food standards in britain: derivation and potential

Food standards in Britain: derivation and

Britain is not alone in imposing legislative controls on the composition of some food. These controls have a dual purpose: they ensure a consistent standard of quality for the purchaser and they protect the honest trader from unfair competition. The author describes the method by which British standards are derived and considers how the system of food standards accords with other aspects of food policy. Using examples, the author ex- plains to which foods defined standards currently apply. He also illus- trates the mechanisms by which standards are decided upon, and what influ- ences the decision.

Keywords: Food legislation; UK; Food standards

Dr Fallows is a research fellow in Food Policy in the School of Science and Socie- ty, University of Bradford, Bradford, BD7 lDP, UK.

This paper forms part of a study supported by the Joint Committee of the Economics and Social Research Council and the Science and Engineering Research Coun- cil.

‘Food Act, 1984, 49, Eliz 2, ch 30, HMSO, London, 1984. ‘Food and Drugs (Scotland) Act, 1955, 4, Eliz 2, ch 16, HMSO, London, 1955.

potential

Stephen J. Fallows

The regulation of food quality in Britain is a two tier system with general legislation applying to all foods and more detailed legislation relating to a specific food or group of foods.

The general legislation on standards of food quality may be subdivided into a number of categories:

The Food Act 1984

This is the principal food law of England and Wales and the direct descendent of 19th century legislation designed to prevent adulteration.’ The Food Act consolidates earlier legislation and is, for the most part, a word-for-word transcription of those sections of the 1955 Food and Drugs Act2 which related to food. The Act applies only to England and Wales but essentially similar requirements based upon the 1955 Act apply to Scotland and to Northern Ireland. The general provisions of the Acts are:

A person is guilty of an offence who adds any substance to food, uses any substance as an ingredient in the preparation of food, abstracts any constituent from food, or subjects food to any other process or treatment, so as (in any such case) to render the food injurious to health, with intent that the food shall be sold for human consumption in that state (Section 1). If a person sells to the prejudice of the purchaser any food . . . which is not of the nature, or not of the substance, or not of the quality, of the food demanded by the purchaser he is guilty of an offence (Section 2). The Ministers may. . .make regulations. . .for requiring, prohibiting or regulating the addition of any specified substance of any specified class, to any food intended for sale for human consumption or any class of such food or the use of any such substance as an ingredient in the preparation of such food, and generally for regulating the composition of such food. . . (Section 4). A person who gives with any food sold by him, or displays with any food exposed by him for sale, a label. .which (a) falsely describes the food, or (b) is calculated to mislead as to its nature, its substance or its quality, shall be guilty of an offence. (Section 6). The Ministers may make regulations for imposing requirements as to, and otherwise regulating, the labelling, marketing or advertising of food intended for sale for human consumption and the description which may be applied to such food (Section 7). A person who sells, or offers or exposes for sale, or has in his possession for the

0306-9192/85/020145-l OS3.00 0 1985 Butterworth & Co (Publishers) Ltd 145

Food standards in Britain:

3The Food Labelling Regulations, 1984, SI No 1305. HMSO, London, 1984. +‘This paper does not list each and every regulation made under the Food Act and its predecessors. An easy-reference work detailing the specifics of British food legislation is D.J. Jukes, Food Legislation of the UK: A Concise Guide, Butterworths, Sevenoaks, UK, 1984.

purposes of sale, or for preparation for sale. .any food intended for, but unfit for, human consumption is guilty of an offence (Section 8). The Ministers may make. . .regulations. .for securing the observance of sanitary and cleanly conditions and practices in connection with (a) The sale of food for human consumption, or (b) The importation, preparation, transport, storage, packaging, wrapping, exposure for sale, service or delivery of food intended for sale or sold for human consumption, or otherwise for the protection of the public health. . . (Section 13).

These sections are central to British food legislation. This paper concentrates on those sections which relate to food compositional and labelling standards rather than those which concern matters of food hygiene. It must, however, be noted that the provisions of Section 13, with their predecessors in earlier legislation, have led to the virtual elimination of food-borne infectious disease in Britain.

