Influencing healthy consumer behaviour is our priorityMonday, September 06, 2021
We note with concern a release issued by the Ministry of Industry, Investment and Commerce (MIIC), dated August 19, stating their “strong support of front of package labelling (FOPL)” — but not the proposed octagonal high in model which was found to be most effective by Jamaican consumers in a recent study (https://www.paho.org/en/news/9-3-2021-octagonal-warning-labels-perform-best-helping-consumers-choose-healthier-food-major) conducted by Ministry of Health and Wellness (MOHW), Pan American Health Organization (PAHO), and University of Technology, Jamaica (UTech). The MIIC has ignored these findings in favour of an approach fraught with consumer challenges.
The MIIC provided an excellent summary of the primary intent of FOPL — its ability to influence healthier selections and the need for Jamaica to reduce diet-related disease burdens. However, the MIIC has, by its publicly stated position on this matter, provided confirmation that trade matters and the perceived burdens to those in the food business are more valuable and worth greater protection and consideration than the health of Jamaican consumers.
It is crucial that we remind the MIIC and the public what FOPL is — its purpose and value to consumers. First and foremost, FOPL is a public health tool designed to give consumers important nutritional information about a product, the primary purpose being to encourage healthier choices and improve health. Consumer attention and understanding are therefore critical. Yet, the MIIC is intent on including the most underperforming and least effective models — the ones most confusing to consumers. Therefore, by claiming to support FOPL the MIIC is only giving lip service to the principle of the Jamaican consumers' right to know.
The MIIC perceives the proposed black octagon high in model may have implications for its business and trade partners. Yet, manufacturers already routinely change their labels for various reasons, including compliance with different regulations of its various export markets. Mexico, one of the USA's main trading partners, has successfully adopted the high in model. Since implementation in 2020, no barriers or negative trade outcomes have been reported. These trade arguments are known deflection tactics.
Is the MIIC purporting that Jamaica must retain minimum local standards but adapt to strict regulations elsewhere? Or that Jamaican consumers do not deserve the same rights to information about the nutrition composition or ingredients in products?
From a cost perspective, it is important to note that only pre-packaged products that exceed nutrient thresholds for salt, fat, and sugar (that is, ultra-processed) will require the proposed FOPL. All other products, including fresh fruits, vegetables, meat products, etc, will not. (For more information on the nutrient thresholds and applicable products visit https://iris.paho.org/handle/10665.2/18621.)
We wholeheartedly agree with the MIIC regarding the need for public education in relation to FOPL. Public education has already started and is continuously being supplemented, hence this discussion. Furthermore, if the high in model was approved, sufficient time and effort would be allowed for its implementation.
Concerns about the economy should focus on the fact that a large proportion of Jamaicans already face overwhelming health and economic burdens from underlying diet-related illnesses such as obesity, diabetes, hypertension, etc, and now face greater risks with COVID-19. These diet-related diseases account for over 70 per cent of all deaths in Jamaica.
In actuality, the balance of health concerns are a sad reflection of the realities related to food consumption. Surveys show that 10 per cent of Jamaicans — 15 to 74 years — consume an excessive amount of salt and 70 per cent consume an excessive amount of sugars.
Approximately 86 per cent of children — eight to 11 years — consume sugars in excess of the recommended limits. This is not surprising since the majority of pre-packaged products are high in salt and sugars, and many labels provide insufficient or inaccurate information. Is the MIIC at all concerned that Jamaicans are being limited to an unhealthy array of food and beverage products at the behest of its partners?
It is our view that the MIIC and partners do not support the high in model precisely because of its proven effectiveness in positively influencing consumer behaviours. This protects the vested interests of a few, over the rights, health, and financial interests of consumers. The irony was not lost that the Consumer Affairs Commission is also an agency of the MIIC. Their rejection of the model deflates their mandate to protect consumers. We consider this a clear conflict of interest.
A grave concern is the seeming influence and involvement of the MIIC in a public health matter which should have been a balanced, impartial, and transparent process. This MIIC public statement directly opposes the position of the MOHW, the country's lead health authority with primary oversight for public health policy decisions.
What sort of precedent is this setting for other health-related issues? Is that not undermining and casting doubt on the function of the MOHW? This does not bode well and has serious implications for public health.
There is solid evidence to support the claim that the black octagonal high in FOPL model is being undermined by speculative trade barriers and unfounded economic claims. It is the Government's responsibility to ensure that the health of the nation takes precedence over the interests of a few. We implore the Government to reconsider its position and approve the high in FOPL. It is time to put people first.
Deborah Chen is the executive director of Heart Foundation of Jamaica. Send comments to the Jamaica Observer or the firstname.lastname@example.org.