Stakeholders acknowledged that it would be unlikely to find a solution that would solve all irregularities but emphasis should be put on finding a solution for products that are consumed in large amounts, have a big impact on health, or gain a lot of media attention. Stakeholders identified a need for consumer research on the understanding consumers have of ‘as prepared’ in relation to the HSR. Additionally, the ‘as prepared’ need further explanation to all stakeholders, including consumers. Pros and cons of each option Option one - Status quo Pros Cons No change to packaging No expense Consistency with Food Standards Code Allows for variation in the way products are made up Practical for the consumer Aids consumers to make meals in line with dietary guidelines e.g. adding fruit and vegetables Avoids complicating the system further Element of confidence and trust already Different application by different companies e.g. within categories some companies use ‘as sold’ while others use ‘as prepared’. Can’t make a comparison between products within the category. Ambiguous- open to different interpretations (leading to the above) Confusion/ difficulty applying the ‘as prepared’ rules by industry Confusion for consumers Mistrust by consumers and media Continued criticism of the HSR and of the process Potentially misleading if consumer doesn’t prepare product as per instruction May not drive reformulation as can manipulate recipe instead to improve HSR Allows precedent setting- problem grows Gives industry the option to ‘creatively market’ products based on recipes Current problem will be unresolved Comments: Make ‘as prepared’ HSRs a different colour to ‘as sold’ so it can easily be differentiated by consumers OR state ‘as prepared’ on the HSR to make it clear Need guidelines on use as currently there is too much ambiguity Need consumer research to know how consumers understand HSR ‘as prepared’ Option two – ‘As sold’ only Pro Con Consistent application (by industry) within category Remove confusion (for industry) Remove criticism around particular products Difficult to compare different forms of the product within category (e.g. stock powder with liquid stock) Doesn’t give information on ‘as consumed’- less meaningful to consumers
Greater consistency with other categories that are not using ‘as prepared’ Simple Reformulation easier to see and possibly encourage reformulation Doesn’t assist outcome of what HSR is trying to achieve Inconsistent with the Food Standards Code May discourage industry from putting preparation instructions that with dietary guidance Possibly discourage industry uptake if not able to display HSR ‘as prepared’ Option three - Multiple HSRs on pack Pro Con Could be beneficial to have ‘as sold’ on the front and on the back have ‘as prepared’ by the recipe (although some commented that this is not necessarily a pro) Enables greater flexibility which may encourage industry uptake May encourage dietary guidelines statements on pack (i.e. in preparation instructions) confusion Lose credibility with different stars Hard to fit on the packaging May be a waste of time, will people look at the additional information? (have to turn pack over) Problem with HSR’s on the back of pack is that it is a front of pack labelling system Comments: An alternative suggestion was to have the HSR ‘as prepared’ on the front of pack and ‘as sold’ on the back of pack OR ‘as prepared’ HSR with a graphic about what is added to obtain this rating (e.g. cup or milk or vegetables) Consumer research would be important to determine if this option is viable Option Four - ‘As sold’ with specific exemptions Pro Con Creates change but provides flexibility Allows comparisons as how they would be consumed Improvement on option one (doing nothing) Aligns with regulations (depending on exemptions) If there are any exemptions it opens it up to criticism again Confusion with what products can have exemptions Comments: Needs to come with clear detailed guidance Possibly a different colour or design for ‘as prepared’? Although colour was seen as less viable) Consideration of special purpose foods that fall under std. 2.9.3 Specific exemptions Exemptions should be limited and be very clear Drained- but only if consumers normally drain to use - only canned vegetables, pulses and possibly fish (depending on whether in flavoured oil or brine (brine= as drained)).