The major purpose of regulations relating to specific foods is to define the ‘nature, substance and quality’ referred to in Section 2, or to define the style of advertising or labelling which meets the terms of Section 6 for a particular foodstuff.

Regulations relating to labelling

These apply mainly to processed or pre-packed foods. The bulk of the provisions relating to labelling are contained within the 1984 Food Labelling regulations.3 The 1984 regulations require the following information to be included on the labels of most, but not all, foods sold to the consumer: the name of the food; the ingredients used (listed in order of weight); a statement of minimum durability; indication of special storage conditions; name of manufacturer packer or seller; statement of origin; instructions for use. The 1984 regulations were the European Economic Community (EEC) harmonization programme.

Regulations dealing with additives and contaminants

These regulations list the specific additives which may be used in foodstuffs.4 The regulations also consider in detail: instances where additives are not permitted; specific limits for particular contaminants; items which must not be used in foodstuffs and items which may or may not be used in the packaging of foods. These regulations may, in general, be thought of as defining for Section 1 of the Food Act - substances and processes which are not regarded as likely to render a foodstuff injurious to health.

Health aspects

Section 132 of the Food Act indicates that the responsible ministers who have powers to make regulations under Sections 4,7 and 13 (above) are the Minister of Agriculture, Fisheries and Food and the Minister of Health acting jointly. In practice, the Ministry of Agriculture, Fisheries and Food (MAFF) plays the leading role in compositional and labelling matters while the Department of Health and Social Security (DHSS) plays the leading role in food hygiene.

The food hygiene regulations stipulate the standards required on food premises and vehicle and by those handling foodstuffs. Other health- related regulations refer to specific treatments and to food imports.

The above provisions refer to all foods under particular circumstances and form the central basis of food legislation in Britain. For certain foods there is specific regulation of quality and presentation.

FOOD POLICY May 1985


Legislation applying to specific foods

A wide range of food products are subject to detailed compositional regulation. Milk and cream are controlled by specific sections within the Food Act, while these and other foods are controlled under regulations made by ministers acting within the powers of the Act. Foods subject to specific regulation have common characteristics.

0 They are all widely available and not simply branded goods available from a single company.

0 They are all difficult (or impossible) for the purchaser to assess

objectively. The quality may in most cases be assessed only after purchase or on consumption, if at all.

The earliest of the food-specific regulations arose from wartime legislation5 and relate only to the composition of the foods, such as self-raising flour,’ tomato ketchup,7 and fish cakes.s More recent legislation covers labelling as well as composition and includes foods such as bread and flour,’ butter,” and margarine.”

Some of these regulations update or restate previous regulations (the sale of bread for example has been regulated on one way or another since 1266)” while the regulations applying to butter and margarine restate maximum water contents included in earlier legislation. Other regulations are much more recent, such as those for soft drinks which were amended in 1976 to bring them in line with regulations applying elsewhere in the EEC.i3

The how and why of food standards

Section 4 of the Food Act 1955 gives ministers the power to make regulations on the composition and Section 7 gives power to make regulations on labelling and description of food. The actual procedures by which regulations are promulgated are lengthy and involve repre-

5Food Standards (General Provisions) sentations from interested parties at all stages. The Food Standards

Order, 1944, SI No 42, HMSO, London, Division of MAFF is the government agency responsible for administer-

1944, (as amended). ing the legislation and for the drafting of regulations or amendments. In ‘Food Standards (Se/f Raising Flour) practice, however, there is official consultation between MAFF and the Order, 7946, SI No 157, HMSO, London, 1946.

DHSS during drafting. The DHSS role is particularly important in the

‘Food Standards (Tomato Ketchup) Order, regulation of food additives. 7949, SI No 1817, HMSO, London, 1949, The existence of identical legislation for Scotland and Northern (as amended). 8Food Standards (Fish Cakes) Order,

Ireland which is de facto identical to that for England and Wales

7950, SI No 589, HMSO, London, 1950. requires that the officials of the ministries responsible in these particular ‘The Bread and Flour Regulations, 1963, parts of the UK maintain close contact with deliberations within the SI No 1435, HMSO, London, 1963, (as amended).

DHSS and MAFF.

