Supplementary Indications revisited

Supplementary indications received a reprieve in 2007, and will now, subject to the Brexit deal negotiated with the EU, need to serve only the needs of the UK economy. Ronnie Cohen wonders where US influence is likely to lead us.

Supplementary indications are justified on the basis that they are necessary for trade with the United States and that if they were not permitted, a trade barrier would be created. This insistence on mutual acceptance of supplementary indications contrasts with the tolerance of different requirements for nutrition information and ingredients. Boxes of US and UK Pringles illustrate this inconsistency.

Pringles_logo_US

Common Supplementary Indications

Supplementary indications are additional non-metric units that can appear alongside metric units. These non-metric units are voluntary in the EU and mostly appear on products imported from the US. Dual labelling is still a legal requirement for goods regulated at federal level in the US under the Fair Packaging and Labelling Act.

Pringles_US_dual_units

As you can see from the image on the box of Pringles, the product weight is expressed in both ounces and grams. As a result of discussions between the European Commission and the US government in 2007, the EU agreed to extend the use of supplementary indications to support trade between Europe and the US.

Different Nutrition Information

However, let’s look at the differences in nutrition labelling for the UK and US markets. The differences reflect different legal requirements.

Pringles - US nutrition information

Pringles – US nutrition information

Pringles - UK nutrition information

Pringles – UK nutrition information

While there are some similarities between UK and US nutrition labelling, there are considerable differences. These differences are described here.

US nutrition information shows the following information:

  • Information in English and Spanish
  • Serving size in ounces and grams
  • Number of crisps per serving
  • Servings per container
  • Food energy in calories only
  • Food energy per serving only
  • Breakdown of total fats for saturated and trans fats
  • Amounts of cholesterol and sodium shown
  • Breakdown of total carbohydrates for dietary fibre and sugars
  • No salt figures given
  • Nutrition figures for amount per serving and % of daily value (based on a 2000 calorie diet)
  • Amount of protein shown
  • % daily values of Vitamin A, Vitamin C, calcium and iron
  • No allergen information is provided
  • Maximum daily intakes of total fat, saturated fat, cholesterol, sodium, total carbohydrates and dietary fibre are given for 2000 and 2500 calorie diets

UK nutrition information shows the following information:

  • Information in English only
  • Serving size in grams only
  • Number of crisps per serving
  • Servings per container
  • Food energy in kJ and calories
  • Food energy per 100 g and per serving
  • Breakdown of total fats for saturated fat only
  • No cholesterol or sodium figures given
  • Breakdown of total carbohydrates for fibre and protein
  • Amounts of salt shown
  • Nutrition figures for amount per serving and per 100 grams
  • No figures given for Vitamin A, Vitamin C, calcium and iron
  • Allergens are highlighted in capital letters (e.g. FIBRE)
  • No maximum daily intake information is provided

Different Ingredients Lists

Pringles - US ingredients list

Pringles – US ingredients list

Pringles - UK ingredients list

Pringles – UK ingredients list

Even though the UK and US ingredients lists look similar. there are some notable differences in the information provided. The British label provides allergen information (in this case, using capital letters), ingredients derived from genetically modified sources, E numbers (alongside descriptive names) and % of dried potatoes of the total contents. The American label provides none of this. Other differences in ingredients lists can be seen in the following table. Ingredients are listed in the order they appear on the labels.

US ingredients list UK ingredients list
  1. Dried Potatoes
  2. Vegetable Oil (contains one or more of the following: Corn Oil, Cottonseed Oil, Soybean Oil, and/or Sunflower Oil)
  3. Cornstarch
  4. Degerminated Yellow Corn Flour
  5. Rice Flour
  6. Maltodextrin
  7. Mono- and Diglycerides
  8. Contains 2% or less of salt
  9. Dextrose
  10. Monosodium Glutamate
  11. Whey
  12. Onion Powder
  13. Citric Acid
  14. Spices
  15. Natural and Artificial Flavours
  16. Autolysed Yeast Extract
  17. Tomato Powder
  18. Garlic Powder
  19. Torula Yeast
  20. Sugar
  21. Lactic Acid
  22. Sodium Diacetate
  23. Disodium Inosinate
  24. Disodium Guanylate
  25. Paprika Extract
  26. Wheat Dextrose
  1. Dried Potatoes (92.3%)
  2. Vegetable Oil (Corn* Oil, Cottonseed Oil, SOYA* bean Oil and Sunflower Oil)
  3. Corn* Starch
  4. Corn* Flour
  5. Rice Flour
  6. Maltodextrin
  7. Emulsifier: Mono- and diglycerides of fatty acids (E471)
  8. Salt
  9. Dextrose
  10. Flavour Enhancer: Monosodium Glutamate (E624), Disodium Inosinate (E631) and Disodium Guanylate (E627)
  11. Whey (MILK)
  12. Onion Powder
  13. Acidity Regulator: Citric Acid (E330), Lactic Acid (E270) and Sodium Diacetate (E262)
  14. Spice
  15. Natural and Artificial Flavouring
  16. Autolysed Yeast Extract
  17. Tomato Powder
  18. Garlic Powder
  19. Torula Yeast
  20. Sugar
  21. Paprika Extract
  22. WHEAT Dextrose

