Montreal, June 16, 2017

The Honourable Lawrence MacAulay Minister of Agriculture and Agri-Food House of Commons Ottawa (Ontario) K1A 0A6

Sir,

Thanks to Health Canada’s Transparency of stakeholder communications for healthy eating initiatives policy, we recently came across a letter dated March 9th, 2017 jointly addressed to you by the Canadian Federation of Agriculture and Food & Consumer Products of Canada. The contents of the letter expressed their opposition to the front-of-pack labelling proposed by Health Canada regarding its Healthy Eating Strategy. We, however, are in support of the measure and we hope that the present letter will help you gain a better appreciation of how at- a-glance labelling of high sugar, sodium and trans-fat type products could be of benefit not only to the health of Canadians, but also for the Canadian economy.

In Canada, the overweight and obesity rates are alarming. The Organization for Economic Cooperation and Development (OECD) recently published the Obesity Update 2017 PDF document1 which reminds us of how severe and prevalent the problem really is in Canada. The Canadian situation is not very encouraging, Canada ranking seconded as having the highest childhood overweight and obesity rate of the country members from OECD. More than one in four adults is obese. Obesity is associated with a number of conditions or morbidities. Recent literature links obesity to a variety of chronic illnesses, such as type 2 diabetes, cardiovascular diseases, along with various cancers and arthritis. Childhood obesity, for its part, increases the risk of obesity later in life and contributes to early onset of a number of chronic conditions. The current situation calls for appropriate and effective preventive government action, in which your department can make a very valuable contribution.

Providing clear, reliable and simple information that enables citizens to make informed food choices is one of the avenues that government could invest in obesity prevention. Front-of-pack labeling, which industry officials are trying to discredit by calling it "severe" and under the

1 Organization for Economic Cooperation and Development. (2017). Obesity Update 2017. Consulted on May 25, 2017 at http://www.oecd.org/health/health-systems/Obesity-Update-2017.pdf. "alarmist" approach, is a promising avenue for Canadians, giving them a clear picture of the contents of processed and ultra-processed food products. In their letter, industry representatives argue that adding information on the front of the package "could hurt the reputation" of their industry. This argument raises important questions about the quality of the food supply offered to Canadians. Why are we so concerned about the idea that Canadians have better access to information about the nutritional quality of their products? In any event, Canadians have the right to know the truth about the contents of processed and ultra-processed foods.

Mandatory nutrition labeling on the front of the package balances the marketing practices used by manufacturers, which only highlight the positive aspects of the product, without reflecting and actually downplaying the overall nutritional value such as the high content of sugars, salt and saturated fat.

The industry spokespeople deem the use of warning labels “harsh”. We, on the other hand, find that it would be more effective for the following reasons:

• It would provide a more user-friendly list of information containing the nutritional values table located on the side or back of packaging. • It will target nutrients that have been found to be harmful to public health when presented in high levels. • It would be visible at a first glance, unlike the current nutritional values table, thus facilitating purchasing decisions at points of sale. • Evidence shows that logos can help consumers make healthier food choices • This measure could encourage manufacturers to reformulate certain products in order to avoid triggering logos, thus improving the food offer. The value and advantage of simplifying nutritional information through the use of official logos lies in the fact that they can be easily understood by everyone (regardless of age, language and literacy level). They can serve the needs of the visually impaired as well. Of the various versions of the labels proposed by Health Canada, the triangular ones seem most appropriate. This shape means a hazard and sends a message encouraging moderation rather than prohibiting outright.

In a cynical attempt to persuade the government not to adopt at-a-glance labelling, citing the second report of the Advisory Council on Economic Growth as proof, the spokespeople underscore the economic weight of their industry, because, according to them, it would “have a dampening effect on Canada’s ability to innovate, grow and compete.” This seems overblown to say the least. The truth of the matter is that while these spokespeople seem to be engaging in economic fearmongering and getting up in arms about logos intended to reveal more clearly the true nutritional value of many food products on the market, overweight and chronic diseases associated with unhealthy eating are taking a heavy toll on our society.

In 2012, the direct cost of obesity to the healthcare system (e.g. medication, health services) and its indirect cost in terms of lost productivity (owing to premature death and long- and short- term disability) were estimated at 19 billion dollars2. Since the problem of overweight has grown worse over the past decade, there’s reason to believe that the magnitude of this economic burden is presently much greater. Therefore, it would be all the more worrisome for taxpayers to learn that the food industry’s spokespeople are opposed to basic measures of transparency, meant to help citizens make more enlightened decisions about what they eat.

Consequently, we urge you not to give in to industry pressures and, instead, to make the health and interests of Canadian citizens the supreme consideration in the matter. The measure proposed by Health Canada would be highly beneficial and minimally restrictive. Indeed, consumers would still be free to buy the products and the industry could go on manufacturing them. The industry could instead choose to manufacture better products, in which case it would have no reason to fear the requirement for greater transparency in front-of-packaging nutritional information. Finally, we urge you to work in concert with the Minister of Health in order to make Canada a global leader in food labelling.

cc. Mr Jean-Claude Poissant, Parliamentary Secretary to the Minister of Agriculture and Agri-Food Mr Chris Forbes, Deputy Minister, Agriculture and Agri-Food Canada The Honourable Jane Philpott, Minister of Health Mr Joël Lightbound, Parliamentary Secretary to the Minister of Health Mr Simon Kennedy, Deputy Minister, Health Canada Mr Pierre Sabourin, Assistant Deputy Minister, Health Canada The Honourable Navdeep Bains, Minister of Innovation, Science and Economic Development Mr John Knubley, Deputy Minister, Innovation, Science and Economic Development Canada The Honourable Bill Morneau, Minister of Finance Mr Paul Rochon, Deputy Minister, Finance Canada The Honourable François-Philippe Champagne, Minister of International Trade Mr Mathieu Bouchard, Senior Advisor to the Prime Minister Mr Justin To, Deputy Director of Policy and Policy Advisor, Prime Minister's Office Mr Tyler Meredith, Policy Advisor to the Prime Minister

2 Krueger, H., Turner, D., Krueger, J., & Ready, A. E. (2014). The economic benefits of risk factor reduction in Canada: Tobacco smoking, excess weight and physical inactivity. Canadian Journal of Public Health, 105(1), e96-e78.