“‘The Butter Regulations, 7966, SI No Ministers have for many years been advised on significant changes to 1074, HMSO, London, 1966, (as food standards by advisory committees. In 1931 a committee under the amended). “The Margarine Regulations, 7967, SI No

Minister for Health was set up to advise whether changes in the law

1867. HMSO. were necessary. Despite advice from the Society of Public Analysts amended).

London. 1967. (as x

“Assisa Panis et Cervisiae, 51, Henry Ill, (SPA) that a permanent body was needed to reconcile the views of the

1266. many parties interested in food standards, the committee considered

13The Soft Drinks [Amendment) Regula- that this was not necessary.14 However, with the need for tighter control tions. 7976. SI No 295. HMSO. London. of food during the second world war. an InterdeDartmental Committee 1976; (as amended).

I

‘%md 4564, Composition and Description (which included members of the SPA as well as civil servants) was set up

of Food: Report of the Departmental Com- in 1942 to advise the Minister of Food. From this body the Food mittee, HMSO, London, 1934. Standards Committee (FSC) was formed in 1947.

FOOD POLICY May 1985 147

Food standards in Britain.

15Ministry of Agriculture, Fisheries and Food, Food Standards Committee Second Report on Bread and Flour, FSCIREPIGI , HMSO, London, 1974. 16Ministry of Agriculture, Fisheries and Food, Food Standards Committee Report on Mince, FSCIREPI77, HMSO, London, 1983. “Consumers Association. ‘How can you spot good mince! Label? Price?‘, Which, August 1982, pp 434-435. ‘*Fish G (Co-ordinator), Minced Meat Sur- vey July/December 7987, London Chief Environmental Officers Association, 1982. ‘gMinistry of Agriculture, Fisheries and Food, Food Standards Committee Report on Claims and Misleading Descriptions, FSC/REP/71, HMSO, London, 1980.

The FSC included industry representatives (appointed in a personal capacity) academics and consumers in the decision-making process. In 1951 a subcommittee was established to consider the use of preserva- tives in food. The subcommittee’s brief was expanded to include all additives and contaminants and in 1964 became the Food Additives and Contaminants Committee (FACC). The role of the FACC was generally as that of the FSC, and included the responsibility to judge the need for an additive over and above its toxicological safety. The FSC and the FACC were merged in 1983 to form the Food Advisory Committee (FAC).

The FAC is a non-expert group responsible for advising ministers (such as the Minister of Agriculture, Fisheries and Food, Secretary of State for Scotland and Head of the Department of Health and Social Services for Northern Ireland) on the composition, labelling and advertising of food and the use of additives.

These are all matters attracting a measure of public interest. The committee members are appointed on a personal basis and are not (as such) representatives of organizations. Members are drawn from the food industry, the Association of Public Analysts, trading standards bodies, medical professions, academic institutions, research organizations and consumer representatives. A review by the FAC is, however, only one stage in the achievement or amendment of a standard for a particular food since the FAC only considers matters referred to it by ministers and subsequently reports within the terms of its brief. The recommendations contained within the report may be subsequently incorporated into legislation. It is useful to examine the entire sequence of events in order to place the work of the FAC into its full context.

In view of the relatively recent establishment of the FAC, the examples cited unavoidably relate to actual reviews conducted by its predecessor, the FSC.

Mechanism of review

The progression to a new standard generally begins with representations to government, particularly to the Minister and Ministry of Agriculture, Fisheries and Food. The style of representation can take many forms; questions may be asked in parliament, or more simply a written request may be forwarded to the responsible ministry. The reviews of additives conducted by the FACC were part of a long-term programme covering the various classes systematically; while other reviews were felt to be necessary in view of the time lapse since a previous review, the Second Report on Bread and Flour is such an example.15 Representations seek to establish a standard where none exists at present or to amend a current standard.