On the British label, whole words written in capitals warn about allergens and words marked with * indicate that the ingredient is derived from a genetically modified source.

I leave you to spot other differences in these lists.

Other Labelling Differences

Other differences in the labels including format and layout, spelling differences (e.g. for words such as “flavour”, etc.), importer information and best before date.

Supplementary Indications and Labelling Issues

A large number of differences in product labelling regulations exist between the United States and the European Union. The way that European importers solve this problem is to stick a label over the section with US nutrition and ingredients lists to conform with EU regulations. However, the British repeatedly argued that the abolition of supplementary indications would create a trade barrier between the US and the EU until they were permitted indefinitely in 2007. Why are potential differences in the use of supplementary indications seen as a trade barrier whereas other differences in labelling regulations are not? Surely, a sticker can overcome not just one problem, but both.

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11 Responses to Supplementary Indications revisited

  1. John Steele says:

    @Ronnie

    I agree there are differences. Some could be resolved by options the US allows:
    1. Spanish is optional, not required. Same for French (to accommodate Canada)
    2. Energy in kilojoules is allowed as supplemental, but Calories (kilocalories) are required.
    3. Nutrition values per 100 g or 100 mL is allowed as supplemental, but per US serving size is mandatory.
    4. We highlight allergens (WHEAT and DAIRY). I don't believe we consider fiber to be an allergen.
    5. We do require sodium, rather than salt, and it includes any form of sodium present, not just sodium chloride.
    6. Low levels of vitamins and minerals don't need to be declared, but can be. If you declare any, there is a panel that must be displayed even when the value is zero (I think that is changing in a recent update).

    The bigger problem is that we each have certain requirements, and a panel that covers both sets would be large and confusing. I would agree that high volume manufacturers consider it better to have a unique panel for markets with different requirements to keep it simple, and have efficient ways of doing so. That is less true for small manufacturers.

    We import food from a number of EU countries. They comply with our label laws and I am sure they are not the same labels they use at home. I like a certain French jam and I am pretty sure they don't use an English-only label in their home market.

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  2. Daniel Jackson says:

    Tailoring labels for local markets is not a big issue. It's done all of the time. I don't know how many American products end up in EU countries or elsewhere, but the labels always have to be tailored for language. In most cases if not all, the USC would be removed anyway.

    Canadian products more often than not even if in USC sizes have a metric only declaration on the label. So, it can be done and often with no complaints from the manufactures.

    What the big fear among American manufacturers is concerning metric only labels is that the next step will be a requirement to go to rounded metric sizing. In fact, decades ago when the issue first appeared a member of the FMI voiced his opposition to metric only by stating this very reason. Over time a list of nonsensical reasons were added:

    https://www.reddit.com/r/Metric/comments/1aeyr6/why_the_fmi_opposes_metric_only_labels_and_an/

    A number of American products come in sizes just shy of the nearest rounded metric amount.

    http://img.tesco.com/Groceries/pi/420/0041500936420/IDShot_540x540.jpg

    https://www.britishcornershop.co.uk/img/large/SGN1721.jpg

    http://www.foodbev.com/wp-content/uploads/2016/08/Frenchs-Yellow-mustard-Spicy-with-Cayenne-Pepper.jpg

    Can you imagine these labels showing 400 g? I'm sure the fills of these products exceed 400 g anyway and putting 400 g on the label would be no issue. But as far the companies filling the containers are concerned is is a big deal as they want to present a rounded USC product to the market and not metric.

