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Listen to this siteTuesday 21 March 2006
The salt targets consultation was published in August 2005, with the aim of obtaining views on the proposed targets and product categories. At the close of the consultation, 74 responses had been received from a wide range of stakeholders, covering the retailing, manufacturing and catering sectors, trade associations, consumer organisations, enforcement bodies and health-related organisations.
The Agency has considered, in detail, the submissions received in response to this consultation and held a series of meetings in January 2006 with stakeholders to discuss the potential for reductions where problems had been identified by respondents.
The responses included comments that covered all aspects of the work to set salt targets. The documents published include a summary of these comments.
Back to topEight questions were raised in the consultation letter.
1. Whether the product categories, and sub-categories, for which targets have been proposed are appropriate and if not, why?
There was general agreement that the product categories, and sub-categories, were largely appropriate although a number of changes were requested.
These included:
2. Whether it is appropriate to have maximum targets in most cases but averages for some specific categories and if not, why not?
A mix of views was received in response to this question. Consumer and health organisations generally favoured setting maxima as it was felt that these would be easier both to regulate and for consumers to understand. Progress towards achieving the targets would also be easier to monitor. Whilst a few food industry respondents agreed, most thought that it would be more appropriate to set either just an average, or both an average and a maximum. Averages were considered more appropriate where product recipes, and hence salt levels, can vary considerably across product categories, and to take into account natural variation within or between batches for products such as cheese.
3. Where averages are proposed, the appropriate level for maximum targets to be set in addition to the averages.
A range of views was expressed, with some support for setting both an average and a maximum - the average to cover the variance in levels across the category.
Others stated that maximum targets were unnecessary where an average had been proposed, as this would complicate the process. Some of the comments received related to specific product categories only.
4. Whether the targets proposed for each category are realistic and achievable, and if not, why? If the targets are not achievable, it would be appreciated if suggestions could be made for what would be.
This question generated the most comments and the widest range of views. Relatively few respondents agreed that the proposed targets were realistic and achievable in all cases, with most requesting some kind of adjustment.
Largely positive responses were received for bacon and ham, and some cheeses.
There were some suggestions for increases to the targets, with alternative figures sometimes given. In some cases, the need for a higher target was based on food safety or technical reasons, but often to ensure continued consumer acceptability.
Reasons for the requested increases were not always provided. Some food industry organisations have requested that some products are exempted from the targets.
Some consumer and/or health-related organisations advocated a reduction in the proposed targets but generally did not make specific suggestions for alternative figures.
5. The additional costs linked to these targets e.g. any additional costs relating to reporting progress.
Additional costs were predicted in a number of areas where work was required to reduce salt levels to meet the targets.
These costs related to the reformulation of the product, including the input of development chefs, marketeers, nutritionists, regulatory and legal advisers to this work, as well as consumer testing and revised packaging.
Costs may also be incurred in collating data and reporting progress against the targets as part of a self-reporting framework (see questions 6 and 7 below).
Some non-industry organisations considered that industry should bear any additional costs.
It is important to note, however, that these costs are likely to be routinely incurred as part of manufacturers' usual programmes to review and reformulate products at intervals. Further information on this can be found in the Regulatory Impact Assessment.
6. Whether the proposed self-reporting framework (backed up by independent surveys) would be effective and whether it would be possible to provide the information indicated.
The majority of comments received on this question, which came from both food industry and other organisations, were generally supportive of there being some form of self-reporting framework.
However, some were unsure of the implications or of the effectiveness of such a framework, citing concerns about the additional burden and costs this would impose.
7. How industry should self-report average levels for the purpose of monitoring.
A number of organisations proposed/supported the idea that any self-reporting framework should be based on weighted sales data, as this would be the most robust way of doing so, although it was acknowledged that some sectors of the food industry may find this difficult.
A number of further suggestions were made on how the self-reporting might be carried out, including:
8. Whether establishment of interim population targets would help monitor progress and if not, why?
Of the comments received most did not support the setting of interim targets, because it was felt that these 'would not help with monitoring progress', 'could result in confusion about what the ultimate targets to be achieved are' and 'detract from the achievement of these'.
Some respondents questioned the implications and/or effectiveness of setting interim population targets. Those respondents who supported the setting of interim population targets felt that progressive annual targets would serve to ensure that salt reductions do occur year on year.
Back to topOne of the questions included in the consultation letter asked 'whether the targets proposed for each category are realistic and achievable, and if not, why. If the targets are not achievable, it would be appreciated if suggestions could be made for what would be'.
As a large number of comments on the individual categories and targets proposed in the consultation were received in response to this question, these comments have been compiled separately.
Back to topThese cover a wide range of areas including labelling; use of brand names; the need to take account of other Government work with industry; salt reduction in imported foods; food safety, technical issues and consumer acceptability; how the targets have been set and the need to set further targets; the use of salt subsitutes; monitoring progress towards achieving the targets and a number of other general areas.
Only very few responses to the questions raised in the Regulatory Impact Assessment
Back to topDownload pdf
(pdf 38KB) Setting targets for salt content in a range of processed-food categories - Regulatory Impact AssessmentDownload pdf
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