
track consumer attitudes and behaviour against the baseline identified, although the participants will be
different so results will not be directly comparable.
Consumer survey sample size
The sample size was set to provide a cost-effective solution within the project’s budget limitations.
Originally the survey was to cover England only, and an estimated sample size of 1,000 participants was
required to provide top-level findings with confidence intervals of around three percentage points, and
findings for the key main shopper demographics as defined by the project steering group within
reasonable confidence intervals (i.e. 95%).
Since the consumer survey was undertaken on the GfK Omnibus survey, and the general public sample
needed to be screened for main (or joint main) shoppers. Our original “cautious estimate” of 70% being
main shoppers was expected to yield an achieved sample of around 1400 main shoppers across the UK
after screening 2000 people, but in the event GfK omnibus screened a total of 2,149 members of the
public, of which 78% proved to be main shoppers, thus yielding a total main shopper sample size of 1,672
across the UK, with 1254 in England, 138 in Scotland, 132 in Wales, and 148 in Northern Ireland. The
confidence level for all consumer samples was 95% with a confidence interval figure for the England
sample of between 2 – 3 percentage point difference. In regards to the geographical regions all had a 1-2
percentage point difference for their confidence intervals. Note that the England and Scotland samples
were achieved within a single week fieldwork, but additional “boost fieldwork” was conducted in Wales
and Northern Ireland in order to ensure that these countries had at least 100 main shopper respondents
in our achieved sample.
For further information on the Omnibus survey sample strategy and survey questions, see Appendix VI.
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3.2.3 Business Survey
1,002 telephone interviews with food business operators (FBO) were undertaken. The FBOs selected
represented a range of small6, medium
7 and large
8 businesses in the food manufacturing (60%) and food
retailing sectors (40%) and a spread of Standard Industrial Classification codes for FBOs. A summary of
the FBO survey participant sample is below:
FBO Criteria FBO Survey
Small FBO 776
Medium FBO 195
Large FBO 32
Table 4 FBO survey participant sample summary
This approach was considered the most appropriate method through which to target a wide and diverse
range of FBOs. Interviewer-led, rather than paper-based or self-completed online questionnaires enabled
more detailed discussion.
Business survey sample size
The sample size was decided on the basis of providing a cost-effective solution within budget limitations.
For the business survey it was decided that a total sample size of 1,000 would be appropriate, providing
total sample findings within confidence intervals of around three percentage points. Originally the plan
was to represent manufacturing and retail equally, with 500 interviews in each, so that sector findings
would be within confidence intervals of four to five percentage points. Following advice from the project
steering group the manufacturing share was increased to 600 interviews, and retail reduced to 400,
reflecting the greater responsibility on manufacturing businesses for implementing the regulatory
changes. The meant that the overall confidence interval for the business sector findings was three
percentage points for both the manufacturing sample and retail samples.
For further information on the business survey refer to Appendix VI.
6 A food business operator (either retail or manufacturer) of between 1- 10 employees and/or up to £999,999 turnover.
7 A food business operator (either retailer or manufacturer) of between 11 – 99 employees and/or £1 million - £9,999,999
turnover.
8 A food business operator (either retailer or manufacturer) of 100 + employees and/or £10 + million turnover.
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3.2.4 In-depth Interviews with Large Food Corporations
A sample of large corporate food retailers and manufacturers affected by the new EU FIC labelling
regulation were interviewed to ascertain their views on the impacts of the changes. A summary of the
split of sample corporation type is below:
Corporation Type Number of participants
Food Manufacturer 3
Food Retailer 4
Table 5 In-depth interview business sample summary
Semi-structured interviews were undertaken with each business interview lasting between 45 and 60
minutes and explored the following themes:
Activities businesses are undertaking in order to meet the EU FIC regulation requirements.
Cost (financial, time and resources) to businesses to implement the required changes.
Ease of implementation.
Overall opinion on the changes, the process, information and guidance.
The potential effectiveness in meeting the stated aims of the EU FIC regulation changes.
In-depth qualitative interview sample size
A sample of between five and eight interviews were proposed with the split of businesses to be
interviewed corresponding with the retailer/manufacturer FBO split adopted in the business survey (i.e.
slightly weighted towards manufacturers, reflecting their greater role in implementing the EU FIC
regulation changes). The research team undertook seven interviews, four with retailers and three with
food manufacturers.
3.3 Analysis Approach
The aim of conducting this research project in two phases was to facilitate the use of multi-disciple
research methods which could be used collectively to create a solid triangulated base of evidence from
which conclusions could be drawn.
Two methods of triangulation were used in this project to bring all three evidence strands together; the
first was methodological triangulation, and the second investigator triangulation. Both approaches were
adopted as it enabled the project team to robustly cross verify all results and overcome any weakness
and or intrinsic biases that can come from the use of single method and single-observers. Evidence of the
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first triangulation approach is clear as both the consumer and business elements of this research draw on
three different methodological approaches to create a solid evidence base (e.g. REA, observations and
survey). Using multiple methods to investigate the same phenomenon created a rich evidence enabling a
detailed cross corroboration process during the analysis of results creating higher levels of confidence in
the insights and findings from the research.
Due to the use of observer led research methods employed within the research project the project team
concluded that investigator triangulation must also be employed to address any biases inherent with the
use of such research methods. Investigator triangulation is invisible to audiences/stakeholders outside the
project team as it concerns the make-up and design of the research and analyst team which conducts the
in-field research. Principally the research team used observer triangulation (the method of using multiple
researchers or analysts in-field) to overcome subjective assessments.
Investigator triangulation was used in two instances, the first in observational fieldwork were five different
researchers were used to conduct the 90 participant observations. Each researcher was briefed with a
false but closely linked research objective to guide their in-field protocol with the true objective of the
research revealed after all field work. This approach was applied to overcome subjective biases and the
observer effect. The second instance occurred in the analysis stage where six different analysts were
gathered to review the research results. The use of investigator triangulation at this point in the project
was critical as it enabled blind spots in the analysis to be illuminated and to allow the project team to
understand the multiple ways in which the research results can be viewed.
3.3.1 Significance testing of consumer and business survey results
The tabulated data provided by the fieldwork agencies incorporated standard significance testing, via their data processing software. All testing was at the 95% level, and technical details were as follows:
For the consumer survey Pearson's chi-squared test was used. The procedure of the test includes the following steps:
1. Calculate the chi-squared test statistic, , which resembles a normalized sum of squared deviations between observed and theoretical frequencies.
2. Determine the degrees of freedom, df, of that statistic, which is essentially the number of frequencies reduced by the number of parameters of the fitted distribution.
3. Compare to the critical value from the chi-squared distribution with df degrees of freedom,
which in many cases gives a good approximation of the distribution of .
For the business survey confidence intervals were calculated using the following formula: confidence interval = +/- Z*standard error.
The z-value is a measure of how sure we want to be. It is fixed value. For example, a z-value of 1.96 is always used to produce a 95% confidence interval. The z-value is derived from a standard normal distribution.
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Standard error is a measure of how variable a survey estimate will be. The size of the standard error depends upon the size of the sample and actual percentage we are estimating. The formula below shows how the standard error is calculated for a percentage (p) and a sample size (n):
Please note that all tables marked with an asterisk (*) denote differences with the data analysis which are
statistically significant to a level of 95%.
3.3.2 Qualitative Data Analysis
This project adopted a multi-method approach creating both a quantitative and qualitative evidence base.
To analyse the qualitative data from interviews and participant observations the research team adopted a
content driven analysis method. The method adopted by the team is outlined below;
Figure 2 Qualitative analysis process summary
As illustrated above the team adopted a researcher led content approach which focused on finding
relationships, sequences and differences which could be used to elaborate on findings from other data
sources or to articulate small generalisations that were found. The qualitative drawn out within this project
proved to be invaluable enabling contextual insight into behaviours. In many instances the qualitative data
was found to reaffirm trends and findings from both the consumer and business survey but also establish
insights on its findings alone. Within this report qualitative analysis can be found in each section as either a
case study example or a summary of findings and themes from stage four of the analysis process.
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4. Baseline Findings: Impacts on Consumers
This chapter addresses the following project questions.
1. How do consumers currently use food labels?
2. What is their level of understanding and awareness of the five food label elements that this
project focused on?
3. What kind of impacts do consumers think label changes may have on their behaviour?
It has been split into five sections, one for each FIC label change this project has focused on (Country of
origin/ place of provenance labelling, Voluntary front of pack nutrition labelling, Food allergen labelling
and information, Labelling of vegetable oil, including palm oil and Quantitative indication of ingredients
(QUID) including meat content and added water declarations). In each section, it draws on the three
evidence bases (REA, consumer omnibus survey and consumer observations) to provide a baseline for
current consumer attitudes and behaviour around food labelling.
4.1 Country of origin/place of provenance labelling
This section assesses how consumers currently use Country of Origin/place of provenance Labelling
(COOL).
Considerations when interpreting data from this section
1. COOL and regional labels are defined as follows:
a. COOL labelling: all country of origin/place of provenance labelling requirements as outlined
with the EU FIC 2011/1169 regulation; and
b. Regional food labels: food labelling information which references specific geographical
locations within the UK e.g. Welsh lamb, Scotch beef or Devonshire clotted cream. Regional
labelling of products is often linked to traditional and speciality foods and or foods which
have a protected designation of origin or protected geographical labelling. For more
information please refer FSA 2010 Consumer Guide to Country of Origin Information on
Food Labels.
2. Please refer to appendix II for more information on COOL requirements.
4.1.1 Rapid evidence assessment (REA) Findings
Country of origin labelling is a growing focus for investigation by the food manufacturing industry,
academia and governmental bodies internationally (see European Commission, 2013, FSA, 2010a, FSA,
2010b, QA Research, 2013, The Smith Institute, 2010). While food origin is a large subject area the REA
found a limited number of detailed sources that explored country of origin labelling in depth. Works found
were commissioned mostly by industry and governmental bodies such as the European Commission and
the Food Standards Agency.
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Five COOL themes emerged from the REA:
1. Benefit of COOL labelling and traceability;
2. COOL labelling influence on purchasing decisions;
3. COOL labelling and localism; and
4. Relative importance of COOL information on different products.
1) Benefit of COOL and traceability
The literature investigated suggests that COOL information is an important indicator and information
source for consumers about the quality of and safety of foods (FSA, 2010a, FSA, 2010c, European
Commission, 2013). The literature also suggests that food traceability has improved due to the use of
COOL labelling (FSA, 2010c).
2) COOL influence on purchasing decisions
The evidence of use of COOL by consumers in the UK is inconclusive with some studies claiming a high
level of use or importance (e.g. European Commission, 2013) whilst others state usage as low (e.g. Van
Camp et al, 2010). This discrepancy seems to stem from researcher perceptions that consumers have
misinterpreted or misunderstood the label. During observations or guided exercises most consumers
could not define COOL accurately or say what it was intended to achieve. In the majority of instances
consumers held erroneous views of the purpose of COOL labelling, including that its role is to prevent
supply chain risks such as horsemeat or mad cow disease. The FSA (2010c) explores COOL and
consumer interaction in depth and suggests that country of origin labels risk presenting consumers with
more information than they can reasonably process, resulting in information overload, leading to
confusion, misunderstanding and uncertainty which, in turn, causes scepticism and mistrust of food
labels. Labelling Matters (2013) suggests that this can result in consumer scepticism about origin validity.
3) COOL and Localism
A number of sources (see Meas et al, 2014, FSA, 2010a, FSA, 2010c) explored ‘food patriotism’ in
consumers’ use of COOL. Food patriotism refers to the emotional connection consumers make to products
from their own country (FSA, 2010a).
4) Relative importance of COOL information on different products
A number of sources (e.g. Smith Institute (2010), FSA (2010c) comment on consumers’ perceptions of
COOL information by product, suggesting that its use is prioritised for unprocessed fresh meat, such as beef
and minced meat and processed products with meat as an ingredient, and fresh fruit and vegetables.
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4.1.2 Consumer Survey Findings
Awareness of COOL
Overall consumers (n=1,672) ranked COOL 8th out of 15 possible types of information
9 they are aware of,
such as nutritional and health information and ingredients lists. These results suggest that 11%
(178respondents) of main shoppers are aware (unprompted10
) of COOL on food labels. When
‘prompted11
’ with a list of 15 possible elements of a food label, main shopper general awareness of COOL
rises to 48% (806 respondents). This result suggests that almost half of the survey respondents (approx.
700) exhibit a level of general awareness (when prompted) of COOL labelling information on food labels.
Table 6 gives a summary of the prompted awareness responses per geographical breakdown for COOL
labelling.
Q10: Please look at this list and tell me which types of information you think are currently shown on food and drink?
Food label information UK (of 1,672)
England (of 1,254)
Scotland (of 138)
Wales (of 132)
Northern Ireland (of
148)
Country of origin/provenance
% % % % %
48 47% 52% 51% 50%
Table 6 Regional prompted awareness for COOL
English participants reported the lowest awareness of COOL at 47% (668 respondents), in contrast to
Scotland with 52% (75 respondents), revealing a small, but statistically insignificant, difference in COOL
awareness amongst the regions. Secondary evidence reviewed in the REA does not provide an
explanation for the geographical differences and this might be an area for further investigation.
9 The options presented were: ‘special offers/money off/BOGOF’; ‘information about the contents/ingredients’; ‘allergy related
information’; ‘nutrition information’; ‘health information’; ‘animal welfare information’; ‘vegetable/palm oil content’; ‘vegetarian/vegan information’; ‘meat content (not specific to vegetarian/vegan)’; ‘added water content’; ‘quantity information about different ingredients’; ‘country of origin/place of provenance’; ‘it depends on the product’; ‘other’; and ‘nothing in particular’.
10 Unprompted questions require respondents to provide a recall response i.e. they were not guided by explanations from the
research team. These questions assess how front-of-mind different types of information are, and cast light on the importance placed on different types of information.
11 Prompted questions are structured with predefined answers or illustrative cards, offered to respondents by the research team to
assess how visual or audio cues may illicit recall of information. For more information on what respondents were prompted with, please refer to annex VI.
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Perceived importance and understanding of COOL labelling information
Survey participants were asked their opinion on COOL changes and whether these changes would affect
their confidence in and understanding of the content of the food they purchase. 47% (798 respondents) of
main shopper respondents indicated that revised COOL labelling would increase their confidence in the
food they purchase. When asked to rank what type of information, out of a possible 12 options12
, would
increase their confidence in the food they buy, COOL labelling ranked second beneath increase in the
minimum font size.
31% (516 respondents) of main shoppers stated that COOL information would increase their
understanding of the content of the food they purchase, and ranked this as the second most important
piece of information for increased understanding. It is important to note that the trends for improving
confidence and understanding by providing COOL are aligned with each other and suggest a potential
positive outcome associated with the introduction with the EU FIC regulation changes. Interestingly,
consumers say their confidence levels would rise more than their understanding (except in Northern
Ireland where the reverse is true).
Table 7 summarises regional responses to consumer survey Q18 & Q19 about COOL and its impact on
confidence and understanding.
Q18 &Q19: Will this information help improve your confidence/or understanding of the content of food and drink you purchase?
Food Label information: An indication of country
of origin or place of provenance.
UK % (of
1,672) R
England % (of 1,254)
R Scot % (of 138)
R Wales % (of 1320
R NI % (of
148) R
Confidence 47% 2nd 48% 2nd 50% 3rd 49% 5th 33%* 4th
Understanding 31% 2nd 29%* 3rd 41% 1st 39% 7th 36% 1st
Table 7 Regional COOL confidence and understanding in food content
*Please note asterisks denote statistical significance within results and highlight large differences within
responses
England, Scotland and Wales all exhibit similar levels of improved confidence resulting from the provision
12 The options presented were: ‘an indication of COOL information’; ‘alcoholic drinks will have information on ingredients
and nutrition’; ‘non-pre-packed foods such as bakery and delicatessen goods will have consumer facing food label
information’; ‘allergy information to be emphasised in the ingredients list’; ‘information must be easy to read with a
minimum font size’; ‘clear labelling of oil plant derivatives’; ‘engineered nano-materials must be specified’; ‘added water
declaration on meat and fish joints/slices’; ‘clear fat and connective tissue labelling on minced meat products’; ‘nutrition
information will be given in a set order’; ‘none of these will help’; and ‘I don’t know’.
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FA0132 Baseline for Evaluation of EU FIC (Food Information to Consumers) labelling
of food label information. However Northern Ireland shows a statistically significantly lower increase in
levels of confidence associated with COOL. The reported level is 14% lower than the average main
shopper rate and 17% lower than the highest geographical break (i.e. Scotland at 50%).
Similarly, the level of confidence and understanding varies between regions. England reports the
statistically significant lowest understanding level at 29% (410 respondents) with Scotland reporting the
highest at 41% (63 respondents). The evidence collected in the REA suggests low levels of COOL
understanding are to be expected as consumers often experience difficulty understanding COOL
information.
Consumer Use of COOL information
Results from the consumer survey suggest that main shoppers do not rank the use of COOL highly (11th
out of 18 possible sources) when making general purchasing decisions. However, when it comes to
specific products, such as meat, COOL is considered important - as REA evidence confirms (The Smith
Institute, 2010, FSA, 2010c).
(Table 8) summarises regional responses on use of COOL information during the decision making
process.
Q2: What information do you look for when purchasing a food or drink product? (please rank the information by importance – out of 18
13)
Food Label information UK England Scotland Wales Northern Ireland
An indication of country of origin or place of provenance
11th 11th 9th 8th 12th
Table 8 Regional use of COOL
Ranking of COOL information during the decision making process varies from 8th in Wales to 12
th in
Northern Ireland. This variation aligns with the regional variation in confidence and understanding driven
13 The options presented were: ‘special offers/money off/BOGOF’; information about the contents/ingredients’; ‘allergy
related information’; nutrition information’; ‘health information’; ‘animal welfare information’; ‘vegetable/palm oil content’;
‘vegetarian/vegan information’; ‘meat content (not specific to vegetarian/vegan)’; ‘added water content’; ‘quantity
information about different ingredients’; ‘country of origin/place of provenance’; ‘it depends on the product’; ‘other’; and
‘nothing in particular’.
