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| Aspects to be considered | What are the WHF recommendations? | What is the reasoning? |
| What should be the principal message to consumers? | Consumers should avoid ultra-processed foods and instead focus on “real food”; that is, less processed, high-nutrient, preferably fresh foods. | There is a significant negative impact of consuming excessive ultra-processed foods on cardiovascular health, including obesity, diabetes, hypertension, and other conditions. |
| Should the system provide a nutritional summary or talk about levels of specific nutrients? | The system should be aligned with national public health and nutrition policies (dietary guidelines) and food regulations, as well as with relevant WHO guidance and Codex guidelines. It should allow for easy and quick identification of ultra-processed and processed products that have an excess of energy and key nutrients of concern, including sugar-sweetened beverages and high-fat or salty snacks, to contribute to the prevention of overweight and obesity and diet-related NCDs. | The purposes of FOPL can vary. In some countries, they seek to allow consumers to better rank products according to their healthfulness (without necessarily allowing them to identify which products are excessive in critical nutrients) and in other countries they seek to help the population easily identify products that are excessive in critical nutrients. Summary scores, such as the Nutri-Score system, meet the first purpose only, not the second. Warning labels meet the second purpose, not the first. When many purposes are pursued, it is unlikely that any one will be fully achieved. Healthy nutrients in a product can work as claims that stimulate the consumption of unhealthy products. For example, a cracker high in sodium with significant amounts of fibre should not be encouraged as a source of fibre. If this conflict is present, it will undermine the achievement of the objective. FOPL systems that are in line with or exceed the minimum requirements and recommendations of Codex and WHO are likely to be better positioned to achieve their health objectives. |
| Is WHF in favour of one system over than another? | WHF does not privilege one system over another and encourages governments to consider their situation and the objectives that best correspond in selecting an FOPL system. Whichever option is used, WHF believes that a comprehensive system should be put in place, rather than reliance on the less effective GDA. | WHF is aware that some countries favour summary systems (such as Nutri-Score) to help their population to be able to rank products according to their healthfulness. WHF is also aware that other countries favour warning labels because they want to help their population to easily identify products that are excessive in critical nutrients. The research on warning labels is very consistent in demonstrating that warning labels meet the regulatory objectives these countries are seeking; namely, helping consumers to easily, quickly and correctly identify products that are excessive in critical nutrients and that are linked to the three risk factors of the most burdensome diseases (high blood pressure, high fasting blood glucose, and overweight and obesity). |
| What foods should be labelled? | Pre-packaged processed and ultra-processed food products (UPP). | Pre-packaged processed and UPP foods apply several persuasive elements to their labels that drive consumers to purchase products that are excessive in critical nutrients and reduce the relevance of nutrition information and the capacity of consumers to make informed decisions. |
| Should the FOPL system be voluntary or mandatory? | FOPL systems should be mandatory. | Voluntary labelling may bias consumer perceptions towards products with labels that are potentially less healthful than products with no labels and takes longer to implement. |
| Who should be involved in developing the national guidelines? | National governments must be responsible for the creation of the FOPL systems in each country. Consumers, civil society/public health groups, and food manufacturers should be allowed to share their views, when appropriate, during public consultation processes. | Governments must ensure there are no conflicts of interest throughout the development of the system. Consumers, manufacturers, and public health groups should be able to provide feedback through public consultations, to ensure transparency, independence, and rigour. |
| What is the role of World Heart Federation and other science-based civil society organizations? | When a government is addressing its responsibilities and mandates towards reducing obesity and improving public health, civil society should support it. However, when a government does not provide the required leadership, civil society should organize and advocate for improved policies and strategies to address malnutrition in all its forms. | To advance the WHF vision of a world where heart health for everyone is a fundamental human right and a crucial element of global health justice, it is necessary to address major risk factors such as obesity and overweight. Front-of-pack labelling is an acknowledged part of an effective strategy to address diet-related risks. |
| What should the education program look like? | Consumer FOPL education must make individuals aware of the existence of new labels and the objectives they pursue. An effective education programme should also help consumers understand what is considered a healthy diet and how the FOPL relate to national dietary guidelines. | Consumers should understand why the labels were developed and how to read them. They should also learn what is considered a healthy diet in order to use the labels to make more nutritious purchases. |
| How will the system be evaluated? | The FOPL system should be regularly monitored by the national government for uptake, impact on purchasing patterns, and efficiencies and improved as necessary. Science-based civil society organizations and/or academic institutions may wish to conduct additional reviews or research that are independent of the government. | Evaluation and success can be based on improvements in consumer nutritional knowledge and changes in consumer spending on food, i.e., is there a higher rate of healthy food being purchased? Because the purposes of FOPL can vary, studies and evaluations should make sure that they evaluate results against the specific objectives of a system; studies that compare Nutri-Score systems and warning label systems cannot evaluate their respective effectiveness well if they only examine issues related to the purpose of one or the other. For example, if a study is designed to examine an FOPL system’s success by asking consumers to correctly identify which products are excessive in any of the critical nutrients, the survey would find good results for warning label systems but poor performance from Nutri-Score, simply because the latter was not designed for that purpose. |
