Recently, the Government of Jamaica took a decision that the CRS 5: 2010 Standard Specification for the Labelling of Pre-packaged Foods to include Front of Package Labelling (FOPL) should, in addition to the “High-In” Octagon Model, include other FOPL in line with our major trading partners.
The introduction of FOPL for pre-packaged foods in Jamaica is of considerable importance and has generated widespread interest and discussions among various stakeholders regarding its implementation. The revision of the CRS 5: 2010 Standard Specification for the Labelling of Pre-packaged Foods to include FOPL is a regional initiative of the Caricom Regional Organization for Standards and Quality (CROSQ) and is being advanced as a voluntary standard for Caricom member states. Consequently, there has been a thrust at the national and regional levels to improve nutritional labelling and introduce mandatory front of package warnings to consumers.
The objective of FOPL is to provide the consuming public with information on the content of sodium/salt, fats, saturated fats, trans-fats, and sugar in pre-packaged foods to assist in making healthy decisions and reduce the incidence of non-communicable diseases (NCDs) and obesity.
Internationally, there are several FOPL models such as the “High-In” Octagon Model, the Facts Upfront System used in the USA, the Multiple Traffic Light System used in the UK, the Nutri-Score System, the Health Star Rating System, and the Reference Intake System, among others.
The Government of Jamaica recognises the negative effects of NCDs on the health of the Jamaican population, the importance of diet in combating NCDs and the role that FOPL can play in better consumer choice in relation to food purchase and consumption. As policymakers, it is necessary to ensure the crucial balance between health concerns, the realities related to food consumption, the need to allow for trade to be conducted freely with our major trading partners to ensure competitiveness, limiting the complexities in trade as well as unfair trading practices, while also ensuring the best prices for local consumers.
Choice of model(s)
The current conversation surrounds the inclusion of the “High-In” Octagon Model as the only FOPL option in the Caricom regional standard currently being developed by the CROSQ. The point of divergence is that some stakeholders do not accept the “High-In” Octagon Model as the best fit and single model for the country, while others contend that it may be the most effective and is, therefore, the model to be utilised in Jamaica.
This conversation is particularly important as the “High-In” Octagon Model is currently utilised in less than seven countries worldwide, primarily in South and Central America. It is important to note that none of the countries that implement the “High-In” Octagon Model are our major trading partners (the USA, UK, EU, Japan or Canada). Canada however is considering utilising an adapted version of warning symbols synonymous with elements of the “High-In” Octagon Model, utilising its own nutrient profile and classifications (See possible depictions below).
The “High-In” Octagon Model utilises the PAHO Nutrient Profile System, which has been the subject of widespread discussion across the private sector in Caricom as manufacturers perceive that more than 90 per cent of the products produced in Caricom would not be able to meet the requirements of the PAHO Nutrient Profile System.
Official position on FOPL implementation
It is important to state publicly that the Jamaican Government, on a whole, is fully supportive of the introduction of FOPL for pre-packaged foods in Jamaica, noting its strength in the fight against NCDs and obesity. It is further important to also note that the Government of Jamaica has never voted against the inclusion of the High-In Octagon Model of FOPL in the informative annex of Revised CRS 5: 2010 Standard Specification for the Labelling of Pre-packaged Foods. The position of the Jamaican Government remains that other FOPL labelling models must be included, along with the High-In Octagon Model in the Caricom Standard.
The only way of guaranteeing that additional FOPL models are added to the draft standard is to “not accept”, with comments, the current draft as presented; commenting that additional FOPL models, in line with our major trading partners, should be included prior to the approval of the standard. This ministry recognises that this position is point of difference among advocates for health, but maintains that this is the most logical position in the interest of balancing trade, public health, and industry.
The current decision by the Government allows for greater flexibility in any final decision by the Jamaican Government, in collaboration with its stakeholder, including health advocates. Where other options are included the Government may, at a later date, select from the options presented based on our specific cultural, practical and legislative realities or develop its own unique model.
A series of stakeholder meetings have been held with all the major stakeholders involved, including the private sector, Government, academia, civil society, and consumer groups. All the stakeholders are in full support of the introduction of FOPL in Jamaica to assist with combating the negative effect of NCDs and the general health of the population, and the majority of the stakeholders agree that additional models should be included in the standard.
Recent indications among the members of CROSQ suggest that the position of Jamaica regarding the need for inclusion of other FOPL models is similar to that of various other Caricom countries. The Caricom Private Sector Organization (CPSO) has successfully advocated to the Council on Trade and Economic Development (COTED) for an impact assessment study to be to be undertaken by that group prior to the approval of the standard by the COTED. As a result, the impact assessment study will occur concurrently with the CROSQ standard development process and in time for consideration of the COTED at its next meeting scheduled for November 2021.
Implementation at the national level
Symbolic of any voluntary standard, the Government of Jamaica will have the option to adopt, make adjustments, modify, or reject the Caricom standard for implementation within its domestic jurisdiction. The Government of Jamaica will make this decision at the time of implementation, in accordance with our local interests. As Government, the thrust towards implementation must be led and determined by a cohesive and balanced national policy, implemented only after considering the interests of all the stakeholders and interest groups involved and measured against the overall objective of the policy measure.
Importance of complimentary measures
It cannot be understated that the FOPL model to be adopted locally is of significant national importance and has substantial implications for health, trade, industry, commerce, and government regulatory practices. The FOPL model selected will require significant buy-in from all the relevant stakeholders across the Government, academia, civil society, consumers, and the private sector and will require complimentary initiatives to achieve its objective.
The implementation of FOPL must be supported by the implementation of complementary legislative, policy, and regulatory measures. Additionally, whatever model is agreed on will need to be supported by robust public education, sensitisation and awareness. These supporting measures combined must be in place to ensure compliance, public awareness, widespread sensitisation, and stakeholder buy-in. This is a consistent approach among all countries in which the FOPL has been introduced.
At the appropriate time, the Government of Jamaica will once again enlist the support of all stakeholders as it seeks to balance the various interests.
The timing of the introduction of the FOPL requirements is also critical. The Jamaican economy remains fragile at this point as the country seeks to recover from the impacts of the novel coronavirus pandemic and combat some of the highest inflation on consumer goods. It is therefore important that we prevent any disruption in the economic stability of the country, secure consumers from additional cost, and mitigate against any widespread negative implications. The implications associated with the issue are varied and are listed in the table below:
The Government of Jamaica does not take any of the views of its stakeholders lightly and has facilitated several stakeholder consultations across all stakeholder groups over several months. The national position advanced to the CROSQ is supported at the highest level of executive decision-making in the country. The decision taken by the Government is not a disagreement with the general objective of FOPL in Jamaica, but rather an indication of a balanced approach, and that consideration must be given to the addition of other FOPL models, including the ability to develop a hybrid local FOPL model for Jamaica and Jamaicans.