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by COOL labelling shown in table 7. Since all survey participants (n=1,672) responded that COOL
information would positively increase both their confidence in and understanding of a product, it would be
interesting to see whether this increases their propensity to look for the information. Results above
suggest that there are regional differences in the use of COOL information, perhaps explained by
differences in promotional campaigns or in-store marketing practices. Such practices were observed to be
influential in the consumer use of COOL labelling during accompanied shops. Measuring the impact of
these factors was not within the scope of this project, but they should be noted as potential influencers.
Regional food labelling
The consumer survey also sought to understand how regional food labelling affects consumers’ decision
and purchasing behaviour. Two aspects of regional labelling were explored:
(1) If shoppers used regional labelling; and
(2) What consumers (particularly those in Northern Ireland) understand by products labelled as
‘Irish’.
For use of regional labelling, main shopper participants were asked ‘When shopping, do you look for food
or drink from particular parts of the UK, for example Welsh lamb, Scotch beef or Devonshire cream?’
19% (312 respondents) reported they used the information often, and 31% (529 respondents) reported
they used the information sometimes. 48% (801 respondents) claimed that they do not use the
information at all.
Q13: When shopping, do you look for food and drink from
particular parts of the UK?
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Figure 3 Use of regional food labels
Responses varied considerably by region, with approximately twice the proportion of participants in
Scotland (63%, n=97 respondents) claiming to use regional food labelling as those in England (49%,
n=691 respondents) and Northern Ireland (40%, n=16 respondents) (see figure 3). This difference could
not be attributed to one factor, however evidence from the accompanied shops illustrated that all regional
participants (from Wales, Scotland and Northern Ireland) claimed a preference for produce from their own
region (predominantly when purchasing unprocessed meats, dairy and bread) which may account for
Scotland’s high use of regional food labels.
Of particular interest to the assessment of regional labelling was the manner in which consumers
interpreted products labelled ‘Irish’. To determine this, respondents from NI were asked, ‘When you see a
product labelled as ‘Irish’ do you consider it to be from Northern Ireland, from the Republic of Ireland, or
from anywhere else on the Island of Ireland?’ 76% (31% respondents) of participants in Northern Ireland
reported the ‘Island of Ireland’, 5% (2 respondents) selected ‘Northern Ireland’,16% (7 respondents)
reported ‘Republic of Ireland’ and 2% (1 respondent) didn’t know what it referred to.
4.1.3 Accompanied Shop Findings
Building on the quantitative assessment of COOL use, the accompanied shops sought to gain insights
into consumers' real world behaviour and their actual use of COOL information. Three key themes
associated with the use of COOL emerged from the accompanied shops:
1. Consumers infer quality from COOL;
2. Consumers’ use of visual assessment of products prioritised above COOL use; and
3. Consumers are easily confused by COOL and wider marketing information.
1. Consumers infer quality from COOL
Participants perceived and valued country of origin and place of provenance information as a means of
determining quality and supporting their local area. During observations it became evident that the
connection made between COOL information and these issues was often unique to the individual, with
participants making linkages and justifications based on their own attitudes and opinions.
(Regional food labelling, male, and family): When asked if the participant would use country of origin
labelling, the participant commented that they would use it if they bought products such as Scottish
mussels or Hereford meatballs. The participant had previously articulated that their purchases were
driven by product quality.
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2. Consumers use of visual assessment of products prioritised above COOL use
During the accompanied shops it was observed that when consumers purchased unprocessed meat and
minced meat, in many instances they prioritised their visual assessment of the product over the food label
information provided. If visual assessment of such products proved inconclusive, then consumers would
refer to the COOL to further inform their decision. COOL was more often used as a proxy for quality,
enabling shoppers to act on assumptions such as ‘British beef is best’. The example below is of a
shopper making a decision about an unprocessed Beef product.
3. Consumers are easily confused by COOL and wider marketing information
Accompanied shops also highlighted that participants use a range of information types to understand
country of origin and place of provenance. These include: branding information, product names, product
descriptions, voluntary text claims and COOL labelling. Participants’ understanding of this information
varied depending on the product (e.g. differences between minced and unprocessed meat labelling vs
ready meal). Participants’ ability to interpret COOL information was also variable.
Evidence from accompanied shops also highlighted that the presence of food label information intended
for use by consumers to make decisions (e.g. COOL) alongside marketing information used to
differentiate products (e.g. ‘Chinese-style curry’) can confuse consumers, as COOL and product
statements may seem to contradict each other. An example of this is outlined below;
(COOL labelling, female, post family): ‘I think that origin information is important as it helps you make
decisions that are more focused on your beliefs (i.e. supporting the local economy) it also helps you
buy the best products available. Say for example you wanted to buy clotted cream, you wouldn’t want
to buy any old clotted cream, you would want to buy Devonshire clotted cream as this is where the
product comes from and so is the best in terms of quality and taste, or at least that’s what I assume’.
(COOL labelling, female, family): (Researcher) “I see you are looking at beef steaks. Can you use the
think out loud technique to explain what exactly you are looking for” (Participant) “Well I’m looking at
the colour and cut of the meat, although this is slightly difficult as the label covers half of the meat. I’m
also looking for what the title the label says that the meat is lean and I think it’s based on looking at the
meat inside the packet” (Researcher) “Is there anything else that you are looking for to help make your
decision?” (Participant) “No I mean I’ll look at price but overall if I think the meat looks of good quality
that’s good enough for me” (Researcher) “What about country of origin information?” (Participant) “I
don’t look at that information often as really the quality of meat is more important that its origin and I
can usually make that decision myself without looking at the label”.
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4.1.4 Conclusion
The consumer survey found that that awareness of, confidence in, and understanding of, and use of
COOL was moderate among main shoppers. When geographical differences were analysed there seems
to be variation on the majority of assessment criteria. These results go some way to contradict secondary
evidence sources which report consumers seeking out COOL information and ranking it highly in regards
to decision making use.
The accompanied shops confirm some REA findings, notably that consumers find it difficult to understand
and process COOL information. The accompanied shops also found that consumers tend to rely on their
own visual assessments, specifically when purchasing unprocessed meat products (the main application
for COOL) and when using COOL use it to infer product quality. These findings suggest that the
additional labelling has the potential to confuse consumers further. Standardising the approach and
language used, as required by the EU FIC, may reduce consumer confusion about COOL, but ultimately
their ignorance of its basic meaning will have to be addressed.
4.2 UK 2013 Front of Pack Nutrition Scheme
This chapter assesses the manner in which food14
label changes stipulated under the EU FIC regulations
may affect ‘main shoppers’ and their interaction with the UK 2013 Front of Pack (FoP) scheme and
revised EU FIC nutrition labelling.
Considerations when interpreting data from this section
1. Terms used within this section and defined as follows:
14 Please note when references are made to food and food label information this phrase also encompasses drinks
products and information provided on drinks.
(COOL, male, pre-family): The participant was confused about the origin of a cheese pizza during a
prompted exercise. The participant first noticed an Italian flag on the front of the pizza packet and
commented it was trying to be Italian. They then saw a Scottish flag on a corner of the pizza packet
and said they were confused what this meant. The participant investigated further by reading the
product name which included the word ‘Italian’ and by reading the country of origin information which
included the word ‘Scotland’. The participant did not understand where the product originated from.
The branding messaging conflicted with country of origin labelling and confused the participant about
the origin of this pizza. This was the case for both visual cues and text information.
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FA0132 Baseline for Evaluation of EU FIC (Food Information to Consumers) labelling
a. EU FIC nutrition labelling requirements: The provision of FoP information remains
voluntary, however if provided it must meet the requirements set out in the EU FIC Article 35
1169/2011 (for more information please see Defra’s FIR Guide to compliance 2012).
b. Health claims: These are claims (often written statements) which suggest or imply a
relationship exists between a food category, a food or one of its constituents and health.
These can include specific statements such as ‘calcium helps maintain normal bones’ and
more generalist statements such as ‘good for you’ which need to be accompanied by a
health statement (EC 1924/2006 Article 2);
c. Nutritional claims: These are claims (often written statements) which suggest or imply a
food has beneficial nutritional properties due to the presence, absence, increased or
reduced levels of energy of a particular nutrient or other substance. For example ‘source of
calcium’, ‘low fat’, ‘high fibre’ and ‘reduced salt’ (EC 1924/2006 Article 2);
d. UK 2013 FoP Nutrition Scheme: This is the UK labelling scheme which makes percentage
reference intakes (% Reference intake) in line with UK health ministers’ recommendations
and the requirements of Article 35 of EU FIC Regulation 1169/2011; and
e. Mandatory nutrition information: This is the mandatory nutrition declaration, usually found
on the back of food products, which comprises information on: energy, fat, saturates
carbohydrates, sugars, protein and salt content.
2. Please refer to Appendix II for more detail on the specific EU FIC change relating to FoP nutrition
labelling.
4.2.1 Rapid evidence assessment (REA) Findings
Three themes emerged from the REA on nutrition labelling.
1) Industry legislation and guidance on how nutrition information should be provided.
Resources reviewed in the REA were predominantly produced by industry, trade association and
government bodies, such as the Food Standards Agency, The Department of Health (DoH) and The Food
and Drink Federation. These resources aim to provide retailers and food manufacturers with assistance
on nutrition labelling implementation and compliance. Examples include the DoH guide to creating front of
pack (FoP) nutrition labels for pre-packed products sold through retail outlets, and the Responsibility Deal
(DoH, 2013).
2) Robust nutritional information is important
It is often argued that robust nutritional information is important for two reasons. Firstly, the UK has one
of the highest rates of obesity in the world with 26% of adults classified as obese and 63% as either
overweight or obese (Responsibility Deal, 2013). Secondly non-transmittable nutrition-related diseases
such as heart disease and diabetes are on the rise (ibid, 2013), a situation which must be addressed.
The literature reviewed tends to focus on:
(1) How nutrition labels promote a balanced diet and enhance public health (FAO, 2013); and
(2) How nutrition labels can help consumers better understand the nutritional values of the food
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FA0132 Baseline for Evaluation of EU FIC (Food Information to Consumers) labelling
they eat, make informed product comparisons of foods, and enable healthier choices to be
made (FDA, 2014; Van Herpen et al, 2011).
3) Consumer use of FoP nutrition information
One of the themes most commonly investigated in the literature reviewed in the REA was the consumer
use of FoP nutrition information. A number of elements were identified within this theme and are
summarised below:
Garretson et al, 2000; Cowburn et al, 2005; and Sharf et al, 2012 have all shown that
consumers prioritise the use of nutritional information as follows: first health claims, then
nutritional claims, and then FoP nutrition information;
Generally, consumers are more interested in nutritional and health claim information on inherently
healthy products than on treat products (which are often high in fat, sugar and salt) as they wish
to confirm the health credentials of their choice;
Generally, consumers prioritise and act on information on specific nutrients over others (e.g. fat
over sugar), with information on fat being the most sought-after, followed by sugar and calorie
information respectively (Grunert et al, 2010; Van Herpen et al, 2011);
Generally, consumers are confused by salt and sodium labelling (FSA, 2010d, NPR, 2013); and
The impact of nutritional and health claims on consumer decision-making can be product-
dependant. Health claims have been demonstrated to be more effective than nutritional claims in
influencing purchasing decisions about products such as cereals and yogurts. Further research in
this area is suggested (Verbeke et al, 2009; Gracia et al, 2009; Markosyan et al, 2009).
4.2.2 Consumer Survey Findings
Awareness of UK 2013 FoP Nutrition Scheme
To measure awareness of UK 2013 FoP scheme information, the consumer survey tested consumers’
‘unprompted’ and ‘prompted’ awareness levels. The study assumed that the higher the unprompted
response, the more familiar consumers are with the information. Table 9 and 10 summarise these
responses in relation to nutrition information found within the UK 2013 FoP nutrition scheme and on food
labels generally.
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FA0132 Baseline for Evaluation of EU FIC (Food Information to Consumers) labelling
Q9: Thinking about product content information on food and drink labels, what subjects are covered in that information? (Ordered in highest to lowest recall awareness - out of 14 information types)
Nutritional information awareness (Unprompted)
UK UK % (of
1,672) England
Eng (of 1,254)
Scotland Scot (of
138) Wales
Wales (of 132)
NI NI (of 148)
Fat content information 1 43% 1 44% 2 41% 4 29% 4 42%
Sugar content information 3 41% 2 41% 3 37% 2 45% 2 50%
Calorie information 4 33% 4 33% 1 34% 6 17% 3 43%
Nutritional information 5 28% 5 28% 5 28% 3 31% 6 22%
Table 9 Recall awareness of UK 2013 FoP Nutrition Labelling15
*Please note the above question asked users to rank food label information out of all 14 types of food label information available (please see footnote 19).
15 The following selection of responses were listed to test respondent prompted and unprompted awareness of consumer food label information: ‘name of food and drink’;
‘list of ingredients’; ‘calorie information’; ‘nutritional information’; ‘fat content information’; ‘sugar content information’; ‘country of origin/provenance’; ‘food/drink allergy
information’; ‘vegetable/palm oil content information’; ‘nano-materials information’; ‘meat content information’; ‘collagen/meat protein information, and ‘other’.
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FA0132 Baseline for Evaluation of EU FIC (Food Information to Consumers) labelling
Q10: Please look at this list and tell me which types of information you think are currently shown on food and drink?
Nutritional information awareness (Unprompted)
UK UK % (of
1,672) England
Eng (of 1,254)
Scotland Scot (of
138) Wales
Wales (of 132)
NI NI (of 148)
Fat content information 2 74% 2 73% 2 78% 3 8% 1 84%
Sugar content information 3 73% 6 72% 5 76% 6 81% 7 84%
Calorie information 3 73% 3 72% 4 76% 4 76% 2 85%
Nutritional information 5 64% 4 63% 6 72% 7 66% 8* 58%
Table 10 General awareness of UK 2013 FoP Nutrition Labelling
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FA0132 Baseline for Evaluation of EU FIC (Food Information to Consumers) labelling
*Please note salt has been excluded from this review as the aim was to review general nutritional
information rather than focus on nutrient and ingredient specific elements.*
When prompted with a list of types of information currently shown on food and drink, around 70% (1,170)
of respondents cite fat, calorie and sugar information . This is approximately 30% higher than the number
of consumers (around 40%, n=669,) who remember that this information is on labels when not prompted
with a list.
Regional Differences
Outlined above in table 10 is a summary of the prompted awareness responses per geographical
breakdown. Across all regions, consumers mention fat, followed by calorie, followed by sugar information
in that order, although the number of respondents who mention these varies (with Wales and NI generally
showing the highest levels of awareness of fat and calorie information in particular)
Awareness (prompted) is most variable in Northern Ireland with both the highest (85%,n=30) for calorie
information and lowest (58%, n=20) for general nutrition information. Both England and Scotland reported
to have high levels of awareness across all nutrition labelling. These results and variations could stem
from a number of factors (regional promotional campaigns, in-store advertising etc. as evidenced during
the in-store observations), which could be directly attributable to the findings. The results also suggest
that the introduction of the EU FIC may have different impacts on different geographical locations. There
is as yet no evidence in the literature to explain how the different regions may be affected, and this is
therefore identified as an area for further investigation.
Perceived importance of UK 2013 FoP nutrition labelling information
For the baseline of the impact of the UK 2013 FoP information on consumers’ decision-making
behaviour, participants were asked if the information would help (1) improve their confidence; (2) improve
their understanding of the content of the food they purchased; and (3) if they thought having nutrition
information on food would help them make healthier choices.
Q18 &Q19: Will this information help improve your confidence/or understanding of the content of food and drink you purchase?
Nutrition information will be listed in a set order
UK % (of 1,672)
England % (of 1,254)
Scot % (of 138)
Wales % (of 1320
NI % (of 148)
Confidence 34% 34% 33% 48%* 29%
Understanding 28% 27% 30% 36% 22%
Table 11 UK 2013 FoP nutrition information contribution to consumer confidence and understanding
Consumers surveyed rate nutritional information (i.e. UK 2013 FoP nutrition information) at mid-level
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importance amongst food label information provided under the EU FIC label changes. At 6th place they
consider it less important than (1) font size; (2) COOL labelling information; (3) added water declarations;
and (4) additional minced meat information. It must be noted that to gather the above results survey
participants were presented with a number of options12
therefore their ranking must be contextualised
within wider EU FIC labelling changes.
To assess if current nutrition labelling helps consumers make healthier food purchasing decisions (as is
the aim of the provision of such information), participants were asked ‘to what extent do you think that
having information on the label about product contents will help you make healthier choices?’16
The
responses, highlighted below, show that 82% (1,375 respondents) reported that UK 2013 FoP nutrition
information will help them make healthier choices, with 47% (784 respondents) stating it’s a ‘big help in
making healthier choices’.
Q20: Do you think that having information on the label about product contents will help you make healthier choices?'
Response UK %
(of 1,672)
England % (of 1,254)
Scot % (of 138)
Wales % (of 1320
NI % (of 148)
A big help in making healthier choices 47% 47% 51% 38% 49%
A small help in making healthier choices 35% 35% 32% 41% 27%
No help in making healthier choices 10% 10% 7% 12% 17%
Don't want to make healthier choices 4% 4% 6% 4% 0%
Don't know/can't say 4% 4% 4% 5% 6%
Table 12 UK 2013 nutrition label contribution to healthier consumer choices
In summary, just over a third (34% - n=576) of consumers say that UK 2013 FoP nutritional information
will improve their confidence, and over a quarter (28% - n=467) state it will improve their understanding
about the food they purchase, helping to meet one of the aims of providing such information on food
labels.
Regional Differences
The survey results suggest that respondents from England, Scotland and Northern Ireland consider the
EU FIC nutrition labelling changes will provide additional confidence in, and understanding of the content
of the food and drink they purchase. This trend is in line with main shopper results.
16 When administering this question and if asked to explain what ‘information about product contents’ referred to
researchers outlined that this was in reference to FoP nutrition information.
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Wales reported the highest increases of both understanding (36% - n=26) and confidence (48% - n=34),
while Northern Ireland reported the lowest increases with a 22% (n=9) increase in understanding and
29% (n=12) in confidence. There was a 19 percentage point difference between Wales and Northern
Ireland in improving confidence and 14 percentage point difference in improving understanding (see
Table 12). As these figures are both above or below the main shopper average reported it is suggested
that this difference is further explored.
