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tfX response to FSA consultation on "traffic light" labelling

This is the tfX response to the FSA consultion on "traffic light" labelling of food, of 30 January 2006. The consultation may be found at

The "traffic light" signposting system proposed is totally inadequate as far as fat is concerned. It appears to be based on the twin precepts that:

This view is not only simplistic, it is also highly misleading. Fat in general, and saturated fat, are both necessary in the diet, and if absent people will suffer from various forms of ill-health and malnutrition leading ultimately to death. Short and medium chain saturates, as found in coconut oil, are highly beneficial to health.

The "essential fatty acids", omega-3 and omega-6, are necessary, in much the same way that vitamins are necessary - however of these, omega-6 are generally in surplus in our diets, while omega-3 are severely deficient. If the ratio of omega-6 to omega-3 exceeds approx 4:1 the omega-6 is actually harmful. Mono-unsaturates (MFA) are also healthy fats, and are associated with cardiovascular health as well as protecting the brain from Alzheimer's disease.

There is only one kind of fat that is unequivocally bad: the synthetic trans fats arising from industrial hydrogenation. These are wholly unnecessary and indeed toxic (causing cardiovascular disease, type 2 diabetes, Alzheimers disease and other cognitive decline among elderly, reduced birth weight in babies, functional deficiency of EFAs). However the proposed system does nothing to highlight their presence.

To simplify this admittedly complex picture we suggest providing:

This might take the form:

fatty acids Multiplier (to be applied to grams/100 grams of fat content, as triglycerides of fatty acids)
omega-3 +10
omega-6 +1 for up to 200% of omega-3, 0 for 200-400% of omega-3, -1 for more than 400% of omega-3
monounsaturates +1
long-chain saturates (more than C12) 0 up to 20% of fat, -1 for more than 20%, -2 above 30%
medium and short-chain saturates (less than C12) +1
trans (as defined in Danish food law) -10

Poor quality fat products would have strongly negative scores (red), average quality fat products around zero (amber) and good quality fat products would have marked positive scores (green). We acknowledge that there is room for debate over the precise multipliers to be used. However this approach has a strong scientific foundation and would provide consumers with important nutritional information which is entirely lacking from the original proposal.

The scheme could if necessary be simplified further with a measure of fat quality based only on the presence of saturates and trans. While this would not in our view be truly adequate it would represent a considerable improvement on the current proposal:

fatty acids Multiplier (to be applied to grams/100 grams of fat content, as triglycerides of fatty acids)
saturates -1
trans (as defined in Danish food law) -10

A single gram of trans fats should count as 10 grams of saturated fat based on the finding of the Danish Nutrition Council (Trans fats and health 2003) that:

"Since 1994, the influence of a high intake of industrially produced trans fatty acids in promoting the development of heart disease has been further documented by, among other things, the presentation of four major prospective population studies. The studies indicate that, gram for gram, the intake of trans fatty acids as compared with saturated fatty acids is associated with an approximately 10-fold higher risk increment for the development of heart disease."

Oliver Tickell, tfX, 30 January 2006.


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