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FA0132 Baseline for Evaluation of EU FIC (Food Information to Consumers) labelling

DefraFA 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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Baseline Evaluation of EU Food Information for Consumers (FIC) Labelling: Final Report

Table of contents1. Project Overview 1

Prepared for:

DefraFood Policy Unit

Nobel House17 Smith Square,LondonSW1P 3JR

Prepared by: Anthesis Consulting Group The Future Centre,9 Newtec Place, Magdalen Road,Oxford, OX4 1RE

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Report written by: Nicola Jenkin, Jennifer Wilson, Oscar Benjamin & Graham KellyContributors: Sue Clegg and Vicky Grinnell-Wright

Quality Assurance

Reviewers:

Nicola Jenkin, 10th July 2014

Report approved by:

Ben Tuxworth

http://www.anthesisgroup.com/


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 19

4.1.3 Accompanied Shop Findings 24

4.1.4 Conclusion 25

4.2 UK 2013 Front of Pack Nutrition Scheme 26



4.2.3 Accompanied Shops Findings 34

4.2.4 Conclusion 36

4.3 Allergen labelling 37




4.3.4 Conclusion 45

4.4 Additional EU FIC ingredient labelling requirements 46

4.4.1 Rapid evidence assessment (REA) 47



4.4.4 Conclusion 55

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



5.2.3 Large Corporation In-depth Interviews 70

5.2.4 FBO General EU FIC Awareness: FBO Characteristic Breakdown 70

5.2.5 Conclusion 70



5.3.3 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


5.4.2 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 88

6.3.2 Business research EU FIC baseline and hypotheses for future research 92

Bibliography 96


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 23

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


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........................................................88

Table 27 Business research EU FIC baseline and hypotheses for future research........................................92


1. Project Overview1.1 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

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delivery timeline could not be extended, so instead the research used smaller sample sizes, and more 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.

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2) To incorporate a wider geographical scope for review (Scotland, Wales and Northern Ireland as 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 LimitationsOutlined 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

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informed of the true aim of the research (i.e. the assessment of food label use and EU FIC regulation 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 UKFood 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;

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5. Special storage conditions or conditions of use; 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; and8. 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; and6. 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 & ToolsThis 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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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 b) Investigating what businesses expect or report the impact of EU FIC changes to be on their businesses.

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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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; and2. 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 Attitudes to Food Labelling 20092 as a benchmark for literature inclusion and exclusion parameters).

2 http://www.fsai.ie/assets/0/86/204/9f8b5edc-565e-4f10-8c0f-7015f742da09.pdf

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http://www.fsai.ie/assets/0/86/204/9f8b5edc-565e-4f10-8c0f-7015f742da09.pdf


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 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

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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.

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.

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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 interviews4 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 conducted.

Accompanied Shop Locations Number conducted

England 28

Scotland 12

Wales 12

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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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);

and4. 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

Purchasing motivationAllergies 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.

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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:

Region Main Shopper Sample Size

England 1,254Scotland 138

Wales 132Northern

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

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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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.

3.2.3 Business Survey

1,002 telephone interviews with food business operators (FBO) were undertaken. The FBOs selected represented a range of small6, medium7 and large8 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

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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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 sizeThe 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.

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.

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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 sizeA 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 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.

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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.

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 AnalysisThis 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;

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http://en.wikipedia.org/wiki/Chi-squared_distribution

http://en.wikipedia.org/wiki/Degrees_of_freedom_(statistics)

http://en.wikipedia.org/wiki/Frequency_(statistics)

http://en.wikipedia.org/wiki/Normalization_(statistics)

http://en.wikipedia.org/wiki/Statistic


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.

4. Baseline Findings: Impacts on ConsumersThis 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

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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 section1. 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.

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; and4. 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).

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http://multimedia.food.gov.uk/multimedia/pdfs/publication/countryoriginlabellingscot.pdf

http://multimedia.food.gov.uk/multimedia/pdfs/publication/countryoriginlabellingscot.pdf


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.

4.1.2 Consumer Survey Findings

Awareness of COOL

Overall consumers (n=1,672) ranked COOL 8th out of 15 possible types of information9 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.

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.

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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.

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 options 12, 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

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.

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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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)

RScot % (of 138)

RWales % (of 1320

RNI % (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 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 (11 th

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 1813)

Q

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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 8 th in Wales to 12th in Northern Ireland. This variation aligns with the regional variation in confidence and understanding driven 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.

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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Q13: When shopping, do you look for food and drink from particular parts of the UK?


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; and3. Consumers are easily confused by COOL and wider marketing information.

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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.

(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’.

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.

(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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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, 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.

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.

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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: 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.


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

14 Please note when references are made to food and food label information this phrase also encompasses drinks products and information provided on drinks.

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(DoH, 2013).

2) Robust nutritional information is importantIt 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

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).


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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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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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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*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.


Nutrition information will be listed in a set order

UK % (of 1,672)


Scot % (of 138)

Wales % (of 1320

NI % (of 148)

Confidence 34% 34% 33% 48%* 29%

Understanding 28% 27% 30% 36% 22%

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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 importance amongst food label information provided under the EU FIC label changes. At 6 th 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 optionsError: Reference source not found 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?'

ResponseUK %

(of 1,672)


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.


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

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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of the food and drink they purchase. This trend is in line with main shopper results.

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

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Outlined above in table 13 is a summary of the geographical differences in how consumers ranked their 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 (14 th 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 (9th) and Northern Ireland (11th).