Will the UK 2013 FoP nutrition scheme labelling information about product contents help consumers
make healthier choices? The majority of respondents reported that it would (England 82% - n=1,160,
Scotland 83% - n=128, Wales 79% -n=57 and Northern Ireland 76% - n=31). The results present a
positive relationship between nutrition information and respondents’ attitudes and therefore suggest that
the EU FIC regulation may positively impact purchasing decisions, and thereby contribute to public
health. This result is however contradicted by the accompanied shops, where researchers found that
consumers do not use this information unless driven by specific purchasing motivations.
Consumer use of UK 2013 FoP nutrition scheme labelling information
To understand current usage of nutrition labelling, survey respondents were asked to rank the food label
information (both existing and EU FIC) they look for when purchasing food in general (see Table 13). Of
the 15 sources of food label information listed, on average, respondents ranked health (claims) and
general nutrition information eighth and ninth respectively, with traceability and supply chain information,
price, ingredients list, product familiarity and brand name preference being of more importance in
making purchasing decisions.
However, it is important to note that for those respondents who had dietary restrictions (e.g. low
cholesterol, low fat diet etc.) 39% (200 respondents) ranked nutrition information as the most important,
making it the highest scoring information. This was followed by the ingredients list at 32% (163
respondents) and shows that respondents with different purchasing motivations use and prioritise
information differently.
Q2: What information do you look for when purchasing a food or drink product? (please rank the information by importance)
Food label information (rank out of 18)
UK England Scot Wales NI
Health Information 8 9 6 4 11
Nutrition Information 9 8 9 9 14
Table 13 Information looked for when purchasing food and drink
Regional Differences
Outlined above in table 13 is a summary of the geographical differences in how consumers ranked their
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FA0132 Baseline for Evaluation of EU FIC (Food Information to Consumers) labelling
use of both health claims and nutritional information. The results show that different regions use the UK
2013 nutrition scheme labelling differently than other food labelling information. Respondents from
Northern Ireland claimed to use this information the least (14th out of 18) and English respondents the
most (8th out of 18). Health information use also varies: it is valued more highly than nutritional
information in Wales (4th out of 18) than in England (9
th) and Northern Ireland (11
th).
4.2.3 Accompanied Shops Findings
Building on the consumer survey, the accompanied shops sought to build a more detailed picture of
consumer usage of FoP information. Four themes emerged from the accompanied shops.
1. Consumer confusion on interpreting nutrition information on food labels;
2. Consumer use of nutrition labelling as a short-cut in the decision making process, and tendency to
prioritise the one nutrient over another in their decisions (this varies across products);
3. Consumers use of nutrition information in a hierarchical order; and
4. Treat buys and lack of nutritional reviews.
1. Consumer confusion on interpreting nutrition information on food labels
Nutrient-specific confusion was observed in the consumer survey results identifying the need for clearer
labelling. The accompanied shops highlighted two possible reasons for this confusion: (1) consumer
inability to compare and trade-off different nutrients with each other (e.g. fat versus sugar); and (2) poor
consumer understanding of nutritional ingredient terminology (e.g. salt and sodium). This is illustrated in
the example below:
2 Consumer use of nutrition labelling as a short-cut in the decision making process, and tendency
to prioritise the one nutrient over another in their decisions (this varies across products).
It was evident during the accompanied shops that if consumers used FoP nutritional labels, they reviewed
nutrients listed on FoP and based on this list, prioritised one nutrient over another in deciding which
product to purchase. If the shopper was specifically looking for ‘healthier’ food or they had a special
dietary requirement then they used the nutritional information, in particular claims such as ‘low in
saturated fat’ or ‘reduced salt’ as a quick reference guide to make their decisions.
(Female, pre-family): “This is what I don’t get, this (ready meal) is low in sugar and saturated fat but
high in sodium, does that mean that it’s not a bad food (nutritionally)? I’m not sure if you can exp lain to
me which one I should be prioritising but for the moment I have no idea if products like this are good,
bad or indifferent so I’m not going to buy it. Also I’m assuming sodium is salt, I seem to remember it is
– what do you think?’
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3 Consumer use of nutrition information in a hierarchical order
As referenced in the REA, there is a hypothesis that consumers use nutritional information on food labels
in a hierarchical manner: health claims valued most, then nutritional claims and lastly FoP and BoP
nutrition information. The accompanied shops confirm this hypothesis, as illustrated below.
The accompanied shops showed that consumers are able to process health claims faster than other
nutritional information and that these claims resonated better with participants than other information. A
hypothesis for this using insights gained from the accompanied shops is that as health claims are often
linked to physical problems, they enable participants to make an emotional link to the product in their
decision making processes (Williams, 2005; Leathwood et al, 2007).
4 Treat buying and lack of nutritional reviews.
Participants were observed to ‘overlook’ nutritional information when buying ‘treats’. Two reasons for this
behaviour became apparent:
1) Some participants mentioned that if they did buy a treat they knew it was ‘unhealthy’, and therefore
did not need nutritional information to confirm the nutritional value of the product.
2) If participants did review the nutritional information then it was likely that they would not purchase the
treat if it suggested the product was ‘overtly unhealthy’.
(Female, family): The participant explained they only use calorie information as their guide because
they cannot relate values of other nutrients to their own diet: ‘Well I’d choose this biscuit because it’s
only 89 calories per biscuit, while that’s a little on the high side I wouldn’t be eating the whole packet in
one go. I do look at the other stuff like fat and salt but I don’t know whether 1.5g of salt is bad or not,
again it seems high but I don’t know if it’s too high. With calories at least I have a better knowledge’
(Female, senior): “I love those Activia yogurts; they are so good for you” (Researcher) “What makes you
say that?” (Participant) “Well I always remember the advert with the BL Regularis stuff which is good for
your gut also they use probiotic yogurt which is meant to be healthier”.
(Female, post family): “My husband has very high cholesterol so I always look for those spreads which
say ‘helps to lower cholesterol or helps a healthy heart’ as they are better than the normal stuff. In fact I
always buy Flora Pro-activ as it says on the packet that it actively lowers cholesterol”.
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FA0132 Baseline for Evaluation of EU FIC (Food Information to Consumers) labelling
4.2.4 Conclusion
There is a substantial body of work which assesses the use of the different types of nutrition information
which is found on food labels. Many of these sources document the nuances of consumer behaviour
surrounding the use of such information. It is unclear from the secondary evidence review what impact the
introduction of the EU FIC regulation may have. The consumer survey results show:
1) A high general awareness of different types of nutrition information presented on food labels.
2) A low perception of nutrition information contributing positively to consumer understanding and
confidence in the content of the food and drink they purchase.
3) A positive self-reported correlation between nutrition information and making healthier choices.
These results also support the evidence from the REA which proposes that consumers use nutritional food
label information in a hierarchical manner, with health claims (if provided) being used above both nutritional
claims and mandatory nutrition information to inform consumer decision making. This suggests that the EU
FIC labelling changes which control the use and accuracy of health claims on food labels have the potential
to affect consumer behaviour. Overall though, the consumer survey results suggest there may be a mixed
impact of the introduction of the EU FIC regulation.
Of all of the consumer-facing EU FIC changes, UK 2013 FoP labelling is the area where there is the
greatest variation in use by different types of shopper, making it an area for further research into the
nuances in consumer behaviour.
4.3 Allergen labelling
This section assesses how the food label changes under the EU FIC may impact medically and self-
(Male, family): “I don’t tend to look at all of this traffic light information or ‘low’ and ‘healthier’ claims as you
know when you buy biscuits that they are not good for you but you’re going to buy them anyway because
you want them. You just have to make sure that when you get home you don’t eat the full packet and mix
things up with some fruit and vegetables. It’s not rocket science”
(Female, family): “I want to buy a pudding for this evening as a treat for the family. We all like chocolate
cake so I want to get one that everyone likes, there’s two here that I would pay for. When you look at
them though one is red and has almost 30g of sugar in it, so I think I’ll get the other one as that looks
marginally better at 22g”
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FA0132 Baseline for Evaluation of EU FIC (Food Information to Consumers) labelling
diagnosed allergy and food intolerance sufferers, notably those consumers who are dependent on accurate
and robust food labelling to prevent adverse health consequences.
Considerations when interpreting data from this section:
1. For the purposes of this research, the consumer survey and accompanied shops focused on ‘main
shopper’ behaviours. However, as allergy sufferers are a key audience for the EU FIC it was
deemed important to include a sample of them to give an indicative account of their use of food
labels;
2. Due to the scope of the project, a deep dive investigation into the 14 listed allergens within the EU
FIC was not conducted;
3. For the purpose of allergy and intolerance participant recruitment for the consumer survey,
accompanied shops and in-home observations respondents were asked the following questions; (1)
‘Thinking about the people you shop for (including yourself), are there any health issues, allergies or
personal choices that influence the grocery products you buy?’ and (2) ‘Have you had a medical
diagnosis of the allergy/intolerance from a qualified doctor?’. Of the 1,672 main shopper respondents
within the consumer survey, 349 participants (21% of the total sample) responded that they had, or
shop for someone with, a food allergy or intolerance. Of these 349 participants, 10% stated that they
had, or shopped for someone with, a medically-diagnosed allergy. This latter figure is approximately
in line with the estimated proportion of food allergy sufferers in the UK population;
4. Of the 90 participant observations (both in-store and in-home) conducted, 14 were conducted with
food allergy and intolerance sufferers as defined by the above qualifying questions;
5. Food allergies and food intolerances are defined in this report as follows:
a. Food allergy: when an adverse reaction to food occurs due to an immunologic mechanism,
these often involve immediate hypersensitivity (IgE) and delayed T-cell mediated responses
(non-IgE) (World Allergy Organisation, 201417
), and
b. Food intolerance: non-allergic (non-immune) adverse reactions to food (ibid, 2014);
6. The results in this section focus on responses gathered from both the 159 medically diagnosed
allergy participants, and the 349 participants (inclusive of those medically diagnosed) who stated
they have a food allergy or intolerance. This ensures a focus on how the EU FIC changes will affect
the people who most use and could be adversely affected by the changes to the presentation of
allergy information; and
7. For detailed information on the EU FIC 1169/2011 allergy changes please refer to Appendix II.
17 http://www.worldallergy.org/public/allergic_diseases_center/foodallergy/
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4.3.1 Rapid evidence assessment (REA) Findings
The REA identified a wide body of literature that explores food allergies and intolerances, spanning
medical journals, industry and charity publications, and guidance and information provided by
governmental departments such as DoH.
It is estimated that 1%- 4% of the UK’s population suffers from a medically diagnosed food allergy
(Morris, 2013). Although this is a small proportion there are potentially significant consequences if
labelling of food and allergenic ingredients is inaccurate or misunderstood. In the literature reviewed there
were two broad themes:
1. Trends surrounding the reporting of food allergies and food intolerances.
2. The use of allergy information by allergy sufferers.
1. Trends surrounding the reporting of food allergies and food intolerances
The literature identifies a growing trend for self-diagnosis (of both allergies and intolerances), and
evidence that this can in some circumstances lead to nutritional deficiency and other health impacts, and
the use/incorrect use of food label information (see Watson, 2013, Sommer, 2013, Voordouw et al, 2010).
This trend has recently been explored in depth by the charity Allergy UK which conducted a study into
dairy intolerance. The study found that 44% of individuals participating who class themselves as dairy
intolerant are self-diagnosed, relying on the internet and other non-conventional methods of diagnosis
(Allergy UK, 2013a). The study found that the trend for self-diagnosis led to under-reliance on health
practioners and GPs as key information sources. The study also found that once self-diagnosed, allergy
and intolerance sufferers remove the offending item from their diets, often without guidance from health
care professionals. This could lead to adverse health consequences, depending on the food item
removed. The study highlighted that while the new EU FIC changes will improve identification of
information, the importance of consistent consumer behaviour (i.e. regular checking of product
information) is required to reduce the incidence of allergic episodes. The study also placed an emphasis
on seeking medical advice.
2. The use of allergy information by allergy sufferers
The second trend uncovered by the REA concerned how allergy and food intolerance sufferers use
existing information provided by food labels (e.g. under The Food Labelling Regulations 199618
), with a
growing body of evidence (journals and blog posts predominantly) looking at the food label changes
outlined by the EU FIC and how these will affect established food allergen reporting protocols (see
Cochrane et al, 2013, Institute of Food Science and Technology, 2014, Food Navigator 2013).
A notable source of evidence which assessed the use of food label allergy information by allergy sufferers
is Barnett et al’s (2011) study, which highlights that sufferers utilise a myriad of food information to inform
their choices including ingredients lists, allergy boxes, product name, level of labelling information detail,
18 http://www.legislation.gov.uk/uksi/1996/1499/contents/made
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photos, product texture and external factors such as perceived trustworthiness of the producer and
previous experience of the product. Overall, the literature reviewed found that experienced allergy
sufferers19
do not make their decisions using a single factor, but use layers of information through usage
of visuals provided by labels. In contrast to experienced allergy sufferers, the literature suggests that
inexperienced allergy sufferers20
use allergy-specific food label information and specific-directed allergy
information, such as ‘contains’ boxes and ‘free from’ product claims.
4.3.2 Consumer Survey Findings
Within this section the consumer survey results reported are from the ‘allergy group’ who are the 349
participants who reported to have, or shop for people who are either medically or self-diagnosed food
allergy and intolerance sufferers.
Awareness of allergen information
Results from the consumer survey suggest that only 16% (57 respondents) of the allergy/intolerance
group are aware ‘unprompted’21
that allergy information is shown on food packaging. This recognition
rate is higher than the average ‘UK main shopper’ awareness rate recorded by the consumer survey at
9%, 135 respondents).
Q9: Thinking about product content information on food and drink labels, what subjects are covered in that information?
Food label information No dietary
restrictions (of 819)
Allergy/food intolerance (of
331)
Other restrictions (cholesterol, low fat etc.)
(of 600)
Food & Drink allergy Information
% % %
6 16% 11%
19 An experienced allergy sufferer is defined as allergy and intolerance sufferer who has been medically diagnosed for
two years or more and therefore possesses the established behavioural shopping patterns associated with experienced allergy suffers, i.e. referring to ingredients list for allergy information.
20 An inexperienced allergy sufferer is defined as a sufferer who has been diagnosed for less than two years and
therefore has less established shopping patterns i.e. relying more on specific allergy information such as ‘contains’ boxes.
21 Unprompted questions require respondents to provide a recall response i.e. they were not guided by explanations from
the research team. These questions assess how front-of-mind different types of information are, and shed light on the importance placed on different types of information.
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FA0132 Baseline for Evaluation of EU FIC (Food Information to Consumers) labelling
Table 14 Unprompted awareness of allergen information per diet demographic
When prompted22
however, the allergy/intolerance group’s awareness of allergy-related information in
labels increased to 60% (208 respondents). When it comes to the list of ingredients shown on food labels,
51% (168 respondents) of the allergy/intolerance group illustrated an ‘unprompted’ awareness that the list
of ingredients is shown on food packaging, again higher than that recorded from the consumer survey for
‘UK main shoppers’ (42%, n=659). Within a prompted exercise the awareness of ingredients lists on food
labels increased to 73% (256 respondents) for the allergy/intolerance group.
Q10: Please look at this list and tell me which types of information you think are currently shown on food and drink?
Food label information No dietary
restrictions (of 882)
Allergy/food intolerance (of
349)
Other restrictions (cholesterol, low fat etc.)
(of 634)
Food & Drink allergy Information
% % %
47 60% 59%
Table 15Prompted awareness of allergen information per diet demographic
The consumer survey results illustrate low ‘unprompted’ recall rates of specific allergy information (i.e.
‘contains’ boxes and product claims) among the allergy/intolerance group, but higher ‘prompted’ recall
rates. This suggests that the EU FIC changes are aligned with allergy and intolerance sufferers
predisposed ‘unprompted’ and ‘prompted’ behaviours (i.e. use of ingredients lists to determine allergen
information) implying a potential for positive outcomes associated with the changes.
Results suggest experienced allergy and intolerance shoppers prioritise the ingredients list as an
information source. Further research could explore when shoppers move from using allergy-related
information to relying on their knowledge and experience of ingredients and recipes.
Perceived importance of allergen information
Profound changes to allergen labelling information are being introduced by the EU FIC regulation. To
further understand the allergy group’s interaction with these changes they were asked their thoughts on
the main substantial change (in which allergy information is to be emphasised in the ingredients, instead
of in a separate ‘contains’ box’) and how this might impact on their understanding of and confidence in the
content of the food and drink they buy. 48% (167 respondents) of the allergy group responded that they
believe the standardisation of allergenic ingredient information in the ingredients list will improve their
understanding of the content of the food and drink they purchase. This was further substantiated by
responses of this group to a question about the ‘general EU FIC changes’ to be addressed (e.g. font size,
22 Prompted questions are structured with predefined answers or illustrative cards, offered to respondents by the
research team to assess how visual or audio cue’s may illicit recall of information.
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FA0132 Baseline for Evaluation of EU FIC (Food Information to Consumers) labelling
COOL etc.) where these changes (i.e. allergy labelling) were the highest ranked by allergy and
intolerance sufferers.
Q18 &Q19: Will this information help improve your confidence/or understanding of the content of food and drink you purchase?
Allergy information to be emphasised in the
ingredients list, instead of on a separate \Contains\" list"
No dietary restrictions (of
882)
Allergy/food intolerance (of
349)
Other restrictions (cholesterol, low fat etc.)
(of 634)
% % %
Confidence 35% 67% 52%
Understanding 25% 48% 34%
Table 16 EU FIC Allergen changes contribution to allergen suffers changes in confidence and
understanding
67% (235 respondents) of allergy and intolerance respondents reported that the change will improve their
confidence in the content of the food and drink that they purchase, rating this change the highest in
boosting confidence levels, followed by font size at 57% (198 respondents).