    But then again maybe this isn't an issue for every company and in every situation. We only hear from those that cry the loudest. Here is a catsup product in English with a rounded metric volume fill and a non-rounded mass fill. At least with this product we see their intended fill is by volume and the density of the product can be calculated. This would be nice for all products where practical, meaning if you need a dual declaration do mass and volume. That is more useful than adding ounces.

    http://pixel.nymag.com/imgs/daily/grub/2014/07/21/21-heinz-ketchup.w600.h315.2x.jpg

    http://c8.alamy.com/comp/E3WRFF/heinz-tomato-ketchup-mexican-chilli-and-fiery-chilli-E3WRFF.jpg

    http://www.heinz.fi/-/media/europe/images/products/heinzbrandsite/denmark/bildarkiv/heinz_mk_570g_topdown.ashx

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  3. Martin Vlietstra says:

    One of the problems with labelling is "What do we mean by the product containing X grams?" Does it mean that each item is guarenteed to contain X grams or does it mean that the average contents of each item in the consignment is X grams? In earlier years UK law used the single item law (which is why so many tinned goods had a declared weight of 15.75 oz). EU regulations use the average contents law.

    Supplementary indicators bring in additional problems - how accurately do they have to reflect the contents? Must they always underestimate the quantity. The EU directive is silent in this respect.

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  4. Mark Williams says:

    @Martin Vlietstra:

    Wouldn't the presence (or absence) of the e-mark ℮ preempt this issue, even for exports outside the EU? The supplementary unit would tighten up the percentages, depending on how it is rounded from the primary, but still have the same meaning as when there is only one unit?

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  5. John Steele says:

    @Martin,

    Assuming the supplemental indication is to satisfy US law, the larger of the two declarations (using conversions which are exact or accurate to at least 6 significant figures) must be true on an lot average basis, and no extreme underfills. I'm not sure our rules on sample and lot sizes, statistical test, intolerable underfills are exactly the same as yours, but the rules can be laid out. At worst, a little extra fill would ensure the most restrictive rule is met.

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  6. Daniel Jackson says:

    Supplementary Indicators may be only the first step:

    http://www.express.co.uk/news/uk/769056/Britain-sell-pounds-ounces-imperial-metric-system-Andrea-Leadsom-weights-measures

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  7. Ezra Steinberg says:

    @Daniel Jackson

    This whole business of turning back the clock on metrication will backfire if seriously attempted. As the UK tries to whip up a bunch of bilateral trade deals to replace being a member of the EU, it will quickly discover that the rest of the world (aside from the USA) has no use for Imperial.

    Let's hope business good sense prevails including the need for the UK to present an international face to the world, which also means a metric face.

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  8. Lee Kelly says:

    I read recently that after we leave the EU we will no longer use metric measures. Is this true, and why in the 21st century is there talk of going backwards? So much for 'Global Britain'.

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  9. Alex Bailey says:

    We’ve already seen many taking the BREXIT vote as de facto permission to ignore metrication rules and some in the tabloid press as well as at least one government minister (Leadsom) seeming to be doing their best to fuel this.

    While I don’t think industry as a whole will start to re-tool and switch to imperial, what we would likely see is some smaller businesses trying to appeal to the Daily Mail set and drop metric from their price lists and trying to belittle those of us who insist on using metric; this may even be fueled by some more vocal consumers stating “We’re no longer in Europe, we want to go back to British measures”. The knock-on effect may well be that businesses who do remain metric will wind up taking on the cost of mistakes and re-training.

    We’re probably moving off-topic here but I do think we need to be a lot more vocal about this, we could draw a parallel with the EU referendum and Trump’s election: many took the stance that “nobody would be that stupid.” Sadly that attitude is allowing the vocal minority to win the day and drag us all back into the 18th century.

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  10. Charlie P says:

    @Alex Bailey
    Perhaps after Brexit, we should lobby for another referendum to inform politicians which measurement units the British population want use.

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  11. Ronnie Cohen says:

    @Charlie P

    Measurement regulations and legislation are not decided by referendum anywhere. I have seen the problems with the Alternative Vote and EU Membership referendums. Both sides were full of lies and propoganda by both sides in these referendums and relatively few facts given. It was hard to tell what was true and what was not. Hence the BBC had a Reality Check section on its website to help the public to assess claims made by both sides.

    For these reasons, I do not think that it would be a good idea to hold a referendum on measurement units. I suspect it would contain a lot of lies, propoganda, emotion, nostalgia and sentimentality and not many facts.

    While the completion of metrication may be unpopular in the short term, I can point out that no country that has completed its transition to the metric system has gone back to the old units. It was originally unpopular in France, the first country to adopt metric measures. Now the metric system is used all over the world. This would not be the case if all leaders just paid attention to opinion polls on this issue. If they did, there probably would be no metric system. Today, the benefits of the metric system are now taken for granted.

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