31 March 2014


BACKGROUND


On 5 March 2014, the World Health Organization (WHO) launched a public consultation on a draft guideline on sugars intake. When finalised, the guideline will provide recommendations on limiting the consumption of sugars to reduce public health problems like obesity and dental caries (commonly referred to as tooth decay). In the draft, the WHO recommends reducing intake of free sugars over the lifetime of both adults and children and strongly recommends that intake of free sugars should not exceed 10% of total energy intake per day. This is based on current WHO recommendations that have been in place since 2002.

The new guideline makes a conditional recommendation to further reduce intake of free sugars to below 5% of total energy intake per day based on dental caries considerations. Five per cent of total energy intake is equivalent to around 25 grams (around 6 teaspoons) of sugar per day for an adult of normal Body Mass Index (BMI).


FIA POSITION

FIA welcomes the opportunity to participate in the public consultation on the draft “Guideline: Sugars intake for adults and children,” released by the World Health Organization (WHO) on 5 March 2014.

While our Members’ products play only a small part in the average diet of consumers in Asia, our companies share a common interest in tackling the problem of noncommunicable diseases (NCDs) and between them employ hundreds of thousands of consumers in the region.

FIA was particularly encouraged by the adoption of the UN Political Declaration in 20111 that recognised the prevention and control of NCDs requires a whole of society approach, multi-sectoral actions and the collaboration of governments, civil society and the private sector. We fully endorse this approach in Asia. Given the complexity and multifactorial causes of NCDs, it is essential that all stakeholders work together to develop holistic, impactful and sustainable solutions.

FIA believes that any approach to policy development should be both evidence-based and collaborative, with a clear focus on the role of industry self-regulation.

In Asia, we firmly believe that the private sector, in particular, has an important and valuable role to play in both the debate and the solution to the complex double burden of obesity and malnutrition.

FIA members have been working constructively with governments in Asia for many years on these complex nutrition issues. In 2012, FIA was consulted by WHO’s Western Pacific Regional Office in the development of the WHO Global Action Plan on the Prevention and Control of NCDs (adopted May 2013).

We recognise the important and unique role the food and beverage industry has to play in these efforts and have been doing our part in support of the stated priorities of WHO, by:

  • Restricting the marketing of foods high in fat, sugar and salt to children;
  • Providing nutrition information to consumers;
  • Promoting balanced diets and physical activity; and 
  • Reformulating where possible, and bringing to market new products which support the goal of improving the healthfulness of foods and beverages. 

Together and individually, our members are reducing key ingredients of public health concern – salt, sugar, saturated and trans fats - and increasing ingredients considered beneficial for good health - fibre, whole grains, fruits, vegetables and low-fat dairy; and reducing total calories.

We continually challenge ourselves to commitments that benefit the health of the public wherever possible and make them relevant at a community level, in an acknowledgement that ever greater efforts are needed to address these pressing issues.

FIA and its members understand that many consumers are increasingly seeking ways to manage their calorie intake. In our view, one of the most important factors in maintaining a healthy weight is energy balance, which factors in total calories consumed as well as those expended through basal metabolism and physical activity. Consumer awareness of the calories provided by a food or beverage product is essential and we are committed to providing easily-accessible and meaningful nutrition information to help consumers make choices that meet their needs.

To this end, FIA has recently launched a region-wide guideline on the consistent use of voluntary front-of-pack nutrition labelling in the form of percentage Guideline Daily Amounts (GDAs). Our members have already made great progress in rolling out these voluntary labels on their key brands across Asia and we expect significant penetration in all countries by the end of 2015.


SPECIFIC COMMENTS ON WHO DRAFT GUIDELINE

The key evidence base for the WHO recommendations was collected and presented through the commissioning of two systematic reviews and meta-analysis on body weight and dental caries.2 3

We acknowledge WHO’s re-confirmation of the dietary goal that the intake of free sugars should not exceed 10% of total energy. WHO has also proposed as a conditional recommendation a further reduction to below 5%.

According to WHO guidelines, the strength of a recommendation is subject to ‘the quality of evidence, balance of benefits versus harms and burdens, values and preferences and resource use’.4 Conditional recommendations are made when there is greater uncertainty about these factors.