The results outlined above illustrate the positive light in which allergy and intolerance sufferers view the
EU FIC allergy labelling changes. However, the results also reveal a gap between confidence and
understanding. 67% (235 respondents) of allergy group shoppers claim the changes will increase their
confidence in the content of the products they buy, whereas only 48% (167 respondents) of the same
group claim the changes will increase their understanding – a difference of 19% (68 respondents). This
gap suggests that increased confidence may outstrip real understanding and therefore growth in
knowledgeable usage of food label information. This is an area for further exploration.
Consumer use of allergy information
To understand current use of allergy information and general food label information by allergy and
intolerance sufferers survey respondents (n=349) were asked to rank food label information (both existing
and EU FIC compliant) in order of importance when purchasing food or drink. Out of 18 possible sources
of information allergy information was ranked eighth.
This prioritisation is also reflected by the main shopper sample (i.e. respondents who do or do not suffer
from a food allergy or intolerance), with both groups ranking price and expiry dates amongst top five
information sources. Allergy and intolerance sufferers rank the of ingredients list 3rd
whereas main
shoppers place it 10th. The allergy group rank specific allergy information 8
th whereas main shoppers
place it 12th. These results support the hypothesis that allergy and intolerance sufferers prioritise
ingredients list labelling above other specific allergy information provided such as ‘contains’ boxes.
Recommended EU FIC changes therefore seem to anticipate allergy and intolerance sufferer behaviour
accurately.
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After assessing current labelling, allergy and intolerance sufferers’ (n =349) were asked to assess the
new EU FIC allergen labelling in comparison to the old style23
(pre EU FIC). Participants were provided
with an example of both old style and new style labels and asked whether they thought the revised
labelling would make it easier or more difficult to find allergen information. Results from this exercise
show that 54% (191 respondents) of allergy and intolerance respondents think the new EU FIC allergen
changes will make it ‘slightly’ or ‘much’ easier to find allergen information on food labels, whereas 18%
(60 respondents) of the same population believe it will make it slightly or much more difficult. See figure
4.
Figure 4 Allergy and intolerance sufferers reported ease of use on new EU FIC allergy labels. N=349
4.3.3 Accompanied Shop Findings
64 accompanied shops were conducted across England, Wales, Scotland and Northern Ireland, of which
10 were conducted with diagnosed food allergy and intolerance sufferers. Four themes emerged from the
shops undertaken with the allergy and intolerance sufferers, these being:
1. Experienced food allergy and intolerance sufferers using the ingredients list above other allergy
specific information;
2. Inexperienced food allergy and intolerance sufferers showing a predisposition to rely on product
claims and ‘may contain’ boxes’;
3. Use of ‘free from’ products in isolation of wider food label information; and
4. Food label review behaviour amongst Allergy and intolerance sufferers.
1. Experienced food allergy and intolerance sufferers using the ingredients list above other
23 Refers to pre EU FIC food labelling practices, notably the use of allergy ‘contains’ boxes.
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allergy specific information
In support of both the secondary evidence from the REA and primary evidence from the consumer
survey, the accompanied shop observations demonstrated that experienced food allergy and intolerance
sufferers use ingredients lists to assess product information, rather than targeted allergy information such
as ‘contains’ boxes, as illustrated in the quote below:
Although allergy and intolerance shoppers used a range of approaches to identifying products which may
trigger their affliction, such as product names, visual cues and their prior knowledge of ingredient and
recipes, all 10 participants used the ingredients list. Participants stated their use of the ingredients list
was for two main reasons:
1) The detail provided within an ingredients list is not replicated anywhere else on a food label; and
2) Allergen information can often be ambiguous (or is perceived to be) and sufferers checking
ingredients lists feel reassured in their decisions.
This finding further supports the potential for the EU FIC allergy changes to make a positive impact on
food allergy and intolerance sufferers.
2. Inexperienced food allergy and intolerance sufferers showing a predisposition to rely on
product claims and ‘contains’ boxes
The second observed consumer behaviour which confirms evidence in the secondary literature is the
predisposition of newly-diagnosed food allergy and intolerance sufferers to rely on targeted ‘old style’23
allergy information such as ‘contains…’ boxes. The two examples below, illustrate the difference
between ‘experienced’ and ‘inexperienced’ sufferers usage of allergen information.
(Allergy suffer, female, family) “I always look at the ingredients list if I’m unsure of a product. I have
quite a severe allergy to nuts and wheat so there is normally a significant amount of information
usually provided on the label. It’s always easier to check the ingredients list as it is more detailed and I
can catch ingredients that some food label classifications don’t capture”.
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The two
examples above show how shopping styles vary and how the experienced allergic participant relied on
more comprehensive information provided in the ingredients list. A more focussed study commissioned
by the Food Standards Agency is currently assessing the type of allergen labelling present on pre-packed
processed food sold in the UK. The results from this research should be considered in any future studies.
During the course of the accompanied shops (between 24th February – 4
th March 2014) three retailers
had begun in-store campaigns to educate consumers on the EU FIC changes. However, during all
accompanied shops with food allergy and intolerance sufferers no participant utilised the information
(predominantly leaflets) provided by retailers, despite its distribution at key points in-store. From this
limited sample, it seems allergy and intolerance sufferers do not yet see retailers as a source of
information about allergens.
3. Use of ‘free from’ products in isolation from wider food label information
Stores visited for the accompanied shops had varying levels of availability and promotion of ‘free from’
products. Participants with a gluten intolerance utilised ‘free from’ aisles and products as much as was
possible during their shops. This behaviour in ‘free from’ aisles is different from practiced and standard
allergen and intolerance shopping behaviour, which focuses on ingredients list). This suggests a higher
level of trust in and/or assurance from products labelled ‘free from’. Inexperienced allergy and food
Example 1: Participant (male, pre-family) who has been diagnosed with multiple intolerances within the
last month
The participant used a combination of allergy boxes, ingredients lists, product names and descriptions,
and free-from claims to indicate if allergenic material was present. This took place for some, but not all
products. The participant indicated they used the allergy box as the main indicator of whether or not
allergenic material was present. They also demonstrated that they believed the lack of an allergy box
indicated no allergic material was present in the product but still expressed some uncertainty or
suspicion if it wasn’t present. They did use the ingredients list to provide evidence behind free-from
claims on products.
Example 2: Participant (female, post family) who has been aware of their multiple allergies for a
number of years
The participant did not use allergy boxes, instead using the ingredients list on almost every product
that she bought for herself to check if allergenic material was present. This took place for products that
were bought both regularly and for unfamiliar products. There were eight products where the
ingredients list was studied in more detail. These were all processed products, such as sausage rolls
and peanut butter. In particular, the participant commented she always checked the contents of curried
products, such as Tandoori paste, even though she bought it regularly because she wanted to be
100% sure about the contents of the product. She inferred allergen risk from the product description or
applied her own knowledge for those allergens with less severe consequences.
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intolerance sufferers also exhibited this shopping behaviour, which correlates with the evidence noted
above that inexperienced sufferers have a predisposition to use product information and claims to inform
their decisions. The departure from established food allergy and intolerance behaviours (i.e. use of
ingredients lists) of experienced allergy and intolerance behaviours in relation to ‘free from’ products is a
potential area of further research.
4. Food label review behaviour amongst Allergy and intolerance sufferers.
The accompanied shops also highlighted areas of potential risk among allergy and food intolerance
sufferers. A notable example of risk found is illustrated by the accompanied shop example above, which
demonstrates that in some instances allergen sufferers may only check ingredients in unfamiliar products
without continuing to check product information for ‘familiar’ products they see as regular purchases.
This poses a risk as businesses may alter production sites and product formulas without advertisement to
consumers altering the allergen risk to consumers. Similarly to above, risks associated with allergen and
food intolerance sufferers may be an area for further research.
4.3.4 Conclusion
Outlined below is a summary of the key findings gathered during the assessment of food allergy and
intolerance consumers’ interaction and use of current food labels and their perceptions of the EU FIC
food allergy labelling changes.
1. Prompted, 50% of allergy and intolerance shoppers are aware list of ingredients on food
labels, and only 16% are aware of allergy-specific labelling information (such as ‘contains’
boxes).
16% (57 respondents out of 349) of food allergy and intolerance sufferers can recall unprompted
that allergy information is shown on food packaging, and 50% (175 respondents) were aware
unprompted that ingredients list information is also provided on food labels.
2. Indication of positive consumer opinion of the proposed EU FIC allergy changes
Evidence from research conducted by Sommer, et al in 2012 suggests that medically diagnosed
food-allergic participants expressed dissatisfaction with the current food labelling practices (i.e.
confusion and ambiguity). Whilst the consumer survey conducted did not seek to assess opinion
on pre EU FIC food labelling it did seek to review attitudes towards proposed EU FIC changes
(Allergy suffer, female, family) ‘I don’t really trust the allergy information provided on products as it is in
different places on different products, some products say one thing, while others say another. It’s much
easier to rely on my own knowledge of what products I can and can’t buy and look at ingredient listed if
I’m really not sure about something’.
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and found that 54% (191 respondents) believe the new labelling changes will make finding
allergen information easier.
3. Differences between experienced and inexperienced food allergy and intolerance sufferers
behaviours and potential for negative impact associated with inexperienced food allergy
and intolerance sufferers and the EU FIC changes
Evidence collected from the REA, survey and accompanied shops suggests that there is a
difference between the manner in which experienced and inexperienced food allergy and
intolerance sufferers use food label information to make food purchasing decisions. This
difference in food label usage has highlighted that this could be an area for further research, as
the distinction between the different shopping styles between the two types of sufferers was not
explored in detail.
4. Food allergy and intolerance consumers use a range (brand imaging, product descriptions
etc.) of information sources to avoid allergenic ingredients
Secondary evidence, such as Barnett et al’s 2011, study shows ingredients list, allergy boxes and
other cues such as product name, photos and product texture are used in conjunction with each
other to assess if a product contains allergenic ingredients. The consumer survey supports this
showing that respondents with allergy or food intolerances look for ingredient and product content
information (i.e. ingredients lists) (34%) more than other allergy related information (27%). This
suggests that while the EU FIC allergy labelling changes are viewed in a positive light by many
(as they are perceived to make finding information easier) they may still remain as a secondary
choice for some consumer’s assessment of allergy and allergy derivative ingredients.
4.4 Additional EU FIC ingredient labelling requirements
This section specifically seeks to explore and understand consumers’ interaction with other new EU FIC
ingredient labelling declarations: (1) minced meat; (2) added water; (3) engineered nano-materials; (4)
quantitative ingredients; and (5) labelling of oils.
Considerations when interpreting data in this section:
1. In comparison to the REA research undertaken on allergens, COOL and UK 2013 FoP labelling
(reported in previous sections), limited detailed information was identified during the REA,
accompanied shops and in-home observations. Therefore the findings for all other EU FIC prioritised
regulation changes for review are combined. For the purposes of this section, these five ingredients
will be classified as ‘other’ unless reported separately; and
2. Please refer to Appendix II for more detailed information on EU FIC 1169/2011 ingredients listing
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requirements.
4.4.1 Rapid evidence assessment (REA)
The literature reviewed offered no evidence to support the view that the EU FIC changes to the listing of
‘other’ ingredients would influence consumers’ purchasing decisions. The REA found no sources which
assessed awareness or use of information relating to the (1) ‘Engineered nano-materials’; (2) added water
and (3) minced meat declarations.
One study found, which suggested that UK consumers show a low level of concern about the use of palm oil
in food products as they have limited knowledge of the health or environmental concerns associated with it
(Disdier, 2013). It could be hypothesised from this evidence that the proposed EU FIC changes, which alter
the manner in which oils are stated on products, will have limited impact on consumers’ decision making
processes but the limited evidence either way makes this an area for further research.
Additionally a small number of studies were identified which assessed QUID and meat declarations. Most of
these sources considered how pre-EU FIC QUID information and meat declarations can lead to consumer
misinterpretation, specifically the phrasing of meat content (Van Wezemael et al, 2014). This study identified
that the positive framing of a meat product attribute e.g. ‘‘75% lean meat’’ resulted in a more positive product
evaluation than the equivalent negative description e.g. ‘‘only 25% fat’’ suggesting that positive framing of
meat content claims can heavily influence consumer’s decision making process. With the introduction of the
EU FIC changes for declaring QUID and more detailed meat content information, a reduction in
misinterpretation of these types of statements is possible – most notably for meat products e.g. minced meat
declaration ‘contains x% fat and collagen’).
4.4.2 Consumer Survey Findings
Awareness of ‘other’ ingredient labelling
Results from the consumer survey suggest that unprompted recognition of the ‘other’ ingredients
information on food labels is very low, with only 1% - 6% of respondents (maximum 100 respondents)
recalling that the information exists. Unprompted awareness levels as follows:
Vegetable oil/palm oil content information 2% (n=35);
Nano-materials 1% (n=19);
Meat content information 6% (n=102);
Added water declaration 4% (n=57); and
Collagen/meat protein information 1% (n=19)
Such a low awareness may be attributed to the fact that this information was not previously required on
food labels and is entirely new to consumers.
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Unsurprisingly, it is evident that prompted levels of awareness of all types of ’other’ ingredients are higher
than unprompted levels (an increase ranging between 5% - 35% in some instances) which rely on
consumers memory of food labelling. There is some consumer awareness of wider ingredient information
on food labels however limited it may be. In regards to the higher response rates (QUID 44% n=685,
added water information 35% n=545) this may be linked to existing consumer familiarity with detailed
content information such as ingredients list which is mandatory on food labels. A summary of differences
between general (prompted) and recall (unprompted) awareness is captured in figure 5 below.
Overall, evidence from the consumer survey shows that consumers who do seek food label ingredient
information (83%, n=1,297) claim to use more general food label information such as product names
(29%, n=330), rather than specific ingredient declarations as evidenced by results in previous sections.
This suggests that while the five EU FIC regulation changes assessed within this section may improve
clarity and standardise food label information, they may not be used or prioritised for use during the
consumer decision making process and therefore may have limited impact on consumers.
Figure 5 Consumer prompted and unprompted awareness of wider EU FIC requirements
Regional Differences
Outlined in table 17 below is a summary of the responses to ingredient labelling information awareness
by region, which clearly illustrates that prompted responses for meat content (QUID) elicited the highest
recall rates at 44% (n=733). However, there is one main differentiator, that is Welsh respondents provided
a 61% (41 respondents) prompted awareness of meat content. Not only is this the highest reported
among geographical regions (England 42% - n=551, Scotland 52% - n=75, Northern Ireland 51% - n=18)
but also higher than the 44% (733 respondents) average recorded for main shoppers. An explanation for
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this heightened awareness was not apparent from the evidence reviewed and gathered during both the
consumer survey and accompanied shops.
Q10: Please look at this list and tell me which types of information you think are currently shown on food and drink?
Food label information (prompted awareness)
UK (of 1,672)
England (of
1,254)
Scotland (of 138)
Wales (of 132)
NI (of 148)
% % % % %
Vegetable oil/Palm oil content information 22% 22% 19% 28% 29%
Nano-materials information 6% 6% 9% 9% 10%
Meat content information 44% 43% 52% 61% 53%
Added water information 35% 33% 44% 40% 47%
Collagen/meat protein information 12% 12% 11% 10% 16%
Table 17 Regional prompted awareness of wider EU FIC requirements
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Perceived importance of nutrition labelling information
Table 18 and 19 below illustrates that the participants surveyed believe that the new EU FIC wider ingredient information will improve their confidence in the content of
the food they purchase, in particular food label information relating to additional meat ingredient information, a trend evidenced within the main shopper results.
Table 18 Wider EU FIC requirements contribution to consumer confidence
Q18: Will this information help improve your confidence of the content of food and drink you purchase? (Rank out of 12)
Confidence UK % (of
1,672) R
England % (of 1,254)
R Scot % (of 138)
R Wales % (of 1320
R NI % (of
148) R
If a product looks like a joint or slice of meat or fish, and contains more than 5% added water, it should have \added water\" on the
label. Previously this level was 10%."
46% 3 45% 3 50% 4 65%* 1 34% 5
Minced meat, depending on the type, will have maximum fat and connective tissue limits and clearer labelling requirements
44% 5 43% 5 52% 2 55% 4 44% 2
For vegetable oil, including palm oil, the label must specify which plant the oil comes
from 27% 8 27% 8 33% 7 34% 8 19% 9
Engineered Nano-materials must be specified
24% 9 23% 9 31% 9 25% 9 20% 10
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Table 19 Wider EU FIC requirements contribution to consumer understanding
Q19: Will this information help improve your understanding of the content of food and drink you purchase? (Rank out of 12)
Confidence UK % (of
1,672) R
England % (of 1,254)
R Scot % (of 138)
R Wales % (of 1320
R NI % (of
148) R
If a product looks like a joint or slice of meat or fish, and contains more than 5%
added water, it should have \added water\" on the label. Previously this level was
10%."
31% 2 28% 5 33% 4 53%* 2 32% 4
Minced meat, depending on the type, will have maximum fat and connective tissue limits and clearer labelling requirements
24% 3 29% 3 36% 3 44% 3 36% 2
For vegetable oil, including palm oil, the label must specify which plant the oil
comes from 30% 3 19% 8 19% 9 39%* 7 17% 9
Engineered Nano-materials must be specified
35% 1 19% 9 21% 8 27% 9 19% 10
*Please note QUID was not included within this specific question as it is an existing labelling requirement and the question sought to understand which of the new EU FIC requirements would improve
understanding.
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With regards to improving consumers’ understanding of the wider EU FIC ingredients labelling, there is a
clear differentiation between information which provides detail on complex ingredient issues, such as
nano-materials and non-complex e.g. added water content. The level of understanding participants
attributed to (1) minced meat declarations and (2) if a product looks like a joint or slice of meat was
significantly (statistically) lower than the confidence they ascribed to those labelling attributes, with an
average 10 percentage point different difference between them both. The evidence suggests that that the
EU FIC regulation changes might positively improve confidence (as the requirements provide much more
detail on complex products), but may not see such an improvement in understanding of the content of
food consumers they purchase as the detail provided may be too complex to interpret and understand. It
will be interesting to see if reported confidence and understanding levels have changed and to what
extent.
Regional Differences
Outlined above in tables 18 and 19 is a summary of the confidence and understanding results presented by
geographical region. Variation between geographical responses is evident for both confidence and
understanding perceptions. A summary of the main findings are outlined below.
