tfX response to FSA consultation on "traffic light" labelling

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:

• "all fat is bad"
• "saturated fat is very bad"

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:

• an indicator of fat quantity, as proposed
• an indicator of "fat quality" to replace the present indicator as to the amount of saturated fat. This would be based on the proportions of different types of fat and oil within the fat and oil constituents of the product. Multipliers would then be applied to these figures according, not only to how "good" or "bad" fats are in themselves, but the proportions in which they occur in the product and how much our bodies can safely and beneficially take in. A positive multiplier indicates positive health impact, and negative one a negative health impact.

This might take the form:

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:

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.