1. Where no standard exists at present

The recently published FSC review of minced meat16 was initiated after consumer organizations had publicized its very variable quality” following a detailed investigation by local authority trading standards officers. lx

Other reviews have been initiated in response to EEC effort aimed at harmonizing food standards throughout the EEC. The 1980 review of claims and misleading descriptions” was such an example and was conducted simultaneously with the EEC discussions leading to the EEC

148 FOOD POLICY May 1985

“‘European Communities, ‘Council Direc- tive of 18 December 1978 on the approx- imation of the laws of the Member States relating to the labelling, presentation and advertising of foodstuffs for sale to the ultimate consumer’, Official Journal of the European Communities, L 033,8 February 1979. “Ministry of Agriculture, Fisheries and Food, Food Standards Committee Report on Infant Formulae: Artificial Feeds for the Young Infant, FSCIREPI73, HMSO, Lon- don, 1981. 2qhe Committee of Medical Aspects of Food Policy (COMA) has the responsibility of advising the government on (as its name suggests) medical topics relating to foods. The Chairman of the committee is always the Chief Medical Officer of the DHSS although most COMA reports are the result of working parties or Advisory Panels under the expert chairmanship of a member of the full COMA committee. Reports from COMA review the current state of knowledge on a topic, present expert opinion and once accepted are definitive statements of government policy. z3Department of Health and Social Secur- ity, Present Day Practice in infant Feeding, Report on Health and Social Subjects No 9, HMSO, London, 1974. 24Department of Health and Social Secur- ity, Artificial Feeds for the Young Infant, Report on Health and Social Subjects, No 18, HMSO, London, 1980. 25Ministry of Agriculture, Fisheries and Food, Food Standards Committee Report on the Date Marking of Food, FSC/REP/ 57, HMSO, London. 26Ministrv of Aqriculture, Fisheries and Food, Food Staidards Committee Report on Cream, FSCIREPI76, HMSO, London, 1982. “Ministry of Agriculture, Fisheries and Food, Food Standards Committee Report on Cheese, FSC/REP/75, HMSO, Lo&on, 1982. “A.G. Ward, ‘The changing role of the food standards committee’, in Ministry of Agriculture, Fisheries and Food, Food Quality and Safety: A Century of Progress, HMSO, London, 1976.


Labelling Directive. 2” The officials representing British interests in the EEC negotiations were part of the team servicing the FSC review.

Other reviews were initiated in response to concerns highlighted by other government committees. The FSC review of infant formulaezl published in 1981 follows closely the recommendations of two reports from the Committee on Medical Aspects of Food Policy (COMA).22 In 1974 COMA published a report on infant feeding practices and suggested that standards be established. 23 This prompted the initiation of an FSC review in 1974. The FSC then requested further information from COMA and a working party on the Composition of Foods for Infants and Young Children was set up, which reported in 1980.24 The subsequent FSC report and the COMA report of 1981 cover different aspects of a single question and the FSC recommendations for standards were based principally on COMA advice.

The review relating to date marking of food? was the direct result of investigative journalism which led to parliamentary questions to the Minister of Agriculture, Fisheries and Food.

2. Where a standard is already in operation

A statutory food standard may restrict the freedom of food manufacturers to adopt new techniques and/or develop novel products. When this happens the food manufacturers (usually through the appropriate trade association) lobby for the initiation of a review in the hope of achieving a slackening of the restrictions which limit their development. The recent reviews of the cream2’ and cheese2’ regulations are examples of this type of review.

Once the process of representations and lobbying has been successful the procedures leading to the FAC review are: civil servants advise minister that a review is timely; the minister is at liberty to accept or reject their advice; if accepted, civil servants prepare preliminary brief for the FAC; an FAC review is formally commissioned.

Any person or organization with information relevant to the review is invited to submit such to the FAC. Interested parties are contacted primarily by means of a press notice issued by MAFF which leads to reports in the interested press. Key groups (appropriate trade associations) are contacted directly by MAFF and their comments actively sought. Expert assessors may be appointed to advise the committee on specific technical issues and background papers are prepared.