In relation to the reported confidence levels of the different geographical locations there are two notable
findings, Northern Ireland reported the lowest figure for improving confidence levels in the provision of oil
labelling at 17% (7 respondents) which is a 22% difference between the highest reported confidence
levels from Wales at 39% (28 respondents). Wales, reported the highest reported increase in confidence
for added water labelling requirements at 65% (46 respondents) which is a 31% difference to the lowest
reported increase in confidence from Northern Ireland at 34% (14 respondents).
When assessing the reported increased understanding levels there is one statistically significant finding, that
Wales reported the highest increase in understanding across all four reviewed wider EU FIC ingredient
listing requirements. The most notable Welsh responses were as follows:
1) Wales reported that vegetable oil labelling would substantially increase their understanding (39%
n=28 - 22% percentage point difference from the lowest reported figure) in Northern Ireland (17%
n=7);
2) Wales also reported the highest levels of understanding (53% (38 respondents) associated with
added water content labelling - 25% percentage point difference from the lowest figure reported –
England 28% n=392); and
3) The highest rate for improving understanding for additional minced meat requirements at 44% -n=32
for Wales (15% percentage point difference from the lowest for England at 29% n=410).
Within the research reviewed during the REA and gathered during the consumer survey and accompanied
shops attributable factors for this result could not be found therefore it is identified as an area for further
research and exploration.
Consumer use of ’other’ ingredient labelling
To understand the current usage of ’other’ ingredient labelling in relation to other types of labelling
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information provided, respondents were asked to rank this information in order of importance when
making a food purchasing decision. Table 20 below illustrates that main shoppers rank existing QUID
information highest of the wider EU FIC ingredients listed. In the overall label listing, this was surpassed
only by price.
Aside from QUID, these results suggest that consumers place more emphasis on information such as
price, brand name, special offers and familiarity than ingredient labelling information when making
purchasing decisions. This suggests that the EU FIC ingredients listing changes (all except QUID) may
have limited impact on consumers’ decision making processes and choices.
Q2: What information do you look for when purchasing a food or drink product? (Please rank the information by importance)? Rank (out of 15)
Food Label information UK England Scotland Wales Northern Ireland
Quantity information about different ingredients (QUID)
2nd
8th 6th 6th 12th
Information on about the contents/ingredients (general - including
nano-materials) 10
th 1st 8th 8th 14th
Vegetable/Palm oil labelling 14th 12th 3rd 3rd 13th
Added water content 15th 11th 11th 11th 1st/2nd
Meat content 0 15th 12th 12th 1st/2nd
Table 20 Consumer use of 'Other' EU FIC labelling information
*Please note additional minced meat requirements are not listed for the UK as this information was not
identified by any respondents.
Regional Differences
Table 20 above illustrates that there is a variation between use of ‘wider’ ingredients listing information
between geographical regions, with Northern Ireland reporting the largest variations for added water and
meat content, as Northern Ireland responses are the reverse of the evidenced trend.
4.4.3 Accompanied Shop Findings
To further understand the potential impacts of the EU FIC regulation changes on ‘other’ ingredients, 64
accompanied shops were undertaken. Two themes emerged from these observations:
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1) Consumers use of QUID information for meat to compare products and infer quality; and
2) Consumers rely on ’other’ ingredient information to gauge product’s content.
1. Consumers use of QUID information for meat to compare products and infer quality
It was observed that participants often used QUID information to inform their decisions, in conjunction
with e.g. price and familiarity, to inform a purchasing decision between two products. This behaviour was
often observed for complex products, such as ready meals (which often contain many ingredients) with
consumer using % of meat information as an indicator of fattiness i.e. the fattier the product the lower the
perceived quality of minced meat or the quality of a meat based product on the % of meat in the
ingredients), as is illustrated in the examples below:
2) Consumers rely on ’other’ ingredient information to gauge product’s content
Evidence gathered from the accompanied shops suggests that when purchasing meat products (fresh
and frozen) consumers use visual indicators – aside from the label – to gauge ingredient content
information (notably the fat to meat content ratio of products), as illustrated below:
Evidence of the use of the wider EU FIC ingredients (added water content, nano-materials labelling, oil
labelling and additional minced meat declarations) was not observed during the accompanied shops. This
trend is aligned with the low awareness, both recall and general, in relation to these changes and
therefore is not unsurprising as consumers would not use information that they report to be unaware of.
As limited qualitative evidence on these changes was gathered at this stage it is identified as an evidence
gap for further exploration.
(Female, family): ‘Look at this ready meal, it’s advertised as a spaghetti bolognaise so you would think
that when you looked at the ingredients on the back you would see a high proportion of minced meat
and tomato sauce, but when you actually look, both of these collectively only make 37%. I mean what
else is contributing to the make-up of the product? I don’t think I’m going to buy this as the core
ingredient % is too low’.
(Male, post family): Participant reviewing the QUID information on sausage packaging ‘Sausages
could have anything in them, so it is good to know how much is meat as it gives you an idea of the
quality’
(Female, family): The participant is looking for good quality steak mince. They first look at the picture
and comment that the paler the meat is the more fat there is in it.
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4.4.4 Conclusion
The literature review offered little evidence to support the view that listing of wider EU FIC ingredients
would influence consumers’ purchasing decisions. Evidence from the consumer survey illustrates an
overall trend that those consumers who do seek ingredient information report using more general
information indicators such as product names, rather than specific ingredient declarations e.g.
collagen/meat protein. However insights from the accompanied shops demonstrated that ingredient listing
information is used in a limited way, with QUID the preferred source of information. Some consumers use
this information to determine product quality based on the percentage of core ingredient or fat to meat
ratio. The evidence base however, is limited.
4.5 Conclusion: Impacts on Consumers
When prompted on the EU FIC changes, respondents to the consumer survey mostly claimed the
changes were beneficial. Unprompted however, most were unable to identify the changes, or identified
practices that are not part of EU FIC changes. In the observed shops, very few consumers used any of
the labelling information.
1) Impact of voluntary front of pack nutrition labels
Whilst nutrition labelling is a public health intervention used by the Department of Health, voluntary
front of pack nutrition labelling was not found to have a significant influence on purchasing decisions.
Other information types such as health claims were ranked higher by survey respondents. Where this
information is used, it most typically acts as a quick reference for consumers to guide their decisions.
This study found that FoP information is not prioritised by consumers or reviewed as often as other
similar types of information, other than by allergy and intolerance shoppers. Consumers observed
and surveyed were most likely to use health claim information first, then nutrition claims, and only
then food label information. This may be because front of pack nutrition labelling competes for
consumer attention with other information such as brand name, nutrition claims and health claims.
2) Impact of country of origin and place of provenance labelling
Country of origin information must now carry detail about the supply chain of a product. This project
found that the impact of this information on consumers is product-specific, with consumers more
interested in two of the five products under review: ready meals and minced meat. Observation
participants said that COOL guides their view of product quality and provides information that enables
them to support the local economy. Though some REA sources suggest consumers are willing to pay
more for local products, this research did not include willingness to pay. It’s interesting to note that
consumers rank COOL 2nd of 12 types of information that would increase confidence (47%, n=786)
and understanding (31%, n=518) of food purchased.
3) Impact of ingredient information
A number of new declarations will provide greater detail on ingredients, including information about:
oil; added water declarations; ‘engineered nano-materials’; and minced meat. QUID is already
something that many consumers use (for example on sausages which already have % meat content).
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Other elements are new so it will be interesting to see what the impact on consumers will be once
QUID is more widespread and has become more familiar.
4) Impact of allergen labelling
Clear allergen labelling is a significant public safety requirement because of the severe
consequences of allergens for a small percentage of the population. Respondents typically believe
the EU FIC labels in this respect are a positive change.
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5. Impacts of the EU FIC regulation on Food Business Operators
Introduction
The business survey and large corporation qualitative interviews were both designed to ‘explore and
identify the barriers and information requirements of the food business operators (FBOs) involved in
rolling out the new EU FIC labelling changes’. Quantitative and qualitative evidence gathering took place
as follows:
1. Telephone survey of 1,002 FBOs across England (702), Wales (100), Scotland (100) and
Northern Ireland (100) to gather evidence on overall awareness, preparedness and
implementation activities; and
2. In-depth interviews with seven large, publicly-listed FBO manufacturers and retailers which
together have over 110 brands, £8.2 bn revenues and 45.7% of UK grocery retailer market share
according to Kantar (2014). For the purpose of this section these will be referred to as in-depth
interviews.
Considerations when interpreting data from the business survey
Please refer to section 3 Method for a summary of the robustness of the survey data outlined within this
section. The following considerations should be taken into account when interpreting the business survey
data:
1) Over-representation of key respondent groups: We were asked to over-represent certain
groups in order to meet requirements for robustness of statistical samples in UK regions.
In the business survey, FBO retailers and manufacturers were deliberately over-sampled to
provide robust regional data in addition to overall UK data. We also over-sampled medium-
sized and large-sized businesses to provide robust FBO data on subsets of FBOs
(manufacturer only; retailer only; and manufacturer and retailer) despite these subgroups
making up only around 8% of manufacturers and 1.5% of retailers;
2) FBO Response weighting: FBO responses from larger companies were not given greater
weight, despite their greater market share. This was because the survey aimed to discover the
proportion of businesses that were aware of regulatory changes, preparing to change and
anticipating extra costs, rather than make predictions about the scale of the overall response;
3) Manufacturers and retailers: The business survey over-represented FBO manufacturers, and
under-represented FBO retailers compared to their overall prevalence. Our 1,002-participant
business survey included 602 FBO manufacturers and 400 FBO retailers. The over-
representation was a deliberate sampling choice to reflect the regulatory compliance
requirements for different kinds of FBO. For example, manufacturers are legally responsible for
the correct labelling of the products they manufacture, whilst retailers are only responsible for
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the products that they sell to the public. The research team decided not to sample FBO
retailers and manufacturers in their natural proportions (see appendix VI Survey design A1.8
business survey for further discussion). Therefore results for “all businesses” in this report are
based on a sample that over-represents manufacturers and under-represents retailers;
4) In-depth FBO interviews: Seven in-depth qualitative interviews were conducted with FBO
retailers and manufacturers to understand the experience of a small group of businesses who
are advanced in their preparations to meet the EU FIC regulatory requirements. Those that
participated were selected from an existing network of FBOs within the project steering group.
These FBOs had a high level of awareness of the EU FIC and were therefore much more
prepared for the changes required than the FBO survey sample. Their insights and the
interview results should therefore be seen as indicative of FBOs who are further along the
journey of EU FIC compliance than the general FBO population. These interview results should
therefore be seen as providing further context for the business survey findings;
5) Survey sample respondents: For the business survey 1,002 FBOs across England, Scotland,
Wales and Northern Ireland were contacted. One person from each FBO acted as a
representative for the business as a whole. The research team qualified the participant using
the following qualifying statement;
"Can I please speak to the person in your business with responsibility for the labelling
of products with information for consumers, such as ingredients, food safety and
allergy information?
EXPLAIN IF NECESSARY: this will be the senior person who decides the wording on
product labels, even if they make that decision based on instructions from a business
customer, for example if they [the business] manufacture food that will go on to be
sold under a different business’s brand or label.
IF NECESSARY EXPLAIN: that the appropriate respondent needs to be the person
who signs off the final wording on product labels.
IF NECESSARY EXPLAIN: In large companies this may sometimes be the role of
managers responsible for regulatory affairs or compliance”
It is key therefore to note that while the research team conducted a qualification procedure the
participating respondent may have responded accurately in relation to their particular business
area, but this does not mean that their answer is representative of the company as a whole;
6) Representation of results: During the analysis of the business survey results it was quickly
identified that a selection of FBO characteristics such as size (small, medium and large) and
type of FBO (retailer, manufacturer or both) influenced the business findings. However these
characteristics did not influence the results in a consistent pattern (e.g. size of business did not
always correlate a FBO being more prepared for the EU FIC changes) therefore the results
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within this report seek to highlight the most interesting, salient and statistically significant
results across all FBO characteristics not least those mentioned above. In addition to this as
the compliance burden of the EU FIC labelling predominantly lies with the FBO manufacturer
we have sought to understand their preparedness status in more details as they will be more
affected by non –compliance than others; and
7) Fieldwork was conducted between 24th March and 7
th May 2014.
6.1.2 Business Survey Terminology
Terms used in this report are defined as follows:
Phrase Definition
FBO
manufacturer
A food business operator that only manufactures food products and does not
sell or resell goods.
FBO
retailer
A food business operator that only sells goods to the public and does not
manufacture goods for sale.
FBO retailer&
manufacturer
A food business operator that both manufactures and sells products to the
public.
Small FBO A food business operator (either retailer or manufacturer) of between 1- 10
employees and/or up to £999,999 turnover.
Medium FBO A food business operator (either retailer or manufacturer) of between 11 –
99 employees and/or £1 million - £9,999,999 turnover.
Large FBO A food business operator (either retailer or manufacturer) of 100+
employees and or £10+ million turnover.
Own-brand
FBO retailer
A food business operator that produces food and drink products for its own
retail brand.
Brand-owning
FBO
A food business operator that manufacturers food and drink products to be
sold by retailers.
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5.1 General awareness of the EU FIC regulation
5.1.1 Rapid Evidence Assessment
During the REA search no studies (academic/peer reviewed and grey literature) were found which explore
businesses awareness of the changes to the EU FIC regulation. A possible reason for the REA yielding no
specific search results in this area might be that at the time this study was taking place (Jan – April 2014) the
EU FIC regulation had just come ‘on the radar’ as only limited scope of the full regulation had come into
force at this time.
However in contrast to the limited yield of academic and grey literature studies on business awareness of the
EU FIC regulation what was gathered by the REA was a wealth of industry literature designed to be used by
businesses to educate about the EU FIC changes coming into force. Business literature was provided by
different industry stakeholders such as the FSA, Defra and the European Union.
In conclusion the findings from the REA presented a significant evidence gap in relation to evidence
surrounding business awareness of the EU FIC regulation.
5.1.2 Business Survey Results
EU FIC regulation awareness levels amongst FBOs at the time of the survey can be summarised as
follows:
On average 63% (635 respondents) of all FBOs surveyed were unaware of any food label
regulation changes to be introduced in the immediate or near future, whether from the EU or
elsewhere;
35% (355 respondents) of all FBOs surveyed were aware of EU FIC or other food label regulation
changes. 1% (11 respondents) said they were unaware of any changes to legislation underway
whether related to food or not;
FBO manufacturers reported the highest level of awareness of the EU FIC regulations, with 78%
(101 respondents) showing a higher awareness than the FBO average;
Small businesses are generally less aware, engaged and prepared for labelling changes with 6%
(117 respondents) of FBOs with fewer than 5 employees being unaware of impending FIC changes
to be introduced, in contrast to only 10% (3 respondents)of FBOs with 100+ employees; and
Awareness of the different EU FIC changes is on average double in the prompted responses
compared to the unprompted responses.
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5.1.3 FBO Awareness: Prompted & Unprompted
The business survey included both prompted24
and unprompted25
questions about awareness of specific
regulation changes within the EU FIC. Unprompted, participants were asked to explain which new
regulations and codes of practice they were aware of. Participants then listened to a number of
statements about individual changes and were asked to indicate if the change referred to was a
regulatory or voluntary change. A summary of the findings, by change, can be found below in figure 6.
Figure 6 FBO awareness of EU FIC regulation requirements
24 Prompted questions were structured with predefined answers that were offered to respondents by the research team.
Survey respondents were read a list of the EU FIC regulation changes and asked to confirm if they believed the change
to be (1) EU compulsory regulation requirement; (2) voluntary code; (3) not required; (4) don’t know or (5) not applicable
to me.
25 Unprompted questions required respondents to provide an unprompted response i.e. they were not guided by
explanations from the research team.
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Recall awareness (unprompted) response findings
Recall awareness levels of EU FIC changes to labelling are all below 5% (less than 50 respondents) with
FBO retailer and manufacturers showing the same low levels of awareness, apart from allergen label
changes for which recall awareness is 30% (301 respondents). Manufacturers have the highest level of
awareness about allergen changes, as shown in table 21.
Q10: What allergy specific food label changes are you aware of?
Allergen EU FIC requirements Retail % Retail
n
Manufacture
r %
Manufacture
r n
No longer having the “contains
box” for allergens
6% 11 21% 22
Allergens need to be
highlighted/bolded/italicised in the
ingredients list
7% 13 18% 18
Food Allergen labelling and
information - any general mention
of this, excluding specifics above
19% 34 30% 30
Table 21 FBO detailed awareness of EU FIC allergy changes
General (prompted) awareness responses
The prompted awareness levels for individual EU FIC regulation changes (i.e. confirmation by participants
that changes suggested were new codes of practice that they are aware of) was much greater than levels
found by the unprompted questions. There was a percentage point increase from 40 – 65% across all
individual changes. This may suggest that although the changes are not “front of mind” and easy to recall
for the businesses surveyed, many have heard something about them.
Almost all FBOs were aware, on prompting, of changes to country of origin labelling (75%, n=755
respondents), minimum font size requirements (75%. n=755 respondents), food allergen labelling
changes in general (89%, n=892 respondents).
When assessing general awareness of each specific change the following findings were identified:
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Q11: Please listen to the statement and tell me whether you think the proposed change will be compulsory within the new EU FIC regulation?
EU FIC Regulation change
FBO retailer
FBO manufacturer
FBO retailer &
manufacturer
% n % n % n
An indication of country of origin or place of provenance will be mandatory in some circumstances, for example for fresh
and frozen meat. 76% 536 68% 89 79% 131
Food allergen information will be needed. 88% 619 92% 120 92% 153
Allergens to be highlighted in the ingredients list, instead of on a separate “contains” list.
58% 407 76% 99 47% 78
Information must be easy for consumers to ready, with a minimum font size.
77% 546 88% 114 73% 122
For vegetable oil, including palm oil the label must specify which plant the oil comes from.
44% 312 45% 58 35% 58
Engineered nano-materials must be specified. 35% 250 36% 47 18% 30
Where a product looks like a single joint or slice of meat or fish, and contains more than 5% added water, this must be
stated with the name of the food. 54% 384 41% 53 51% 85
Composition of minced meat must meet fat and collagen limits unless it is only for the UK market.