From the evidence presented, it appears there is insufficient scientific support that would justify the lowering of the current WHO guideline on consumption of free sugars to 5%. The evidence is classified by the authors to be of very low quality, “With the <5% energy cutoff, a significant relationship was observed, but the evidence was judged to be of very low quality.5

Given the significance of this global guideline and the burden it will place on governments, businesses and consumers in Asia, we strongly believe that the WHO’s suggestion to further reduce free sugars intake to less than 10% of total energy requires further scientific substantiation and more comprehensive consultation.

FIA members are aware of the scientific evidence relating to factors contributing to obesity and health outcomes and we are committed to making a constructive contribution to this growing challenge. We stand ready to support governments in developing scientifically robust solutions to address non communicable diseases, including the complex aspects of product reformulation, consumer understanding and communication.

We believe fact-based consumer education is a key component of any intervention and would propose that WHO considers supporting governments by providing practical, actionable, evidence-based guidance that can be readily adopted by general populations all over the world, not just in the most developed nations.


ADDITIONAL COMMENTS

The importance of collaborative, evidence-based approaches to policy development in Asia

When governments are equipped with the latest and best science-based information, they can develop successful policies that achieve the optimal outcome for all concerned.

FIA believes it is undoubtedly in the best interests of all stakeholders – industry, consumers and governments – for policy decisions to be based on sound science. Likewise, practical initiatives that enjoy support and cooperation from industry are far more likely to succeed in achieving a positive impact.

Associations such as FIA have access to top-level communications capabilities and are informed by the latest science. Together, we can provide valuable regional support for local policy objectives.

It is particularly important that all stakeholders are assured a place in this debate. The food industry understands the challenges and is responding. In particular, FIA believes that the best and most cost-effective way for the different stakeholders to work together is through public-private partnerships.

It is clear that public private partnerships can provide a valuable platform for exchange and communication. They offer a more targeted method to meet complex goals and they bridge the gap between public and private ‘cultures’ to overcome market and government limitations in the prevention of obesity.

Stakeholders in Asia are acutely aware that the prevention and control of NCDs requires a whole of society approach – this means a concerted and collaborative effort by government, civil society and the private sector. FIA is pleased to see Member States promoting whole-of-society solutions, we would like to see the WHO place greater emphasis on this approach.

We are grateful for the constructive engagement we have had with Asian governments and NGOs over the last four years and we look forward to providing further input in the development of interventions to tackle obesity.


About FIA

Food Industry Asia (FIA) is a non-profit industry association that has been established in Asia to serve as a leading think tank for the food industry and a trusted partner in regional development.

Our goal is to harness the expertise of major food and beverage companies and respond to the region's complex challenges in food safety, regulatory harmonisation and effective approaches to public health. Our members share common values on sustainability, food security and the responsible promotion of balanced diets and lifestyles. Together, we promote the role of public private partnership as a cost-effective mechanism for delivering socio-economic outcomes.

At the heart of our philosophy lies a belief that the private sector can play a more positive role in civil society if it has a seat at the table. To this end, FIA is committed to working collaboratively with governments and policy makers throughout Asia, either directly or through existing local industry groups.

For more information please contact the FIA secretariat in Singapore via: www.foodindustry.asia



References

1. United Nations Political Declaration of the High-level Meeting on the prevention and control of noncommunicable diseases, unanimously adopted by Member States in 2011.

2. Te Morenga L, Mallard S, Mann J., Dietary sugars and body weight: systematic review and meta-analyses of randomised controlled trials and cohort studies. Brit. J. Med. 2013 346:e7492.

3. Moynihan PJ, Kelly SA., Effect on caries of restricting sugars intake: systematic review to inform WHO guidelines. J Dent Res. 2014 93(1): 8-18

4. Annex 8: Summary of considerations for determining the strength of the recommendations (Quality of evidence)

5. Moynihan PJ, Kelly SA., Effect on caries of restricting sugars intake: systematic review to inform WHO guidelines. J Dent Res. 2014 93(1): 8-18




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