The committee considers the background papers, the written submissions and assessments from other committees established to advise ministers (eg that Committee on Medical Aspects of Food Policy), and

previously, the Food Additives and Contaminants Committee and its toxicity subcommittee. Key organizations or individuals are invited to present information orally. The aim of the deliberations is to achieve a consensus. One basic principle identified by a former chairman is that: ‘in the long term, there can be no fundamental divergence of interest between the consumer and the industries which supply him with his food. The food manufacturing industry must satisfy the desires, preferences and nutritional needs of the consumer’.*s

When the review is completed, its report is presented to the Minster and published. The reports follow a similar general structure:

l statement of scope of review; l reasons for review:



29Ministry of Agriculture, Fisheries and Food, Food Standards Committee Report on Meat Products, FSClREPl72, HMSO, London, 1980. 3a/bid.

discussion of market for food under review; current legislation; suggested need for control; discussion of compositional matters; discussion of labelling issues; discussion on issues related to additives, etc; summary of recommendations; appendices containing technical information or reports from working parties (eg on nutrition, toxicology or analytical aspects).

In virtually every instance, despite the divergent backgrounds of committee members, the recommendations contained within the report are an agreed view. The only exception is in the 1980 review of meat products where one member recorded a note of dissent on a single issue.*’

The function of the FAC is to advise and throughout their reports the Committee makes detailed and specific recommendations. The publication of the Committee’s report ends the involvement of the FAC in the decision-making process.

After publication of the FAC report the sequence of events is as follows:

comments invited from interested parties; proposals for regulations drafted; comments sought; revised proposals for regulations; comments; Statutory Instrument drafted; ministerial approval; laid before parliament; approval - unless negative resolution in parliament;

transition period; regulations enforced.

The sequence of events is necessarily slow since many opportunities are provided for comment. This slow approach has both positive and negative qualities. It is positive in that it provides a framework through which the views of all those with an interest in the particular issue can be heard. It is negative because it delays the development of new products unnecessarily if new composition is outside the limits of existing standard. Also, the industry (or consumer interests) can use the protracted opportunities for comment to delay or block legislation with which they disagree.

Example of meat products review

The length of time required to reach agreement on new regulations can be illustrated by examining the timetable of events relating to the meat products regulations.

1) The need for a review was noted in the early 1970s and the FSC review announced on 5 February 1975.

2) Review by the FSC, taking five years. This delay largely due to the number of other reviews being handled simultaneously by the Commit-

tee. 3) The FSC report was published early in 1980.30 The Committee


Food standardr in Britain:

recommended major changes to the description and composition of

meat products. 4) The press notice announcing publication stressed that the FSC

recommendations did ‘not commit ministers’ and pointed out that ‘they will give full consideration to representations made by interests concerned’. Three months were allowed for receipt of comments.

5) Comments were received from the various interested parties - in particular from the industry which did not agree with the recommendations.

6) Draft regulations were published on 17 July 1981 and it was suggested that they should come into effect two years later on 1 July 1983. Over 700 copies of the draft were circulated.

7) Certain details in the proposals were revised by MAFF in September 1981.

8) Comments were invited on both these dates and again the industry objected to many of the proposals. A hundred and twenty representations were received.

9) Furthermore, the enforcement agencies and the consumer organizations, indignant at the various concessions made by the ministry to the food manufacturers and at being by-passed in the discussions, insisted on discussions with ministry officials and made representations. 10) New revised draft regulations were published in August 1983 and again a three month consultative period announced. ‘The proposed regulations are unlikely to come into effect before 1 January 1986.’ Seventy-five representations received by MAFF. 11) Further major revisions to the proposals were published in June 1984 with a two week period allowed for representatives where ‘changes present. , .significant difficulties’. 12) New regulations31 were finally laid before parliament on 22 October 1984 and came into effect from 12 November 1984. 13) The previous regulations may continue to be complied with until 1 July 1986.

This sequence of events seeks to reconcile the views expressed by the various interests. In the example given the recommendations of the FSC were generally unacceptable to the industry concerned and representations were strong and repeated. The FSC recommendations on the labelling of meat products were desirable to those representing the consumer interest and this group pressed strongly for their incorpora- tion into the proposals at every stage.

The rate of progress indicated above is not particularly unusual. Reviews of margarine,32 cheese33 and cream34 (published in September 1981, November 1982 and December 1982 respectively) contained less contentious recommendations, but are still being assessed by the Food Standards Division of MAFF with a view to formulating proposals for regulations.