63% 219 16% 2 73% 65
A nutrition declaration will need to be given with nutrients listed in a set order.
51% 363 55% 72 38% 63
Table 22 FBO awareness of EU FIC requirements
As summarised in the table above there are varying levels of awareness of different EU FIC changes. Of
those changes assessed, allergen labelling, COOL and the minimum font size requirements are the most
widely recognised. Different FBO types have similar levels of awareness across the board, with the
exception of minced meat composition and nutrient declarations where FBO splits illustrated large
awareness differences.
Regional differences in prompted awareness responses
Figure 6 highlights overall FBO general awareness of each of the EU FIC regulation changes. There are
some regional differences within this picture:
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Northern Ireland FBOs reported the highest level of awareness of the COOL changes at 88% (33
respondents) in comparison to England 74% (605 respondents), Scotland 79% (77 respondents)
and Wales 77% (40 respondents);
Northern Ireland FBOs had the highest levels of awareness of added water declarations at 69%
in comparison to England 51% (415 respondents), Scotland 54% (53 respondents), and Wales
53% (28 respondents); and
Northern Ireland (74% - 15 respondents) and Wales (71% - 14 respondents) had higher levels of
awareness of minced meat compositional requirements compared with England (63% - 232
respondents) and Scotland (58% - 26 respondents).
5.1.4 FBO General EU FIC Awareness: FBO Characteristic Breakdown
FBO Manufacturer Vs FBO Retailer
For FBOs most aware of the EU FIC regulation changes (notably FBO manufacturers), 57% (215
respondents) felt that implementing the changes would be difficult because the effort and resource
requirements to meet regulation compliance; and
Of those FBOs which are aware, 81%, (140 respondents) reported receiving advice from sources
outside their business, such as government, trade bodies or consultancies) in respect of EU FIC
compliance. These FBOs display higher levels of awareness of the EU FIC regulation than the 26%
(215 respondents) who are aware and not receiving advice.
FBO Size (small, medium & large)
FBOs that are part of larger corporations show higher levels of awareness. 51% (41 respondents) of
large FBOs are aware of the general EU FIC regulation changes. This is 18% higher than awareness
levels of FBOs who are independent single site (33%, n=249 respondents) and 9% higher than
independent multi-site FBOs (42%, n=65 respondents).
FBO Regional Variations
Awareness of the EU FIC changes is similar across the regions. Awareness stands at 35% (287
respondents) in England, 31% (31 respondents) in Scotland, 44% (23 respondents) in Wales, and
39% (15 respondents) in Northern Ireland.
5.1.5 Large Corporation Interview results
Seven in-depth qualitative interviews were conducted with FBO retailers and manufacturers who had
heightened levels of awareness of the EU FIC regulation. Those that participated were selected from an
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existing network of FBOs within the project steering group. These FBOs had a high level of awareness of
the EU FIC and were therefore much more prepared for the changes required than the FBO survey
sample.
For the purpose of this subsection of the business survey the project team have not included the insights
from the large corporation interviews as it was deemed that the interview results are representative of a
small group of FBOs which were recruited with known high levels of EU FIC awareness, the results may
therefore place undue weight on their answers in regards to this section.
5.1.6 Conclusion
The evidence shows that, without prompting on specific changes, 63% (635 respondents) are unaware of
any (EU FIC, or otherwise) food label regulation changes to be introduced in the immediate or near future.
Once prompted with examples of specific EU FIC changes (e.g. allergens must be highlighted within the
ingredients list), general awareness of EU FIC changes increases. This result suggests that the majority
of FBOs are aware the EU FIC changes rather than recognise the regulation as a whole, and that there is
an awareness of some of the specific EU FIC changes required, particularly allergen label changes and
font size requirements). Responsibility for adherence to the EU FIC regulation changes is primarily with
the manufacturer so the finding that manufacturers tend to have higher unprompted recall awareness
levels of the changes is a positive outcome.
5.2 Preparedness to meet the EU FIC requirements
This section shifts the focus from awareness to the preparedness of FBOs, specifically the activities they
are engaging in and the perceived ease of implementation of the EU FIC regulation changes. It is
important to remember that the regulations first appeared in 2011 and are due to become mandatory in
December 2014.
5.2.1 Rapid Evidence Assessment
Similarly to the REA results outlined within section 5.1.1 the REA search gathered no data or studies which
addressed the current (as of Feb 2014 when the REA was conducted) preparedness levels of FBO’s to meet
the EU FIC regulation. Rather what was captured was a general message by industry trade magazines and
industry bodies such as the FSA and Defra ‘to begin preparation’ (if it hadn’t already) as the compliance date
was drawing ever closer. This insight was captured by the documentation of a number of trade press articles;
however as their REA score fell below the required quality and content average of 6.5 these fell out of the
detailed REA process.
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5.2.2 Business Survey Results
EU FIC preparedness levels amongst FBOs at the time of the survey can be summarised as follows:
Generally, FBO self-reported preparedness is low, mirroring the low awareness rates in section 5.1.
On all activities FBO manufacturers were significantly (statistically) more advanced than retailers;
The most common response from FBOs was that they have plans to conduct preparedness
activities but have yet to start. This was the response for 56% (395 respondents) of FBO retailers,
37% (48 respondents) of FBO manufacturers, and 55% (92 respondents) of both FBO retailers
and manufacturers;
FBOs were asked about six potential preparation activities for EU FIC labelling changes. 34%
(241 respondents) of FBO retailers and 7% (10 respondents) of FBO manufacturers had ‘no
current plans’ to do any of these activities. The specific activities are listed in figure 7 below; and
FBOs receiving advice on compliance tended to be much more advanced in preparing for the
changes than those not receiving advice.
FBO Preparedness Level: Summary
As illustrated in table 23 FBO manufacturers are the most prepared for EU EIC. Probably reflecting the
fact that the legal requirement for compliance lies predominantly with manufacturers. The results also
show that FBO retailer preparedness activities remain low at less than 10% for any prompted activity,
suggesting little sense of urgency about compliance amongst these businesses.
Q21: What actions are you involved in preparing to meet the EU FIC changes? (already completed/started this work but not complete responses)
EU FIC Regulation change
FBO retailer FBO manufacturer FBO retailer & manufacturer
% n % n % n
Reading about the new EU regulation and the voluntary code to find out how
it will affect your business. 7% 52 66% 86 14% 23
Working out exactly what information you need to include on your labels to
meet the new requirements. 9% 65 70% 92 28% 47
Talking to suppliers and/or clients about how to implement these
changes. 6% 41 47% 61 16% 26
Briefing your staff about the changes, such as sales staff.
5% 33 51% 66 28% 47
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Drawing up designs for the new labels 5% 38 53% 69 22% 35
Fully implementing the new requirements.
5% 34 55% 235 20% 35
Table 23 FBO preparedness to meet EU FIC requirements by activity
The most common preparation activities include initial engagement such as (1) working out exactly what
information is required to be incorporated on the compliant food labels and (2) reading the regulation in-
depth to determine the implications it may have. The prevalence of these activities suggests that the
majority of businesses are still at the early stages of becoming EU FIC compliant.
Figure 7 Summary of FBO activities to prepare for the EU FIC regulation
FBO preparedness activities
To further understand the FBO preparedness results researchers investigated potential underlying
influences which might impact preparedness activities, in particular the extent to which FBOs are
receiving advice and how the EU FIC regulation can be used as an opportunity for positive change. The
summary findings are as follows:
1. Advice/guidance received by FBOs
Over 79% (795 respondents) of all FBOs surveyed claimed they are not receiving any advice (i.e. they
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are not being sent advice directly), with FBO retailers less likely to be receiving advice (88% - 624
respondents) in comparison to FBO manufacturers (41%, n=53 respondents). Additionally FBOs that are
part of a corporate group are more likely than those FBOs who are not to receive advice at 30% (24
respondents), with the proportion rising in line with turnover.
2. Opportunities to influence change via greater advice provision
79% (795 respondents) of all FBOs surveyed stated that they were not receiving advice and a further 3%
(33 respondents) didn’t know if their business was receiving advice. This presents an opportunity to
provide FBOs with the information that they require to better understand the required EU FIC regulation
changes. To explore the potential for providing this information the business survey examined whether
FBOs felt there were any information gaps and who they believed should address these. Results are
shown in table 24 and 25.
Q: What information would help your business to prepare for new legislation, and which
organisation do you think should provide it?
Information that would help % n
A letter/leaflet/guidance sent to businesses, explaining changes
42% 418
A website/ app/ online information explaining the changes
27% 274
Trade press articles explaining the changes 8% 79
A helpline that I could call about the changes 5% 48
A seminar/workshop/webinar 4% 40
We don’t need help/can’t deal with it ourselves 4% 40
Sharing best practice with other businesses (e.g. case studies)
3% 27
Face-to-face (meeting) 3% 35
Email 3% 28
Table 24 FBO suggestions on the most effective communications for future EU FIC messaging
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Q: What information would help your business to prepare for new legislation, and which
organisation do you think should provide it?
Organisations that should provide help % n
Defra/government 43% 435
Food Standards Agency 15% 151
Trading Standards 12% 121
Environmental Health 9% 87
Industry Bodies/Trade Associations* 7% 73
Local Authority 6% 61
Table 25 Summary of FBO suggested information sources to deliver future EU FIC messaging
* Many other sources of information were mentioned, but none exceeded 5%.*
43% (retailers 39%, n=278 respondents, manufactures 32%, n=43, & 114 retailer and manufacturer (both)
respondents) identified Defra/Government26
as their preferred source of EU FIC guidance information.
Businesses were informed that the survey was being conducted on behalf of Defra which may have
influenced their responses on this question. The Food Standards Agency (15%, n=151 respondents,
retailers 11% - n=79, manufacturers 28% -n=37) came next. Other institutions ranked by the FBOs were
mostly trade associations such as the Institute of Grocery Distribution, the Chilled Food Association and
the Food and Drink Federation. However, each of these institutions was mentioned by only 1% or 2% of
respondents.
In addition to the source of information, FBOs also suggested the communication modes they would
prefer. The most common methods mentioned were a letter/leaflet explaining the changes at 42% (418
respondents) and a website/app at 27% (274 respondents). The leaflet/letter tended to be more
commonly mentioned by smaller businesses at 44% (82 respondents), and the website tended to be
mentioned by medium sized businesses at 44% (57 respondents) and large businesses at 51% (13
respondents).
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5.2.3 Large Corporation In-depth Interviews
All the FBOs interviewed in-depth had a full programme for implementation, but claimed progress was
impeded by a lack of consistent definition and interpretation of the changes required. Six of the seven
interviewees cited concern about the December implementation date and about mandatory enforcement
of the regulations in the early stages.
The in-depth interviews also gave further insights on perceptions of information provided. FBOs were finding
difficulties because of what they perceived to be a changing landscape of requirements and terminology, and
some claimed that some messages were inconsistent. For example one interviewee claimed that in some
information the phrase ‘largest printable area’ was used, but in others ‘largest surface area’ was used,
creating confusion and packaging challenges for companies where non-printable materials make up the
largest surface area. Some interviewees also see there is a risk that label changes already programmed by
an FBO may need to be changed again once the regulations are finalised.
5.2.4 FBO General EU FIC Awareness: FBO Characteristic Breakdown
FBO Manufacturer Vs Retailer
Only 6% (7 respondents) of FBO manufacturers and no FBO retailers surveyed have fully
implemented the required business changes to be EU FIC compliant;
49% (63 respondents) of manufacturer FBOs and 5% (32 respondents) of FBO retailers have
started their EU FIC compliance activities but have not completed their work;
Whereas 37% (48 respondents) of FBO manufacturers and 56% (395 respondents) FBO retailers
FBOs reported that they have not started but plan to become EU FIC compliant; and
In contrast over 7% (10 respondents) of manufacturers and 34% (241 respondents) of retailer
FBOs reported that they had no current intentions to do any work to become EU FIC compliant.
FBO Size
Medium-sized businesses (25+ employees) were more than twice as likely to receive advice
(from consultancies, governmental and trade bodies etc.) than smaller businesses.
5.2.5 Conclusion
Generally, FBO self-reported preparedness is to meet the EU FIC regulation is low, mirroring the low
awareness rates in section 5.1. On all activities FBO manufacturers were significantly (statistically) more
advanced than retailers, again a factor that can be linked to the compliance implications predominantly
linked to FBO manufacturers not retailers.
The most common response from FBOs was that they have plans to conduct preparedness activities but
have yet to start. This was the response for 56% (395 respondents) of FBO retailers; 37% (48
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respondents) of FBO manufacturers. Of the six potential preparation activities for EU FIC labelling
changes retailers ranked the following two activities were ranked the highest terms of FBO engagement:
1) Working out exactly what information is required to be incorporated on the compliant food labels;
and
2) Reading the regulation in-depth to determine the implications it may have.
5.3 FBO perceptions of the ease of implementation of the EU FIC regulation
requirements
Beyond awareness and preparedness, what do FBOs think the implications are of implementing the EU
FIC regulations? This section sets out what researchers discovered about the perceived difficulty, cost
and impact of compliance.
5.3.1 Rapid Evidence Assessment
Following the same vein as previous REA sections 5.1 and 5.2 the REA results for the implementation of
the EU FIC regulation within FBOs was limited, as no academic and peer reviewed studies were found to
form a secondary evidence base upon which primary research could be conducted. However within
previous REA sections it was noted that grey literature and industry literature from stakeholders such as
the FSA, European Union and Defra were collected. However in regards to the implementation of the
regulation requirements within FBOs neither industry nor grey literature sources were found.
The limited literature available in relation to business activities within the REA conducted can suggest
many things. The first, that the search terms are incorrect and in need of revision. This was not the case
in this instance as the project team adopted an iterative approach to the search term used revising as
needed. The second and seeming reason for the lack of literature is that at the time of the REA very few
business had in fact implemented changes within their businesses to meet the requirements that no
literature existed documenting their progress. Furthermore as each FBO is different industry bodies did
not feel it appropriate at this time to advise on the methods that could be used to meet the regulatory
requirements, therefore only producing literature which highlighted what the changes were not how to
address them. These hypotheses are supported within wider research findings below.
5.3.2 Business Survey Results
FBO perceptions of ease of implementation of the EU FIC at the time of the survey can be summarised as
follows:
Over half (51%, n=320 respondents) of all brand-owning FBOs surveyed felt it would be very easy or
fairly easy to implement the EU FIC requirements;
FBO retailers are much more likely to think that implementation would be very easy at 28% (99
respondents) compared with FBO manufacturers at 9% (12 respondents);
Corporate group respondents tend to anticipate less difficulty in implementing the changes: 54%
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(33 respondents) of Own-brand FBOs that are part of a corporate group think that implementation
will be ‘very easy’ compared to only 14% (64 respondents) of independent, single-site FBO
respondents;
Half of brand owners anticipate extra costs in association with the EU FIC regulation changes;
27% - 23 respondents had received extra advice and anticipate extra costs, compared to 69% (281
respondents) who had received no advice and did not anticipate extra costs; and
Similarly 31% (41 respondents) of other brand FBOs have done at least some preparatory work and
anticipate extra costs, whereas of those who had done no preparatory work, 85% (426 respondents)
did not anticipate extra costs.
FBO Perceptions: Ease of implementation
Figure 8 below shows the variations in the perceptions of ease that implementing the EU FIC regulation
would be.
Over half (51%, n=320) of all brand-owning FBOs surveyed felt it would be very easy or fairly easy to
implement the EU FIC requirements. In general FBO retailers are much more likely to think that
implementation would be very easy at 28% (99 respondents) compared with FBO manufacturers at 9%
(12 respondents). This may reflect the greater responsibility on FBO manufacturers who are much more
likely to be brand owners and therefore responsible for providing and placing the information on the label.
FBO Perceptions: Cost of compliance
Half of brand owners anticipate extra costs in association with the EU FIC regulation changes. Not
surprisingly the picture is very different for businesses selling brands that they do not own, with only 16%
Figure 8 FBO ease of implementing the EU FIC regulation
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(102 respondents) anticipating extra costs. When asked about the brands that they sell but do not own,
anticipation of extra costs was greater amongst those receiving advice. 27% - 23 respondents had
received extra advice and anticipate extra costs, compared to 69% (281 respondents) who had received
no advice and did not anticipate extra costs. Similarly 31% (41 respondents) of other brand FBOs have
done at least some preparatory work and anticipate extra costs, whereas of those who had done no
preparatory work, 85% (426 respondents) did not anticipate extra costs. Those FBOs receiving advice
and/or those a part of a large corporation who have begun preparatory work to become EU FIC compliant
are more likely to be able to respond with an estimate for cost implications. There is no difference in the
business type split or in geographical locations.
FBO Perceptions: Investment requirements to become compliant
The two most commonly stated ‘costs’ required to meet the EU FIC requirements are (1) extra packaging
and print costs, and (2) extra burden on existing staff - as shown in figure 9 below. Those citing extra
burden on existing staff were predominantly FBOs not receiving advice and having done very little (or no)
preparation so far. Better-advised and more prepared FBOs were more likely to specify extra
packaging/printing costs.
Figure 9 FBO perceptions of areas for financial investment to meet EU FIC requirements
Within brand and non-brand owning FBOs perceptions are varied as to where investment would be
needed. With brand-owning respondents reporting nutritional analysis, time, waste of old stock, software
changes, research and labour costs as potential ‘other’ costs associated with compliance, but less than
5% of respondents listed these as significant. Non brand-owning FBOs responses followed a similar
pattern.
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For each cost factor assessed, the participants who reported that there would be costs associated with
EU FIC compliance were whether they expected this activity to be a one-off cost, or an ongoing cost to
the business in the long term.
50% (323 respondents) Brand owners who anticipated extra costs were more likely to expect one-off
costs, rather than ongoing costs, with the exception of additional burdens on existing staff. Of the 16%
(102 respondents) non brand-owners who anticipated extra costs, the great majority thought that the
additional burden on existing staff and costs around changing production methods or ingredients would
be ongoing. A small number of them thought that graphic design and consultancy/adviser costs would be
one-off.
