The action of the Ministry of Food, which was designed to check the abuses that had developed with regard to the advertising of food stuffs and the labelling of packages made up for the retail trade, is not only most welcome but very necessary in the public interest. The term misleading is applied by the Ministry to the proceedings that have led them to take action. It is accurate, but official reticence necessarily causes it to be somewhat lacking in vivacity. The fact is that the consumer, for a number of years past, has been misled by means of deceptive labels and advertisements, as to the real nature of an admittedly important part of his food supply. The wording of the suggested code is incidentally exposure and condemnation of this. The mislabelling of foods has for a very considerable time attracted the attention of Public Analysts and of others who are interested in the purity of our food supply and in public health. We need only refer to the periodical reports of the health authorities to obtain convincing proofs of the need that had arisen for official action. The cruder forms of this particular species of fraud were obvious and scandalous. Others were more subtle and less obvious. With regard to the former we have had digestive teas said to contain a lower proportion of tannin than ordinary blends, but found on examination to contain the normal quantity. Diabetic foods containing unaltered starch though the label said otherwise. Cream made of nut oil, and so forth. Vitamins then appeared on the scene. Their discovery aroused great public interest, and certain types of food manufacturers took good care that this interest, however unenlightened it might be, should not be allowed to flag. On the contrary, it was recognised as a valuable trade asset and it was therefore encouraged by advertisements which were not characterised by pedantic adherence to accuracy. Accuracy of statement was in fact not demanded at that time by anyone, and it was not supplied by the advertisers who, in apparent confidence, proclaimed in many of these advertisements the superior vitamin content of the food advertised and the peculiar advantage to health that would accrue to the consumer of it. The campaign was entered on with a light heart and was for a time successful. The statements made proved to be very effective stumbling blocks for the blind, and sales, presumably, increased. Unfortunately everybody whose business it was to manufacture certain kinds of processed foods thus advertised began to be involved. The straightforward manufacturer found his interests threatened by the action of his less scrupulous competitors. The unscientific use of the commercial imagination in this respect threatened to bring about a chaotic state of affairs when it was used as a weapon in acute trade competition. The great complexity of the chemical and physiological problems which a study of the vitamins involves was, and is, recognised by all who have dealt with these matters. In 1936 the Medical Officer of Health for Kensington, in a report, dealing with the misleading and deceptive labelling of food, says originally jam invariably consisted of fruit plus sugar, but keenness of competition amongst manufacturers to secure the lion's share of the trade led to the substitution of such cheaper substances as apple pulp, pectin and fruit juices for a percentage of the named fruit, with a consequent lowering of the general standard of the jams placed on the market. The jam manufacturers apparently became alarmed at the chaotic condition which they themselves had created. The result, as we all know, was the drawing up of unofficial standards for jam by the trade and primarily for the benefit of the trade. The interests of the consumer were by no means the main object of the transaction. We have referred to this episode of some ten years ago and more because the question of the vitamin and mineral content of certain foods both in kind and quantity seemed to be drifting into the same unsatisfactory condition. Some of these foods were made for the benefit of children or of persons in a weak state of health. It was therefore the more important that they should be what they claimed to be. It may be conceded that under certain conditions unofficial regulations are better than no regulations at all, but it is unquestionably better that if regulations are to be made they should be made by impartial official experts and receive ipso facto the support of law. This has now been done. The interests of the consumer as well as legitimate trade interests, which theoretically at least should be identical with those of the consumer, have been taken into account. Under the Labelling of Food No. 2 Order, 1944, it will be remembered, the disclosure of the quantity of vitamins or of minerals is obligatory. This, however, is not sufficient. Not only must the quantity of vitamins or minerals be disclosed, but that quantity must be such as to justify the claims made in respect thereof, and further the amount of the food which an average consumer may reasonably be expected to consume daily should contain not merely a significant quantity of the vitamin or mineral in question, but a quantity sufficient in the light of modern nutritional science to justify whatever reference is made to it in the advertisement or on the label. These remarks are quoted from the preamble to the suggested code of practice in framing labels and advertisements. The code was drawn up in response to many requests from traders to the Ministry of Food, and the composition of this suggested code is the result of the consultation of the Ministry with the Medical Research Council. It is printed verbatim below
British Food Journal – Emerald Publishing
Published: May 1, 1946
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