Reviews of additives are generally accepted with little argument from industry and the government has normally adopted recommendations fairly quickly. The review system acts to absolve the food industry from responsibility over matters of additive safety and use.

It is worth noting the role of the industrial trade associations. In general the reviews relate to a particular industry the members of which have a common interest in achieving (or inhibiting) change, in this case industry will be best served if a single institution is seen to speak for all. For example when margarine was reviewed the Margarine and

” The Meat Products and Spreadable Fish Producfs Regulations, 1984, SI No 1566, HMSO, London, 1984. 3ZMinistry of Agriculture, Fisheries and Food, Food Standards Committee Report on Margarine and Other Table Spreads, FSC/REP/74, HMSO, London, 1981. 33FSC, op tit, Ref 28. 34FSC, op tit, Ref 27.


Food standardr in Britain:

Shortening Manufacturers’ Association presented the case for the entire industry while the dairy industry (seeking to restrict the sale of margarine and other butter substitutes) was represented by the Association of Butter Blenders and Butter and Cheese Packers. In this instance there was no common interest between the butter and margarine sectors of the food industry and industry representations were organized along opposing product lines. For other issues the entire food industry has a common interest and representations have been made by organizations such as the Food and Drink Industries Council (an association of 17 industry-specific trade associations in the UK) or the Food Manufacturers Federation (now merged to form the Food and Drink Federation). Multi-sector submissions are in addition to rather than instead of submissions from individual companies or industry- specific trade associations.

The law in practice

The central theme of this paper has been to describe the processes through which specific standards are devised. From this description, several features may be noted which have a major significance in this particular aspect of British food policy.

Difficulty with democracy

Amendment of food standards legislation only takes place after protracted debate to which all interested parties may contribute. This process has obvious merits, but in practice there are limitations.

Although the debate is theoretically open to all, in practice most individuals will be unaware of the existence of the review procedure, of their right to submit evidence, and the mechanisms and timetable of doing so. The outcome of this is that the debate may be out of balance with industry interests having a clear advantage.

The debate is protracted and procedures designed to elicit comment at all stages of the review process may be unsurped by particular interest groups willing to delay or avoid implementation of legislation with which they disagree. The changes to the meat products regulations illustrate this point well.

Arbitrary nature of legislation

The legislative process has only been applied in detail to a relatively small group of foodstuffs. In general, these foods are widely available, significant in the diet and difficult for any individual to assess prior to purchase. By contrast, the situation elsewhere offers other models; Canada, for example, operates a system whereby food standards are reviewed systematically as an on-going process.

This inconsistency results in a number of anomalies where essentially similar foodstuffs are not all subject to specific regulation. This can be illustrated by two examples:

152

1) Yellow fats. Butter and margarine are each regulated very closely with regard to fat content, labelling and vitamin supplementation (margarine only). Low-fat spreads are not subject to close regulation and the addition of vitamins is not required by law. Similarly, when FSC reviewed margarine and low-fat spreads, the brief did not include butter.

FOOD POLICY May 1985


2) Coated products. Meat products are subject to detailed compositional standards, but most fish products are not, even though notable similarities exist between these foods. If the meat pie and the fish finger are considered in detail both could (crudely) be described as a portion of animal flesh wrapped in cereal-based coating, widely available and common in the dietary practices of the British population and impossible for the consumer to assess quantitatively prior to purchase. But there exists detailed regulation only for the meat pie. The composition of the fish finger is controlled only by the economics of manufacture and marketing and evidence from the trading standards officers indicates that price does not always reflect quality.35

The choice of foods to be subjected to legislation is purely arbitrary and no discernable programme of review can be observed. (It should be noted, however, that the reviews of food additives took a systematic progression through the various categories.) Once initiated, the review process follows a more-or-less consistent pattern, but there is less order or obvious logic in the choice of reviews undertaken.

Fewer new regulations

In recent reviews there is a noticeable tendency to recommend clear labelling rather than to stipulate a specific compositional standard. This change in emphasis has come about for a number of reasons.