5.3.3 Large Corporation Interviews
During the large corporation interviews it was found that perceptions of ease or difficulty around
implementation appear to be associated with expectation around the cost of change. Those FBOs
thinking implementation will be easy are predominantly those that report no significant extra cost
associated with the change. Those who think change will be difficult also tend to think it will be expensive.
It was also noted that the scale and scope of work required by the EU FIC changes is significant. In some
cases the changes affect thousands of products and work began two years ago to achieve compliance by
14th December 2014. All seven FBOs expressed frustration with the process to date, the level of resource
required and the financial burden imposed. Retailers restructuring their businesses and making
redundancies in the face of declining sales asked researchers to note that food retail has to be agile and
responsive in challenging trading conditions against a backdrop of consumer demand for low prices.
Interviewees (who acknowledged extra cost associated with the change) claimed both direct and indirect
costs which they predicted would have considerable impact one or more of low price promises, profit
margins, shareholder returns and fair supplier agreements27
.
5.3.4 FBO perceptions concerning ease of implementation of the EU FIC regulation: FBO characteristic summary
Brand owning FBOs
Amongst FBO manufacturers 70% (87 respondents) anticipated extra costs in comparison to
retailers at 41% (147 respondents);
48% (11 respondents) of brand-owning large FBOs are likely to anticipate extra costs. These
FBOs also have the highest levels of awareness and preparedness in relation to required
27 Please note the statement above was gathered during in-depth qualitative interviews with seven
businesses and survey and is therefore representative of a small sample of FBOs.
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changes;
Those with lower levels of awareness were less likely to anticipate extra costs. This may indicate
that recognition of extra costs grows with increased awareness of the changes; and
Half of brand-owning FBOs (50%, n=323 respondents) anticipated extra costs, but most of these
businesses could not quantify those costs as a proportion of production costs, either because it
was too difficult to estimate, it would vary across products, or they just did not know.
Other brand owning FBOs
81% (522 respondents) of retailers thought that there would not be extra cost associated with the
implementation of the EU FIC changes;
Amongst manufacturers 47% (25 respondents) anticipating extra costs; and
As observed for FBOs that own brands, FBOs selling non-owned brands were also more likely to
anticipate extra costs if they were receiving advice and if they had already done some
preparatory work.
5.3.5 Conclusions
Over half (51%, n=320 respondents) of all brand-owning FBOs surveyed felt it would be very easy or fairly
easy to implement the EU FIC requirements with FBO retailers much more likely to think that implementation
would be very easy at 28% (99 respondents) compared with FBO manufacturers at 9% (12 respondents).
The majority of FBOs anticipate some cost associated with becoming compliant to the EU FIC regulation.
With half of brand owners anticipating extra costs in association with the EU FIC regulation changes. Not
surprisingly the picture is very different for businesses selling brands that they do not own, with only 16%
(102 respondents) anticipating extra costs.
Of the costs associated with becoming compliant the two most commonly stated ‘costs’ are (1) extra
packaging and print costs, and (2) extra burden on existing staff. Additional costs cited were those
associated with packaging/printing costs.
5.4 Opportunities associated with the EU FIC regulation changes
This section sets out what researchers discovered about the perceived positive opportunities and
negative effects that are associated with implementing the EU FIC regulation with FBOs.
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5.4.1 Rapid Evidence Assessment
No literature sources were identified within the REA which unpacked FBO opinion of the opportunity that the
EU FIC regulation may provide them with. Please refer to section 5.3.1 for a hypothesis on the limited
resources available to inform the primary research within the business element of this research.
5.4.2 Business Survey Findings
FBO perceptions of opportunities and impacts associated with the EU FIC regulation at the time of the
survey can be summarised as follows:
70% (701 respondents) of FBO survey respondents felt that the new label requirements will have
positive impacts, with negligible difference between the views of retailers and manufacturers
(retail only 69% - manufacturing only 72%);
63% (627 respondents) of FBOs surveyed believe implementation of EU FIC requirements will
have negative impacts;
Only 3% (27 respondents) of all FBOs surveyed (both retailer and manufacturers) believed the
introduction of the EU FIC label changes creates business opportunities.
Increased consumer awareness and healthier eating are by far the most common positive
impacts expected at 61% (429 respondents). 65% of retail FBOs (319 respondents) expect these
effects, compared to 45% of manufacturers (42 respondents); and
FBO Opinion: Positive Opportunities linked with the EU FIC
Only 3% (27 respondents) of FBOs believed there would “definitely” be opportunities to use the
introduction of the label changes to introduce new products or change existing products;
A further 11% (105 respondents) thought there may “possibly” be opportunities. The majority -
68% (684 respondents) believed there is “definitely” no opportunity to create an opportunity for
business of the back of the EU FIC; and
Manufacturing FBOs appear more likely to see opportunities in modifying ingredients and
introducing new/varying existing products as a result of the label changes, but the sample size is
small so these are not particularly robust findings.
The FBOs that thought there would definitely or possibly be market opportunities (14% - 132 respondents)
were asked (unprompted) “in what way might this be an opportunity for your business?” A quarter of
these businesses (just 3% of all businesses surveyed) said it was a chance to emphasise the healthiness
of their product(s), and nearly a third (just 4% of all businesses) talked of introducing new products to
meet demand generated by the new consumer information. Only 1% of all businesses mentioned the
opportunity to modify ingredients, and only 1% mentioned an opportunity to emphasise the country of
origin or place of provenance.
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FBO Opinion: Positive outcome associated with the introduction of the EU FIC
70% (701 respondents) of FBOs felt there will be positive outcomes from the new information
requirements. This proportion was higher at 78% (381 respondents) amongst those who felt
implementation will be easy, and higher still at 85% (34 respondents), amongst those who felt
implementation would be neither easy nor difficult. Only 48% (119 respondents) of those who expect
implementation to be difficult are similarly optimistic. There is little variation in expectation of impact
amongst the regions. The FBOs most commonly relate their positive attitudes to the EU FIC changes to
three outcomes:
1) Greater consumer awareness of healthier eating 61% (429 respondents);
2) Clear/easier to read labels 20% (138 respondents); and
3) Standardisation of allergy information 16% (113 respondents).
FBO Opinion: Negative impacts linked to the EU FIC
63% (627 respondents) of FBOs surveyed see downsides from the implementation of EU FIC
requirements, so clearly some have both positive and negative expectations. Manufacturers, at 78% (101
respondents), are more likely to have negative expectations than retailers at 57% (405 respondents). This
may reflect the greater compliance burden facing manufacturers.
Those FBOs expecting implementation to be difficult (86% - 213 respondents) or neither easy nor difficult
(78%, n=31 respondents) are more likely to expect negative outcomes, as are those who anticipate extra
cost to be attached to the changes (77%, n=294 respondents). The main negative outcomes they
anticipate:
1) Increase in costs at 28% (177 respondents);
2) Overload of information for consumers at 24% (153 respondents); and
3) An increase in work load at 12% (77 respondents).
5.4.3 Large Corporation Interviews
Within the business survey results outlined above there appeared to be some conflicting results, notably the
findings surrounding FBOs perceptions that there will be both positive and negative outcomes associated
with the implementation of the EU FIC. The survey results stated that 70% (701 respondents) of all FBO
respondents believe that there will be positive outcomes associated to the EU FIC. However 63% (627
respondents) of all FBO respondents also believe there will be negative impacts associated with the EU FIC.
When this seeming conflict of opinion was investigated in more detail during the large corporation interviews
the conflict was not found to be a conflict at all, rather that business truly believe the EU FIC will have a ying
and yang effect.
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The corporations interviewed held the opinion that while there will be positive effects associated with the
regulation it is not a panacea and therefore does not meet every business or consumer need and nor should
it attempt to. In fact while the majority of FBOs perceive a positive impact will be had overall (especially for
the consumer) stating clearer labels and increased font size as the top two positive benefits associated with
the EU FIC, they state that on the other side of the coin more negative impacts such as additional
information creating consumer disinterest is potential risk and negative impact that could be linked to the
introduction of the EU FIC.
This 50/50 approach to the perceptions of the outcomes of the EU FIC will change over time as the EU FIC
comes fully into force. It is hypothesised that initially the negative outcome opinion will be held closer to
regulation deadlines with more positive opinions growing in the months after the EU FIC regulation is
established. Any future work conducted should aim to measure this hypothesis.
5.4.4 Conclusions
14% (140 respondents) of FBOs surveyed believed implementation of the EU FIC definitely or possibly
introduced market opportunities. For those FBOs who do not view the introduction of the new EU FIC
regulation as a business opportunity, there is no dominant single reason, and one third said “no particular
reason”. The most common reasons for expecting no opportunities are: that it is for the manufacturers to
decide (21% of those who only retail responded in this way); the belief that consumers do not read food
labels and therefore the changes implemented will have little effect (10% of retailers and 15% of
manufacturers); and that the FBO already has well-established products and will continue with business
as usual (13%).
Primary and secondary research undertaken within this project aligns with the above business responses.
FBOs interviewed in-depth claim there has not been definitive guidance on the specifics of the EU FIC
and they feel they have had to repeat work already done with every additional or iterative EU FIC
clarification). An example provided is that some food retailers had already signed up to DEFRA principles
on Provenance and/or DOH Nutritional requirements (voluntary) but found that the new rules are
inconsistent with these agreements already in place, necessitating changes on pack, even though the
relevant information is already provided on the food label/pack albeit in another format.
5.6 Wider food label issues explored
Other topics raised during the in-depth large corporation interviews provide some indication of wider
issues around EU FIC changes, but cannot be taken as widespread without further research.
Respondents highlighted difficulties in a number of areas:
Managing consumer food label expectations e.g. of what it is possible to include on food labels;
Marketing opportunities e.g. the labelling information may counter in-store point of purchase
initiatives;
Meeting other demands for on-pack information; and
Meeting obligations or voluntary commitments such as Courtauld which require food businesses
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to commit to reducing packaging and therefore space available on pack.
Interviewees pointed out the multiple and often conflicting demands from marketing and compliance for
‘share of pack’. FBO consumer market research conducted by major retailers and brands, highlights
consumer demand for more/broader information on food labels such as recipes, food storage information
and disposal advice. Those same FBOs are trying to meet targets to reduce packaging and make it more
sustainable. Meanwhile they are also using on-pack space to provide added-value information to
consumers (e.g. recipes) and to meet other sustainability commitments related to packaging, cooking,
storage and disposal.
Some interviewees claimed to be unsure as to which change to make first, and claimed some changes
were more expensive than others, particularly where they necessitated a packaging change (for example
font size changes). Whilst there is no quantitative evidence to support this view, or of the numbers of
SKUs directly impacted, one major retailer was keen to have this issue logged as a cost for them.
5.6 Conclusion: Impacts on Business
FBOs attitudes towards the EU FIC changes showed some variation, the most notable of which was
between respondents who were engaged and active on EU FIC, and the yet-to-be informed/engaged.
The former group routinely cited the high costs of the changes, whereas the uninformed and yet-to-be
engaged anticipated limited time and financial resource implications. The evidence suggests the need for
a more consistent approach to ensuring that all FBOs are aware, engaged and progressing towards the
December 2014 compliance deadline and that particular emphasis should be given to smaller and
independent FBOs.
Summary findings
70% (701 respondents) of FBOs felt there will be positive outcomes from the new information
requirements, with negligible difference between the views of retailers and manufacturers (retail only
69% - manufacturing only 72%);
63% (627 respondents) of FBOs surveyed believe negative implications will also arise from the
implementation of EU FIC requirements;
Increased consumer awareness/healthier eating are by far the most common positive outcome
expected at 61% (429 respondents). 65% of retail FBOs (319 respondents) reported agreement to
this in comparison to 45% of manufacturers (42 respondents);
Key differences exist between smaller and larger food business operators in relation to the evidenced
levels of relative, engagement understanding and action towards compliance. Smaller businesses are
typically less prepared than their larger food business counterparts;
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Little evidence has been found (by business) to support the position that the regulations will change
or enhance the consumer decision making towards safer or healthier choices;
Branded manufacturers are most likely to have implemented the changes to date;
Costs to business are considered excessively high by those who have undertaken the work required
to effect the changes;
Guidance and information flows are not considered by industry to have been best practice and some
issues still remain around interpretation of elements of the changes; and
There are expressions of concern around non-compliance and enforcement protocols.
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6 Research summary and conclusions
Key findings
This project had four overarching objectives (refer to Purpose of this Study for more information) aimed at
covering three evidence outcomes:
1. Gain an understanding of the existing evidence on consumer and business views of food labels
and the implications of the changes that the EU FIC regulation may have on the food labelling
landscape;
2. Develop a summary of the current consumer understanding of food label information and how the
FIC label changes have impacted on behaviours; and
3. Identification of the barriers facing businesses expected to implement the new labelling changes,
and their information requirements.
Outlined below are the findings collected to meet the above outlined evidence outcomes.
Objective: 1. Gain an understanding of the existing evidence on consumer and business views of
food labels and the implications of the changes that the EU FIC regulation may have on the food
labelling landscape
The REA method used to reach the above objective indicated that whilst there is an abundance of
literature which assesses consumer use of food labels (449 resources on this topic were identified during
the initial REA scoping) there is limited research which adequately assesses or explores the implications
of the changes that the introduction of the EU FIC regulation might have on the food labelling landscape
(none of the 158 resources reviewed in-depth captured this information). Instead the literature assessed
and explored what the changes were, providing guidance on different elements of the EU FIC changes.
This was particularly true of sources from industry or governmental bodies such DEFRA, The Food
Standards Agency and the European Commission. Academic and peer-reviewed literature tended to
focus more on:
Consumer interaction with and the effectiveness of FoP nutrition labelling;
Consumer use of nutrition labels; and
How specific shopper categories respond to/use food labels differently (for more detailed
information on the outputs of the REA please refer to the Impacts on consumer in chapter 4).
Specifically, the REA identified core data gaps relating to the use of all five prioritised FIC information
changes for consumers:
Country of origin/ place of provenance labelling.
Voluntary front of pack nutrition labelling.
Food allergen labelling and information.
Labelling of vegetable oil, including palm oil.
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Quantitative indication of ingredients (QUID) including meat content and added water
declarations.
The detailed findings of the REA are summarised within the impact on consumer chapter within the body
of the final report.
Objective: Develop a summary of the current consumer understanding of food label information and
how the FIC label changes have impacted on behaviours
Summary:
Currently, 58% (n=985) of survey respondents feel that the product content information on food and drink
labels provide information is always or usually easy to understand. Only 13% (n=213) say it it usually or
never easy to understand. Nearly three quarters of respondents (70%, n=1174) say they feel very or fairly
confident that labels provide accurate information about the food and drink they buy. Around a quarter
(26%,n=451) say they are not very or not at all confident.
The reviewed evidence and information from consumers surveyed (n = 1,672) demonstrate that they expect
changes to labels to have a positive impact in terms of increasing their understanding and confidence in the
food and drink that they buy, despite their low use of labels in store. For future assessments it will be
interesting to see if the levels of understanding and confidence consumers hold increases from the current
baseline established by this project following the full roll out of label changes.
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Figure 10 FBO Improving understanding and confidence
Apart from those consumers with special dietary requirements (e.g. allergies), consumers tend to report
higher levels of engagement with labels than they reveal in store. 45% (n=750) of respondents in the survey
said they always or usually read the label before they buy a product they are not already familiar with. This
goes down slightly to 41% (n=143) for respondents who do online food and drink shopping. But consumers
exhibited low actual use of food labels when making purchasing decisions as was found in the majority of
instore and in-home participant observations.
Most purchases are driven by time and budget constraints, as well as what is available, on offer or familiar
suggesting that consumers place more emphasis on information such as price, brand name, special offers
and familiarity than ingredient labelling information when making purchasing decisions.
Actual use of labels drops further for online shoppers, with just under half (11 out of 26) of online shoppers
claiming they never, or only occasionally read food labels when purchasing food products, compared to
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around a third (22 out of 46) of in-store shoppers. Given the difference between reported use of labelling and
actual use in store, it will be interesting to see whether label changes impact on behaviours and in what way.
Despite this, when asked about how valuable it is to have information about product contents for consumers
personally, 55% (n=926) say that it is either essential, extremely or very valuable. A further 30% (n=500) say
it is fairly valuable.
Primary Research Findings on consumer understanding, use of and confidence in food labels
Outlined below is a brief summary of the primary research findings across the different food label elements
reviewed as part of this project.
Country of Origin Labelling
Consumers place high value on provision of COOL but generally the use of COOL for purchase
decisions is low.
In the survey, consumers rank COOL 2nd of 12 types of information that they report would increase
confidence (47%, n=798) and understanding (31%, n=516) of food purchased. However, they rank
COOL 11th out of 16 types of information they look for when purchasing food or drink (rising to 8th for
Welsh consumers (n=132) and 9th for Scottish consumers (n=183) though the sample size is
small).This varies by product type (e.g. higher for meat). These counter intuitive results reinforce
behaviour that was exhibited during instore observations which is that while consumers rate that
COOL would increase their confidence and understanding of the products they buy they still prefer to
use and rely on their visual assessments of products (especially meat) to inform their decision
making process.
Though sample sizes for the Scotland are small, results indicate that Scottish consumers are around
twice more likely to look for food and drink from particular parts of the UK than English consumers.
With 36% (n=49) of Scottish consumers reporting to use this information ‘often’ when purchasing
food and drink products compared to 17% (n=339) of English consumers. It should also be noted
that 49% (n=616) of participants from England ‘often’ or ‘sometimes’ report that they look for food
and drink from particular parts of the UK in contrast to 63% (n=87) of participants from Scotland.
In-store observations revealed that for unprocessed meat, COOL is often used as a proxy for
product quality after visually assessing the product.
Health & Nutrition information
Many observed and interviewed participants claimed an interest in the health and wellbeing
effects of products. Despite this, there was little evidence that these concerns were driving the
product evaluation and buying behaviours observed in-store or online unless there are particular
health concerns.
80% (n=1338) of consumers surveyed report that having information on the label about product
contents will help them make healthier choices with 47% (n=786) stating it will be a ‘big help’ and a
further 35% (n=585) stating it will be a ‘small help’.
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Around a third of consumers surveyed (35%, n=568) say health and nutrition information will improve
their confidence in the food they purchase and a quarter (16%, n=267) say it will increase their
understanding of the food.
