Editorial: Despite good intentions, FOP labels could do more harm than good

When Health Canada updated Canada’s Food Guide in January 2019, it was markedly different than previous guides. 

Unlike previous editions that focused on food ‘groups’ such as dairy, meat, grains, fat, vegetables and fruit, it categorizes food into nutritional categories such as ‘protein’ and ‘fibre’. Rather than dictating how many servings a citizen should consume from each food group, it focuses on telling consumers to choose whole, unprocessed foods and most importantly, shows them how to do this. 

Prominent on the front of the guide is a plate of food showing that half of the plate should be made up of fruits and vegetables, one-quarter of the plate is whole grain products (foods like bread, pasta, quinoa, rice, oats) and one-quarter of the plate is protein (foods like meat, nuts, legumes and dairy). 

No one single food group is vilified or promoted over another. The goal of the ministry was to simplify healthy eating for Canadians, and educate them on how to do it. 

The simple visual approach to the guide has been influential. According to an Angus Reid Global poll conducted after the guide’s release, 34 per cent of Canadians said they had changed some of their food-consumption habits due to recommendations in the new guide. 

The guide is just one component of the federal government’s Health Eating Strategy, which began in 2015. 

Of course the guide is particularly useful when eating at home or in a restaurant, where its mostly whole foods being used for cooking and eating. While most whole foods recommended in the guide come wrapped in plastic or in some other type of packaging to preserve freshness, they are not really considered ‘packaged’ foods in food industry terminology, because they haven’t been further processed. Many don’t require a nutrition label for this reason. 

But for further processed or ‘ultra’ processed foods — often the type of packaged foods that give a crunching sound when opened (think chips and cookies), Health Canada proposes to revise nutrition labelling to make sugar, saturated fat and sodium levels more prominently displayed on packaging. 

Called front-of-package labelling (FOP), the ministry wants to have a label on the front of a package with a symbol such as an exclamation mark in bold font to alert buyers that a product contains what it deems to be an unhealthy level of sugar, saturated fat and/or sodium. 

These nutrients are known to contribute to chronic health conditions such as type 2 diabetes, obesity and heart disease. 

But while the intention of the label is noble, there are some glaring, and rather ridiculous, exemptions that could not only prevent citizens from choosing some healthy options, but could have detrimental effects on certain agriculture sectors and international trade. 

When first proposed in 2017, the ministry said that FOP label rules would not apply to raw, single-ingredient meats, poultry and fish that are not ground because these ““are considered less standardized than ground meats, which make deriving accurate nutrient values challenging.” Whole and partly skimmed milk and whole eggs are also exempt from the proposed FOP rules. 

How does putting beef or pork through a grinder significantly change its nutritional make-up from a whole piece of meat? Meat, inherently, contains some saturated fat. Why is a beef roast (especially a less lean cut) exempt but lean ground beef is not? Only the form of the product has changed, and the change in saturated fat level is most likely nominal. 

The Canadian Cattlemen’s Association (CCA) agrees. It released a statement earlier this month urging Health Canada to review its FOP policy on ground beef. The CCA said “Canadians consume approximately half of their calories from low nutrient, ultra-processed foods. By contrast, ground beef is a nutrient-dense protein that contributes iron, zinc, and vitamin B12. FOP labelling of whole, single-ingredient foods starkly contrast with the foundational principles of healthy eating and will distract from the real priority — Canadians need to reduce their consumption of ultra-processed foods.”

While Canada is not the first country to implement FOP rules, the CCA said that to its knowledge, “Canada will be the only jurisdiction in the world placing a health warning label on its ground beef.” 

Yogurt is an example of another food that could be negatively impacted. While milk and fruit contain natural sugars, this is not differentiated on the label from the type of sugars that are added to food products. If the total amount goes over Health Canada’s threshold, it will be prominent on the FOP label.

Health Canada would like to begin implementing FOP labelling later this year. If it truly wants to help Canadians to eat well, it needs to take a harder look at what is exempted, and ask itself, “does this make sense?”