a deterrent for manufacturers to put the HSR on products – if optional, needs to be mandatory could be less take-up by companies if the ‘halo’ effect of associated products is not permitted companies are likely to remove HSRs altogether as not appropriate some products would have to remove HSRs as they’re not compliant with the Code nutrition isn’t reflected in the HSR Option three – Multiple HSRs on pack Pros Cons encourages transparency provides more information for educated consumers encourages consumers to prepare foods as suggested and prepare more balanced meals could educate consumers on how to create a healthier choice if instructions are followed could provide extended information, e.g. on websites, to help consumers understand how different recipes or iterations can have different outcomes consumers can see two scores – one ‘as sold’ and one ‘as prepared’ – and then make a decision more information if you can understand it and know the rules satisfy stakeholders who want both ‘as sold’ and ‘as prepared’ more complicated reduces intended simplicity of the HSR, especially for who don’t have time or ability to read current information on the level, e.g. NIP or ingredient list goes against the principle of being consistent potential consumer confusion, especially ESL consumers assumes a level of literacy and numeracy transition between old and new packaging be confusing for consumers less convenience for consumers communications are challenging to consumers, could undermine the system more complicated labels discourage consumers from reading labels (disengagement) would require further consumer nutrition education variation in how consumers will interpret the different HSRs doesn’t benefit consumers or industry not applicable across all categories assumes packaging resource cost to fast-moving consumer goods (FMCG ) on calculations, pack updates, etc packaging real estate cost for industry to change packaging and therefore a deterrent for having the HSR why stop at two? Could then have lots of recipes and HSRs added complexity with rolling out HSR on packaging with two sets of HSRs: added work for R&D, checking artwork, etc. manipulation is still possible doesn’t solve current issues
incorporates issues of Options 1 and 2 too difficult to interpret potentially too much information doesn’t represent every possible use doesn’t give level playing field for industry some foods would not be in line with regulatory requirements, e.g. nutritional supplements Option four – ‘As sold’ with specific exemptions Pros Cons fairest option of all four could align with ADGs as more flexible (if continuously reviewed) can be tailored flexibility clarity for industry removes room for interpretation strict good compromise to address media/high profile products aligns with the NIP with the ‘3rd point rehydrated with water only and drained’, e.g. for drained vegetables and dehydrated soups solves some problems related to manipulation by adding additional nutrients with another product water doesn’t add additional nutrients reflective of product as it is meant to be consumed (intended) transparency of having some products ‘as sold’ result in more industry uptake comparison would be easier for stocks which are sold next to each other, e.g. cubes, powders, liquids good for simple rehydration and draining we can see a benefit if the following exemptions are included: recipe mixes, cake mixes, meal mix bases (e.g. beef stroganoff), stock cubes, formulated supplementary foods doesn’t align with the Code cost to industry complicated costing assumes literacy continuous evolving and revisiting ongoing work required with innovation/new products open to errors lack of certainty for both industry and consumers confusing for consumers: how are they meant to know what’s in/out open to variation by consumers consumers unlikely to understand which products are ‘as sold’ or ‘as prepared’ need to communicate/provide obvious disclaimer to consumers re which products are exempt communication is challenging lack of transparency definition of ‘rehydration’ and ‘hydration’ regulation required definition required would need very clear definition/rules about exemptions exemptions undermine the core/intended HSR principles would create problems with companies trying to get exemptions creates inconsistencies outweighs benefits HSR should match NIP information, e.g. canned tuna - nutrition information provided based on drained product - therefore HSR should reflect nutrition information of drained product use of products can vary: cake/pancake mixes: some are complete, others require added ingredients canned varied additions and uses