Consumers with dietary restrictions rank nutrition information as the most important information to be
provided on food and drink labels (39%, n=103), followed by ingredients list (33%, n=87). Regional
differences apply in reference to wider consumer ranking (please refer to full report).
Allergen information
EU FIC allergy regulation changes did have an effect on their intended target group, with many
allergy and intolerance shoppers using this information as evidenced by both accompanied shop
observations and consumer survey results.
14% (n=236) of overall survey respondents report an allergy that influences the food and drink they
buy. A further 12% (n=194) say that have a food intolerance. 6% (n=93) purchase food for
somebody with other special dietary requirements.
For those consumers with food and drink allergies, 67% (n=235) say the changes to allergen
information will improve their confidence in the content of food and drink purchases, though fewer
(48%, n=167) say it will increase their understanding.
During the 26 online shopper observations, online shoppers used the thumbnail image of the product
as the main basis for a decision, and only allergy sufferers clicked through to a larger image of the
product.
Additional EU FIC label requirements
Less than 13% (n=213) of consumers surveyed where aware (unprompted) of the wider EU
FIC requirements:
o vegetable oil/palm oil content information 2% (n=35);
o nano-materials 1% (n=19);
o meat content information 6% (n=102);
o added water declaration 4% (n=57): and
o collagen/meat protein information 1% (n=19).
In contrast when prompted with a list of potential label options awareness of each item
increases with awareness of:
o vegetable oil/palm oil information increasing by 20% to a 22% (n=348);
o nano-material awareness increases to 6% (n=102);
o awareness of meat content increasing the most (by 38%) to 44% (n=685);
o added water declaration awareness increasing by 31% to 35% (n=545);and finally
o collagen/meat protein awareness increasing to 12% (n=195).
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Nearly half of consumers say that added water information and minced meat declarations would
increase their confidence in the food they buy. They are around 10% less likely to say it would
increase their understanding.
For further insight into how consumers reported use of, and interacted with, different food label elements
a summary of the key findings by label element is outlined below. For a more detailed exploration please
refer to the full report.
Objective: Identification of the barriers facing businesses expected to implement the new labelling
changes, and their information requirements
It is worth noting that fieldwork was carried out early in 2014, before the regulations were due to be rolled
out, though some businesses had already made some changes.
Summary:
Overall for companies impacted by the EU FIC regulation changes research findings suggest that the
most significant barrier that businesses may face towards implementation of the new labelling changes is:
1. Low awareness levels of the legislation (at the time of primary research);
2. Low levels of preparedness to meet the impending changes (at the time of primary research);
3. Associated investment requirements of implementation.
On average 63% (635 respondents) of all FBOs surveyed were unaware of any food label regulation
changes to be introduced in the immediate or near future. Of those aware (35%, n=355) FBO
manufacturers reported the highest level of awareness of the EU FIC regulations, with 78% (101
respondents) showing a higher awareness than the FBO average whether from the EU or elsewhere. The
evidenced low awareness level mirrors the low levels of FBO self-reported preparedness to meet the EU
FIC changes. On all preparedness activities FBO manufacturers were significantly (statistically) more
advanced than retailers. The most common response from FBOs was that they have plans to conduct
preparedness activities but have yet to start. FBOs receiving advice on compliance tended to be much
more advanced in preparing for the changes than those not receiving advice.
Half of brand owners anticipate extra costs in association with the EU FIC regulation changes. Not
surprisingly the picture is very different for businesses selling brands that they do not own, with only 16%
(102 respondents) anticipating extra costs. The two most commonly stated ‘costs’ required to meet the
EU FIC requirements are (1) extra packaging and print costs, and (2) extra burden on existing staff.
Those citing extra burden on existing staff were predominantly FBOs not receiving advice and having
done very little (or no) preparation so far. Better-advised and more prepared FBOs were more likely to
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specify extra packaging/printing costs.
Primary research findings on business awareness, perception of and opinion of the EU FIC
legislation changes
A summary of key primary research findings are below; please refer to the full report for a deeper
exploration of findings.
Awareness
There are varying levels of awareness of different EU FIC changes, with allergen labelling, COOL
and minimum font size most widely recognised.
Small businesses are generally less aware, engaged and prepared for labelling changes with 6%
(117 respondents) of FBOs with fewer than 5 employees being unaware of impending FIC changes
to be introduced, in contrast to only 10% (3 respondents)of FBOs with 100+ employees.
Preparedness
On all preparedness activities FBO manufacturers were significantly (statistically) more
advanced than retailers.
The most common response from FBOs was that they have plans to conduct preparedness
activities but have yet to start. This was the response for 56% (395 respondents) of FBO
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retailers, 37% (48 respondents) of FBO manufacturers, and 55% (92 respondents) of both FBO
retailers and manufacturers.
FBOs receiving advice on compliance tended to be much more advanced in preparing for the changes
than those not receiving advice.
Ease of implementation perceptions
Half of brand owners anticipate extra costs to implement changes (extra packaging/printing
costs being the most regularly cited extra cost), but about half of those surveyed felt it would be
very/fairly easy to implement the changes.
Opportunities for change
FBOs expect positives and negatives and do not see labelling changes as a panacea but do
seem to recognise that they are part of a package of initiatives that might influence consumer
behaviour, if done in a way that doesn't overload consumers with information.
70% (701 respondents) of FBOs surveyed felt the new label would have positive impacts for
consumers (mostly greater awareness of healthier eating but also easier to read labels and
standardised allergy information).
Meanwhile, 63% (631 respondents) also thought there would be downsides (increase in costs,
overload of information for consumers most commonly cited).
Key EU FIC baseline findings & hypotheses for future consideration
The table below summarises the main findings about the EU FIC labelling changes reviewed in this study
(Country of Origin, Allergen Information, Nutrition/Health labelling and Additional EU FIC labelling
requirements). These findings make up the ‘Baseline Position’. The table also offers research hypotheses
for each baseline position. The research hypotheses have been designed as a starting point for
measuring particular areas of change in consumer and businesses behaviour post EU FIC regulation
implementation. In the final column, the table also offers guidance on research methods needed to
measure change most effectively.
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6.3.1 Consumer research EU FIC baseline and hypotheses for future research
Table 26 Consumer EU FIC Baseline & hypotheses for future research
Assessment
area Criteria/theme Baseline Position Hypothesis Method of assessment
Country of
Origin Labelling
Limited COOL
information use
during decision
making
a) COOL ranked 2nd
of 12 types of information that would increase both confidence and understanding of food purchased.
b) COOL ranked 11th of 16 when
making general food purchasing
decisions (though this varied by
product type).
Consumers will continue to place a high value
on the provision of COOL (i.e. that COOL
information will improve their confidence and
understanding of the food they purchase) and
its use during the decision making process will
increase.
Qualitative: accompanied
shop observations & in-
home observations
Use of regional
food label
information
Small sample but interesting to note 36%
(n=49) survey respondents from
Scotland look for food and drink from
‘particular parts of the UK’ often,
compared to 19% in the UK (17%
England, n=339).
Of the four regions assessed within the UK,
Scottish participants use regional food label
information (i.e. Devonshire Cream, Scotch
Beef etc.) will remain higher than other UK
regions.
Quantitative: consumer
survey
COOL information
as a proxy for
product quality
Consumers use COOL when other visual
assessments of food quality are
inconclusive. There is no clear-cut
characterisation of how a consumer will
COOL label information is used as a primary
decision making criteria. COOL is used to
confirm if a product meets the home
grown/local produce criteria that the majority of
Qualitative: accompanied
shop observations & in-
home observations
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use COOL information though when
used, COOL often infers product quality.
consumer strive for which, to the majority of our
participants is deemed an indication of product
quality.
Nutrition/Health
Labelling
Hierarchical use of
nutrition/health
information
REA evidence suggested hierarchical
use of nutrition, health and UK Front of
Pack (FoP) labelling. Finding also
supported by accompanied shop
evidence.
Continued hierarchical use of food labelling
information during consumer decision making,
with the following ranking applied: (1) health
claims; (2) nutrition claims; and (3) UK 2013
FoP & BoP nutrition information.
Quantitative: consumer
survey
Qualitative: accompanied
shop & in-home
observations
Prioritisation of
individual nutrients
on food labels
REA evidence outlined that fat, sugar
and energy information are the most
used by consumers. The consumer
survey concluded that awareness of
nutrition information ranks the three
types of information above, in the same
order, for consumer awareness on food
labels.
Continued prioritisation of individual pieces of
nutrition information in a hierarchical order
within the decision making process. The
following ranking will be applied: (1) fat; (2)
sugar; and (3) calories.
Qualitative: accompanied
shop & in-home
observations
Contribution of
nutrition labelling
to consumer use of,
and confidence in
the food they
47% (n=786) of consumers claim
consistently formatted nutrition
information is a ‘big help’ in making
healthier choices. 34%(n=576) say such
information will improve their confidence
Increased levels of consumer understanding of,
and confidence in, the food they purchase as a
consequence of the food label changes
introduced by the EU FIC regulation.
Quantitative: consumer
survey
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purchase in the food they purchase, and 28%
(n=467) state that it will increase their
understanding of the food they are
purchasing.
Health & nutrition
labelling informing
healthy decision
making
80% (1,375 respondents) reported that
UK 2013 FoP nutrition information
helped them make healthier choices,
with 47% (n=786) stating it’s a ‘big help
in making healthier choices’.
The changes introduced to nutrition labelling by
the EU FIC will positively affect consumers
purchasing decisions, with a potential to
increase the number of consumers making
healthier food choices.
Quantitative: consumer
survey
Allergy
information
Allergy label use by
allergy and food
intolerance suffers
50% (175 respondents) of the allergy
group illustrated an ‘unprompted’
awareness that the list of ingredients is
shown on food packaging. Within a
prompted exercise the awareness of
ingredients lists on food labels increased
to 73% (256 respondents) for the allergy
group.
Allergy food label information will increase in
use by its intended audience (i.e. food allergy
and intolerance suffers) and will continue to
positively impact consumers through its
standardisation
Quantitative: consumer
survey
Qualitative: accompanied
shop & in-home
observations
Allergy and food
intolerance suffers
confidence and
understanding
48% (167 respondents) of the allergy
group responded that they believe the
standardisation of allergenic ingredient
information in the ingredients list will
improve their understanding of the
contents of food products. 67% (235
respondents) of allergy and intolerance
Increased, and or maintained, levels of
confidence (67%) and understanding (48%) in
food labels with the introduction of the EU FIC
changes and the standardisation of allergy food
label information by food allergy and
intolerance suffers.
Quantitative: consumer
survey
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respondents reported that the change
will improve their confidence in the
content of the food and drink that they
purchase, rating this change the highest
in boosting product confidence levels,
followed by font size at 57% (198
respondents).
Inexperienced food
allergy and
intolerance suffers
use of food label
information
Evidence from the REA, the consumer
survey and accompanied shop
observations demonstrated that
experienced food allergy and intolerance
sufferers use ingredients lists to assess
product information, rather than targeted
allergy information such as ‘contains’
boxes which is predominantly used by
newly diagnosed allergy and intolerance
sufferers.
Inexperienced food allergy and intolerance
suffers have limited engagement with detailed
food allergy labelling. Whilst newly diagnosed
food allergy and or intolerance suffer may be
negatively impacted by the EU FIC changes as
they are accustomed to ‘contains’ or allergy
boxes in their initial diagnosis phase.
Qualitative assessment:
accompanied shop & in-
home observations
Additional EU
FIC ingredient
labelling
requirements
Literature
availability on
additional EU FIC
ingredient labelling
requirements
The literature reviewed offered no
evidence to support the view that the EU
FIC changes to the listing of ‘other’
ingredients would influence consumers’
purchasing decisions. The REA found no
sources which assessed awareness or
use of information relating to the (1)
‘Engineered nano-materials’; (2) added
Wider availability of secondary literature on the
following additional EU FIC labelling
requirements: (1) minced meat declarations; (2)
added water content declarations; (3)
engineered nano-materials; (4) quantitative
ingredient declarations; and (5) labelling of oils.
Quantitative: Rapid evidence
assessment
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water and (3) minced meat declarations.
Awareness,
confidence and
understanding of
the information
provided by
additional EU FIC
ingredient
requirements
Currently awareness of additional EU
FIC Label requirements is below 50%
(n=836) as is consumer confidence in
the information it provides, with less than
35% (n=585) of main shoppers also
reporting an understanding of what
information the label changes are trying
to provide.
Increased levels of consumer awareness (+
50%), confidence in (+ 50%) and
understanding (+35%) associated with the
following addition EU FIC ingredients
requirements: (1) minced meat declarations; (2)
added water content declarations; (3)
engineered nano-materials; (4) quantitative
ingredient declarations; and (5) labelling of oils.
Please note the % is across all five
requirements assessed.
Quantitative: consumer
survey
6.3.2 Business research EU FIC baseline and hypotheses for future research
Table 27Business research EU FIC baseline and hypotheses for future research
Assessment
area Criteria/theme Baseline Position Hypothesis
Method of
assessment
Awareness of
EU FIC
regulation
requirements
General business
awareness of the
EU FIC
On average 63% (635 respondents) of all
FBOs surveyed were unaware of any food
label regulation changes to be introduced in
the immediate or near future, whether from
the EU or elsewhere.
Increased levels of awareness (from current level of
35%) of any (EU FIC or otherwise) food regulation
changes to be introduced by FBO’s.
Quantitative:
survey
assessment
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FBO type
awareness levels
FBO manufacturers reported the highest
level of awareness of the EU FIC
regulations, with 78% (101 respondents)
showing a higher awareness than the FBO
average. Awareness levels were also
varied with FBO size with 74% (424
respondents) of FBOs with fewer than 5
employees claimed to be unaware of any
impending regulation, whereas 90% (88
respondents) of FBOs with 100+
employees were aware of impending
regulation.
Increased awareness (50%+) among retailer FBO’s from
current level of 25%. Additionally an increased level
(50%+) of awareness of the EU FIC changes among
small FBOs, with large FBO awareness remaining the
same.
Quantitative:
survey
assessment
Individual
requirement
awareness levels
Recall awareness levels of EU FIC
changes to labelling are all below 5% with
FBO retailer and manufacturers showing
the same low levels of awareness, apart
from allergen label changes for which recall
awareness is 30%.
FBO awareness of individual EU FIC regulation
requirements (with the exception of allergen labelling
requirements) to increase from the current average
(unprompted) awareness levels of >5%. Projected
increase to 55%.
Quantitative:
survey
assessment
Preparedness
to meet EU FIC
regulation
requirements
Implementation of
changes required
to meet the EU FIC
requirements
Only 6% (7 respondents) of FBO
manufacturers and no FBO retailers
surveyed have fully implemented the
required business changes to be EU FIC
compliant. 49% (63 respondents) of
manufacturer FBOs and 5% (32
Increased pan FBO implementation of changes required
to meet EU FIC regulations. Increased to 70% from
current level of 6% FBO manufacturers and 0% FBO
retailers.
Quantitative:
survey
assessment
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FA0132 Baseline for Evaluation of EU FIC (Food Information to Consumers) labelling
respondents) of retailers have started their
EU FIC compliance activities but have not
completed their work.
Activities engaged
with to meet
requirements
The most common preparation activities
include initial engagement such as (1)
working out exactly what information is
required to be incorporated on the
compliant food labels and (2) reading the
regulation in-depth to determine the
implications it may have. The prevalence of
these activities suggests that the majority of
businesses are still at the early stages of
becoming EU FIC compliant
Activities that businesses detail that they engaged with to
meet the EU FIC requirements encompass but are not
limited to the following ranked activities: (1) read about
the EU FIC regulation; (2) brief staff on the changes that
need to be implemented; (3) talk to suppliers about the
EU FIC changes; (4) draw up designs for new labels; and
(5) research wider information requirements.
Quantitative:
survey
assessment
Qualitative: in-
depth qualitative
interviews
Cost of
implementing
EU FIC
regulation
requirements
Implementation
costs incurred in a
hierarchical order
Half of brand owners anticipate significant
extra costs in association with the EU FIC
regulation changes. Not surprisingly the
picture is very different for businesses
selling brands that they do not own, with
only 16% (102 respondents) anticipating
significant extra costs. The two most
commonly stated ‘costs’ required to meet
the EU FIC requirements are (1) extra
packaging and print costs, and (2) extra
burden on existing staff.
The business costs associated with implementing the
changes required to meet the EU FIC regulations are
encompasses but is not limited to the following ranked
activities: (1) extra packaging/printing costs; (2)
additional burden on existing staff; (3) extra graphic
design costs; (4) changing production methods; and (5)
consultant/lawyer/adviser to provide guidance on EU FIC
requirements.
Quantitative:
survey
assessment
Qualitative: in-
depth qualitative
interviews
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Business
perceptions of
EU FIC
regulation
changes
Expansion of
positive business
perceptions of the
EU FIC regulation
70% (701 respondents) of FBO survey
respondents felt that the new label
requirements will have positive impacts,
with negligible difference between the
views of retailers and manufacturers (retail
only 69% - manufacturing only 72%).
Increased levels of positive opinion associated with the
three most widely recognised (by FBO’s) positive outputs
of the EU FIC: (1) greater consumer awareness of
healthier eating (70%+); (2) clearer/easier to read labels
(50%+); and standardisation of all allergy information
(50%+).
Quantitative:
survey
assessment
Qualitative: in-
depth qualitative
interviews
Reduction of
negative business
perceptions of the
EU FIC regulation
63% (627 respondents) of FBOs surveyed
believe implementation of EU FIC
requirements will have negative impacts.
Decreased levels of negative opinions associated with
the three most widely recognised (By FBO’s) negative
outputs of the EU FIC: (1) increase in costs (-25%); (2)
overload of information (-25%); and (3) an increase in
work load (-10%).
Quantitative:
survey
assessment
Qualitative: in-
depth qualitative
interviews
As outlined above there are multiple potential baseline criteria and themes for testing in the future. These have been developed with the view of comprehensive future
assessment and the testing of the diversity of the EU FIC requirements. It is suggested that the body of the above hypotheses are tested in future work, however these
have been broken down into key requirements and areas of focus allowing future research to respond to both consumer and business feedback and test key areas of
change.
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