On September 4, the World Health Organization (WHO) announced the publication of a new draft guideline, Nutrition labelling policies. Prompted by requests from Member States and WHO’s view that labeling is now “a valuable marketing asset aimed at influencing food decisions and purchases,” the guideline aims to inform new – and strengthen existing – FOPL policies around the world. WHO is accepting public comments on the guideline through October 11, 2024.
The guideline makes recommendations for back-of-pack nutrient declarations and ingredient lists, nutrition and health claims, and front-of-pack labeling (FOPL). WHO convened the NUGAG Subgroup on Policy Actions to conduct systematic evidence reviews and articulate conclusion statements based on the strength of available science.
Guideline Conclusions:
- [Good-practice statement] WHO recommends the inclusion of a list of ingredients on prepackaged food, consistent with the Codex Alimentarius General standard for the labelling of prepackaged foods. In particular, the guideline encourages specifying partially hydrogenated oils in the ingredients list to support national policies on trans-fat removal.
- [Strong recommendation] WHO recommends a policy to implement nutrient declarations. WHO urges mandatory nutrient declarations when claims are made and for all other prepackaged food, and notes that evidence suggests the presence of nutrient declarations “diminishes the promotional effects of claims.”
- [Strong recommendation] WHO recommends a policy to implement FOPL. Also recommended is a FOPL nutrient profiling model for which the government has ultimate authority.
- [Strong recommendation] WHO recommends implementation of interpretive FOPL in preference to non-interpretive FOPL. WHO considers there to be “moderate certainty evidence” that interpretive FOPL outperforms non-interpretive FOPL related to consumer understanding, food choice/intent to purchase and food purchasing decisions.
- [Good-practice statement] WHO recommends protecting consumers from false, misleading and/or deceptive nutrition and health claims on food, through regulation of the use of nutrition and health claims. WHO expects this action will help avoid “health halo” effects for foods that are high in saturated fat, trans-fat, sugars and/or sodium.
Additional FOPL Insights & Impressions:
- This guideline adds to a growing consensus among public health nutrition organizations and stakeholders that interpretive FOPL is a best practice approach. Non-interpretive systems, including Facts Up Front, the industry-backed system used in the U.S., are losing support. Future FOPL regulations likely will reflect this stance, including the proposal expected from the U.S. Food and Drug Administration (FDA) this fall. Global Food IQ previously shared our thoughts on the forthcoming decision.
- WHO acknowledges the evidence on FOPL is of low-to-moderate certainty, but judged the “balance between desirable and undesirable effects [to favor] implementing a policy on FOPL.” There is enough momentum on FOPL that evidence gaps are unlikely to stop or slow policy action.
- Like other FOPL evidence reviews of late, the guideline concludes there is no single best performing FOPL system. There are elements of FOPL that are differentiated in the research (e.g., format, nutrient profiling model, enforcement) – many of which were included in WHO’s 2019 FOPL publication, Guiding principles and framework manual for front-of-pack labelling for promoting healthy diets – but ultimately, labels should be customized to local standards and needs. There is room to inform outcomes that are feasible and impactful on a country-level basis.
- While not referenced in the top recommendations, WHO discusses ultra-processed foods (UPF) towards the end of the guideline. WHO suggests that some FOPL formats (particularly those that include “positive” food group or nutrient elements) allow UPF to receive favorable scores. To avoid this, the guideline proposes FOPL include processing level in the nutrient profiling model or through ingredient consideration. This already has been explored for existing FOPL systems, like Nutri-Score, and further illustrates momentum around integrating processing with nutrition policy.
FOPL continues to dominate the global nutrition policy dialogue. Reach out to Global Food IQ for further information and to discuss impacts of actions like these on your organization.