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; and4. 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:

(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 explain 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?’

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

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saturated fat’ or ‘reduced salt’ as a quick reference guide to make their decisions.

(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’

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.

(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”.

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

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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’.

(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”

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.

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4.3 Allergen labelling

This section assesses how the food label changes under the EU FIC may impact medically and self-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

17 http://www.worldallergy.org/public/allergic_diseases_center/foodallergy/

36

http://www.worldallergy.org/public/allergic_diseases_center/foodallergy/


7. For detailed information on the EU FIC 1169/2011 allergy changes please refer to Appendix II.


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

18 http://www.legislation.gov.uk/uksi/1996/1499/contents/made

37

http://www.legislation.gov.uk/uksi/1996/1499/contents/made


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, 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.


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 informationNo 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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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.


Food label informationNo dietary

restrictions (of 882)


349)


(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, COOL etc.) where these changes (i.e. allergy labelling) were the highest ranked by allergy and intolerance sufferers.

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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Allergy information to be emphasised in the

ingredients list, instead of on a separate \Contains\" list"

No dietary restrictions (of

882)


349)


(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 3 rd whereas main shoppers place it 10th. The allergy group rank specific allergy information 8th 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.

After assessing current labelling, allergy and intolerance sufferers’ (n =349) were asked to assess the

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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


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; and4. Food label review behaviour amongst Allergy and intolerance sufferers.

1. Experienced food allergy and intolerance sufferers using the ingredients list above other 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

23 Refers to pre EU FIC food labelling practices, notably the use of allergy ‘contains’ boxes.

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sufferers use ingredients lists to assess product information, rather than targeted allergy information such as ‘contains’ boxes, as illustrated in the quote below:

(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”.

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; and2) 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’Error: Reference source not found allergy information such as ‘contains…’ boxes. The two examples below, illustrate the difference between ‘experienced’ and ‘inexperienced’ sufferers usage of allergen information.

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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.

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 24 th February – 4th 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

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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 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.

(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’.

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.

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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 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.

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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 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’).


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);

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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.

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.

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Figure 5 Consumer prompted and unprompted awareness of wider EU FIC requirements


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 this heightened awareness was not apparent from the evidence reviewed and gathered during both the consumer survey and accompanied shops.


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


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

from27% 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


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 from30% 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.


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

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To understand the current usage of ’other’ ingredient labelling in relation to other types of labelling 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)10th 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.


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.

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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:

1) Consumers use of QUID information for meat to compare products and infer quality; and2) 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:

(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’

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:

(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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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.

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 labelsWhilst 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 labellingCountry 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)

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and understanding (31%, n=518) of food purchased.

3) Impact of ingredient informationA 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). 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 labellingClear 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 7th 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

Recall awareness (unprompted) response findings

Recall awareness levels of EU FIC changes to labelling are all below 5% (less than 50 respondents) with

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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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

Manufacturer %

Manufacturer 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:

Northern Ireland FBOs reported the highest level of awareness of the COOL changes at 88% (33

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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 existing network of FBOs within the project steering group. These FBOs had a high level of awareness of

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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.


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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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 changeFBO 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 are not being sent advice directly), with FBO retailers less likely to be receiving advice (88% - 624

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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

Q: What information would help your business to prepare for new legislation, and which

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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).

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

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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 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

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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.


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.


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% (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;

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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% (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

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Figure 8 FBO ease of implementing the EU FIC regulation


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.

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.

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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 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.

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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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.


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:

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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.

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:

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1) Greater consumer awareness of healthier eating 61% (429 respondents);2) Clear/easier to read labels 20% (138 respondents); and3) 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); and3) 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.

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.

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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

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

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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;

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 conclusionsKey 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,

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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. 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

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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.

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

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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 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 8 th 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

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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’.

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

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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 finallyo collagen/meat protein awareness increasing to 12% (n=195).

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

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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 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.

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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 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

COOL label information is used as a primary decision making criteria. COOL is used to confirm if a product meets the home

Qualitative: accompanied shop observations & in-home observations

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characterisation of how a consumer will use COOL information though when used, COOL often infers product quality.

grown/local produce criteria that the majority of 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.


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.


Contribution of nutrition labelling to consumer use of,

47% (n=786) of consumers claim consistently formatted nutrition information is a ‘big help’ in making

Increased levels of consumer understanding of, and confidence in, the food they purchase as a consequence of the food label changes


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and confidence in the food they purchase

healthier choices. 34%(n=576) say such information will improve their confidence in the food they purchase, and 28% (n=467) state that it will increase their understanding of the food they are purchasing.

introduced by the EU FIC regulation.

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.


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



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

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


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improve their understanding of the contents of food products. 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 product confidence levels, followed by font size at 57% (198 respondents).

label information by food allergy and intolerance suffers.

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

The literature reviewed offered no evidence to support the view that the EU FIC changes to the listing of ‘other’ ingredients would influence consumers’

Wider availability of secondary literature on the following additional EU FIC labelling requirements: (1) minced meat declarations; (2) added water content declarations; (3)

Quantitative: Rapid evidence assessment

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requirements

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.

engineered nano-materials; (4) quantitative ingredient declarations; and (5) labelling of oils.

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.


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

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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

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.


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%.


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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 respondents) of retailers have started their EU FIC compliance activities but have not completed their work.

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.


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.


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

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


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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.

design costs; (4) changing production methods; and (5) consultant/lawyer/adviser to provide guidance on EU FIC requirements.


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%+).



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%).



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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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