1) The growth in consumer awareness of food issues and increases in the demands for information about food composition. This is reflected in the generally more informative labelling of foods required under the current food labelling regulations. 2) The development of new food products which substitute for traditional foods but which have radically different composition. Such products may be interpreted as either grossly adulterated versions of the traditional and which ought to be illegal, or completely new products outside the scope of legislation. Clear labelling avoids the problems associated with either of these situations. 3) The overwhelming philosophy of the current British (Conservative) government (since 1979) is one of freedom of enterprise. Removal of statutory controls on food composition is in general accord with this political philosophy. Clear labelling enables the fullest operation of market forces arising from freedom of consumer choice.

The switch to a system with fewer controls on composition provides a situation where food product development may proceed at a more rapid pace for those foods presently restricted by legislation. Several recent reviews have been initiated following petitions from industry for this reason.

The factors included within the decision-making process appropriate to changes in regulation are many, and are limited in theory only by the range of material submitted as evidence or comment. The personal knowledge of the FAC members and civil servants involved in the review process is also crucial. Each FAC member is appointed in a personal capacity although there is clearly an understanding that the various interest groups are well balanced vis-h-vis each other. It is this

35LACOTS, Coated Fish Products Survey, balance which provides the real strength of the FAC system. An

Local Authorities Coordinating Body on advisory committee, which was composed completely of industry Trading Standards, October 1983. representatives would clearly provide a different analysis than that of



%oyal College of Physicians/British Car- diac Society, ‘Prevention of coronary heart disease’, reprinted from Journal of the Royal College of Physicians of London, Vol 10, 1976; WHO Expert Committee Prevention of Coronary Heart Disease Technical Report Series No 678, World Health Organization, Geneva, 1982. Royal College of Physicians Working Party, ‘Obesity: A report of the Royal College of Physicians’ reprinted from Journal of the Royal College of Physicians of London, Vol 17, No 1, 1983; NACNE and hoc Working Party, A Discussion Paper on ‘Proposals foi Nutritional Guidelines for Health Education in Britain’, Health Educa- tion Council, London, 1983. 37Department of Health and Social Secur- itv. Diet and Cardiovascular Disease. Re- port on Health and Social Subjects, No 28, HMSO, London, 1984. %. Cockbill, (Head, Food Standards Divi- sion, MAFF), ‘Future legislation’, Paper presented at Institute of Food Science and Technology 20th Anniversary Symposium, Reading, UK, 19 July 1984.

consumer representatives or nutritionists. Balance or compromise is the central pillar of British food policy with regard to standards and it is therefore very unlikely that the review system could be utilized to enforce a radical change in food composition practice.

Major changes to the British diet have been recommended on numerous occasions by groups of medical experts considering issues such as obesity or cardiovascular disease.36 The most recent report was published in July 1984 by the Committee on Medical Aspects of Food Policy on ‘Diet and cardiovascular disease’.37 This report, in addition to advising dietary changes per se, made several recommendations of relevance to food standards. The Committee principally recommended that foods should be labelled with information on total fat content and on the quantity of saturated, polyunsaturated and trans-fatty acids. Butter, margarine, cooking fats and edible oils were specifically cited for such labelling, together with other foods containing over 10% fat or which are major contributors to fat intake. This recommendation was addressed to the food industry with a further recommendation to government that consultations take place which will lead to legislation. The advice given by COMA is given very serious consideration by the Food Standards Division of MAFF, and discussions were soon underway with industry to consider the recommendation.38 In the longer term, it seems likely that such labelling will be required by law. The major question which must be tackled by legislators and all interested parties is the detailed format of any labels. The system of repeated consultation described in this paper provides a system for ensuring that workable legislation is drafted; however, it seems likely, from past experience, that it will be many years before a concensus view is achieved.

Britain’s food standards legislation is primarily a device to provide consistency in the quality of national food supplies. The detailed food standards of the present are likely to be replaced by less specific standards of composition coupled with more detailed standards of labelling. A switch to a system of compositional labelling will widen the scope of legislation to a greater number of foods, removing many of the restrictions to production with which the food industry is unhappy. Improved labelling, in turn, accords with recent COMA recommendations and would provide a foundation for greater food awareness, giving each consumer the opportunity to balance personal tastes with informed choice.


food standards in britain: derivation and potential

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